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3225

KELLY AR # 3225 of 72

Kelly Restoration Advisory Board (RAB)Technical Review Subcommittee (TRS)

Meeting AgendaSeptember 13, 2005, 6:30 p.m.

Greater Kelly Development Authority143 Billy Mitchell Blvd., Bldg. 43, Suite 6

GKDA Conference Room

6:30 - 7:00 TAPP Contractor AppointmentFor Semi Annual Compliance Plan Review

7:00 Adjournment

Chartered Bus Tour7:00 — 8:30 Tour of remediation sites

Upcoming Meeting Dates

Next RAB Meeting (Elections): 18 October 2005Oct. 18, 6:30p.m.: Kennedy High School, Cafeteria, 1922 S. General McMullen*Next TRS MeetingNov. 8, 6:30p.m.: Environmental Health & Weliness Center, 911 Castroville Rd*

*MEETING DATES, LOCATIONS AND AGENDA ITEMS ARE SUBJECT TO CHANGE.


September 13, 2005Technical Review Subcommittee (TRS) Meetingof the Kelly Restoration Advisory Board (RAE)

Greater Kelly Development Authority143 Billy Mitchell Blvd., Bldg. 43, Suite 6

San Antonio, Texas 78226-1816

Meeting Minutes

RAE Community Member Attendees:Mr. Robert Silvas, Community Co-chairMr. Rodrigo Garcia, Jr.Mr. Daniel GonzalezMa; Coriene HannapelMr. Ruben MartinezMr. Nazirite PerezMr. Arniando QuintanillaMr. Michael Sheneman

flAB Government Member Attendees:

Other Attendees:Mr. Todd Colbum, Air Force Real Property Agency (AFRPA) ContractorMs. Larisa Dawkins, AFRPAMs. Cheri Kirkpatrick, AFRPA ContractorMs. Norma Landez, AFRPAMr. Rey Nieto, AFRPADr. David Smith, Facilitator

The meeting began at 6:40 p.m.

I. Introduction — Dr. David SmithDr. David Smith began the meeting by welcoming RAB members and other attendees.

IL TAP? Contractor Selection for 2005 Semiannual Compliance Plan Report — Mr. ReyNieto

Mr. Rey Nieto summarized the TAPP contractor bids received for the 2005 SemiannualCompliance Plan Report and the importance of RAE members explaining their reasoning forhow the contractor will provide the best value when voting.

RAE members voted on the TAPP contractor and explained their reasoning for best value. Thevote was 7 in favor of Clearwater Revival, none opposed.

III. Announcement of GWTP and cleanup bus tour — Dr. David Smith


Dr. David Smith informed everyone the meeting would be adjourned to begin the bus tour.

JV. Adjournment

The meeting was adjourned at 7:20 p.m.

These minutes have been composed in accordance with Robert's Rules of Order as per the request ofthe RAB members.

__________

%Robert Silvas Date Adam Antwine ateCommunity Co-chair Installation Co-chair


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$7,

275.

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TAPP Budget Update

Beginning Amount $100,000.00

Fiscal Year Project/Document Name Contractor Amount1998 ATSDR Report (Water) University of Maryland $9,706.00

.1998 1997 Base-wide Remediation Assessment Clearwater Revival $6,975.001998 OU-2 Workplan Neathery Environmental $5,145.001999 Zone 3 Corrective Measures Study Addendum Clearwater Revival $6,375.001999 Remedial Investigation of Zone 4 OU-2 Neathery Environmental $6,195.001999 Final Zone 5 Corrective Measures Study Geomatrix $3,617.502000 Shallow Groundwater Report - Geomatrix $5,572.50

2000 Site S-8 Draft Final Corrective Measures. .

Investigation.Neathery Environmental $5,660.00

2000 Site MP Draft RCRA Facility Investigation Clearwater Revival $5,925.002001 Zone 3 RCRA Facility Investigation Clearwater Revival $5,775.002001 Zone 4 Corrective Measures Study Geomatrix $8,390.002001 — ATSDR Health Assessment University of Maryland $7,428.00

2003 (Mod-Ol) Additional Travel Expenses for.

Presentation to RAB.Clearwater Revival $500.00

20032003Zone 2/3 Correctives Measures Study

ATSDR Air Emission StudyNeathery EnvironmentalUniversity of Maryland

$5,570.00$8,366.00

2005 . 2015 Sém:annuaI Corn j1iance P/an TB1) &. T8tiTotal Spent to Date $91,200.00Remaining Balance $8,800.00


STATEMENTS OF OBJECTIVES (SOO)REVIEW JANUARY 2005 SEMIANNUAL COMPLL&NCE PLAN REPORT

1.0 GENERAL

1.1 Scope

This task is to review the January 2005 Semiannual Compliance Plan Report for the formerKelly Air Force Base (AFB), focusing on the off-base impacts from Zones 2, 3, 4, and 5,including an identification of gaps in the location of monitoring wells, and identification of anytrends in the contamination, providing a layperson's explanation of the 2004 annual shallowgroundwater assessment.

1.2 Background

The compliance plan report documents the results of the annual groundwater sampling conductedatthe former Kelly AFB in San Antonio, Texas. The former base conducts annual assessmentsof the shallow groundwater in accordance with the Texas Cominission of Environmental Quality(TCEQ) issued Compliance Plan (CP-50310), dated on June 12, 1998. The annual assessment isused to determine the effectiveness of ongoing remedial activities in improving the quality ofgroundwater in the surficial (shallow groundwater) aquifer. The annual groundwaterassessments began in 1994. The report describes current remedial activities, summarizes resultsof groundwater data collected during 2004, and evaluates these results with respect to historicaldata collected since 1994. In addition to these data, the, analysis for the 2004 assessmentconsiders site hydrogeology, including groundwater and surface water interaction.

1.3 Objectives

1.3.1 The contractor shall furnish all professional non-personal service labor, management,supervision, tools, materials, equipment, transportation, mailings, and reproductions, unlessspecified herein, for the assigned tasks issued against this Blanket Purchase Agreement.

1.3.2 The contractor shall provide technical assistance to the Restoration Advisory Board (RAB)and RAB Technical Review Subcommittee (TRS) by interpreting and translating the data in thecompliance plan report.

1.3.2.1 The following specific tasks may be required for this project:

N Attend a pre-performance meetingN Develop and submit a schedule for completion of the work

Conduct a technical review of the compliance plan reportConduct an oral presentation of the report's conclusions at a TRS meeting

N Provide a review of the compliance plan report in layman's terms• Provide a response to TRS comments, either orally or in writing


• Present the final report at a RAE meetingParticipate in teleconference call

1.4 Guidance and Compliance Documents

All assessments and recommendations shall comply with all Federal, State, and localenvironmental laws and regulations including, but not limited to applicable portions of thestatutes and regulations cited below. The contractor shall be provided with the Compliance PlanReport; however, the ontractor is responsible for obtaining all public documents as neededbased on the individual tasks issued against this agreement. Examples of the types of documentsthat may be required are listed.

• Kelly Permit HvT503 10 and Compliance Plan CP-503 10, 12 June 1998, and subsequentClass 3' Modifications.

Installation and Closure of Shallow Aquifer Wells and Soil Borings on Kelly Air ForceBase Technical Design specifications (TDS), December 1998.

• Final Quality Program Plan 2004 Compliance ProgramlGroundwater Monitoring, April2004.

• Final Kelly AFB Basewide Quality Assurance Program Plan and Sampling and AnalysisPlan, August 1999.

2.0 PROGRAM MANAGEMENT

2.1 Background Data/Information Review

2.1.1 The Air Force Real Property Agency (AFRPA) shall provide the contractor, whereavailable, all pertinent and available background information concerning this task order. Thecontractor may be required to review/obtain additional background data information as requiredfor the performance of the required services.

2.1.2 To accommodate the Air Force's remediation schedule, the contractor and the Air Forceshall agree on a schedule or timeline for this task based upon the hours agreed on between thecontracting officer and the contractor at time of award of the task. The contractor shall berequired to meet the required tirneline. Any extension of time must be agreed to by the AFRPAand RAB, and approved in writing by the Contracting Officer.

2.2 Meetings

2.2.1 Pre-Perfonnance Conference — A pre-performance conference shall be held after the awardof the order and prior to commencement of the work at a time, place and date specified by theContracting Officer, as soon as the Compliance Plan report is received bythe Air Force.Discussions at the meeting shall include the development of a mutual understanding relative toissuing task orders, scheduling and administering the work.


2.2.2 Contractor is invited to attend TRS meetings (normally held the second Tuesday ofFebruary, March, May, June, August, September, November, and December) and IRAB meetings(normally held the third Tuesday of January, April, July and October).

3.0 PROJECT EXECUTION

3.1 Specific Requirements

3.1.1 Technical Review Report: This requires a review of the specific report and the applicabledocuments to be reviewed. The contractor is tasked with evaluating the report with respect tocurrent enviromnental actions by the Air Force, assessing the completeness of the reports andadequacy of proposed or current actions, and making recommendations for future actions.

3.1.1.1. The written report shall include a defense of the process for making the determinationsand an evaluation of the levels of confidence in the recommendations. The report need not belengthy — an executive summary format is desirable. It must be written in layman's terms, so theRAB shall easily be able to communicate the findings to the community, if necessary.

3.1.1.2 All submittals must be double-sided, 1 OO% post-consumer, recycled paper.

3.1.2 Technical Oral Presentation: This task order involves presenting the findings to themembers of the TRS at a regularly scheduled TRS meeting time, followed by presenting a finalpresentation. to the RAB at a regularly scheduled RAB meeting time. A firth date for thesemeetings shall be scheduled at the time the order is placed. TRS meetings are normally held thesecond Tuesday of February, March, May, June, August, September, November, and Decemberat 6:30 pm. TRS meetings are usually held at the Environmental Health and Weliness Center,911 Castroville Road, San Antonio, Texas. RAB meetings are normally held on the thirdThursday of January, April, July, and October at 6:30 p.m. at Kennedy High School, 1922 SouthGeneral McMullen, San Antonio, Texas.

3.1.3 Response to Comments: Following the review of the written report and/or oralpresentation, RAB members may have comments they wish addressed. The Contractor shallprovide a written response to each question from the RAB, if so stated in this task order.Comments received before the oral presentation may also be delivered verbally at thepresentation.

3.2 Public Affairs

The contractor shall not make available to the news media, nor make public disclosure ofanydata resulting from this contract during the performance of this contract. During theperformance of this contract, the contractor shall refer all press or public contacts to the DoD co-chair. The documents produced and a transcription of the RAE presentation shall be placed inthe Adn-rinistratjve Record and Information Repository by the Air Force. Afler completion of allrequirements the public disclosure restriction shall be removed.


4.0 SUBMITTADELIYEPLES

Each task order shall specify the required deliverables, with the quantities and time framespecified. Each written submittal shall include a cover letter stating the deliverable beingprovided and shall include the Blanket Purchase Agreement number and Tasic order number. Thecontractor shall provide a copy of the cover letter to the contracting officer. Copies of reports donot need to be provided to the contracting officer unless specified in the Task order. The detailsQf the spcific deliverables shall be identified with the award of the project.

5.0 CONTR&cT SURVEILLANCIE

5.1 Quality of Work

The contractor is solely responsible for the quality of the work. The Inspection of ServicesClause applies to this order.

5.2 Inspection/Oversight Responsibilities and Acceptance

5.2.1 The Senior Representative of the former Kelly AFB. is the Installation Co-Chair of theRAB. The Contracting Officer (C.O.) shall designate a C.O. Representative (COR) who shall actas liaison between the Contractor and the RAB. The Contracting Officer shall be notified of anyconflicts and shall resolve any problems that cannot be mutually resolved between theContractor, Installation Co-Chair, and the RAB Community Co-Chair, or designatedrepresentatives. A meeting of all parties, at no additional cost to the government, may be calledby the Contracting Officer to discuss and propose solutions to resolve discrepancies.

5.2.2 The Contractor is advised that only the Contracting Officer can obligate the government ordirect the contractor. The COR and the RAB members DO NOT have this authority. Thecontractor SHALL NOT EXCEED the total amount of any order awarded without prior written

- - approval of the contracting officer

5.2.3 The COR, with the RAB's concurrence, shall certify acceptance at completion of the task.

6.0 POINTS OF CONTACT

A list of Points of Contact shall be available with the award of this task order.


BPA F41622-g8A5882 Request Date: 15 Jul 05

Semiannual Compliance Plan. Report

Cleaniva tar Revival

TASK HOURS RATE AMOUNT

Attend

_______

$ 75.00

________

Preperf Mt Mtg Exp $ 500.00

Develop Sched

________

$ 75.00

________

Tech Review

________

$ 75.00

________

Oral Prst-TRS

________

$ 75.00Mtg Exp $ 500.00

Report

________

$ 75.00

________

Response IRS

________

$ 75.00

________

RAB Present

________

$ 75.00

________

Mtg. Exp $ 500.00

TOTAL


BPA F41$22--A-5ea1quest D

SeminnuaI Compliance Plan Report

reom8tri

HOURS RATE

— $ 115.00

_______

I

________

12-

___

4

___

'-1

____

AMOUNTZOLI

-',, I..-'

$115.00 1/-'-'

$ 115.00

$ 115.00 q,0

TOTAL

_____

te; 15 Jul

TASK

Attend

Preperf Mt Mt Exp

Pavlop Schd

Thch Rsvllw

$ 115.00

$ IIS.00

$ 1T5.00Oral PrEt-TRS

Mtg Exp

Report

Response TRS

RAB Present

Mtg. Ep


FROM : Dobson NatKery ssociats FRiX NO. : 21O—S3—E2E2 Jul. 21 225 O935flM P2

BRA F41622-98-A-5884 Request Date '15 Ju 05

S9rniannual Compliance Plan ReportNeathery

TASK

Attend Preperforrnance meeting

Develop Scheduie

Tech Review

Oral Presentation to TRS

Report Praparation

Prepare Response to TRS

Presentation to RAB

Hours

2.00

tOO

30,005.00

&0O

8.00

3.00

3.00

Rate

$90.00

$90.00

$80.00$135.O0

$90.00

$80.00

$80.00

saoo

TOTAL

Amount

8000

$90.00

$2400.00$67500

$270.00

$640.00

$?40.00

$270.00

$4765.00


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August 9, 2005 Technical Review Subcommittee (TRS) Meeting

of the Kelly Restoration Advisory Board (RAE) Environmental Health and Weilness Center 911 Castroville Road

San Antonio, Texas 78237

RAB Community M her Attendees: Mr. Robert Silvas, Conunity Co-chair Ms. Esmeralda Galvan \ Mr. Rodrigo Garcia, Jr. '\ Ms. Coriene Harmapel \ Mr. Nazirite Perez Mr. Armando Quintanilla Mr. Sam Murrah, alternate for

.

