THE BOOK OF GENESIS Layman's Bible Commentary Charles T. Fritsch
1 T T T 11 I (. ç' VCrWTS · 2016-08-19 · lengthy — an executive summary format is desirable....
Transcript of 1 T T T 11 I (. ç' VCrWTS · 2016-08-19 · lengthy — an executive summary format is desirable....
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3225
KELLY AR # 3225 Page 1 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.
KELLY AR # 3225 Page 2 of 72
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
KELLY AR # 3225 Page 3 of 72
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
KELLY AR # 3225 Page 4 of 72
Sem
iann
ual C
ompl
ianc
e P
lan
Rep
ort
Ora
l Pre
sent
atio
n to
TR
S
Rep
ort P
repa
ratio
n
Pre
pare
Res
pons
e to
TR
S
Pre
sent
atio
n to
RA
B
1$9
0 $
90.0
0
30$
80$
2,40
0.00
5$1
35$
675.
00
3$
90$
270.
00
8$
80$
640.
00
3$
80$
240.
00
3$
90$
270.
00
$4,
765.
00
TA
SK
Geo
mat
rixH
OU
RS
RA
TE
AM
OU
NT
Atte
nd P
repe
rfor
man
ce M
eetin
g
Dev
elop
Sch
edul
e
Tec
h R
evie
w
HO
UR
SN
eath
ery
RA
TE
AM
OU
NT
2$
90$
180.
00
Cle
arw
ater
Rev
ival
HO
UR
S R
AT
E A
MO
UN
T2
$75
$2
$115
$23
0.00
1$1
15$
115.
00
12$1
15$
1,38
0.00
4$1
15$
460.
00
8$1
15$
920.
00
4$1
15$
460.
00
4$1
15$
460.
00
TO
TA
LS$
4,02
5.00
150.
00$
500.
00
I$7
5 $
75.0
0
50$
75$
3,75
0.00
2$
75$
150.
00$
500.
00
12$
75$
900.
00
8$
75$
600.
00
2$
75$
150.
00$
500.
00
$7,
275.
00
KELLY AR # 3225 Page 5 of 72
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
KELLY AR # 3225 Page 6 of 72
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
KELLY AR # 3225 Page 7 of 72
• 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.
KELLY AR # 3225 Page 8 of 72
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.
KELLY AR # 3225 Page 9 of 72
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.
KELLY AR # 3225 Page 10 of 72
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
KELLY AR # 3225 Page 11 of 72
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
KELLY AR # 3225 Page 12 of 72
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
KELLY AR # 3225 Page 13 of 72
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
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g M
inut
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The
mee
ting
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con
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ed b
egin
ning
at 1
p.m
. on
9 A
ugus
t 200
5 at
the
Air
For
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eal P
rope
rty
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an A
nton
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as, C
onfe
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e R
oom
No.
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CT
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and
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port
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.D
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MS
Rev
iew
of
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osed
rev
isio
ns Y
esD
raft
res
pons
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FC
EQ
and
EPA
rev
iew
com
men
ts o
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eto
the
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ft F
inal
Zon
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and
Dra
ft F
inal
Zon
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orre
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easu
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Stud
y (C
MS)
3 C
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Stud
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ere
disc
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he f
ollo
win
g cl
arif
icat
ions
wer
e re
ques
ted
byT
CE
Q a
nd E
PA:
Com
men
t/Res
pons
e #6
: TC
EQ
req
uest
ed f
urth
er e
labo
ratio
n on
how
the
dens
e no
n-aq
ueou
s ph
ase
liqui
d (D
NA
PL)
reco
very
wel
ls a
t Site
MP
wer
e re
deve
lope
d, i.
e. w
hen
and
how
?A
FRPA
indi
cate
d th
ey w
ill e
labo
rate
on
rede
velo
pmen
t eff
orts
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e re
spon
se to
the
com
men
t and
in th
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vise
d C
MS.
KELLY AR # 3225 Page 14 of 72
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
KELLY AR # 3225 Page 15 of 72
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
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eetin
g M
inut
es
Page
23
iuiy
als
oas
ked
if u
nnee
ded
or u
n-re
stor
able
wel
ls w
ill b
epl
ugge
d an
d ab
ando
ned.
AFR
PA in
dica
ted
wel
l dev
elop
men
tor
plu
ggin
g w
ill b
e co
nduc
ted
base
d on
fin
al s
elec
ted
rem
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san
d th
e su
cces
s/fa
ilure
of
rede
velo
pmen
t. U
nnee
ded
and
unpr
oduc
tive
wel
ls w
ill b
e re
mov
ed a
nd p
lugg
ed.
