File: 17G

CANNON AFB NEW MEXICO

ADMINISTRATIVE REC ORD COVER SHEET

AR File Number / 9:)

J

RCRA FACILITY INVESTIGATION

PROJECT MANAGEMENT PLAN

CANNON AFB, NEW MEXICO

JUNE 1990

Prepared for

27 CSG/DEV

Cannon AFS, NM 88103-5000

Prepared by

Lee Wan & Associates, Inc.

qoo N. Fairfax St., Suite 250

Alexandria, VA 22314

DO 50 5 90

File:

/o RFICAN . PMP

DO 50 5 90

RCRA FACILITY INVESTIGATION

PROJECT MANAGEMENT PLAN

CANNON AFB, NEW MEXICO

JUNE 1990

Prepared for

27 CSG/DEV

Cannon AFB, NM 88103-5000

Prepared by

Lee Wan & Associates, Inc.

700 N. Fairfax St., Suite 250 Alexandria, VA 22314

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TABLE OF CONTENTS

ACRONYMS

DEFINITIONS ............................... ii

SUMMARY ................................. i

i. INTRODUCTION ........................... 2

1.1. RCRA FACILITY INVESTIGATION PROGRAÌ'( DESCRIPTION ....... 2

1.2. CANNON AFE RFI ....................... 2

1.3. REPORT PURPOSE AND ORGANIZATION ............... 3

2. INSTALLATION BACKGROUND ...................... 5

3, INITIAL EVALUATION ........................ 17

4. WORK PLAN RATIONALE ........................ 20

4.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS ..... 20

4.2 DATA QUALITY OBJECTIVES ................... 33

5. RCRA FACILITY INVESTIGATION TASKS ................. 37

6. FVNDING SOURCE, AUTHORITIES, AND RESTRICTIONS ........... 42

7. SCHEDULE OF INVESTIGATION ..................... 43

8 . PROJECT XANACEMENT ......................... 45

8.2 COORDINATION ........................ 46

8.3. STAFFING .......................... 52

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ACRONYMS

ARAR Applicable or Relevant and Appropriate Requirement

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CLP Contract Laboratory Program CRP Community Relations Plan DMP Data Management Plan EPA U. S. Environmental Protection Agency FSP Field Sampling Plan

HSP Health and Safety Plan NPDES National Pollutant Discharge Elimination System PMP Program Management Plan QAP Quality Assurance Plan RCPA Resource Conservation and Recovery Act RFA RCRA Facility Assessment SOP Standard Operating Procedure SWMTJ Solid Waste Management Unit TCL Target Compound List

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DEFINITIONS

'Faci1ity" means all contiguous property under the control of the owner or

operator seeking a permit under Subtitle C of RCRA.

"Release" means any spilling, leaking, pouring, emitting, emptying, discharging,

injecting, pumping, escaping, leaching, dumping, or disposing of hazardous wastes

(including hazardous constituents) into the environment (including the

abandonment or discarding of barrels, containers, and other closed receptacles

containing hazardous wastes or hazardous constituents).

"Solid Waste }anagement Unit" means any discernible unit at which solid wastes have been placed at any time, irrespective of whether the unit was intended for the management of solid or hazardous waste. Such units include any area at or

around a facility at which solid wastes have been routinely and systematically released.

"Hazardous waste' means a solid waste, or combination of solid wastes, which

because of its quantity, concentration, or physical, chemical, or infectious

characteristics may cause, or significantly contribute to, an increase in

mortality or ari increase in serious irreversible, or incapacitating reversible, illness; or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of,

or otherwise managed. The term hazardous waste includes hazardous constituent as defined below.

"Hazardous constituent" means any constituent identified in Appendix VIII of 40

CFR Part 261, or any constituent identified in Appendix IX of 40 CFR Part 264.

"Administrative Authority" means the Director of the New Mexico Environmental

Improvement Division, or designee, or in case of HSWA provisions for which the State is not authorized, the U.S. Environmental Protection Agency shall be the Administrative Authority.