Michael

RAB Government Member Atte ees: Mr. Gary Martin, Greater Kelly Dev lopm t Authority (GKDA) Mr. Greg Lyssy, Environmental Prote ti Agency (EPA) Region VI Ms. Melanie Ritsema, San Antonio Me politan Health District (SAIMIRD) Mr. Mark Weegar, Texas Commissic Environmental Quality (TCEQ)

Other Attendees: Mr. Don Buelter, Air Force ncy (AFRPA) Ms. Sonja S. Coderre, AFRP Ms. Kyle Cunningham, Center for Health Ms. Cassie Kahn, TCEQ / N

Ms. Linda Kaufman, Envftonmental Health and Vçllness Center (EHWC) Ms. Kelley Kravitz, AF A Contractor Ms. Norma Landez, RPA Ms. Martha A. Mo uo, Community Member Mr. Jerry Needha

, San Antonio Express-News

Ms. Abbi Power ,

TCEQ Ms. Heather R on-Ayala, AFRPA Contractor Dr. David S

, Facilitator

Ms. Linda ard, Community Member N

Mr. Davi anez, Office of Texas Senator Leticia Van de Putt, District 26

Them ing began at 6:35 p.m.

I. Introduction —

Dr. David Smith Dr. David Smith began the meeting by welcoming RAE members and other attendees.

II. Administrative —

Ms. Norma LandezlMs. Sonja Coderre

DRAFT Meeting Minutes


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ctio

n of

the

CM

S w

ere

bein

g co

nsid

ered

for

cla

rifi

catio

n.

Com

men

t/Res

pons

e #1

3: T

CE

Q in

dica

ted

the

prob

lem

with

the

disc

ussi

on o

f B

uild

ing

348

in th

e C

MS

is th

e fa

ct th

ere

is a

NA

PL (

calib

ratio

n fl

uid)

flo

atin

g on

the

shal

low

gro

undw

ater

,ho

wev

er th

e PC

E is

the

only

CoC

dis

cuss

ed H

ow w

ill th

eN

APL

be

reco

vere

d? A

FRPA

res

pond

ed th

at th

e sp

ecif

ic a

ctio

nat

Bui

ldin

g 34

8 O

WS

is to

add

ress

the

PCE

con

tam

inat

ion

inth

e so

il, h

owev

er th

e in

stal

latio

n of

pas

sive

bai

lers

isre

com

men

ded

in a

ll al

tern

ativ

es p

ropo

sed

for

grou

ndw

ater

at

Bui

ldin

g 34

8 to

add

ress

NA

PL f

ound

in m

onito

ring

wel

ls

1.(c

ont.)

Lan

dez,

N.

Dav

is, R

.Z

one

2 an

d 3

CM

S R

evie

w o

f pr

opos

ed r

evis

ions

to th

e D

raft

Zon

e 2

and

3C

onec

tive

Mea

sure

s St

udy.


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

9 A

ugus

t 200

5 M

eetin

g M

inut

es

Item

#L

ead

Supp

ort s

iMj

Cór

nmU

W I

'E

tiWW

nW

1Ii*

ft

(con

t)L

ande

z, N

.D

avis

, R.

Zon

e 2

and

3 C

MS

Rev

iew

of

prop

osed

rev

isio

ns Y

esou

tsid

e of

the

Bui

ldin

g 34

8 O

WS

area

. The

EPA

rep

rese

ntat

ive

to th

e D

raft

Zon

e 2

and

3as

ked

if S

VE

had

bee

n co

nsid

ered

for

trea

tmen

t. T

he A

FRPA

Cor

rect

ive

Mea

sure

s St

udy.

resp

onde

d no

, how

ever

a b

io-s

lurp

er s

yste

m h

ad b

een

inst

alle

din

the

area

, but

was

inef

fect

ive

beca

use

of f

luct

uatin

ggr

ound

wat

er le

vels

. The

EPA

rep

rese

ntat

ive

aske

d ho

w th

ick

the

NA

PL la

yer

is. T

he A

FRPA

res

pond

ed it

is r

elat

ivel

y th

in(l

ess

that

1.0

foo

t in

tota

l thi

ckne

ss).

The

AFR

PA n

oted

ask

imm

er w

as in

stal

led

prio

r to

the

bio-

slur

per,

but

was

als

oin

effe

ctiv

e in

NA

PL r

emov

al. T

he A

F be

lieve

s th

e be

st m

etho

dfo

r N

APL

rem

oval

is p

assi

ve b

aile

rs, b

ecau

se o

f th

e m

inim

alam

ount

of

NA

PL p

rese

nt.

Com

men

t/Res

pons

e #1

4: T

CE

Q in

dica

ted

the

AF

resp

onse

did

not p

rope

rly

addr

ess

the

com

men

t, in

that

is w

as s

till u

ncle

arw

hy th

e A

F di

d no

t sel

ect t

he c

heap

er, q

uick

er a

ltern

ativ

e. T

heA

FRPA

res

pond

ed th

at th

e in

itial

com

para

tive

anal

ysis

of

rem

edia

l alte

rnat

ives

ove

r-ra

ted

Ele

ctri

c R

esis

tive

Hea

ting

(ER

H)

as a

rem

edy

as it

did

not

acc

urat

ely

acco

unt f

or th

elim

itatio

ns o

f th

e m

etho

d to

add

ress

dis

solv

ed-p

hase

chr

omiu

mim

pact

. AFR

PA c

oncu

rred

that

this

was

not

cle

arly

pre

sent

ed in

the

draf

t Res

pons

e to

Com

men

t and

indi

cate

d it

will

rev

ise

the

resp

onse

and

the

CM

S as

app

ropr

iate

to a

ddre

ss th

is is

sue.

Com

men

t/Res

pons

e #1

7: T

CE

Q e

xpre

ssed

a p

revi

ous

unde

rsta

ndin

g th

at th

e re

fere

nced

DN

APL

impa

ct w

ould

be

exca

vate

d an

d di

d no

t see

the

reas

on f

or f

urth

er e

valu

atio

n of

alte

rnat

ives

. The

AFR

PA r

espo

nded

the

TC

EQ

reco

mm

enda

tion

to e

xcav

ate

the

soils

at S

ite M

P is

bei

ngco

nsid

ered

. How

ever

the

earl

iest

fun

ding

for

this

alte

rnat

ive

wou

ld b

e av

aila

ble

is 2

008,

with

a p

oten

tial f

undi

ng w

ould

not

be a

vaila

ble

until

201

0. T

he T

CE

Q a

sked

if th

e $1

3.1

mill

ion

cost

for

the

pref

erre

d re

med

y id

entif

ied

with

in th

e C

MS

had

alre

ady

been

exp

ende

d at

the

site

. The

AF

resp

onde

d, n

o, th

atdo

llar

amou

nt in

clud

ed f

utur

e op

erat

ion

and

mai

nten

ance

of

the

extr

actio

n an

d gr

ound

wat

er r

ecov

ery

syst

em c

urre

ntly

in p

lace

.

Page

3 o

f 5


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

9 A

ugus

t 200

5 M

eetin

g M

inut

es

Item

#L

ead

Supp

ort

Dis

cuss

ion

Top

icbi

iAIn

Ite

ms

onc1

uded

?(c

ont.)

Lan

dez,

N.

Dav

is, R

.Z

one

2 an

d 3

CM

S R

evie

w o

f pr

opos

ed r

evis

ions

Yes

AFR

PA in

quir

ed w

heth

er th

e C

orre

ctiv

e M

easu

res

to th

e D

raft

Zon

e 2

and

3Im

plem

enta

tion

Wor

k Pl

an (

CM

I W

P) c

ould

incl

ude

a sc

hedu

leC

orre

ctiv

e M

easu

res

Stud

y.in

dica

ting

the

timin

g of

the

impl

emen

tatio

n of

the

fina

l rem

edy

wou

ld b

e co

ntin

gent

upo

n av

aila

bilit

y of

fun

ds, m

eanw

hile

keep

ing

the

inte

rim

sys

tem

ope

ratio

nal.

The

TC

EQ

indi

cate

dth

is w

ould

be

acce

ptab

le p

rovi

ded

exis

ting

sour

ce c

ontr

ol w

asm

aint

aine

d up

to im

plem

enta

tion

of th

e fi

nal r

emed

y.

Com

men

t/Res

pons

e #1

9: T

he T

CE

Q in

dica

ted

the

CM

S sh

ould

be r

evis

ed to

indi

cate

fur

ther

eva

luat

ion

of s

oil v

apor

ass

ocia

ted

with

chl

orin

ated

sol

vent

s in

the

nort

hwes

t cor

ner

of B

uild

ing

360

will

be

cond

ucte

d an

d th

e sc

ope

of th

at e

valu

atio

n.

Furt

her

revi

ew o

f th

e A

FRPA

res

pons

e to

TC

EQ

and

EPA

com

men

ts w

ill b

e m

ade

by th

e T

CE

Q th

is w

eek

and

any

furt

her

conc

erns

reg

ardi

ng A

FRPA

res

pons

es w

ill b

e fo

rwar

ded

to

____

____

____

___

____

____

____

____

____

___

____

____

____

____

____

____

____

____

_A

FR

PA

.2.

Lan

dez,

N.

Zon

eZ

one

Upd

ates

Rev

iew

of

maj

or p

roje

ct s

tatu

s Y

esZ

one

2 —

Sam

plin

gof

the

mon

itori

ng w

ells

at t

he Z

one

2M

anag

ers

for

all I

RP

Zon

es.

perm

eabl

e re

activ

e ba

rrie

r (P

RB

) ne

ar L

eon

Cre

ek in

dica

tes

the

PRB

is w

orki

ng a

s in

tend

ed. C

once

ntra

tions

in a

ll bu

t one

dow

n gr

adie

nt w

ell a

re b

elow

det

ecta

ble

conc

entr

atio

ns (

ND

),w

ith o

ne w

ell e

xhib

iting

det

ecta

ble

conc

entr

atio

ns b

elow

the

appl

icab

le m

axim

um c

onta

min

ant l

evel

(M

CL

). S

ampl

esco

llect

ed f

rom

the

hydr

ogen

rel

easi

ng c

ompo

und

(HR

C)

inje

ctio

n po

ints

indi

cate

chr

omiu

m c

once

ntra

tions

are

ND

, with

the

exce

ptio

n of

one

poi

nt lo

cate

d ne

ar a

gro

undw

ater

ext

ract

ion

wel

l. A

dditi

onal

HR

C in

ject

ion

is p

lann

ed w

ithin

the

Zon

e 2

area

.

Zon

e 4

-P

roje

cted

date

to b

egin

inje

ctio

n of

iron

in th

e w

ells

at

the

UPR

R y

ard

is A

ugus

t 23.

Fur

ther

inje

ctio

n of

HR

C is

plan

ned

for

two

area

s in

Zon

e 4.

Zon

e 5

— A

dditi

onal

inje

ctio

n of

HR

C in

the

Bui

ldin

g 14

14 a

rea

—__

____

____

___

____

___

____

____

____

____

__ _

____

____

____

____

____

____

___

is p

lann

ed.

.P

age


i rT

CE

Q in

dica

ted

Tru

stee

Age

ncy

com

men

ts o

n th

e Fi

nal

Eco

-Ris

k A

sses

smen

t Rep

ort a

re a

ntic

ipat

ed b

y th

e en

d of

Oct

ober

200

5. E

PA in

dica

ted

thei

r le

ad e

colo

gica

l ris

k as

sess

orw

ould

like

to s

ched

ule

a m

eetin

g or

tele

conf

eren

ce w

ith a

llin

tere

sted

par

ties

prio

r to

sub

mitt

ing

com

men

ts o

n th

e re

port

toth

e A

ir F

orce

. The

TC

EQ

indi

cate

d th

ey w

ould

initi

ate

the

appr

opri

ate

coor

dina

tion

to e

xecu

te th

e m

eetin

g. A

FRPA

requ

este

d as

muc

h up

fro

nt n

otic

e on

the

mee

ting

requ

irem

ents

to c

oord

inat

e at

tend

ance

by

thei

r E

coR

isk

cont

ract

or.

AFR

PA in

quir

ed w

heth

er th

e E

PA h

ad b

egun

thei

r re

view

of

the

5 Y

ear

Rev

iew

sub

mitt

ed in

mid

-Jul

y. T

he E

PA r

espo

nded

that

rev

iew

of

the

docu

men

t had

not

bee

n st

arte

d an

d as

ked

wha

t tim

elin

e A

FRPA

is tr

ying

to m

eet.

AFR

PA r

eque

sted

any

revi

ew c

omm

ents

be

prov

ided

to th

e A

ir F

orce

by

Aug

ust

17th

,

2005

.

EPA

indi

cate

d an

EPA

HQ

dec

isio

n fo

r fu

ture

5 y

ear

revi

ews

wou

ld n

eed

to b

e m

ade

on A

genc

y re

sour

ce a

lloca

tion

prio

ritie

sfo

r do

cum

ent r

evie

w a

nd th

at th

e A

genc

y m

ay d

eclin

e to

rev

iew

the

futu

re r

epor

ts, s

ince

Kel

ly is

not

an

NPL

site

.

EPA

indi

cate

d th

eir

resp

onse

to th

e N

atio

nal E

nvir

onm

enta

lJu

stic

e A

dvis

ory

Cou

ncil

(NE

JAC

) st

udy

has

been

dra

fted

and

is w

aitin

g on

the

Div

isio

n .D

irec

tor's

app

rova

l and

sig

natu

re.

Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

9 A

ugus

t 200

5 M

eetin

g M

inut

es

Zon

ePe

ndin

g D

ocum

ent R

evie

w o

f do

cum

ents

to b

eM

anag

ers

Subm

ittal

ssu

bmitt

ed f

or r

egul

ator

yre

view

with

in th

e ne

xt 9

0da

ys;

Stat

us o

f do

cum

ents

alr

eady

in r

evie

w.

4.L

ande

z, N

.M

isce

llane

ous

Yes

Page

5of

5


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

19 J

uly

2005

Mee

ting

Min

utes

The

mee

ting

was

con

duct

ed b

egin

ning

at 1

p.m

. on

19 J

uly

2005

at t

he A

ir F

orce

Rea

l Pro

pert

y A

genc

y D

ivis

ion

C —

Kel

ly(A

FRPA

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ce in

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Ant

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exas

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fere

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posi

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Act

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Item

s

Lan

dez,

N.

Lon

eZ

one

Upd

ates

Rev

iew

of

maj

or p

roje

ct s

tatu

s Y

esM

anag

ers

for

all I

RP

Zon

es.

The

Lac

klan

d A

FB C

orre

ctiv

e M

easu

res

Stud

y (C

MS)

cont

ract

or (

WE

STO

N)

prov

ided

an

upda

te o

n th

e pr

ogre

ss o

fth

e pr

ojec

t. W

EST

ON

per

sonn

el in

dica

ted

the

hum

an h

ealth

risk

ass

essm

ent (

RA

) po

rtio

n of

the

proj

ect w

as b

eing

initi

ated

.W

EST

ON

had

que

stio

ned

the

need

for

a f

ull R

A in

ass

ocia

tion

with

impl

emen

tatio

n of

a p

resu

mpt

ive

rem

edy

and

had

cont

acte

d th

e T

CE

Q f

or g

uida

nce

on th

e sc

ope

of th

eas

sess

men

t.