Com
men
t/Res
pons
e #7
: TC
EQ
req
uest
ed c
lari
fica
tion
as to
why
the
calib
ratio
n fl
uid
was
not
con
side
red
a co
ntam
inan
t of
conc
ern
(CoC
) at
the
Bui
ldin
g 34
8 O
WS.
AFR
PA r
espo
nded
that
cal
ibra
tion
flui
d (a
jet f
uel-
type
mix
ture
) its
elf
was
not
cons
ider
ed a
CoC
. CoC
s co
nsid
ered
in th
e C
MS
are
limite
d to
the
indi
vidu
al c
hem
ical
com
pone
nts
of th
e fl
uid
iden
tifia
ble
thro
ugh
labo
rato
ry a
naly
sis,
suc
h as
tota
l pet
role
umhy
droc
arbo
ns (
TPH
). V
olat
ile o
rgan
ic c
ompo
und
(VO
C)
and
sem
i-vo
latil
e or
gani
c co
mpo
und
(SV
OC
) an
alyt
ical
sui
tes
utili
zed
for
sam
ples
at t
he B
uild
ing
348
OW
S in
dica
te th
e on
lyC
oC a
ssoc
iate
d w
ith th
e B
uild
ing
348
OW
S is
tetr
achi
oroe
thel
yne
(PC
E).
The
cal
ibra
tion
flui
d w
as n
otso
urce
d by
the
OW
S at
Bui
ldin
g 34
8. A
FRPA
indi
cate
d th
eyha
d in
terp
rete
d th
e co
mm
ent t
o be
dir
ecte
d to
war
d pr
ovid
ing
clar
ific
atio
n re
gard
ing
the
diff
eren
ce b
etw
een
the
text
and
tabl
eof
the
CM
S an
d th
at a
dis
cuss
ion
of T
PH a
s a
CoC
rel
ated
to th
eca
libra
tion
flui
d re
leas
e w
as a
ddre
ssed
els
ewhe
re in
the
repo
rt.
The
res
pons
e to
the
com
men
t was
ther
efor
e ph
rase
d to
add
ress
cone
ctin
g th
e ta
ble
head
ing
so a
s to
be
cons
iste
nt w
ith th
e te
xtof
the
CM
S. A
FRPA
indi
cate
d re
visi
ons
to th
e te
xt o
f th
isse
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.
KELLY AR # 3225 Page 16 of 72
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
KELLY AR # 3225 Page 17 of 72
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
KELLY AR # 3225 Page 18 of 72
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
KELLY AR # 3225 Page 19 of 72
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
JDC
-K)
offi
ce in
San
Ant
onio
,T
exas
, Con
fere
nce
Roo
m N
o. 1
. BC
T m
embe
rs a
nd s
uppo
rt p
erso
nnel
atte
ndan
ce s
tatu
s is
sho
wn
belo
w.
BC
T M
embe
rsN
orm
a L
ande
zA
FRPA
/DC
-KX
Gar
y M
iller
Env
iron
men
tal P
rote
ctio
n A
genc
y (E
PA)
IR
egio
n6
X
Mar
k W
eega
rT
exas
Com
mis
sion
on
Env
iron
men
tal Q
ualit
y (T
CE
Q)
.
(Aus
tin)
X
Supp
ort S
taff
and
Oth
er A
ttend
ees
Cha
rlie
Mat
thew
sA
FRPA
/DC
-KX
Wal
t Pec
kA
FRPA
/DC
-KX
Gre
g L
yssy
EPA
IReg
ion
6X
.
Mic
hael
Cha
paA
FRPA
/DC
-K (
TE
AM
Int
egra
ted
Eng
inee
ring
,In
c.[T
EA
M])
X
Abb
i Pow
erT
CE
Q/R
egio
n 13
XE
llie
Web
ner
TC
EQ
(A
ustin
)X
Mau
rice
Coo
per
Lac
klan
d 37
CE
SIC
EV
RX
Ric
helle
Col
lingh
amB
ooz-
Alle
n H
amilt
onX
Gre
g B
radd
yW
esto
n So
lutio
ns, I
nc. (
WE
STO
N)
XC
assi
e K
alin
ecT
CE
Q/R
egio
n 13
Int
ern
XR
on D
avis
AFR
PAID
C-K
(B
AH
)X
Item
#L
ead
Supp
ort
Dis
cuss
ion
Top
ic $
çmni
ents
'"1
Dis
posi
tioni
Act
ion
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.
KELLY AR # 3225 Page 20 of 72
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.