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StflOfARY

The Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and Recovery Act (RCRA) were enacted into law on November 8, 1984.

One of the major provisions (Section 3004(u)) of these amendments requires corrective action for releases of hazardous vaste or constituents from solid waste management units (SWMUs) at hazardous waste treatment, storage, or disposal facilities. Under this provision, any facility applying for a RCRA hazardous waste management facility permit will be subject to a RCRA Facility Assessment (RFA) . The RFA is conducted by the regulatory agency and is designed to identify SWMtJs which are, or are suspected to be, the source of a release to the

environment. If any such units are identified, the owner or operator of the

facility will be directed to perform a RCRA Facility Investigation (RFI) to

obtain information on the nature and extent of the release so that the need for interim corrective measures or a Corrective Measures Study can be determined. Information collected during the RFI can also be used by the owner or operator to aid in formulating and implementing appropriate corrective measures. Such corrective measures may range from stopping the release through the application of a source control technique to a full-scale cleanup of the affected area. In

cases where releases are sufficiently characterized, the regulatory agency may require the owner or operator to collect specific information needed to implement corrective measures during the RFI.

The RFI tJork Plan consists of six documents prepared concurrently:

a. Data Collection Quality Assurance Plan b. Data Management Plan C, Health and Safety Plan d. Community Relations Plan e. Field Sampling Plan f. Project Management Plan

This Project Management Plan provides information regarding the technical approach, schedules and key personnel and is the primary docuiienc for this RCRA Facility Inspection. The other plans listed above are companion documents and elaborate on specific activities and procedures.

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1. INTRODUCTION

1,1. RCRA FACILITY INVESTIGATION PROGRAM DESCRIPTION

The Hazardous and Solid Waste Amendments (HWSA) to the Resource Conservation and Recovery Act (RCRA) were enacted into law on November 8, 1984.

A major provision, Section 300(u) , of these anendments requires corrective action for releases of hazardous waste or constituents from Solid Waste Management Units (SWMTJs) at hazardous waste treatment, storage, or disposal facilities. Such corrective measures may range from stopping the release through the application of a source control technique to a full-scale cleanup of the affected area.

Potential release sites have been identified in a RCRA Facility Assessment conducted by A.T. Kearney under contract to the U.S. Environmental Protection Agency (EPA) Region VI. Evaluation of past operational activities and waste management practices resulted in the identification of 76 solid waste management units (SWMU) that could have adverse impacts on the environment.

Based on release determinations made by the U.S. Environmental Protection Agency Region VI, Cannon AFE has been notified that various SWMtJs and releases (known or suspected) must be investigated. The investigation is to provide information to characterize the nature, extent, and rate of migration of contaminant releases to soils, groundwater, subsurface gas, air, and surface water. This information will ultimately be used to decide whether a corrective measures program is required.

1.2. CANNON AFE RFI

The RFI process at Cannon AFB, as outlined in this Project Management Plan, follows the methodology established for characterizing the nature and extent of risks posed by uncontrolled hazardous waste sites and for evaluating potential remedial options (EPA l988c). This approach should be a dynamic, flexible process that can and should be tailored to specific circumstances of individual sites; it is not a rigid, step-by-step approach.

The objective of the RFI at Cannon AFB is nrt the unobtainable goal of removing all uncertainty, but is to gather information sufficient to support an informed risk management decision regarding which remedy appears to be most appropriate for a given site (EPA 1988e) . The appropriate level of analysis to

meet this objective can only be reached through constant evaluation and careful planning concerning the essential data needed to reach a remedy selection decision. As hypotheses are tested and either rejected or confirmed, adjustments or choices as to the appropriate course for further investigations and analyses are required. These choices, like the remedy selection itself, involve the

balancing of a wide variety of factors and the exercise of best professional judgment (EPA 1988e).