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

19 J

uly

2005

Mee

ting

Min

utes

Page

2 o

f 7

WE

STO

N in

dica

ted

Mr.

Kip

Han

ey o

f T

CE

Q h

ad p

rovi

ded

reco

mm

enda

tions

on

how

to p

roce

ed w

ith th

e R

A a

s fo

llow

s:(1

) as

k th

e T

CE

Q p

roje

ct m

anag

er (

Mr.

Mar

k W

eega

r) f

orco

ncur

renc

e on

the

idea

that

impl

emen

tatio

n of

a p

resu

mpt

ive

rem

edy

prec

lude

s th

e ne

ed f

or a

RA

; (2)

con

duct

the

RA

bas

edon

an

assu

mpt

ion

of u

ncon

trol

led

expo

sure

to s

ite c

onta

min

ants

;or

(3)

con

duct

the

RA

und

er p

oten

tial e

xpos

ure

scen

ario

s bu

tw

ithou

t cal

cula

tion

of a

ccep

tabl

e ri

sk-b

ased

con

cent

ratio

ns f

orre

sidu

al s

ite c

onta

min

ants

. WE

STO

N p

rovi

ded

a do

cum

ent

sum

mar

izin

g sa

lient

RA

issu

es u

nder

eva

luat

ion

and

thei

rpr

opos

ed m

eans

of

addr

essi

ng th

ose

issu

es f

or B

CT

mem

bers

revi

ew.

The

TC

EQ

indi

cate

d th

at u

tiliz

atio

n of

a p

resu

mpt

ive

rem

edy

does

not

pre

clud

e th

e re

quir

emen

t for

a h

uman

hea

lth r

isk

asse

ssm

ent i

n th

e C

MS

proc

ess.

Im

plem

enta

tion

of a

pres

umpt

ive

rem

edy

need

s to

incl

ude

docu

men

tatio

n of

wha

tth

e "u

ncon

trol

led"

ris

k at

the

site

wou

ld b

e w

ithou

t the

corr

ectiv

e ac

tion.

The

TC

EQ

agr

eed

in c

once

pt th

at th

e R

Aco

uld

likel

y be

lim

ited

to th

e ev

alua

tion

of r

isk

leve

ls f

rom

unco

ntro

lled

expo

sure

if th

e pr

esum

ptiv

e re

med

y w

as to

incl

ude

capp

ing

and

long

term

mon

itori

ng. T

he T

CE

Q in

dica

ted

they

wou

ld r

evie

w th

e su

mm

ary

docu

men

t and

pro

vide

fee

dbac

k to

WE

STO

N a

s ap

prop

riat

e.

WE

STO

N in

dica

ted

they

are

als

o ev

alua

ting

soil

inor

gani

can

alyt

e co

ncen

trat

ions

rel

ativ

e to

est

ablis

hed

back

grou

ndco

ncen

trat

ions

for

the

form

er K

elly

AFB

to f

urth

er r

efin

e th

ebo

unda

ries

of

land

fill

units

req

uiri

ng a

rem

edia

l res

t,ons

e.

L&..

Lce

Upd

ates

-R

evie

wof

maj

or p

roje

ct s

tatu

sM

anag

ers

for

all I

RP

Zon

es.


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

19 J

uly

2005

Mee

ting

Min

utes

Item

#L

ead

Supp

ort I

Tus

sion

Top

iD

ispo

sitio

nlA

ctio

n It

ems

(con

t)L

ande

z, N

.Z

one

Zon

e IJ

pdat

esR

evie

w o

f m

ajor

pro

ject

sta

tus

Yes

AFR

PA a

dded

that

inor

galli

c an

alyt

e ba

ckgr

ound

Man

ager

sfo

r al

l IR

P Z

ones

.co

ncen

trat

ions

for

gro

undw

ater

hav

e al

so b

een

dete

rmin

ed f

orK

elly

and

sho

uld

also

be

refe

renc

ed in

the

deve

lopm

ent o

f th

eC

MS.

WE

STO

N p

rese

nted

an

isop

leth

map

with

app

roxi

mat

eth

ickn

esse

s of

exi

stin

g so

il co

ver

at th

e la

ndfi

ll un

its u

nder

eval

uatio

n in

the

CM

S. I

n di

scus

sion

of

the

exis

ting

cove

r,W

EST

ON

indi

cate

d th

at a

reas

with

sam

ple

resu

lts n

otex

ceed

ing

defa

ult a

ccep

tabl

e ri

sk le

vels

(i.e

., T

CE

Q R

isk

Red

uctio

n St

anda

rd N

o. 2

[R

RS2

] co

ncen

trat

ions

) m

ay r

equi

rem

inim

al, i

f an

y, r

ewor

king

of

surf

ace

cove

r.

The

TC

EQ

indi

cate

d th

at if

it c

ould

be

dem

onst

rate

d th

atm

ater

ials

with

in a

par

ticul

ar la

ndfi

ll se

ctio

n w

ere

not a

thre

at to

grou

ndw

ater

(i.e

., no

con

cent

ratio

ns e

xcee

ding

RR

S2gr

ound

wat

er p

rote

ctiv

e [G

WP]

leve

ls o

r no

leac

habl

e ch

emic

alof

con

cern

[C

0C]

conc

entr

atio

ns d

eter

min

ed b

y th

e sy

nthe

ticpr

ecip

itate

leac

hing

pro

cedu

re [

SPL

P]),

the

surf

ace

cove

rre

med

y re

quir

emen

ts c

ould

be

limite

d to

act

ions

to p

reve

ntpo

ndin

g an

d to

oth

erw

ise

faci

litat

e ap

prop

riat

e su

rfac

e ru

noff

at

the

site

.

The

USA

CE

rep

rese

ntat

ive

aske

d if

the

abov

e re

fere

nced

scen

ario

wou

ld p

recl

ude

pres

umpt

ive

rem

edy

requ

irem

ents

for

thos

e lo

catio

ns.

The

TC

EQ

res

pond

ed th

at it

wou

ld. U

tiliz

atio

n of

apr

esum

ptiv

e re

med

y as

sum

es s

ite c

ondi

tions

pre

sent

an

unac

cept

able

ris

k if

not

con

trol

led

in s

ome

fash

ion.

If

thos

ele

vels

of

risk

do

not e

xist

, the

n th

ere

is n

o re

quir

emen

t for

impl

emen

tatio

n of

a p

resu

mpt

ive

rem

edy.

His

tori

cal

asse

ssm

ents

of

the

land

fills

may

hav

e no

t acc

urat

ely

char

acte

rize

d th

e re

sidu

al r

isk

at th

ese

units

, res

ultin

g in

the

curr

ently

ass

umed

req

uire

men

t for

impl

emen

tatio

n of

apr

esum

ptiv

e re

med

y.

Page

3 e

2 (I


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

19 J

uly

2005

Mee

ting

Min

utes

Item

#L

ead

uppo

rT

hscu

ssio

piW

4io

1'e1

1R

DiO

Sttio

n/A

ctni

ms

i1

(con

t.)L

ande

z, N

.Z

one

Zon

e U

pdat

esR

evie

w o

f m

ajor

pro

ject

sta

tus

Yes

The

USA

CE

ask

ed if

the

land

fill

cont

ents

hav

e be

en e

valu

ated

Man

ager

sfo

r al

l IR

P Z

ones

.su

ffic

ient

ly to

allo

w f

or c

losu

re w

ithou

t the

pre

sum

ptiv

ere

med

y co

ver

requ

irem

ents

. WE

STO

N r

eplie

d th

at th

is h

ad n

otye

t bee

n do

ne, b

ut w

ould

be

a co

nsid

erat

ion

in th

e C

MS

eval

uatio

n.

The

TC

EQ

add

ed th

at th

ose

area

s no

t mee

ting

requ

irem

ents

for

clos

ure

unde

r R

RS2

wou

ld r

equi

re a

red

unda

nt c

ap.

WE

STO

N a

sked

whe

ther

clo

sure

und

er R

RS2

was

stil

l an

optio

n fo

r th

e si

tes

in c

onsi

dera

tion

of T

CE

Q d

eadl

ines

for

tran

sitio

n of

cor

rect

ive

actio

n fr

om th

e R

isk

Red

uctio

nSt

anda

rds

to th

e T

exas

Ris

k R

educ

tion

Prog

ram

(T

RR

P).

The

TC

EQ

res

pond

ed th

at th

e R

RS2

sun

set d

ate

does

not

app

lyin

this

cas

e as

the

form

er b

ase

is m

anag

ed u

nder

a R

CR

Ape

rmit

stip

ulat

ing

use

of th

e R

RSs

for

cle

anup

. The

TC

EQ

advi

sed

WE

STO

N a

nd L

AFB

to c

onsi

der

utili

zatio

n of

the

cont

aine

d-in

pol

icy

to c

onso

lidat

e no

n-ha

zard

ous

was

tes

and

ther

eby

limit

area

s re

quir

ing

a ba

selin

e ri

sk a

sses

smen

t and

the

subs

eque

nt im

plem

enta

tion

of a

pre

sum

ptiv

e re

med

y.

The

EPA

cau

tione

d th

at "

cher

ry-p

icki

ng"

and

cons

olid

atin

gm

ater

ials

with

hig

her

cont

amin

atio

n le

vels

will

req

uire

mor

eri

goro

us c

hara

cter

izat

ion

data

col

lect

ion

and

eval

uatio

n th

anth

at r

equi

red

to im

plem

ent a

pre

sum

ptiv

e re

med

y ov

er a

mor

een

com

pass

ing

area

.

WE

STO

N a

sked

if g

roun

dwat

er p

rote

ctiv

e st

anda

rds

for

soil

mus

t stil

l be

met

if g

roun

dwat

er is

bei

ng r

ecov

ered

fro

m a

part

icul

ar la

ndfi

ll an

d th

ere

are

no in

dica

tions

of

cont

amin

atio

nto

gro

undw

ater

fro

m th

at u

nit.

AFR

PA in

dica

ted

soils

at t

he la

ndfi

ll m

ust s

till b

e de

mon

stra

ted

to b

e pr

otec

tive

of g

roun

dwat

er, i

.e.,

less

than

RR

S2 G

WP

or n

ole

acha

ble

CO

C c

once

ntra

tions

by

SPL

P. I

f so

, the

n cl

osur

e of

the

soils

at t

he u

nit c

an b

e do

ne s

epar

atel

y fr

om g

roun

dwat

er.

Page

4 o

f 7


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

19 J

uly

2005

Mee

ting

Min

utes

Page

5

WE

STO

N a

sked

for

gui

danc

e on

how

to a

ddre

ss la

bora

tory

anal

ytic

al d

ata

Qua

lity

Ass

uran

ce /

Qua

lity

Con

trol

issu

es f

orsa

mpl

e re

sults

obt

aine

d du

ring

inve

stig

atio

ns c

ondu

cted

at t

hesi

te m

ore

than

ten

year

s ag

o. D

ata

from

thes

e in

vest

igat

ions

may

not

mee

t cur

rent

val

idat

ion

requ

irem

ents

.

The

TC

EQ

adv

ised

that

the

CM

S pr

oces

s sh

ould

ens

ure

prac

tical

qua

ntita

tion

limits

(PQ

Ls)

for

his

tori

cal s

ampl

e re

sults

are

com

men

sura

te w

ith c

losu

re c

rite

ria

for

the

site

CoC

s.A

dditi

onal

sam

plin

g m

ay b

e re

quir

ed to

res

olve

con

flic

ts in

the

data

set

.

Zon

es 2

and

3T

he A

FRPA

's r

espo

nses

to c

omm

ents

rec

eive

d fr

om T

CE

Q o

nth

e Z

ones

2 a

nd 3

CM

S ar

e al

mos

t com

plet

e. A

FRPA

isev

alua

ting

revi

sed

was

te c

lass

ific

atio

n as

sum

ptio

ns w

hich

may

lead

to e

xcav

atio

n an

d di

spos

al a

s th

e se

lect

ed r

emed

y at

Site

MP.

TC

EQ

inqu

ired

on

the

plan

ned

date

for

sub

mitt

al o

f th

e re

vise

ddo

cum

ent.

AFR

PA r

espo

nded

it c

urre

ntly

pla

nned

to p

rese

ntpr

opos

ed r

espo

nses

to c

omm

ents

for

dis

cuss

ion

duri

ng th

eA

ugus

t 200

5 B

CT

mee

ting

and

to s

ubm

it th

e re

vise

d C

MS

for

form

al r

evie

w s

oon

afle

r.

Zon

e 4

Com

plet

ion

of th

e pe

rmea

ble

reac

tive

barr

ier

(PR

B)

with

in th

eU

nion

Pac

ific

Rai

lroa

d al

ignm

ent i

s st

ill p

endi

ng in

ject

ion

ofir

on m

edia

, ant

icip

ated

to b

e do

ne w

ithin

thre

e w

eeks

of

the

mee

ting

date

.

The

Com

mer

cial

Str

eet P

RB

has

bee

n co

mpl

eted

, inc

ludi

ng s

itesu

rfac

e re

stor

atio

n w

ork.

Zon

e 5

AF

RP

Ais

coo

rdin

atin

g w

ith th

e C

ity o

f Sa

n A

nton

io to

com

plet

e st

reet

rep

airs

alo

ng th

e34

thS

tree

tPR

B a

lignm

ent.

1.(c

ont.)

Lan

dez,

N.

Zon

eZ

one

Upd

ates

Rev

iew

of

maj

or p

roje

ct s

tatu

s Y

esM

anag

ers

for

all I

RP

Zon

es.


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

19 J

uly

2005

Mee

ting

Min

utes

flrn

#L

ead

Supp

brl y

P is

Izio

pibi

iptc

tiofl

Ite

ms

Con

elud

éd?

(con

t.) L

ande

z, N

.Z

one

Zon

e U

pdat

esR

evie

w o

f m

ajor

pro

ject

sta

tus

Yes

The

Cor

rect

ive

Mea

sure

s Im

plem

enta

tion

Wor

k Pl

ans

and

Man

ager

sfo

r al

l IR

P Z

ones

.C

ompl

ianc

e Pl

an m

odif

icat

ions

ass

ocia

ted

with

the

Zon

e 4

and

Zon

e 5

CM

S do

cum

ents

are

in p

repa

ratio

n an

d ar

e ex

pect

ed to

____

____

____

____

_ __

____

__ _

____

____

____

___

____

____

____

____

____

____

____

____

____

__be

subm

itted

to th

e T

CE

Q in

Sep

tem

ber

2005

.2.

Lan

dez,

N.