KELLY AR # 3225 Page 21 of 72
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
KELLY AR # 3225 Page 22 of 72
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
KELLY AR # 3225 Page 23 of 72
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.
KELLY AR # 3225 Page 24 of 72
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
KELLY AR # 3225 Page 25 of 72
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
wou
ld in
clud
e ab
ove-
subm
itted
for
the
form
ergr
ound
, vau
lted,
and
bur
ied
lines
.N
on-v
aulte
d su
b-gr
ade
lines
Env
iron
men
tal P
roce
ssw
ould
hav
e be
en s
ampl
ed a
s ap
prop
riat
e fo
r re
leas
eC
ontr
ol F
acili
ty (
EPC
F).
dete
rmin
atio
n pu
rpos
es. T
his
sam
plin
g da
ta is
con
tain
ed w
ithin
the
repo
rt; h
owev
er, i
t cou
ld b
e re
vise
d to
mor
e re
adily
pre
sent
this
info
rmat
ion.
The
TC
EQ
ask
ed if
the
indi
cate
d re
visi
ons
coul
d be
mad
e pr
ior
to T
CE
Q c
ompl
etin
g th
eir
revi
ew o
f th
e dr
aft d
ocum
ent.
AFR
PA o
ffer
ed to
sub
mit
repl
acem
ent p
ages
and
sup
plem
enta
lta
bles
to in
clud
e th
e re
fere
nced
info
rmat
ion
in th
e cu
rren
tve
rsio
n of
the
repo
rt. T
CE
Q in
dica
ted
that
wou
ld b
eac
cept
able
.
The
TC
EQ
ask
ed f
or a
list
of
units
incl
uded
on
the
form
er K
elly
Not
ice
of R
egis
trat
ion
(NO
R)
that
are
bei
ng r
eque
sted
for
clos
ure
in th
e re
port
. AFR
PA in
dica
ted
that
the
list w
ould
be
prov
ided
.3.
Lan
dez,
N.
Zon
eM
anag
ers
Pend
ing
Doc
umen
tSu
bmitt
als
Rev
iew
of
docu
men
ts to
be
subm
itted
for
reg
ulat
ory
revi
ew w
ithin
the
next
90
days
;St
atus
of
docu
men
ts a
lrea
dyin
rev
iew
.
Yes
Atta
ched
list
rev
iew
ed.
4.N
/AM
isce
llane
ous
Var
ious
issu
es r
aise
d in
clos
ing
of m
eetin
g ag
enda
.Y
esT
he T
CB
Q in
dica
ted
its g
uida
nce
on c
ondu
ctin
g Fi
ndin
gs o
fSu
itabi
lity
for
Ear
ly T
rans
fer
(FO
SET
) ha
s be
en f
inal
ized
.T
heT
CE
Q a
dded
that
the
agen
cy w
ould
pre
fer
if th
e A
ir F
orce
wou
ld n
ot in
itiat
e th
e ea
rly
tran
sfer
pro
cess
unt
il pe
ndin
gC
ompl
ianc
e Pl
an m
odif
icat
ions
for
Zon
es 4
and
5 h
ave
been
com
plet
ed.
The
EPA
indi
cate
d an
age
ncy
engi
neer
ing
foru
m m
eetin
g is
tobe
hel
d in
San
Ant
onio
dur
ing
Oct
ober
200
5. I
nter
este
dat
tend
ees
may
req
uest
a to
ur o
f th
e fo
rmer
Kel
ly if
the
AFR
PAca
n ho
st th
em a
t tha
t tim
e.
Page
7c2
KELLY AR # 3225 Page 26 of 72
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
The
mee
ting
was
con
duct
ed b
egin
ning
at 1
p.m
. on
14 J
une
2005
at t
he A
ir F
orce
Rea
l Pro
pert
y A
genc
y D
ivis
ion
C—
Kel
ly(A
FRPA
!DC
-K)
offi
ce in
San
Ant
onio
,T
exas
, Con
fere
nce
Roo
m N
o. 1
. BC
T m
embe
rs a
nd s
uppo
rt p
erso
nnel
atte
ndan
ce s
tatu
s is
sho
wn
belo
w.
....
.N
ame
Ogn
inB
CT
Mem
bers
Nor
ma
Lan
dez
AFR
PAID
C-K
XG
ary
Mill
erE
nvir
onm
enta
l Pro
tect
ion
Age
ncy
(EPA
)/R
egio
n 6
X
Mar
k W
eega
r
Supp
ort S
taff
and
Oth
e
Tex
as C
onun
issi
on o
n E
nvir
onm
enta
l Qua
lity
(TC
EQ
)(A
ustin
)r
Atte
ndee
s
X
Ash
ley
Alli
nder
AFR
PA/D
C-K
XD
on B
uelte
rA
FRPA
IDC
-KX
.