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The goals of the RFI at Cannon APS are:

to determine whether releases have occurred and to what extent contaminants may have migrated to reduce adverse impacts on public health and the environment from

releases of hazardous or radioactive materials, and

to bring all inactive wastes sites requiring remediation into

compliance with existing state and federal regulations and requirements.

A RCRA Facility Assessment (RFA) was conducted at Cannon AFB in 1987 which included the identification of 76 potential release sites (ICearney 1988) The

EPA review of the RFA concluded that the total RFI should be completed in three phases. This first phase RFI is addressing 26 potential release sites identified

in the Appendix I of the RFA.

1 . 3 . REPORT PURPOSE AND ORGANIZATION

This document has been prepared in order to comply with regulatory

direction and follows the work plan format recommended by the U.S. EPA for

conducting RFIs (EPA 1989) . It is intended to provide background and preliminary

information applicable to all of the SWMUs. The following topics are addressed

in this Work Plan:

:- Section 2 of this report gives background information on Cannon AFB;

:- !.: including the regional setting, physical geography, land use,

geology, hydrogeology, surface hydrology, and climatology.

Section 3 gives a preliminary conceptual site model for this

investigation. This model presents an initial environmental

assessment for these sites. Primary and secondary contaminant

sources and release mechanisms, predicted pathways, and potential receptors are identified. More detailed information on the potential

release sites is provided in the Field Sampling Plan.

Section 4 gives the work plan rationale, including applicable or relevant and appropriate requirements (ARARs) and data quality objectives (DQOs). ARARs include federal, state, or local

promulgated requirements that may be applicable to the contaminants or conditions at Cannon AFB. DQOs are qualitative and quantitative statements that specify the quality of data required to support the

decisions made during remedial response activities. They are

determined based on the end uses of the data.

Section 5 discusses the RFI tasks. These tasks have been identified by EPA to describe activities that will be performed during the

various phases of the RFI process. They include project planning,

field investigations, sample analysis, and data evaluation.

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- Section 6 discusses the funding source, authorities, and restrictions for the RFI.

- Section 7 gives the preliminary RFI schedule.

- Section 8 discusses project management, including staffing and coordination, for Rh activities.

In addition to this Project Management Plan, a Field Sampling Plan, Data Collection Quality Assurance Plan (QAP), Health and Safety Plan (HSP), and

Community Relations Plan (CR?) are provided as companion documents.

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2. INSTALLATION BACKGROtTND

2.1 History of Cannon AFB

Cannon AF is located in Curry County, New Mexico, approximately 7 miles west of the City of Clovis. The base is situated on approximately 4,320 acres of land. The vicinity map of Cannon AlB is shown on Figure 1 and the site map of Cannon AFS is shown on Figure 2. Off-base facilities include the Meirose

Bombing Range and the Conchas Lake Recreation Annex.

Cannon AFB dates to 1929, when Portair Field was established on the site. Portair Field was a civilian passenger terminal for early commercial transcontinental flights. In 1942, the Army Air Corps took control of the

civilian airfield and it became known as the Clovis Army Air Base. In early 1945, the base was renamed Clovis Army Air Field. Flying, bombing, and gunnery classes continued through the end of World War II. By mid-1946, however, the

airfield was placed on a reduced operational status and flying activities

decreased. The installation was deactivated in May 1947. The types of aircraft stationed at Cannon AFB from 1942 to 1947 included B-17, B-24, and B-29 heavy bombers.

The base was reassigned to the Tactical Air Command in July 1951. The first unit, the 140th Fighter-Bomber Wing, arrived in October of that year. The airfield was formally reactivated in November 1951 as Clovis Air Force Base.

:: Between 1952 and 1957, the 50th and 388th Fighter-Bomber Wings were activated

and, upon their transfer, were replaced by the 312th and 474th Fighter-Bomber Groups. Predominant aircraft stationed at Cannon AFB from 1951 to 1957 included the P-51 "Mustang" fighter and the F-86 "Sabre" fighter jet.