Dav

is, R

. EPC

F R

FIR

evie

w o

f th

e R

CR

A F

acili

ty Y

esA

FRPA

sta

ff p

rese

nted

a s

umm

ary

brie

fing

on

the

met

hodo

logy

Inve

stig

atio

n (R

FI)

repo

rtof

the

RFI

pro

cess

and

the

cont

ents

of

the

RFI

rep

ort.

subm

itted

for

the

form

erE

nvir

onm

enta

l Pro

cess

The

TC

EQ

ask

ed if

the

repo

rt d

iscu

sses

non

-EPC

F re

late

dC

ontr

ol F

acili

ty (

EPC

F).

sour

ces

of c

onta

min

ated

gro

undw

ater

und

erly

ing

the

form

erfa

cilit

y ar

ea.

AFR

PA r

espo

nded

that

mos

t gro

undw

ater

CoC

s pr

esen

t but

not

sour

ced

from

the

EPC

F ar

e di

scus

sed

in th

e re

port

as

eman

atin

gfr

om S

ite E

-3 o

r ot

her

up-g

radi

ent Z

one

2 an

d 3

sour

ces

ofco

ntam

inat

ion.

An

exce

ptio

n is

the

spor

adic

ally

iden

tifie

dpr

esen

ce o

f ch

rom

ium

in g

roun

dwat

er. N

o de

fini

tive

asso

ciat

ion

with

on

or o

ff-s

ite s

ourc

es h

as b

een

mad

e fo

rch

rom

ium

in g

roun

dwat

er a

t the

EPC

F. T

he o

nly

sign

ific

ant

area

of

chro

miu

m im

pact

to s

oil i

dent

ifie

d du

ring

the

faci

lity

dem

oliti

on a

nd c

losu

re a

ctiv

ities

was

sam

pled

and

did

not

exih

ibit

leac

habl

e co

ncen

trat

ions

(ba

sed

on S

PLP

anal

ysis

).N

otw

ithst

andi

ng a

ny p

oten

tial f

or im

pact

, the

maj

ority

of

chro

miu

m im

pact

ed s

oil w

as e

xcav

ated

.

The

TC

EQ

ask

ed c

lari

fica

tion

on th

e ex

tent

of

veri

fica

tion

sam

plin

g co

nduc

ted

for

proc

ess

pipi

ng d

ecom

mis

sion

ed o

n th

eva

riou

s un

its c

lose

d. T

he r

epor

t rea

dily

des

crib

es th

e pr

oces

sfo

r cl

osin

g m

ain

infl

uent

and

eff

luen

t pip

ing,

but

anc

illar

yin

term

edia

te p

roce

ss p

ipin

g w

as n

ot a

dequ

atel

y di

scus

sed.

Was

rele

ase

dete

ctio

n sa

mpl

ing

cond

ucte

d fo

r th

ese

inte

rmed

iate

proc

ess

pipe

s?

Page

6 o

f 7


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB

) B

RA

C C

lean

up T

eam

(B

CT

)19

Jul

y 20

05 M

eetin

g M

inut

es

-ite

m#

Lea

dSu

ppor

tD

iscu

ssio

n T

opic

Com

men

tsD

iscu

ssio

n T

opic

Dis

posi

tion/

Act

ion

item

s-

Con

clud

ed?

2.(c

oul.)

Lan

dez,

N.

Dav

is, R

.E

PCF

RFI

Rev

iew

of

the

RC

RA

Fac

ility

Yes

The

AFR

PAre

spon

ded

that

the

inte

rmed

iate

pro

cess

pip

ing

inIn

vest

igat

ion

(RFI

) re

port

ques

tion

wou

ld h

ave

vari

ed in

nat

ure

and

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adily

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The

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the

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visi

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CE

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fere

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repo

rt. T

CE

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dica

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wou

ld b

eac

cept

able

.

The

TC

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ask

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or a

list

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units

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uded

on

the

form

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port

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dica

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the

list w

ould

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.3.

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dez,

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anag

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Pend

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Doc

umen

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Rev

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itted

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atus

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Var

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San

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MS)

con

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EST

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STO

N in

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the

land

fill

boun

dari

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win

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e re

view

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sam

plin

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alys

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ata

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fro

m th

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iron

men

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rev

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lted

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ses

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e ar

eas

assu

med

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dres

sed

duri

ng th

e C

MS

proc

ess.


.Fo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

14 J

une

2005

Mee

ting

Min

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Page

2 o

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iiire

ques

ted

to r

evie

w th

e an

ticip

ated

sco

peof

the

CM

S pr

ojec

t. W

EST

ON

indi

cate

d th

e fi

rst t

ask

wou

ld b

eto

pre

pare

a s

umm

ary

of h

isto

rica

l inv

estig

atio

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war

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velo

pmen

t of

a co

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tual

site

mod

el (

CSM

). T

he C

SM w

illbe

use

d to

eva

luat

e ad

ditio

nal d

ata

requ

irem

ents

, if

any,

and

the

risk

exp

osur

e as

sum

ptio

ns to

be

utili

zed

in th

e re

med

y se

lect

ion

proc

ess.

The

dev

elop

men

t of

the

CSM

will

incl

ude

fiel

d da

taco

llect

ion

to "

grou

nd tr

uth"

ass

umed

land

fill

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ition

s.A

dditi

onal

site

dat

a re

view

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incl

ude

eval

uatio

n of

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ilabl

ehi

stor

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aer

ial p

hoto

grap

hs a

nd p

revi

ousl

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llect

edge

ophy

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l sur

vey

info

rmat

ion.

The

CM

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s w

ill in

clud

ea

hum

an h

ealth

ris

k as

sess

men

t. W

EST

ON

indi

cate

d a

stan

d-al

one

risk

ass

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ent d

ocum

ent m

ay b

e su

bmitt

ed f

or a

genc

yre

view

sep

arat

ely

from

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CM

S re

port

.

The

TC

EQ

indi

cate

d th

eir

file

for

Zon

e 1

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udes

corr

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nden

ce to

the

Air

For

ce r

elay

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st f

orad

ditio

nal a

sses

smen

t act

iviti

es in

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pons

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rev

iew

of

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rca

1995

Rel

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Inv

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epor

t. T

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ed th

atA

ir F

orce

res

pons

es to

suc

h a

requ

est w

ould

hav

e lik

ely

been

addr

esse

d du

ring

the

Feas

ibili

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ase

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e pr

ojec

t.T

he A

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omm

ende

d th

at W

EST

ON

rev

iew

the

Kel

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istr

ativ

e R

ecor

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r po

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then

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atur

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w o

f th

e 19

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d fo

rpo

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spon

ses

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RI

with

in th

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pend

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ter

FS r

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t. T

he T

CE

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epre

sent

ativ

ein

dica

ted

that

any

cor

resp

onde

nce

rela

ted

to th

e 19

95 R

I re

view

in th

e A

genc

y fi

le w

ould

be

prov

ided

via

fax

to W

EST

ON

.

WE

STO

N c

ontin

ued

disc

ussi

ons

of th

eir

prel

imin

ary

revi

ew o

fsi

te c

ondi

tions

and

cur

rent

ass

umpt

ions

ass

ocia

ted

with

deve

lopm

ent o

f th

e C

MS.

For

eva

luat

ion

of c

orre

ctiv

e ac

tions

,la

ndfi

ll ar

eas

have

bee

n ca

tego

rize

d by

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type

s of

was

tes

cont

aine

d (c

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ruct

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is, m

unic

ipal

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id w

aste

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zard

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inal

cov

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Fina

l

Zon

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one

Upd

ates

Rev

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maj

or p

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tatu

sM

anag

ers

for

all I

RP

Zon

es.


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

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Tea

m (

BC

T)

14 J

une

2005

Mee

ting

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Item

#L

ead

Supp

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Dis

cuss

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Top

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____

____

____

____

____

conc

lude

d?(c

orn.

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ande

i, N

.Z

one

Zon

e U

pdat

esR

evie

w o

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ajor

pro

ject

sta

tus

Yes

WE

STO

N a

ntic

ipat

es c

losi

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ontig

uous

land

fill

area

s un

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ers

for

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RP

Zon

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sing

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isk

Red

uctio

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tially

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fere

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ver

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sed

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pes

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aste

con

tain

ed. W

EST

ON

'scu

rren

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umpt

ions

for

add

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the

Lan

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12

"Dru

mD

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rea"

indi

cate

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or e

xcav

atio

n an

d of

f-si

tedi

spos

al o

f th

e dr

ums

wou

ld e

xcee

d a

wor

kabl

e po

rtio

n of

the

proj

ect b

udge

t. T

he T

CE

Q in

quir

ed o

n th

e fa

ctor

s in

flue

ncin

gth

e hi

gh c

ost f

or th

e al

tern

ativ

e. W

EST

ON

rep

lied

that

man

agem

ent o

f th

e dr

ums

and

asso

ciat

ed c

onta

min

ated

envi

ronm

enta

l med

ia a

s ha

zard

ous

was

te w

ould

be

proh

ibiti

vely

expe

nsiv

e. E

xcav

atio

n of

the

drum

s w

ould

nec

essa

rily

incl

ude

de-w

ater

ing,

with

rec

over

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roun

dwat

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ache

ate

also

requ

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g tr

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ent a

s ha

zard

ous

was

te p

rior

to d

isch

arge

.Fu

rthe

r, th

e ex

cava

tion

proc

ess

wou

ld r

equi

re s

igni

fica

ntdi

vers

ion

of s

urfa

ce w

ater

flo

w (

stor

m w

ater

dra

inag

e) a

t the

site

. The

TC

EQ

inqu

ired

if th

e U

SAC

E r

epre

sent

ativ

e w

asfa

mili

ar w

ith a

sim

ilar

drum

rem

oval

pro

ject

con

duct

ed a

tC

arsw

ell A

FB, T

X, c

ondu

cted

at a

sig

nifi

cant

ly lo

wer

cos

t tha

nth

at c

urre

ntly

est

imat

ed b

y W

EST

ON

. The

USA

CE

repr

esen

tativ

e in

dica

ted

that

the

Car

swel

l pro

ject

was

con

duct

edth

roug

h th

e C

orps

of

Eng

inee

rs, b

ut h

e w

as n

ot a

war

e of

the

proj

ect s

peci

fics

. The

USA

CE

indi

cate

d it

wou

ld a

ttem

pt to

acqu

ire

info

rmat

ion

on th

e ex

ecut

ion

and

cost

of

the

proj

ect t

opr

ovid

e to

WE

STO

N.

The

AE

TC

rep

rese

ntat

ive

inqu

ired

if m

ultip

le la

ndfi

ll un

itsw

ould

be

addr

esse

d w

ith th

e co

nstr

uctio

n of

a s

ingl

e ca

p if

the

natu

re o

f th

eir

cont

aine

d w

aste

s w

as o

f a

com

patib

le n

atur

e.W

EST

ON

rep

lied

that

this

was

gen

eral

ly th

e pl

an, w

ith th

eex

cept

ion

of s

ome

units

pot

entia

lly n

eedi

ng to

be

addr

esse

dea

rlie

r th

an o

ther

s du

e to

Air

For

ce I

RP

prog

ram

last

rem

edy

inpl

ace

(LR

IP)

requ

irem

ents

. The

TC

EQ

inqu

ired

how

WE

STO

Nw

ould

add

ress

the

prop

osed

bre

aks

in th

e ty

pe o

f co

ver

cons

truc

ted

over

abu

tting

por

tions

of

the

land

fills

. WE

STO

Nin

dica

ted

that

tech

nica

l iss

ues

asso

ciat

ed w

ith p

reve

ntin

gm

igra

tion/

infi

ltrat

ion

from

are

as o

f le

ss r

igor

ous

capp

ing

requ

irem

ents

(i.e

., co

nstr

uctio

n de

bris

) to

thos

e w

ith m

ore

robu

st c

over

(i.e

., ha

z w

aste

) ar

e cu

rren

tly b

eing

eva

luat

ed.


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

14 J

une

2005

Mee

ting

Min

utes

Page

4 o

f 6

AFR

PA a

dvis

ed th

at p

oten

tial m

aint

enan

ce r

equi

rem

ents

of

sani

tary

sew

er li

nes

with

in th

e la

ndfi

ll ar

eas

shou

ld b

ead

dres

sed

in th

e fi

nal r

emed

y se

lect

ion

and

desi

gn.

WE

STO

N a

ckno

wle

dged

the

conc

ern

and

indi

cate

d th

is a

ndot

her

requ

irem

ents

ass

ocia

ted

with

exi

stin

g si

te c

ondi

tions

(spe

cifi

cally

citi

ng s

urfa

ce w

ater

flo

w d

iver

sion

to p

rote

ct c

apin

tegr

ity)

wou

ld b

e ad

dres

sed

as a

ppro

pria

te. O

ther

cur

rent

lyev

alua

ted

alte

rnat

ives

with

in th

e C

MS

incl

ude

repl

acem

ent o

fth

e gr

ound

wat

er r

ecov

ery

wel

l arr

ay w

ith a

rec

over

y tr

ench

and

inst

alla

tion

of a

per

mea

ble

reac

tive

barr

ier

(PR

B)

to p

reve

ntbr

eakt

hrou

gh o

f co

ntam

inan

ts to

dow

n gr

adie

nt a

reas

. Lan

dfill

boun

dari

es c

urre

ntly

bei

ng c

ompr

omis

ed b

y er

osio

n as

soci

ated

with

the

Leo

n C

reek

str

eam

cha

nnel

will

als

o be

add

ress

ed b

yim

plem

enta

tion

of th

e fi

nal r

emed

y.

The

TC

EQ

rec

omm

ende

d ev

alua

ting

pote

ntia

l eco

nom

ies

in c

apco

nstr

uctio

n by

con

solid

atio

n of

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der

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n Po

licy.

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adv

ised

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nges

to m

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l loc

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ns r

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ting

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impl

emen

tatio

n of

the

fina

l rem

edie

s ne

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ured

with

in th

e as

soci

ated

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ss 3

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plia

nce

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mod

ific

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n.

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ata

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labl

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sion

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es 2

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omm

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and

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men

t. T

he A

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indi

cate

d re

spon

ses

to th

eT

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omm

ents

wer

e in

pre

para

tion.

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ed o

n co

mm

ents

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dez,

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eM

anag

ers

Rev

iew

of

maj

or p

roje

ct-

for

all I

RP

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es.

curr

ently

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icip

ated

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n co

nsis

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f th

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uctio

n 01

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hor

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ches

" be

twee

n va

ryin

g co

ver

type

s.


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lFo

rmer

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ly A

ir F

orce

Bas

e (A

FB)

BR

AC

Cle

anup

Tea

m (

BC

T)

14 J

une

2005

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ting

Min

utes

rela

ting

to w

aste

cla

ssif

icat

ion,

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dica

ted

the

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aybe

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to in

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te e

xcav

atio

n w

ith o

ff-s

ite d

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sal a

s th

epr

efer

red

alte

rnat

ive

for

Site

MP.