Mic
hael
Cha
paA
FRPA
/DC
-K (
TE
AM
Int
egra
ted
Eng
inee
ring
,In
c. [
TE
AM
])X
Wal
t Pec
kA
FRPA
/DC
-KX
—A
bbiP
ower
TC
EQ
/Reg
ion
13X
Gar
y M
artin
Gre
ater
Kel
ly D
evel
opm
ent A
utho
rity
(G
KD
A)
—X
Mau
rice
Coo
per
Lac
klan
d 37
CE
S/C
EV
RX
Kla
us G
uent
her
HQ
AE
TC
/CE
VR
.X
Ken
Keb
bell
USA
CE
.X
Gre
g B
radd
yW
esto
n So
lutio
ns, I
nc.
XC
assi
e K
alin
ecT
CE
Q/R
egio
n 13
Int
ern
X
— It
em#
Lea
dSu
ppor
tD
isE
ussi
on T
opic
Cts
Dlo
pic
Dis
posi
tion/
Act
ion
Item
s
Lan
dez,
N.
Zon
e7o
ne U
pdat
esR
evie
w o
f m
ajor
pro
ject
sta
lus
Yes
Zon
e I
Man
ager
sfo
r al
l IR
P Z
ones
.T
he Z
one
1 C
orre
ctiv
e M
easu
res
Stud
y (C
MS)
con
trac
tor,
Wes
ton
Solu
tions
, Inc
. (W
EST
ON
), d
istr
ibut
ed g
raph
ic f
igur
espr
esen
ting
the
boun
dari
es o
f la
ndfi
lls to
be
addr
esse
d du
ring
the
on-g
oing
pro
ject
. WE
STO
N in
dica
ted
the
land
fill
boun
dari
esw
ere
revi
sed
follo
win
g th
e re
view
of
sam
plin
g an
d an
alys
is d
ata
obta
ined
fro
m th
e K
elly
Env
iron
men
tal R
esou
rce
Prog
ram
Info
rmat
ion
Man
agem
ent S
yste
m (
ER
PIM
S) d
atab
ase
and
from
site
obs
erva
tions
. The
rev
ised
bou
ndar
ies
resu
lted
in in
crea
ses
in th
e ar
eas
assu
med
to b
e ad
dres
sed
duri
ng th
e C
MS
proc
ess.
KELLY AR # 3225 Page 27 of 72
.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
utes
Page
2 o
f 6
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
ns to
war
dsde
velo
pmen
t of
a co
ncep
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
cond
ition
s.A
dditi
onal
site
dat
a re
view
will
incl
ude
eval
uatio
n of
ava
ilabl
ehi
stor
ical
aer
ial p
hoto
grap
hs a
nd p
revi
ousl
y co
llect
edge
ophy
sica
l sur
vey
info
rmat
ion.
The
CM
S pr
oces
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
essm
ent d
ocum
ent m
ay b
e su
bmitt
ed f
or a
genc
yre
view
sep
arat
ely
from
the
CM
S re
port
.
The
TC
EQ
indi
cate
d th
eir
file
for
Zon
e 1
thcl
udes
corr
espo
nden
ce to
the
Air
For
ce r
elay
ing
a T
CE
Q r
eque
st f
orad
ditio
nal a
sses
smen
t act
iviti
es in
res
pons
e to
rev
iew
of
a ci
rca
1995
Rel
ease
Inv
estig
atio
n (R
I) r
epor
t. T
he A
FRPA
add
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
ty S
tudy
(FS
) ph
ase
of th
e pr
ojec
t.T
he A
FRPA
rec
omm
ende
d th
at W
EST
ON
rev
iew
the
Kel
lyA
dmin
istr
ativ
e R
ecor
d fo
r po
tent
ial c
orre
spon
denc
e fr
omT
CE
Q (
then
the
Tex
as N
atur
al R
esou
rce
Con
serv
atio
nC
omm
issi
on [
TN
RC
CJ)
rel
ated
to r
evie
w o
f th
e 19
95 R
I an
d fo
rpo
ssib
le A
F re
spon
ses
to c
omm
ents
on
the
RI
with
in th
eap
pend
ices
of
a la
ter
FS r
epor
t. T
he T
CE
Q r
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
the
type
s of
was
tes
cont
aine
d (c
onst
ruct
ion
debr
is, m
unic
ipal
sol
id w
aste
,ha
zard
ous
was
te)
whi
ch w
ill d
icta
te f
inal
cov
er r
eciu
irem
ents
.