In June 1957, the base became a permanent installation and was renamed Cannon Air Force Base in honor of the late General John K. Cannon, a former commander of the Tactical Air Command. In October 1957, the 312th and 474th Fighter-Bomber Groups were redesignated tactical fighter wings and the 832nd Air Division was activated to oversee their activities.

In 1959, the 312th Tactical Fighter Wing (TFW) was deactivated and replaced at Cannon AFS by the 27th TFW. In December 1965, the base's mission changed to that of a replacement training unit, and the 27th TFW became the largest such unit in the Tactical Air Command. The predominant aircraft stationed at Cannon AFE from 1957 to 1965 was the F-100 "Super Sabre' fighter jet.

The 832nd Air Division was deactivated in July 1975, leaving the 27th TFW the principal Air Force unit at Cannon AFB. In early 1981, the 27th TFW was designated a Rapid Deployment Joint Task Force member.

The primary mission of Cannon AFB has remained relatively unchanged since 1965, i.e., to develop and maintain ari F-111 tactical fighter wing capable of day, night, and all-weather combat operations and to provide replacement training

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of combat aircrews for tactical organizations worldwide. Aircraft stationed at Cannon AF since 1965 include the F-100 Super Sabres' fighter jet (1957-1969), the F-lilA (1969), the F-111E (1969-1971) and the F-hiD (1971-present).

There are approximately 70 F-hiD aircraft assigned to Cannon AFB. The total work force on Cannon AFB numbers approximately 4,000, which includes 3,500 military and 450 civil service.

2.2 Site Characteristics

2.2.1 Physical Geography

Cannon AFB is situated in the Southern High Plains Physiographic Province in the Llano Estacado subprovince. The Llano Estacado is a nearly flat plain sloping gently (10 to 15 feet per mile) to the east and southeast. Elevations in the eastern New Mexico portion of the Llano Estucado exceed 4,000 feet above mean sea level (msi). In the vicinity of Cannon AFB, elevations range from 4,250 feet to 4,350 feet above msi.

The most prominent geomorphic features in the vicinity of Cannon AFB are blowouts and broad, widely spacedvalleys. Less common landforms are relict sand dunes located along the northern side of the Portales Valley south of the base. Relict dunes are not found on or near Cannon AFS.

:r Blowouts are broad shallow depressions which form as the result of soil

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erosion by wind. Blowouts commonly collect surface runoff from small to moderate sized drainage areas. During periods of rainfall, runoff collects in blowouts to form ephemeral playa lakes. Playas have no external surface drainage. Water is lost by infiltration to the soil and evaporation; without recharge, playa lakes persist for only a few days or weeks. Three playas are located within the base, and several more are found to the north and east of the base.

Stream valleys tend to be fairly broad and widely spaced. Streams are ephemeral and drainages are poorly developed. No streams exist on or near Cannon AFB. Running Water Draw and Patrick Draw, located about 10 and 20 miles,

respectively, north of Cannon AFB, are the nearest streams. These are second- order streams. Both streams are very straight, flow southeast, and have rectilinear drainage patterns with short laterals. Runoff from Cannon AFB does not reach either stream.

2.2.2 Land Use Near Cannon AFB

Cannon AFB is located just south of U.S. Highway 60.84 (Figure 1.2-3) in a farming and ranching area. The majority of the land surrounding the Base is

productive irrigated farmland or grassland. The major crops are wheat, sorghum, sugar beets, corn, cotton, alfalfa, barley, and peanuts. The land is also used for cattle grazing, both beef and dairy, and Clovis is considered the "Cattle Capital of the Southcest." Portales is the home of Eastern New Mexico University, which provides a variety of educational programs and a rich cultural life to area residents.