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TC

EQ

sug

gest

edre

visi

ting

assu

mpt

ions

for

was

te c

lass

ific

atio

n th

roug

hout

the

CM

S do

cum

ent t

o en

sure

con

sist

ency

bet

wee

n di

ffer

ent

envi

ronm

enta

l med

ia a

ffec

ted

by th

e sa

me

sour

ce a

nd to

ver

ify

accu

rate

des

igna

tion

of li

sted

and

cha

ract

eris

tical

ly h

azar

dous

was

te. T

he A

FRPA

inqu

ired

if th

e T

CE

Q w

ould

like

to d

iscu

ssth

e A

ir F

orce

's p

ropo

sed

resp

onse

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a B

CT

mee

ting

prio

r to

subm

ittal

bac

k to

the

Age

ncy.

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indi

cate

d th

at w

ould

be a

t the

dis

cret

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of th

e A

ir F

orce

, but

it w

as n

ot n

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sari

lyre

quir

ed.

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e 4/

Off

-bas

eA

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inqu

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if r

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nses

to T

CE

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omm

ents

on

the

Zon

e4

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entia

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oor

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tile

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nic

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poun

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OC

) va

por

expo

sure

cou

ld b

e ad

dres

sed

with

in a

sep

arat

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bmitt

al f

rom

the

revi

sed

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S do

cum

ent.

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TC

EQ

indi

cate

d th

is w

ould

be

acce

ptab

le.

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ctiv

e m

edia

inje

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n eq

uipm

ent f

or c

onst

ruct

ion

of th

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nion

Pac

ific

Rai

lroa

d PR

B is

stil

l in

repa

ir. T

he e

stim

ated

com

plet

ion

date

for

the

barr

ier

cons

truc

tion

is J

uly

2005

.Su

rfac

e re

stor

atio

n as

soci

ated

with

the

cons

truc

tion

of th

eC

omm

erci

al S

tree

t PR

B is

in p

roce

ss.

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ewid

eA

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is in

the

proc

ess

of r

emov

ing

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ndan

t Com

plia

nce

Plan

gro

undw

ater

mon

itori

ng w

ells

and

oth

erw

ise

unne

eded

wel

ls lo

cate

d in

City

of

San

Ant

onio

(C

oSA

) ri

ght-

of-w

ayar

eas.

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a re

late

d no

te, t

he T

CE

Q in

dica

ted

that

corr

espo

nden

ce a

ssoc

iate

d w

ith c

losu

re o

f w

ells

in th

e 11

00A

rea

(Zon

e 5)

offo

rmer

Kel

ly w

ould

be

fort

hcom

ing.

AFR

PA's

res

pons

e to

reg

ulat

or c

omm

ents

on

the

Bas

ewid

eE

colo

gica

l Ris

k A

sses

smen

t are

bei

ng p

repa

red

and

shou

ld b

eou

t for

fin

al r

egul

ator

rev

iew

by

late

Jun

e or

ear

ly J

uly

2005

.

l.(co

nt.)

Lan

dez,

N.

Zon

eZ

one

Upd

ates

Rev

iew

of

maj

or p

roje

ct s

tatu

s Y

esM

anag

ers

for

all I

RP

Zon

es.


Fina

lFo

rmer

Kel

ly A

ir F

orce

Bas

e (A

FB

) B

RA

C C

lean

up T

eam

(B

CT

)14

Jun

e 20

05 M

eetin

g M

inut

es

Zon

ePe

ndin

g D

ocum

ent

Rev

iew

of

docu

men

ts to

be

Yes

The

list

of

docu

men

ts p

lann

ed f

or r

egul

ator

y re

view

with

in 9

0M

anag

ers

Subm

ittal

ssu

bmitt

ed f

or r

egul

ator

yre

view

with

in th

e ne

xt 9

0da

ys;

Stat

us o

f do

cum

ents

alr

eady

in r

evie

w.

•

days

of

the

mee

ting

date

(at

tach

ed)

was

rev

iew

ed. A

lthou

gh n

oton

the

list,

AFR

PA in

dica

ted

that

the

Sem

i-A

nnua

l Com

plia

nce

Plan

rep

ort w

ould

be

subm

itted

for

TC

EQ

rev

iew

in J

uly

2005

.

3.L

ande

z, N

.D

SMO

AR

evie

w o

f T

CE

Q 's

req

uest

for

Yes

The

AFR

PA in

dica

ted

a tw

o-ye

ar e

xecu

tion

plan

wou

ld h

ave

toad

ditio

nal f

unds

und

er th

ebe

dev

elop

ed f

or T

CE

Q f

undi

ng u

nder

the

exis

ting

coop

erat

ive

Def

ense

and

Sta

teag

reem

ent.

The

TC

EQ

con

curr

ed b

ut c

autio

ned

that

the

Mem

oran

dum

of

Agr

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ent

Coo

pera

tive

Agr

eem

ent d

oes

not p

rovi

de f

or a

"lin

e ite

m(D

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A)

revi

ew/a

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val"

of

prop

osed

TC

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cos

ts f

or p

rogr

am r

evie

wsu

ppor

t.

Page

6 o

f 6


c DEPARTMENT OF THE AIR FORCE• AIR FORCE REAL PROPERTY AGENCY

AFRPA/DC-Kelly143 Billy Mitchell Blvd Ste 1San Antonio TX 78226-18 16

Dear Kelly Restoration Advisory Board Members

The following are read-ahead materials for the upcoming Kelly Technical ReviewSubcommittee (TRS) meeting 13 September2005, 6:30p.m. at the Greater Kelly DevelopmentAuthority, 14TBfflMftchell Blvd., Bldg. 43, Suite 6, San Antonio, TX 78226. The meeting willbegin in the GKDA Conference Room, followed by a chartered bus tour of various cleanup sitesat the former Kelly Air Force Base (AFB).

The first thirty minutes of the TRS meeting will be devoted to the selection of a newTAPP contractor. The meeting will adjourn at 7:00p.m. At that time, all interested parties will beinvited to board a bus in the GKDA parking lot. The Kelly Restoration Advisory Board (RAB)has expressed a desire to educate new RAB members about the various cleanup technologiesbeing used at Kelly. This tour will be an excellent opportunity for the community to becomefamiliar with these cleanup technologies first hand. In order to see as many sites as possible priorto the loss of sunlight, this will be a driving window tour with the exception of the final stop atthe groundwater treatment plant. There will be a 30-minute walking tour of the groundwatertreatment plant to experience the cleanup process in person.

The following materials are included for your review prior to the meeting:

• September TRS agenda• TAPP contractor information• Remediation tour itinerary• New co-chair library documents

If you have questions regarding the materials, please contact the Public Affairs OfficerSonja Coderre at (210) 925-0956.


TAPP Budget Update

Beginning Amount $100,000.00

Fiscal Year Project/Document Name - Contractor Amount1998. ATSDR Report (Water) University of Maryland $9,706.001998 1997 Base-wide Remediation Assessment Clearwater Revival $6,975.001998 OU-2 Workplan Neathery Environmental $5,145.001999 Zone 3 Corrective Measures Study Addendum Clearwater Revival $6,375.001999 Remedial Investigation of Zone 4 OU-2 Neathery Environmental $6,195.001999 Final Zone 5 Corrective Measures Study Geomatrix $3,617.502000 Shallow Groundwater Report Geomatrix $5,572.50

2000.

Site S-8 Draft Final Corrective MeasuresInvestigation

-

Neathery Environmental $5660.00

2000 Site MP Draft RCRA Facility Investigation Clearwater Revival $5,925.002001 Zone 3 RCRA Facility Investigation Clearwater Revival $5,775.002001 Zone 4 Corrective Measures Study Geomatrix $8,390.002001 ATSDR Health Assessment University of Maryland $7,428.00

2003

—

(Mod-Ui) Additional Travel Expenses forPresentation_to_RAB Clearwater Revival $500.00

2003 Zone 2/3 Correctives Measures Study Neathery Environmental $5,570.002003 ATSDR Air Emission Study University of Maryland $8,366.002005 2005 Semiannual Compliance P/an TBD. TBD

Total Spent to Date $91,200.00Remaining Balance $8,800.00


STATEMENTS OF OBJECTIVES (SOO)REVIEW JANTJARY 2005 SEMIANNUAL COMPLIANCE PLAN REPORT

1.0 GENERAL

Li Scope

This task is to review the January 2005 Semiannual Compliance Plan Report for the formerKelly Air Force Base (AFB), focusing on the off-base impacts from Zones 2, 3, 4, and 5,including an identification of gaps in the location of monitoring wells, and identification of anytrends in the contamination, providing a layperson's explanation of the 2004 annual shallowgroundwater assessment.

1.2 Background

The compliance plan report documents the results of the annual groundwater sampling conductedatthe former Kelly AFB in San Antonio, Texas. The former base conducts annual assessmentsof the shallow groundwater in accordance with the Texas Commission of Environmental Quality(TCEQ) issued Compliance Plan (CP-50310), dated on June 12, 1998. The annual assessment isused to determine the effectiveness of ongoing remedial activities in improving the quality ofgroundwater in the surficial (shallow groundwater) aquifer. The annual groundwaterassessments began in 1994. The report describes current remedial activities, summarizes resultsof groundwater data collected during 2004, and evaluates these results with respect to historicaldata collected since 1994. In addition to these data, the, analysis for the 2004 assessmentconsiders site hydrogeology, including groundwater and surface water interaction.

1.3 Objectives

1.3.1 The contractor shall furnish all professional non-personal service labor, management,supervision, tools, materials, equipment, transportation, mailings, and reproductions, unlessspecified herein, for the assigned tasks issued against this Blanket Purchase Agreement.

1.3.2 The contractor shall provide technical assistance to the Restoration Advisory Board (RAB)and RAB Technical Review Subcommittee (TRS) by interpreting and translating the data in thecompliance plan report.

1.3.2.1 The following specific tasks may be required for this project:

• Attend a pre-performànce meetinga Develop and submit a schedule for completion of the work• Conduct a technical review of the compliance plan report

Conduct an oral presentation of the report's conclusions at a TRS meeting• Provide a review of the compliance plan report in layman's terms• Provide a response to TRS comments, either orally or in writing


• Present the fmal report at a RAB meeting• Participate in teleconference call

1.4 Guidance and Compliance Documents

All assessments and recommendations shall complywith all Federal; State, and localenvironmental laws and regulations including, but not limited to applicable portions of thestatutes and regulations cited below The contractor shall be provided with the Compliance PlanReport; however, the contractor is responsible for obtaining all public documents as neededbased on the individual tasks issued against this agreement. Examples of the types of documentsthat may be required are listed.

• Kelly Permit HW-50310 and Compliance Plan CP-503 10, 12 June 1998, and subsequentClass 3 Modifications.

• Installation and Closure of Shallow Aquifer Wells and Soil Borings on Kelly Air ForceBase Technical Design specifications (TDS), December 1998.Final Quality Program Plan 2004 Compliance ProgramlGroundwater Monitoring, April2004.

• Final Kelly AFB Basewide Quality Assurance Program Plan and Sampling and AnalysisPlan, August 1999.

2.0 PROGRAM MANAGEMENT

2.1 Background Data/Information Review

2.1.1 The Air Force Real Property Agency (AFRPA) shall provide the contractor, whereavailable, all pertinent and available background information concerning this task order. Thecontractor may be required to review/obtain additional background data information as requiredfor the performance of the required services.

2.1.2 To accommodate the Air Force's remediation schedule, the contractor and the Air Forceshall agree on a schedule or timeline for this task based upon the hours agreed on between thecontracting officer and the contractor at time of award of the task. The contractor shall berequired to meet the required timeline. Any extension of timemust be agreed to by the AFRPAand RAB, and approved in writing by the Contracting Officer.

2.2 Meetings

2.2.1 Pre-Performance Conference — A pre-performance conference shall be held after the awardof the order and prior to commencement of the work at a time, place and date specified by theContracting Officer, as soon as the Compliance Plan report is received by the Air Force.Discussions at the meeting shall include the development of a mutual understanding relative toissuing task orders, scheduling and administering the work.


2.2.2 Contractor is invited to attend TRS meetings (nonnally held the second Tuesday ofFebruary, March, May, June, August, September, November, and December) and RAB meetings(normally held the third Tuesday of January, April, July and October).

3.0 PROJECT EXECUTION

3.1 Specific Requirements

3.1.1 Technical Review Report: This requires a review of the specific report and the applicabledocuments to be reviewed. The contractor is tasked with evaluating the report with respect tocurrent environmental actions by the Air Force, assessing the completeness of the reports andadequacy of proposed or current actions, and making recommendations for future actions.

3.1.1.1. The written report shall include a defense of the process for making the determinationsand an evaluation of the levels of confidence in the recommendations. The report need not belengthy — an executive summary format is desirable. It must be written in layman's terms, so theRAB shall easily be able to communicate the findings to the community, if necessary.

3.1.1.2 All submittals must be double-sided, 100% post-consumer, recycled paper.

3.1.2 Technical Oral Presentation: This task order involves presenting the findings to themembers of the TRS at a regularly scheduled TRS meeting time, followed by presentinga finalpresentation to the RAB at a regularly scheduled RAB meeting time. A flrth date for thesemeetings shall be scheduled at the time the order is placed. TRS meetings are normally held thesecond Tuesday of February, March, May, June, August, September, November, and Decemberat 6:30 p.m. TRS meetings are usually held at the Environmental Health and Weliness Center,911 Castroville Road, San Antonio, Texas. RAB meetings are normally held on the thirdThursday of January, April, July, and October at 6:30 p.m. at Kennedy High School, 1922 SouthGeneral McMullen, San Antonio, Texas.

3.1.3 Response to Comments: Following the review of the written report and/or oralpresentation, RAB members may have comments they wish addressed. The Contractor shallprovide a written response to each question from the RAB, if so stated in this task order.Comments received before the oral presentation may also be delivered verbally at thepresentation.

3.2 Public Affairs

The contractor shall not make available to the news media, nor make public disclosure of anydata resulting from this contract during the performance of this contract. During theperformance of this contract, the contractor shall refer all press or public contacts to the DoD co-chair. The documents produced and a transcription of the RAB presentation shall be placed inthe Administrative Record and Information Repository by the Air Force. After completion of allrequirements the public disclosure restriction shall be removed.


4.0

Each task order shall specify the required deliverables, with the quantities and time framespecified. Each written submittal shall include a cover letter stating the deliverable beingprovided and shall include the Blanket Purchase Agreement number and Task order number. Thecontractor shall provide a copy of the cover letter to the contracting officer. Copies ofreports donot need to be provided to the contracting officer unless specified in the Task order. The detailsof the speci de1iyebles shall be identified with the award of the project.

5.0 CONTRACT SURVEILLANCE

5.1 Quality of Work

The contractor is solely responsible for the quality of the work. The Inspection of ServicesClause applies to this order.

5.2 Inspection/Oversight Responsibilities and Acceptance

5.2.1 The Senior Representative of the former Kelly AFB is the Installation Co-Chair of theRAB. The Contracting Officer (C.O.) shall designate a C.O. Representative (COR) who shall actas liaison between the Contractor and the RAB. The Contracting Officer shall be notified of anyconflicts and shall resolve any problems that cannot be mutually resolved between theContractor, Installation Co-Chair, and the RAB Community Co-Chair, or designatedrepresentatives. A meeting of all parties, at no additional cost to the government, may be calledby the Contracting Officer to discuss and propose solutions to resolve discrepancies.