Fina
l
Zon
eZ
one
Upd
ates
Rev
iew
of
maj
or p
roje
ct s
tatu
sM
anag
ers
for
all I
RP
Zon
es.
KELLY AR # 3225 Page 28 of 72
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
Item
#L
ead
Supp
ort
Dis
cuss
ion
Top
icC
omm
ents
Dis
cuss
ion
Top
icD
ispo
sitio
n/A
ctio
n It
ems
____
____
____
____
____
conc
lude
d?(c
orn.
)L
ande
i, N
.Z
one
Zon
e U
pdat
esR
evie
w o
f m
ajor
pro
ject
sta
tus
Yes
WE
STO
N a
ntic
ipat
es c
losi
ng c
ontig
uous
land
fill
area
s un
der
aM
anag
ers
for
all I
RP
Zon
es.
sing
le R
isk
Red
uctio
n St
anda
rd, b
ut w
ith p
oten
tially
dif
fere
ntco
ver
type
s ba
sed
on th
e ty
pes
of w
aste
con
tain
ed. W
EST
ON
'scu
rren
t ass
umpt
ions
for
add
ress
ing
the
Lan
dfill
12
"Dru
mD
ispo
sal A
rea"
indi
cate
cos
ts f
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
ed g
roun
dwat
er/le
ache
ate
also
requ
irin
g tr
eatm
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.
KELLY AR # 3225 Page 29 of 72
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
non
-haz
ardo
us w
aste
s un
der
the
Con
tain
ed-I
n Po
licy.
The
TC
EQ
adv
ised
that
any
cha
nges
to m
onito
ring
wel
l loc
atio
ns r
esul
ting
from
impl
emen
tatio
n of
the
fina
l rem
edie
s ne
ed to
be
capt
ured
with
in th
e as
soci
ated
Cla
ss 3
Com
plia
nce
Plan
mod
ific
atio
n.
AFR
PA a
nd T
CE
Q a
dvis
ed W
EST
ON
to r
etur
n to
the
BC
T to
obta
in "
head
ing
chec
ks"
from
the
team
thro
ugho
ut th
e C
MS
proc
ess
as m
ore
defi
nitiv
e si
te a
nd r
emed
y sp
ecif
ic d
ata
was
avai
labl
e fo
r di
scus
sion
.
Zon
es 2
and
3T
he T
CE
Q in
quir
ed if
AFR
PA h
ad a
ny q
uest
ions
on
the
Age
ncy'
s re
cent
ly p
rovi
ded
revi
ew c
omm
ents
on
the
Zon
e 2
and
3 C
MS
docu
men
t. T
he A
FRPA
indi
cate
d re
spon
ses
to th
eT
CE
Q c
omm
ents
wer
e in
pre
para
tion.
Bas
ed o
n co
mm
ents
Lan
dez,
N.
Zon
eM
anag
ers
Rev
iew
of
maj
or p
roje
ct-
for
all I
RP
Zon
es.
curr
ently
ant
icip
ated
sol
utio
n co
nsis
ts o
f th
e co
nstr
uctio
n 01
"anc
hor
tren
ches
" be
twee
n va
ryin
g co
ver
type
s.
KELLY AR # 3225 Page 30 of 72
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
rela
ting
to w
aste
cla
ssif
icat
ion,
AFR
PA in
dica
ted
the
CM
S m
aybe
rev
ised
to in
dica
te e
xcav
atio
n w
ith o
ff-s
ite d
ispo
sal a
s th
epr
efer
red
alte
rnat
ive
for
Site
MP.
The
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
s in
a B
CT
mee
ting
prio
r to
subm
ittal
bac
k to
the
Age
ncy.
The
TC
EQ
indi
cate
d th
at w
ould
be a
t the
dis
cret
ion
of th
e A
ir F
orce
, but
it w
as n
ot n
eces
sari
lyre
quir
ed.
Zon
e 4/
Off
-bas
eA
FRPA
inqu
ired
if r
espo
nses
to T
CE
Q c
omm
ents
on
the
Zon
e4
CM
S re
latin
g to
pot
entia
l ind
oor
vola
tile
orga
nic
com
poun
d(V
OC
) va
por
expo
sure
cou
ld b
e ad
dres
sed
with
in a
sep
arat
esu
bmitt
al f
rom
the
revi
sed
CM
S do
cum
ent.
The
TC
EQ
indi
cate
d th
is w
ould
be
acce
ptab
le.
Rea
ctiv
e m
edia
inje
ctio
n eq
uipm
ent f
or c
onst
ruct
ion
of th
eU
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.