5.2.2 The Contractor is advised that only the Contracting Officer can obligate the government ordirect the contractor. The COR and the RAB members DO NOT have this authority. Thecontractor SHALL NOT EXCEED the total amount of any order awarded without prior writtenapproval of the contracting officer

5.2.3 The COR, with the RAB's concurrence, shall certify acceptance at completion of the task.

6.0 POINTS OF CONTACT

A list of Points of Contact shall be available with the award of this task order.


Report

Response IRS

RAB PresentMtg. Ep

$ i.is.oo

_______

a/, F\$ 115.00

_______

ii$ ¶15.00 -

I, -$ 11&00 '•-ra'Q

TOTAL QZ

BPA F4122--A-5ea1 Rqus D te; 15 Jul 05

SeminnuaJ Compliance Plan Report

9omatrirx

HOURS

1

___

TASK

AttidPTeperf Mt Mt Exp

Pevp Schec

TGch Rsvtsw

AMOUNT2ORATE

S 115.00

$ 115.00

$ 115.00

I

12-.L!d5'3ESO

Oral Prst-TS 4Mtg Exp —.

4.


BPA F41622-98-A-5882 Request Date: 15 Jul 05

Semiannual Compliance Plan. Report

Cleaiwater Revival

Oral Prst-TRSMtg Exp

Report

Response TRS

RAB PresentMtg. Exp

HOURS RATE AMOUNT

________

$ 75.00

________

$ 500.00

________

$ 75.00

________________

$ 75.00

________________

$ 75.00

________

$ 500.00

TOTAL

lAS K

AttendPreperl Mt Mtg Exp

Develop Sched

Tech Review

$ 75.00$ 500.00

$ 75.00

$ 75.00


Dobson NatKr flssociats F6X NO. 210—930—5252 Jul. 21 2005 0935flM P2

BPA F41 622-98-A-5884 Request Date: 15 Jul 05

Semiannual Compliance Plan ReportNeathery

TASK

Attend Preperformance meeting

Develop Schedule

Tech Review

Oral Presentation to TRS

Report Praparation

Prepare Response to TRS

Presentation to RAB

Hours

2.00

1.00

30.005.00

3.00

8.00

3.00

3.00

Rate

$90.00

$90.00

$80.00$135.00

$90.00

$80.00

$80.00

-. $9000

TOTAL

Amount

$1 8000

$90.00

$2400.00$67500

$270.00

$640.00

$240.00

$270.00

$4,765.00


IVEDIAUG 092005iBY:Documents to the TRS/RAB

I, Robert Silvas, Co-chair of the Kelly Restoration Advisory Board, accept the followingdocument(s) to be included in the Co-chair Library at the Environmental Health andWeilness Center. The document(s) will remain in the Co-chair library to allow fellowRAB members the opportunity for review. The documents will not be replaced ifremoved.

1. Semiarmual Compliance Plan Report for July 2005 (Jan — Jul 05) with Parts 1,2,32. Ecological Risk Assessment Addendum Tier 2, Tier 3 with CD3. AFRPA Letter to Neighbors/Residents on Removal of Groundwater Recovery

Well STOO6RW112 from S-44.Cc t-t 3p5. J1 *R&I ..

________/__ __________

obert Silvas Date / Adam AntwineAB Co-chair Installation Co-chair

S. 1 i)' '42f4J

ii 7'1j.cd Q/izk


PATCOALITION SEEKING JUSTICE FOR PEOPLE

AFFECTED BY TOXINS WHILE WORKING AT ORLIVING NEAR MILITARY INSTALLATIONS

319 West Kings Highway, San Antonio, Texas 78212-2831

July 29, 2002

Jeffrey SaitasExecutive DirectorTexas Natural Resource Conservation Commission.c/o Office of the Chief Clerk

MC 105TNRCCP.O. Box 13087Austin, Texas 78711-3087

RE: Kelly Air Force Base Compliance Plan for Site 5-4 GroundwaterClass 3 Modification; Compliance Plan CP-50310

Dear Mr. Saitas:

The purpose of this letter is to submit the comments of the Coalition Seeking Justice for PeopleAffected by Toxins While Working at or Living Near Military Installations (PAT) on theCompliance Plan referenced above. This orgrni7ation is primarily made up of former KAFBworkers and residents living in the areas contfiminated by the hazardous substances releasedfrom KAFB. Several of our members live in Zone 5 and are affected by the proposed plan forclean up of site S-4 Groundwater. The proposed plan is not technically complete and hasfailed to address numerous issues with regards to the contamination, which has migratedinto the neighboring communities surrounding the former Kelly Air Force Base (KAFB)and the underlying Edwards Aquifer. Furthermore, this plan was developed withoutproper public participation as mandated by federal and state law.

An independent review of the scientific studies used in determining the plan to be selected, wasconducted by Dr. Catherine Squibb, who identified numerous flaws in the technical approachand the lack of significant data upon which to base the selection of the clean up method. Whenthese deficiencies were presented to the Technical Review Subcommittee of the RestorationAdvisory Boan4 a TNRCC representative acknowledged that those deficiencies were real andthe further testing would be required to validate the proposals for clean up. Air Forcerepresentatives also acknowledged that further testing and study would be dune. The .Page 1 of3


additional testing was proposed to be undertaken within the next 12 months. To approve the

plan as presented ic contrary to the admissions of theparty responsible for the clean up and

the agency mandated to regulate thin' clean up.

The proposed plan is based on computer modeling of the contamination and its migration

patterns. That modeling is based on data that is incomplete and insufficient for the purpose for

which it is being used. The deficiencies of the data are due in part to information that has been

designated classified and therefore unavailable. Members of the ATSDR investigation team

were frustrated in the preparation of their health impact reports because the data supplied by the

Air Force had been in many cases redacted or considered classified. This withhoijling of

information is in direct conflict with Executive Order 12856— Federal Cómpliwwe with Right-

to-Know Laws and Pollution Prevention Requirements and its provisions for compliance without

regard to the Standard Industrial Classification delineations that appy to federalfacilities.

The issue of the migration of conthninants from the shallow underground aquifer

underneath KAFB and the surrounding neighborhoods into the Edwards Aquifer has not

been resolved. To date all drinking water wells in the area have not been identified and capped.

Evidence has been presented that there have been leaks from on base wells into the Edwards

Aquifer. Presentations made to the San Antonio City Council regarding the likelihood of

contaminant migration from the shallow underground aquifer underneath the adjacent

communities were based on assumptions. It was assumed that the clay soil layer separating the

aquifers is consistent in its thickness and characteristiCs. When these assumptions were

challenged, the only response was to refer back to the model. To date there has been no

resolution to the issued raised during those presentations nor has there been any new data

introduced to suggest that the model is correct. There has also been no answer to the fact that the

chemicals at issue in the permit have migrated into the Edwards Aquifer, that evidence has not

been refuted. To propose aclean up plan ofTmonitored natural attenaiQPLa-itY--i&ith2.8

unde ,groun4drin! wig source is uncoisciorzablc.

The proposed clean up using monitored natural attenuation along with permeable reactive

barriers and a few pump and treat stations is aweak attempt to appease the neighboring

communities. The cleanup p!opes has nqt been 'progressng

tate andfederal laws. While attention has been focused on the most volatile chemicals present

in the contamination plumes, there has been little mention of the clean up of heavy metals and

other more stable pollutants. The proposed permeable reactive barriers (PRB) may remove the

volatile PCE and TCE chemicals, but they will not remove mercury or other heavy metals.

These remaining pollutants will persist and continue to impact the community long after the

proposed 25 year clàan up period. Nothing is being done to address this portion of the

contamination. Several alternative clean up processes have been introduced during Technical

Review Subcommittee meetings that would be more protective of human health and the

environment. None of these proposals has been given due consideration because of the cost

involved. The Air Force is choosing economics over the health of the community. To approve

that strategy is to act as a conspirator in the negative impact on the community.

Finally, the process for selecting a clean up plan for the shallow groundwater aquifer has

violated the mandates ofExecutive Order 12898 regarding environmental justice in low-

Page 2 of 3


income and minority coinniunities. Public participation has been allowed at the convenience

of the Air Force with no real partnership eStabliShe4i The atmosphere between the community

and the Air Force has been adversarial and contentious, so much so that the EPA has recognized

a valid Title VT complaint regarding this ficility. Community members have been denied access

to the real decision making processes. The adniinistiative record for the clean up has been

inaccessible and those documents that are available have been redacted to the point of being

useless. CERCLA and Executive Order 12580 require development and maintenance of an

administrative record when restoration is undertaken at a Departnnt ofDefense facility. One of

the purposes of keeping the record is to provide "a means for keeping the public informed about

clean up activities." There has not been compliance with this marKiate. T isj Qt the

partnership relationship that is mandated by federal law and outlined in tbeTDefense

Environmental Restoration Process.

As you can see there are serious issues that have not been addressed in the development of

•the proposal in question. Those issues must be resolved before any further action may be taken

n approvgi of the proposedpjaia P4T requests apul!lic hearing on the issueriicd in these

comments. PAT would like to receive copies of the responses to comments along with the

Executive Director's decisions on the application. Please place our organization on the mailing

list for all future public notices for this application. Also, please place our organization on the

mailing list for any and all matters dealing with the activities at KAFB and the suiroundi rig

community. It is our hope that you and the TNRCC will address these comments in a meaningflLl

y and workwith the community to insure an aggressive, expeditious cleanuj' of our

contamInated neighborhoods.lly •Gail J. B , President

Irma T Smith, mem

Page 3 of 3


• Ratheen Hartntt Wnit, Chainnan

E. "Ralph' Marauez, Commissioner

Larr.R: Sowarc. Commissioner

Marart Hoffman. Executive Director

TEXAS CoMMIssIoN ON.ENVIRONMENTAL QUJJTY

Protecting Texas by Reducing and Preventing Poliution

July 1, 2004

mMs. Gail Beagle, President ,People Affected by Toxins (PAT)319 Vv Kings HwySan Antonio, Texas 78212

Ms. YolanaA. Johnson3859 Bay StreetSan Antonio, Texas 78237

Ms. Irma Smith2420 McCullough, Suith 219San Antonio, TX 78212

Re: Application of Kelly Air Force Base, Site S-4Compliance Plan Modification

Dear Ms. Beagle, Johnson, and Smith:

The Executive Director of the Texas Commission on Environmental Quality (TCEQ or the"Commission") received letters from you on July 30, 2002, on behalf of PAT, an organization of

former Kelly APE workers and residen-ts living near Kelly APB. Yourietters request a contested

case hearing regarding a pending application by Kelly AFB which would authorize a final Coective

Action Prorain for the rernediation of groundwater_associd with releases from Site S-- and

would monitor the concentration of hazardous constituents in groundwater until compliancewithgroundwater quality standards.has been attained. Site S-4 is located along the eastern boundary of

Kelly APE adjacent to the Union Pacific Railroad (RR railyard. Site S-4 is in Zone 3 and is

south and west of the arer Zone 4 Dlume which has migrated off site on the east side of the Base.

The ruies of the Commission provide that the Executive Director may request a group or association

tc provide an explanation of how the group or association meets the requirements of 30 T EXAS

NISTRATIVE CODE (TAC) § 55.205. Section 55.205(a) states that a group or association may

reques: a contested case hearing only if it meets three requirements:

So: ?.3057 ' .kustr., Texas 7S7t-3O3 ' S12'23-iOOO interns: address: wan':.tcec.siat.rn.us

I Ii


Kathleen Hartnett W1ita. Chairman

R. B. "Ralph" Marquez. Commissioner

Larry R. Soward Commissioner

Glenn Shankle. Executive Director

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

Protecting Texas by Reducing and Preventing Pollution

September 7, 2004

LaD onna Castafluela eOffice of Chief ClerkTCEQMC-105F:O.Boxl3087Austrn,TX 78711-3087

(.0n.Re: Association Standing Letter of Inquiry

United States Air Force, Kelly AFBCompliance Plan50310DOCKET NUMBER-2004-0699-llfW

Dear Ms. Castañuela:

As requested by the Office of the General Counsel, the Executive Director of the Texas Commissionon Environmental Quality files an original and eleven copies of an Association Standing Letter ofInquiry. That letter was sent to assist in the development of his Response to Hearing Requests onthe United States AirForce - KellyAirForceBase (Ke11yAFB) application for a Class 3 complianceplan modification for Site S-4.

The letter dated July 1, 2004, was sent tO the three hearing requesters to identifyany member in theassociation they represent that may be an affected person with standing to request a hearing in his.or her owi right.

To date, the Executive Director has not received a reply or any communication regarding thisAssociation Standing Letter.

If you have any questions regarding this matter, please contact me at 512/239-0454.

Sincerely,I - / , 7 /,7'.ç //(L. ----

Ssan JereWhi1eErivironmntal Staff Attorney

Enclosure

cc: Mailing List


•

Appiatior of Keli' Airforne Base Site SComiiance Modificaiion PlanJune 3C. 2004Page3 of 3

Alternatively, if you do not wish to pursue a contested case heang on the Site S-4 matter, you may

withdraw your hearing request. We will need the signatures of all three signatories to the comment

letter on any letter seeking to withdraw your hearing request.

If you have any questions about the ADR process, please contact Kyle Lucas (5 12) 239-0687.

Sincerely. /Sflsan Jere ThØ, Staff AttorneyEnvironmental Law DivisionPhone (5 12) 239-0454Fax (512) 239-0606

cc: Dianna Tilierson, Chief Clerk's OfficeRichard L. Lowerre, Lowerre & Kelly, Attorneys at LawMs. Leslie Brown, Kelly AFB, Air Force Real Property Agency


Kelly Restoration Advisory Board (RAB)Technical Review Subcommittee (TRS)

Kelly Remediation Site TourSeptember 13, 2005, 7:00p.m. — 8:30p.m.

Remediation Tour Stops

STOP 1 — Commercial Street, Zone 4 (7:00 — 7:10)

The permeable reactive barrier (PRB) located at Commercial Street was installed in 2004.A PRB is an underground, flow through system that helps clean groundwater. PRB'shave been installed at Kelly using (2) methods of installation:

1) Trench method — A trench is excavated and then filled with sand and iron fillings.2) Injection method — Injection wells are installed over the contaminated area, and

an iron gel is injected into the ground creating the wall. The installation of theinjection method is less intrusive to the surrounding area.

As contaminated groundwater passes through PRB, iron reacts with TCE and PCE andhelps break them down. PRBs are not visible after installation.


STOP 2— Malone Street, Zone 4 (7:10 — 7:20)

The Malone Street remediation site began construction in 2005, and will be the 18th

remediation system in place. This location is a PRB site, and construction is expected tobe completed by the end of September 2005.

STOP 3— 34th Street, Zone 5 (7:20 — 7:30)

The Street remediation site was installed in 2004, and is also a PRB.


STOP 4— Enhanced bioremediation, Zone 5 (7:30 — 7:40)

The cleanup process at Stop 4 was completed in 2002, and uses enhanced bioremediationtechnology.

Through enhanced bioremediation, a vegetable oil-like substance is injected into thegroundwater where contamination is present. Microorganisms which are naturally foundbelow the surface "eat" the oil-like substance and breakdown the contaminants in theprocess.

During each step of the breakdown process, a chlorineatom is taken away.

I

PCE TCE DCE VC EtheneTetrachioroethene Tnchloroethene Dichioroethene Vinyl Chionde

•Carbon )Chloflns Hydrcen

4 4 4 4


STOP 5— Permeable reactive barrier and slurry wall, Zone 2 (7:50 — 8:00)

This cleanup remediation site was completed in 2004, and used both PRB and slurry walltechnologies.

A slurry wall is a low-permeability material used to control the spread of contaminatedgroundwater. This method requires the use of heavy machinery and excavation. Afterexcavating a narrow trench, typically 1.5 to 5 feet, the trench is then filled with anengineered fluid that provides chemical resistance and a physical underground barrier.

STOP 6— E-3, Zone 2(7:40—7:50)

Site E-3 was installed in 1998 and used (2) forms of cleanup technology.

1) Soil vapor extraction (SVE) — SVE involves the removal of harmful chemicalsfrom the soil in the form of vapors. The vapors are removed from the groundthough extraction wells by applying a vacuum to pull the vapors out.

2) Bioventing — This technology involves the use of extraction wells to circulateair into the ground to supply oxygen to naturally occurring microorganisms.


STOP 7— Groundwater Treatment Plant (GWTP), Zone 2 (8:00 — 8:30)

The GWTP was completed in 1993 and uses a pump-and-treat technology. At the GWTP,groundwater is continually pumped out of the ground and treated at a rate of up to onemillion gallons a day. The treated groundwater is tested for safe contaminant levels andreleased into Leon Creek, or put to another beneficial use. The GWTP was installed onbase to prevent contamination from spreading off base.


Adam AntwineInstallation Co-chair

AUG 09 2005

Documents to the TRS/RAB IBY

I, Robert Silvas, Co-chair of the Kelly Restoration Advisory Board, accept the followingdocument(s) to be included in the Co-chair Library at the Environmental Health andWeliness Center. The document(s) will remain in the Co-chair library to allow fellowRAB members the opportunity for review. The documents will not be replaced ifremoved.

1. Semiannual Compliance Plan Report for July 2005 (Jan — Jul 05) with Parts 1,2,32. Ecological Risk Assessment Addendum Tier 2, Tier 3 with CD3. AFRPA Letter to Neighbors/Residents on Removal of Groundwater Recovery

Well STOO6RW112 from S-4rCc4 tq4.

5.

c,4I ..Wt\ 'i ;, A. j

Co-chair c2 i6 at


PATCOALITION SEEKING JUSTICE FOR PEOPLE

AFFECTED BY TOXINS WHILE WORKING AT ORLIVING NEAR MILITARY INSTALLATIONS

319 West Kings Highway, San Antonio, Texas 78212-2831

July 29, 2002

Jeffiey SaitasExecutive DirectorTexas Natural Resource Conservation Commission.c/o Office of the Chief Clerk

MC 105TNRCCP.O. Box 13087Austin, Texas 78711-3087

RE: Kelly Air Force Base Compliance Plan for Site S-4 GroundwaterClass 3 Modification; Compliance Plan CP-50310 .

Dear Mr. Saitas:

The purpose of this letter is to submit the comments of the Coalition Seeking Justice for PeopleAffected by Toxins While Working at or Living Near Military Installations (PAT) on theCompliance Plan referenced above. This organization is primarily made up of former KAFBworkers and residents living in the areas conthminated by the hazardous substances releasedfrom KAFB. Several of our members live in Zone 5 and are affected by the proposed plan forclean up of site S-4 Groundwater. The proposed plan is not technically complete and hasfailed to address numerous issues with regards to the contamination, which has migratedinto the neighboring communities surrounding the former Kelly Air Force Base (KAFB)and the underlying Edwards Aquifer. Furthermore, this plan was developed withoutproper public participation as mandated by federal and state law.

An independent review of the scientffic studies used in determining the plan to be selected, wasconducted by Dr. Catherine Squibb, who identified numerous flaws in the technical approachand the lack of significant data upon which to base the selection of the clean up method. Whenthese deficiencies were presented to the Technical Review Subcommittee of the RestorationAdvisory Boan4 a TNRCC representative acknowledged that those deficiencies were real andthe further testing would be required to validate the proposals for clean up. Air Forcerepresentatives also acknowledged that further testing and study would be done. The

Page 1 of 3


additional testing was proposed to be undertaken within the next 12 months. To approve the

plan as presented is contrary to the admiscions of the party responsible for the clean up and

the agency mandated to regulate that clean up.

The proposed plan is based on computer modeling of the contamination and its migration

patterns. That modeling is based on data that is incomplete and insufficient for the purpose for

which it is being used. The deficiencies of the data are due in part to information that has been

designated classified and therefore unavailable. Members of the ATSDR investigationt

were frustrated in the preparation of their health impact reports because the data supplied by the

Air Force had been in many cases redacted or considered classified. This withding of

information is in direct conflict with Executive Order 12856- Federal Compliii we with Right-

to-Know Laws and Pollution Prevention Requirements and itsprovisions for compliance without

regard to the Standard Industrial Classficafiofl delineations that app'y to federalfacilities.

The issue of the migration of contiuninants from the shallow underground aquifer

underneath KAFB and the surrounding neighborhoods into the Edwards Aquifer has not

been resolved. To date all drinking water wells in the area have not been identified and capped.

Evidence has been presented that there have been leaks from on base wells into the Edwards

Aquifer. Presentations made to the San Antonio City Council regarding the likelihood of

contaminant migration from the shallow underground aquifer underneath the adjacent

communities were based on assumptions. It was assumed that the clay soil layer separating the

aquifers is consistent in its thickness and characteristiCS. When these assumptions were

challenged, the only response was to refer back to the modeL To date there has been no

resolution to the issued raised during those presentations, nor has there been any new data

introduced to suggest that the model is correct. There has also been no answer to the Ihet that the

chemicals at issue in the permit have migrated into the Edwards Aquifer, that evidence has not

been refuted. To propose Qcleqn up plan ofmonitored natural atenuaJi2IifQTaciwiti2iunderground dnnlang squrce is unco,scionable.

The proposed clean up using monitored natural attenuation along with permeable reactive

barriers and a few pump and treat stations is a weak attempt to appease the neighboring

communities. The cleal!uppJY)PeSS has nqt been 'progressing

state and federal laws. While attention has been focused on the most volatile chemicals present

in the contamination plumes, there has been little mention of the clean up of heavy metals and

other more stable pollutants. The proposed permeable reactive barriers (PRB) may remove the

volatile PCE and TCE chemicals, but they will not remove mercury or other heavy metals.

These remaining pollutants will persist and continue to impact the community long after the

proposed 25 year clean up period. Nothing is being done to address this portion of the

contamination. Several alternative clean up processes have been introduced during Technical

Review Subcommittee meetings that would be more protective of human health and the

environment. None of these proposals has been given due consideration because of the cost

involved. The Air Force is choosing economics over the health of the community. To approve

thai strategy is to act as a conspirator in the negative impact on the communitY.

Finally, the process for selecting a clean up plan for the shallow groundwater aquifer has

violated the mandates of Executive Order 12898 regarding environmental justice in low-

Page 2 of 3


income and minority communities. Public participation has been allowed at the convenience

of the Air Force with no real partnership established- The atmosphere between the community

and the Air Force has been adversarial and contentious, so much so that the EPA has recognized

a valid Title VI complaint regarding this facility. Community members have been denied access

to the real decision making processes. The administrative record for the clean up has been

inaccessible and those documents that are available have been redacted to the point of being

useless. CERCLA and Executive Order 12580 require development and maintenance of an

administrative record when restoration is undertaken at a Department of Defense facility. One of

the purposes of keeping the record is to provide "a means for keeping the public informed about

clean up activities." There has not been compliance with this mandate. ThiJot thepartnership relationship that is mandated by federal law and outlined in the Defense

Environmental Restoration Process.

As you can see there are serious issues that have not been addressed in the development of

the proposal in question: Those issues must be resolved before aiv urther action may be taken

in approval of the proposedplan. PAT requests a public hearing on the issues raisd in thescomments. PAT would like to receive copies of the responses to comments along with the

Executive Director's decisions on the apulication. Please place our organization on the mailing

list for all future public notices for this application. Also. please place our organization on the

mailing list for any and all matters dealing with the activities at KAFB and the surrounding

community. It is our hope that you and the TNRCC will address these comments in a meaningful

way and work with the communIty to insure an aggressive, expeditious cleanzq' of our

contaminated neighborhoods.

Irma T Smith, mem

Page 3 of 3


Kathleen Hartnett Wnite, Chairman

R. B. "Rh" Marguez. Commissioner

Lam'.R. Soward Commissioner

Margaret H ofirnan. Executive Director

TEXAS COMMISSION ON.ENIIRONMENTAL QUALITY

Protecting Texas by Reducing and Preventing Pollution

July 1, 2004

Ms. Gail Beagle, PresidentPeople Affected by Toxins (PAT) E319W. Kings Hwy,San Antonio, Texas 78212

Ms. YolandaA. Johnson3859 Bay StreetSan Antonio, Texas 78237

Ms. Irma Smith2420 McCullough, Suite 219San Antonio, TX 78212

Re: Application of Kelly Air Force Base, Site S-4Compliance Plan Modification

Dear Ms. Beagle, Johnson, and Smith:

The Executive Director of the Texas Commission on Environmental Quality (TCEQ or the"Commission") received letters from you on 3uly 30, 2002, on behalf of PAT, an organization Qf

former Kelly AFB workers and residents living near Kelly AFB. Yourietters request a contested

case heañng regarding a pending application by Kelly AFB which would authorize a final Conective

Action Proaram for the remediatiori of groundwater associated with releases from Site 5-4 and

would monitor the concentration of hazardous constituents in groundwater until compliancewith

groundwater quality standards has been attained. Site S-4 is located along the eastern boundary of

Kelly AFE adjacent to the Union Pacific Raliroad (RR railyard. Site S-4 is in Zone 3 and is

south and west of the iamer Zone 4ulurne which has mjgrd off site on the east si de of the B as;.

The rules of the Commission provide that the Executive Director may request a group or association

to provide an explanation of how the group or association meets the requirements of 30 T EXAS

ADIrnSTPTI\ CODE (TAC) § 55.205. Section 55.205(a) states that a group or association may

reque.s: a contested case hearing dnly if it meets three requirements:

So:. 3O .kustr., Texas 7S71-3US S12'23._iOO( interns: address: wwv..roec.ssats.L':us


Kathleen Hartnett White. Chairman

R. B. "Ralph" Marquez. Commissioner

Larry R. Soward, Commissioner

Glenn Shankle. Executive Director

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

September 7, 2004

Laflonna CastafluelaBOffice of Chief Clerk

TCEQMC-105 mP.O. Box 13087 I

Austin, TX. 78711-3087 .

ci: —fl. —

Re: Association Standing Letter of Inquiry —United States Air Force, Kelly AFBCompliance Plan50310DOCKET NUMBER-2004-0699-lljW

Dear Ms. Castañuela:

As requested by the Office of the General Counsel, the Executive Director of the Texas Commissionon Environmental Quality files an original and eleven copies of an Association Standing Letter ofInquiry. That letter was sent to assist in the development of his Response to Hearing Requests onthe United States Air Force - KellyAir Force Base (Kelly AFB) application for a Class 3 complianceplan modification for Site S-4.

The letter dated July 1, 2004, was sent tO the three hearing requesters to identify any member in theassociation they represent that may be an affected person with standing to request a hearing iii hisor her own right.

To date, the Executive Director has not received a reply or any communication regarding thisAssociation Standing Letter.

If you have any questions regarding this matter, please contact me at 512/239-0454.

Sincerely,,1f /' /:

S.san JerehiteEnvironmntal Staff Attomey

Enclosure

cc: Mailing List

Protecting Texas bp Reducing and Preventing Pollution


Apni*.atior of Kelly Airforce Base, Site SComiliance Modification PlanJune 30. 2004Page3 of 3

Alternatively, if you do not wish to pursue a contested case heang on the Site S-4 matter, you rna

withdraw your hearing reauest. We will need the siatures of all three signatories to the comment

letter on any letter seeking to withdraw your hearing request.

you have any questions about the ADR process, please contact Kyle Lucas (512) 239-067.

Sincerely,

TIan Jere WhiØ, Staff AttorneyEnvironmental Law DivisionPhone (512) 239-0454Fax (512) 239-0606

cc: Dianna Tillerson, Chief Clerk's OfficeRichard L. Lowerre, Lowene & Kelly, Attorneys at LawMs. Leslie Brown, Kelly AFB, Air Force Real Property Agency


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contamination during environm

entalcleanup activities. P

IFE

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to comm

unity requests for a study to testhoniegrow

ii produce lhr contaminants.

Kelly area fruits and nuts w

ere determined

safe to cat and no conta',iination was

detected during Air F

orce constructionand installation of thur P

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ater.

Additionally, the A

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issioned privateshullow

groundwater w

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area. Although m

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ells For agricultural purposes,

75 wells w

ere plugged in order to ensureprotection of hum

an health and theenvironm

enta' throughout the comm

unity.T

he Air F

orce and SA

MI ID

worked

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unity mem

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ater providedby the S

an Antonio W

ater System

comes

The E

nviron mental I-lea lth and W

cl lessC

enter, with funding provided by the

Agency for T

oxic Substances and D

iseaseR

egistry. provides free health exanis andinform

ation to comm

unity mem

bers. To

date, nearly2,000 lice

health screeninushave been provided.

meets quarterly to disc irss

progress. pros ide input, reviewplans and suggest projects.R

AB

advice is iictorcd into theenv ronm

ental cleanup program.

The

Air Force also

providesannual inform

ational mail E

nto

the surrotindrng eolllilitEiIit\,

partners with various com

munity

groups, gives tours and attendsneighborhood associationm

eetings.

FW

orking Today for a B

etterT

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Akey

part olsan Antonio's future,

KellyU

SA

generates $2.5 billion annuallythrough

a combined w

orkibrec ol 12,000jobs.