Bas
ewid
eA
FRPA
is in
the
proc
ess
of r
emov
ing
redu
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.
On
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.
KELLY AR # 3225 Page 31 of 72
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
eem
ent
Coo
pera
tive
Agr
eem
ent d
oes
not p
rovi
de f
or a
"lin
e ite
m(D
SMO
A)
revi
ew/a
ppro
val"
of
prop
osed
TC
EQ
cos
ts f
or p
rogr
am r
evie
wsu
ppor
t.
Page
6 o
f 6
KELLY AR # 3225 Page 32 of 72
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.
KELLY AR # 3225 Page 33 of 72
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
KELLY AR # 3225 Page 34 of 72
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
KELLY AR # 3225 Page 35 of 72
• 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.
KELLY AR # 3225 Page 36 of 72
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.
KELLY AR # 3225 Page 37 of 72
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.
KELLY AR # 3225 Page 38 of 72
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.
KELLY AR # 3225 Page 39 of 72
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
KELLY AR # 3225 Page 40 of 72
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
KELLY AR # 3225 Page 41 of 72
KELLY AR # 3225 Page 42 of 72
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
KELLY AR # 3225 Page 43 of 72
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
KELLY AR # 3225 Page 44 of 72
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
KELLY AR # 3225 Page 45 of 72
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
KELLY AR # 3225 Page 46 of 72
• 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
KELLY AR # 3225 Page 47 of 72
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
KELLY AR # 3225 Page 48 of 72
•
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 AR # 3225 Page 49 of 72
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.
KELLY AR # 3225 Page 50 of 72
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.
KELLY AR # 3225 Page 51 of 72
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
KELLY AR # 3225 Page 52 of 72
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.
KELLY AR # 3225 Page 53 of 72
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.
KELLY AR # 3225 Page 54 of 72
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
KELLY AR # 3225 Page 55 of 72
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
KELLY AR # 3225 Page 56 of 72
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
KELLY AR # 3225 Page 57 of 72
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
KELLY AR # 3225 Page 58 of 72
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
KELLY AR # 3225 Page 59 of 72
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
KELLY AR # 3225 Page 60 of 72
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
KELLY AR # 3225 Page 61 of 72
valu
e yo
ur f
eedh
acak
ea
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ll
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an 8
0 ye
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elly
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ce B
ase
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aiiii
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ase
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elly
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ly 1
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ir F
orce
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l Pro
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y ha
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erty
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sfer
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ly. A
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ks w
ithth
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iron
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ial
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lys
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e ye
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arily
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man
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t tiri
ng a
ndm
aint
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ce d
epot
. Wli
Ic th
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orce
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oyed
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use
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ems
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n th
e pl
ume
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e iir
st in
stal
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reve
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nal
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ff th
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se. T
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rce
then
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oyed
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e te
chno
logi
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ove
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amin
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h as
usi
ng m
icro
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reak
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iern
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ing
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ater
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tmen
t pla
nts
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mp
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amin
ated
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erF
rom
(lie
shal
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at it
and
then
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char
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e tr
eate
d gr
ound
wat
er in
to L
eon
and
Six
Mile
cre
eks
— th
e na
tura
l dis
char
gear
eas
fir th
e sh
allo
w g
roun
dwat
er z
one.
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Air
For
ce is
cur
reni
ly in
stal
ling
the
final
grou
ndw
ater
rem
edia
tion
syst
em.
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rmea
ble
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tive
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ier.
on
Mal
one
Ave
nue.
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s PR
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ike
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othe
rsin
stal
led
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ut th
e K
elly
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mad
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lfi
lings
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act w
ith th
ech
emic
als
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e sh
allo
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er.
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reak
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ss-
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ful b
y—pr
oduc
ts.
conh
iiluc
unt
il re
gula
tory
sta
ndar
ds a
rem
et.
Drin
king
wat
er fo
r th
e K
elly
com
mun
ity, a
s w
et! a
s th
e ci
ty o
f San
Ant
onio
. com
es fr
om th
e E
dwar
dsA
quife
r no
t the
sha
llow
gro
undw
ater
zone
. The
sha
llow
gro
undw
ater
zone
lies
appr
oxin
iate
ry 3
0 fe
et u
nder
grou
ndan
d th
e E
dv.a
rds
is a
ppro
xim
atel
y 1,
500
feet
bel
ow th
e sh
allo
w g
roun
dwat
erzo
ne.