With

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erK

ellyA

FB land in reuse at K

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illy Mitchel

San Antonio, T

X

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Reaching out to the C

omm

unity

To ensure com

munity m

embers

receive the most com

plete and timely

information regarding the environm

entaland property transfer program

s, the AF

orce employs a num

ber of outreachinitiatives at the form

er Kelly A

FB

.C

entral to these is the Kelly R

estorationA

dvisoryB

oard. Created in

994 to seek

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u 'lit y nvol venicil Iin the K

elly cleanup program, the R

AB

4 .crsenhNr era,,I,,IeN

coni,n,'taiIidaring the fl',,lf

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Through open and ongoing involvem

ent. U

i the comm

unity und federal aridstate regulators, the im

plementation

olin no at cc cii' i roil mental cI etm

utechnologies. property transfer andredevelopm

ent andan

unwavering

comm

itment

to protecting human health

and the environment, the dosure and

redevelopment of the F

ormer K

elly AF

B is

a sticcess story.

day of January. April, July

Ketinedy H

igh School922

South G

eneral McM

uIS

anA

ntoiiio, TX

78226

--

..ifflormation R

epositorytntonio C

entralPublic L

ibrary-

600N

orth Soledad-

a San A

ntonio, TX

78205

——

Local (210) 207-2500w

w.sananionio.gov/library

JJk

y1 Blvd., Suite

78226-1816

(Fodondottedne)

Please

complete the survey on back and return to the address provided.

Kelly R

estoration Advisory B

oard Meetings

Joinus the second T

uesand O

ctober at 6:30p.m.!

1len


KELLYU SA

The Governor has asked San Antonio and the County to assist those devastated by HurricaneKatrina. San Antonio is in a position to help; we are extending our support to the evacuees fromLouisiana in assistance of shelter, food, and medical attention. The City and County expect toreceive anywhere from 5,000 to possibly 25,000 evacuees anytime over the next couple ofweeks. As part of the emergency support plan, Ke11yUSA has been identified as an initialreception area for the first 2,500 evacuees. The City of San Antonio has designated other areas ifneeded.

Mayor Phil Hardberger requested assistance from Ke11yUSA Thursday morning; this request waslast minute due to Governor Rick Peny' s plea for Texas to help in the relief efforts.

As part of the logistical efforts, the following has been implemented:

• Building 171 has been designated as a site for those from New Orleans. This locationwill provide shelter for approximately 2,500 individuals. Building 1536 will handle theoverflow.

• The City of San Antonio and the Red Cross will provide the following:o Logistical supporto Enhance securityo Setup triageo Secure watero Provide additional port-a-potties (if needed)

• Ke11yUSA will provide the following:o Additional security for the propertyo Communication to tenants (when needed)o Support to relief efforts

For information regarding how you can help as a volunteer, dial 211.

For information regarding donations of food, money and water, please call the Salvation Army at1-800-SAL ARMY or the American Red Cross at 1-800-HELP NOW.

Should you have specific questions pertaining to the Ke11yUSA property, please contact: TerryBritton, 210-643-1360.

Thank you for your support.

Bruce E. MillerChief Executive Officer


USAF Action Today USAF Action To-DateRescues 107 Rescues 5110Sorties 261 Sorties 2514Passengers flown 801 Passengers flown 23,517Cargo tons delivered 796 Cargo tons delivered 11,260Aeromedical evac. patients moved 2 Aeromedical evac. patients moved 2555Civil Air Patrol sorties 21 CMI Air Patrol sorties 156

USAF AIRCRAFT IN ACTION

Aircraft Mission Aircraft MissionC-i 30 Hercules Airlift/Aeromed evac E••3 Sentry Air traffic controlC-i 30 Scathe View Aerial photo -- KC-1 0 Extender Airlift & aerial tankerC-17 Globemaster IllC-S Galaxy

Airlift/Aeromed evac -Heavy airlift

HC-130HH-60 Pave Hawk

Helicopter aerial refuelingSearch & Rescue

C-141 Stratolifter Airlift/Aeromed evac MC-i30 Combat Talon Search & RescueKC-135 Stratotanker Airlift & aerial tanker MH-53 Pave Low Search & RescueOC-i35 Open Skies Aerial photo C-9 Nightingale Aeromedical evacuationC-23 Passenger transfer C-i 2 Passenger transferC-21 — Passenger transfer UH-1 Search & Rescue

AF HIGHLIGHTS:

• Air Force hurricane relief efforts represent the largest ever peacetime air operation onU.S. soil

• Total Force effort — nearly 7,800 active duty, Air National Guard and Reserve Airmen aresupporting Hurricane Katrina relief efforts

• Air Force medical teams have treated more than 5,800 people, and air-evac'd more than2,550 people

• Air Force crews are conducting the largest search and rescue operation since Vietnam• Ninety-five percent of base operating support (BOS) is devoted to ongoing-ops• 1265 Security Forces deployed to 15 locations

USAF SYSTEMS IN ACTION

1. 374th Expeditionary Rescue Group pararescuemen have supported more than 2,500 people airlifted out of theNew Orleans area and taking them to local care centers. As the forced evacuation of New Orleans continues, AirForce helicopter crews are flying fewer rescues and conducting more ferry missions from evacuee collectionpoints.

2. Little Rock Air Force Base was tapped as the hub arid clearinghouse for all international aid air shipments forHurricane Katrina victims. The first international aid for Hurricane Katrina victims touched down in Arkansas Sept.5 and more international flights are scheduled to land here in the next week.

SNAP SHOT: HURRICANE KATRINA USAF RELIEF EFFORTSAS OF 1SOOL. 8 SEP 2005


OVERALL AF MESSAGE: The Air Force's primary focus involves saving lives, sustaining lives andassisting FEMA in recovery operations for HURRICANE KATRINA.

KEY MESSAGES:• More than 7,700 Active, Guard and Reserve Airmen are supporting hurricane relief operations.

• The U.S. Air Force Total Force is working around the clock to save and sustainlives withaeromedical evacuations and EMEDS, airlift, search and rescue and air refueling missions beingflown.

• America's Air Force is answering the call for emergency assistance in this crisis Our total force—active, Air Guard and Air Force Reserve units — using a mix of air support, transportable hospitals,logistics and vital services are superbly trained and well equipped to respond to the nation's call tohelp.

• U.S. Air Force Pararescue specialists are equipped with specialized night vision capabilities forsearch and rescue missions. They are highly trained emergency medical technicians.

• The U.S. Air Force re-opened the New Orleans International Airport and are supervising flyingoperations in and out of the city. We're experts in aerial operations in austere conditions.

• The Air Force is committed helping those in need for as long as we are needed.

• This is a collaborative effort. We are working to meet local and state requirements forwarded tothe Department of Defense through state governors and FEMA federal coordinators.

• We are partnering with state and federal agencies, such as the Dept of Transportation to movesupplies and equipment and the Dept of Health and Human Services to augment hospitals andprovide medical support.

• US Northern Command is leading the Department of Defense effort, as directed by SecretaryRumsfeld, in direct support of FEMA and in accordance with the National Response Plan.

• Responding to disasters is something we have planned for, trained for, and are ready for.

SECAF statement: "Our active, Air Guard and Air Force Reserve units have responded as atotal force to this national emergency. Our goal is to save lives and help the people of Louisiana,Mississippi, and Alabama recover from this disaster."

CSAF statement: "America's Air Force is answering the call for emergency assistance in thiscrisis. "Our total force -- active, Air Guard and Air Force Reserve --using a mix of air support,transportable hospitals, logistics arid vital services, are superbly trained and well equipped torespond to the call for help. We will continue to work with other agencies to provide this muchneeded support."


DEPARTMENT OF THE AIR FORCEAIR FORCE REAL PROPERTY AGENCY

.SEP a 2005

AFRPA/DC-Kelly143 Billy Mitchell Blvd Ste 1San Antonio TX 78226-1816

Dear Kelly Restoration Advisory Board Members

Concerns over a possible cluster of arnyotrophic lateral sclerosis (ALS) among past wokersat the former Kelly Air Force Base (Kelly APB) led to the implementation of a series ofscientific investigations. Efforts to gain insight into the occupational, environmental and lifestyleexposure histories of persons with ALS (PALS) resulted in a collaboration between the ALSAssociation-South Texas Chapter, the ALS Association-National Office, the Texas Departmentof State Health Services, the San Antonio Metropolitan Health District, the Agency for ToxicSubstances and Disease Registry and the Air Force Institute for Operational Health (AFIOH) ona case series-investigation. The investigation focused on PALS who had reviously beenemployed at the fonner Kelly AFB.

The findings of these investigations were released 29 August 2005 in a document titled CaseSeries Investigation ofAtnyotrophicLateral Sclerosis (ALLY) Among Former Kelly Air Force BaseWorkers. The document identifies study questions, methods for data collection, results,discussions and conclusions pertaining to persons previously employed at the former Kelly AFBwho reported having ALS.

The full report can be found online at the Webslte listed below.

httP ://www.bro oks. af inil/afioh/5 ervices/publi cad ons info hUnAir Force Institute for Operational HealthRisk Analysis DirectorateRisk Assessment Division2513 Kennedy CircleBrooks Cit-Base, TX 78235-5116

Additional questions should be directed to the AFIOH at (210) 536-3872.

Sincerely

ADAM G. ANTWThIESenior Representative


IOH-RS-BR-TR-2005..000l

UNITED STATES AIR FORCEAFIOH

Case Series Investigation ofAmyotrophic Lateral Sclerosis (ALS)Among Former Kelly Air Force Base

Workers

Brooke L. WackermanShari L. ShanklinWilson W. McGriff

Oak Ridge Institute for Science and EducationP.O. Box 117

Oak Ridge, TN 37831-0117

Kenneth L. Cox, Col, USAFJ. Kevin Grayson, Lt Col, IJSAF

April 2005

distribution is unlimited.

Air Force Institute for Operational HealthRisk Analysis DirectorateRisk Assessment Division2513 Kennedy CircleBrooks City-Base TX 78235-5116

Approved for pub/ic release;


EXECUTIVE SUMMARY

Concerns over a possible cluster of aniyotrophic lateral sclerosis (ALS) amongformer workers at Kelly Air Force Base (Kelly AFB) prompted a series of scientificinvestigations. In an attempt to gain insight into the occupational, environmental andlifestyle exposure histories of persons with ALS (PALS), the ALS Association-South TexasChapter (ALSA-STC) and the Air Force Institute for Operational Health (AFIOH)collaborated on a case series investigation of persons linked to KelLy AF,B who reportedhaving ALS.

Study questions• In what ways are the Kelly AFB PALS similar to or different from the ALS cases

described in the scientific/medical literature?• In what ways are the Kelly AFB PALS similar to or different from the U.S. adult

population in general?

Methods• Individuals were primarily identified through self-referral to the ALSA-STC and

were accepted as potential cases if they self-reported both ALS and a Kelly AFBconnection.

• Data collection began in February 2002 and was completed in March 2003.• The data collection tool covered demographic, lifestyle, medical, residential, and

occupational history factors.• Proxy reports were accepted if patients were deceased or unable to complete the

questionnaire.• Descriptive analyses were run for all sections; frequency and percent distributions

were reported.

Results• Out of 142 potential cases initially identified, 93 returned questionnaires that were

ultimately included in the analysis. The results below apply to those 93 cases.o Cases were mainly white (82%) and male (91%).o Four participants (4%) reported having a blood relative with ALS,

signifying a familial case of ALS.o Among deceased PALS, median time from symptom onset to death was

27.6 months, while median time from diagnosis to death was 14.4 months.o The most frequently mentioned concurrent or prior medical conditions

were high blood pressure (n=22, 24%), heart disease (n18, 19%), cancer(n=12, 13%), and arthritis (n1 0, 11%).

o 7 (8%) cases sustained an injury requiring a doctor or emergency roomvisit in the year prior to diagnosis.

o 18 (19%) cases underwent surgery for reasons other than injury in the yearprior to diagnosis.

o The top five recreational activities regularly participated in by PALSincluded gardening (n=46, 50%), auto repair (n=31, 33%),

VIII


woodworking/carpentry (n=21, 23%), hiking/camping (n'20, 22%), andhunting (n19, 20%).

o Six (6%) PALS had been professional or semi-professional athletes.o Two-thirds (ii=62, 67%) of PALS had smoked at least 100 cigarettes in

their lifetime.• A quarter (n=22, 24%) of all PALS were current smokers at

diagnosis.o 80% (n74) of cases had served in the military.

• Over half of all cases had served in the Air Force (n=54, 58%).• Over half (n=53, 57%) had also served during campaigns.• 39% of cases were WWII veterans.

o Kelly AFB was not as principal a work location as initially expected forthe 20-year work history preceding cases' diagnoses.

• Only 40 PALS (43%) held a Kelly AFB job during this time frame.• The remainder either worked at (Or was somehow linked with)

Kelly AFB outside that time frame or did not provide enough dateinformation to identify Kelly AFB jobs.

• Among jobs occurring at Kelly AFB, half (n3O) were whitecollar, and half (n=30) were blue collar.

o Of the 79 lastjobs held prior to diagnosis, including Kelly and non-Kellyemployment, 53% were white collar, and 47% were blue collar.

o Professional, technical, and managerial jobs were most prevalent overalland also among job subsets—on Kelly AFB, outside Kelly AFB, and lastjob held.

DiscussionUpon loose comparison to publicly available prevalence figures, PALS appearedsimilar to other ALS cases and the U.S. population for:

o ALS disease courseso Recreational activitieso Family medical historieso Immunization historieso Infection/trauma historieso Tobacco and alcohol usage histories

• Historically, these cases may have been more physically active, in general, thanother ALS series and the general population.

o Cases reported a low prevalence of obesity-related diseases.o Cases were also athletic; 6 of the 93 PALS had been professional or semi-

professional athletes.• The preponderance of males was a major difference between this ALS case series

and those described in the literature.o Possible explanations 'for this difference include that many of the WW-I1

respondents were at Kelly AFB learning to fly or training for other war-time jobs, opportunities that were not available to women at the time.

• A "healthy worker" or "healthy soldier effect" might be present, as our casesreported extensive military histories.

ix


• Tt is very important to keep in mind that this study was necessarily limited inseveral respects:

o All information was self-reported.o Since no comparison group was selected for this highly heterogeneous

case series, no risk assessments or causal inferences could be made.o At 77 pages, the survey was lengthy and time-consuming to complete.o Proxies, not patients, completed a majority of the questionnaires.

• Proxy recall of exposures is generally less reliable.• Proxies tend to underreport more often than patients do.

o General U.S. population prevalence figures were used for comparisons tomany sections of the questionnaire.

• U.S. figures specific to the age, gender, and ethnic background ofthis series were not always available.The validity of these comparisons should not be overestimated.

Conclusions• Using reported prevalence figures as a comparison, PALS appeared similar to

other ALS cases and the U.S. adult population for ALS disease course,recreational, immunization, infection/trauma, tobacco use, alcohol use, and familymedical histories.

• Historically, these cases may have been more physically active than other ALS• case series and U.S. adults overall, perhaps due to a "healthy worker" or "healthy

soldier effect."• The limitations of the study, including the highly heterogeneous population,

amount of proxy report, absence of a control group, length of the questionnaire,and use of generalized comparison figures, must be considered when discussingand interpreting the results.

x


FINAL PAGE

ADMINISTRATIVE RECORD

FINAL PAGE


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