The
two
aqui
fers
are
sep
arat
edby
app
roxi
mat
ely
one-
quar
ter-
nile
of i
mpe
rmea
ble
clay
, ens
urin
gdr
inki
ng w
ater
is s
afe
from
any
Kel
lyco
ntam
irlat
ton,
Add
ress
ing
Hea
lth C
once
rns
Des
pite
num
erou
s st
udie
s un
able
tolin
k pa
st o
r pr
esen
t Kel
ly a
ctiv
ities
toth
e he
alth
con
cern
s of
the
eom
nlun
ity.
the
Air
For
ce e
nter
ed in
to a
coo
pera
tive
agre
emne
rlt w
ith ti
le S
an A
nton
ioM
eiro
polit
an H
ealth
Dis
tric
t in
2002
.T
he a
gree
men
t pro
vide
s S
5.O
UIJ
,000
in
fund
ing
over
a te
n ye
ar p
erio
d. F
undi
ngpr
ovid
ed a
llow
s th
e P
ublic
Cen
ter
for
Env
ironm
enta
l Hea
lth to
dev
elop
and
cond
uct h
ealth
-rel
ated
res
earc
h st
udie
s.T
o da
te, P
CE
H h
as c
ondu
cted
sev
eral
stud
ies
to m
onito
r ai
r fo
r po
ssib
le
Dur
ing
the
past
12
mon
ths,
hav
e yb
u...
Hea
rd a
nym
ii
Com
mun
ity F
eedb
ack
For
mng
the
Air
For
ce's
env
ironm
enta
l cle
anup
at t
ilequ
est i
ons
belo
wan
d re
turn
Eli
isfo
rmto
the
add
Yes
t
No
nip?
____
____
____
____
____
___
____
____
____
____
____
__
Ver
y F
amili
arS
omew
hat F
amili
ar fl
Don
't K
now
S
How
fam
iliar
or
unfa
mili
ar a
re y
ou w
ith th
e en
viro
nmen
tal c
lean
up a
t Kel
ly?
4;t
Som
ewha
t Unf
amili
ar fl
Kel
ly: T
hen
and
Now
Ple
ase
tell
us h
ow m
uch
you
agre
e or
dis
agre
ew
ith th
e fo
llow
ing
stat
emen
ts:
Ver
y U
nfli
ni li
ar
In 1
988,
alo
ng Q
uint
ana
Roa
d, th
e A
iriro
rce
firs
t det
ecte
dth
e co
ntam
inat
ion
in th
e sh
allo
w g
roun
dwat
er. S
ince
then
, the
Air
For
ce h
as e
valu
ated
and
iii p
lem
ente
d a
varie
ty o
f inn
ovat
ive
clea
nup
teci
lniq
ues
tore
mov
e an
d/or
trea
t tile
con
tam
inat
ion
oF th
e so
il an
dsh
allo
wgr
ound
wat
er.
Dur
ing
the
next
12
mon
ths,
how
like
ly is
it th
at y
ou w
ill d
oth
e fo
llow
ing?
Pro
tect
ion
Age
ncy
and
Tex
as
Cor
nill
issi
on O
n F
m i
roll
men
tal
Qua
lity
toen
sure
cont
amin
atio
nis
cle
aned
up
in o
rder
to tr
ansl
r th
epr
oper
tyto
the
Gre
ater
Kel
ly D
evel
opm
ent
Aut
hori
ty—
the
loca
lre
deve
lopm
ent a
utho
rity
. Tod
ayK
elly
ope
rate
sas
KeI
IyIJ
SA
,a
mul
ti-us
eai
rpor
t and
rail-
serv
edbu
sine
ss p
ack.
AF
RP
A/D
C-K
eIl
143
Bill
y M
itche
lSa
n A
nton
io, T
X
Kel
lyT
he E
nviro
nmen
tal P
rogr
am a
t
Iron
fiu
i,ri i
rIje
riw
s' "
wi/i
odf
iir th
e pe
rmea
ble
reac
live
bar,
!,',
rug
( os
igm
ercI
ril S
tree
t
form
er b
ase
long
-ter
m im
pact
s W
ere
not k
now
n un
til a
11c
r ye
ars
of o
pera
ting.
As
are
sult
ofap
prov
ed w
aste
-dis
posa
lpr
actic
es d
urin
gba
seop
erat
ions
, lea
ksan
dsp
ills
ofje
t fue
l and
chl
orin
ated
solv
ents
use
dto
degr
ease
Ille
lala
ircra
ftpa
rts
cont
[ulii
nale
dth
eso
il an
d sh
allo
wgr
ound
aate
r on
base
and
aro
und
Kel
ly.
The
Air
For
ce w
ill c
ontin
ue to
ope
rate
thes
e cl
eanu
p sy
stem
s un
til ti
le s
hallo
wgr
ound
wat
er m
eets
TC
EQ
's r
egul
ator
yst
anda
rds.
TC
EQ
and
EP
A p
ro id
ere
gula
tory
over
sigh
t of
the
Air
Forc
eth
roug
hout
this
pro
cess
to e
nsur
e
rem
edia
l act
ions
are
effe
ctiv
ean
d
Air
For
ce R
eal P
rope
rty
Age
ncy
The
For
mer
Kel
ly A
ir F
orce
Bas
e(2
10)
925-
0956
• T
oll F
ree
1-86
6-72
5-76
17 •
ww
w.a
frpa
.hq.
af.m
il
We
k re
gard
ifo
rmer
Kel
ly A
ir F
orce
Bas
e.Pl
ease
tsw
er th
ere
ss p
rovi
ded
on th
e op
posi
te s
ide.
Rec
eive
d by
mai
l any
info
rmat
ion
abou
t the
cle
anun
?
ing
abou
t the
cle
anup
in th
e ne
ws?
Tal
ked
to a
fri
end
or n
eigh
bor
abou
t the
cle
a
Sook
en o
r in
tera
cted
with
an
Air
For
ce r
epre
sent
ativ
e?
Nei
ther
Str
ongl
yS
tron
gly
Don
Agr
eeA
gree
nor
D s
agre
eA
gree
Dis
agre
eK
now
Dis
agre
e
The
Air
For
ce is
bei
ng v
ery
open
in it
s co
mm
unic
atio
ns.
The
A F
orce
is v
ery
resp
onsi
ve to
com
mun
ity c
once
rns
The
Air
For
ce is
pro
vidi
ng u
sefu
l inf
orm
atio
n to
me
I ca
n ea
sily
und
erst
and
info
rmat
ion
from
the
Air
For
ce
The
env
iron
men
tal c
lean
up is
bei
ng d
one
safe
ly
The
env
iron
men
tal c
lean
up is
bei
ng d
one
as q
uick
ly a
s po
ssib
le.
In g
ener
al, t
he e
nvir
onm
enta
l cle
anup
is g
oing
wel
l
Ver
yS
omew
hat
Not
Ver
yLk
eyN
otS
ure
Like
lyLi
kely
Like
ly
Rea
din
form
atio
n ab
out t
he c
lean
un
Tal
k to
my
neig
hbor
(s)
abou
t the
cle
anup
Atte
nd c
omm
unity
mee
tings
abo
ut th
e cl
eanu
p.
Cal
l the
Air
For
ce w
ith q
uest
ions
abo
ut th
e cl
eanu
p.
Wri
te a
lette
r to
a n
ews
edito
r ab
out t
he c
lean
up
Play
an
activ
e ro
le in
rep
rese
ntin
g m
y co
mm
unity
's in
tere
sts
rega
rdin
g th
e cl
eanu
p
y 1 B
lvd.
, Sui
te 1
7822
6-18
16
KELLY AR # 3225 Page 62 of 72
contamination during environm
entalcleanup activities. P
IFE
E also responded
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
R 13s w
ithinproxim
ity to the coiiiiiiuiiity that work to
dean the shallow groundw
ater.
Additionally, the A
ir Force and S
AM
HD
identified and decomm
issioned privateshullow
groundwater w
ells in the Kelly
area. Although m
ost residents used theseprivate w
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
extensively to ensure comm
unity mem
bersunderstand the drinking w
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
omorrow
Akey
part olsan Antonio's future,
KellyU
SA
generates $2.5 billion annuallythrough
a combined w
orkibrec ol 12,000jobs.
With
a totalof 1,887
acresofform
erK
ellyA
FB land in reuse at K
eUyU
SAand 96 percent
ofa ailable industrialspace currently under m
anagement ofthe
Greater K
elly Developm
entA
uthority, thedevelopm
ent oFK
eIIyLSA
is allowing new
growth
insouthw
est San A
ntonio.
Ironi the Edw
ards Aqu i F
r.
Place
PostageH
ere
I
AFR
PA/D
C-K
elI143 B
illy Mitchel
San Antonio, T
X
III
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
andp roniote con' m
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
a,,,? Vat
Sludi
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
KELLY AR # 3225 Page 63 of 72
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
KELLY AR # 3225 Page 64 of 72
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
KELLY AR # 3225 Page 65 of 72
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."
KELLY AR # 3225 Page 66 of 72
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
KELLY AR # 3225 Page 67 of 72
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;
KELLY AR # 3225 Page 68 of 72
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
KELLY AR # 3225 Page 69 of 72
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.
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• 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.
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ADMINISTRATIVE RECORD
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