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2.2.3 Climatology

R.FICAN. PMP

The climate of east-central New Mexico is classified as tropical semi- arid, with summer temperature and precipitation maxima. Average monthly temperatures range from a January low of 12°C (39°F) to a July high of 26 oc

(78°F) . Extreme daily temperatures range from -24 oc (-11°F) to 41°C (106°F) (AWS

Climatic Brief, 1986). Average monthly precipitation ranges from i cm (0.4 in) in winter to 6.9 cm (2.7 in) in July. (AWS 1986) The maximum recorded 24 hour rainfall is 12.2 cm (4.8 in), which occurred inAugust. Rainfall occurs on eight or more days per month during the summer precipitation maximum. Mean annual precipitation is approximately 41 cm (16 in). The mean annual evapotrans- piration rate is 181.4 cm/yr (71.4 in/yr) (Walk, Haydel & Associates, 1990). Prevailing winds are from the west at an average of S k/hr (8 mph) during fall, winter, and spring. During the summer, winds are from the south at an average of 3.7 km/hr (6 mph). (AWS 1986).

The atmosphere around the area of Cannon AFB is generally well mixed. The seasonal and annual average mixing heights can vary from 400 meters in the

morning to 4000 meters in the afternoon. The afternoon mixing heights are typically greater during the spring and fall seasons. The morning mixing heights are usually low, due to nighttime heat loss from the ground producing surface- based temperature inversions. After sunrise these inversions break up, and solar heating of the earth's surface causes vertical mixing in the atmosphere.

Dust is frequently entrained into the atmosphere in this region of the ¿.1 country because of gusty winds and the semiarid climate. The Texas Panhandle-

eastern New Mexico area is considered the worst area in the United States for windblown dust. Occasionally this windblown dust is of sufficient quantity to

restrict visibility. Most of the seasonal dust storms occur in March and April, when the wind speeds are typically high.

2.2.4 Geology

The near-surface stratigraphic units of interest at Cannon AF are the Late Miocene-Late Pliocene age Ogallala Formation and the Early Triassic Dockum Group.

The Dockum Croup consists of three formations (Fig.3). The

stratigraphically lowest unit is the Santa Rosa Sandstone. Overlying the Santa Rosa Sandstone are the Chinle and Redonda Formations. The Chinle and Redonda Formations are composed mainly of red shales with lesser interbedded sands, and are known locally as 'redbeds". The top of the Dockum Croup is marked by an erosional unconformity having relief of up to several hundred feet (Frye & Leonard 1971).

Overlying the Dockum Group redbeds is the Ogallala Formation. The Ogallala Formation extends from eastern New Mexico and Colorado into Texas, Oklahoma, Kansas, Nebraska, and South Dakota. Drillers logs from Cannon AFB indicate that the Ogallala Formation varies from 360 ft to 415 ft. in thickness. The incised upper surface of Triassic redbeds strongly influences Ogallala thickness. Stream

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valleys in the post-Triassic unconformity are deep and trend dominantly east- west. Ogallala thickness may thus vary significantly over short north-south distances.

The Ogallala is erosionally truncated to the south along the abandoned Portales Valley, to the west along the Pecos River Valley, and to the north in a series of ephemeral stream valleys. The Ogallala Formation extends more than 125 miles to the east before terminating as an escarpment in Briscoe County, Texas. Springs and seeps are common along the erosional margins of the

Ogallala.

The Ogallala dips gently and monoclinically to the southeast in the

vicinity of Cannon AFB. Frey and Leonard (1972) suggest that some Quatenary warping may have occurred. Most of the structures recognized by Frye and Leonard (1972) are well to the northwest and southwest of Cannon AFS. No faults or

buried structural linements are known in the vicinity of Cannon AlB.

The Ogallala Formation is composed of unconsolidated poorly sorted gravel, sand, silts, and clays. The base of the Ogallala is generally marked by a gravel, cobble, and boulder deposit. This basal member contains sediments derived from igneous and sedimentary rocks transported from the mountains to the west. The Ogallala Formation was laid down by stream and overbank deposits formed within coalescing alluvial fans. These fans form a broad pediment along the eastern flank of the Rocky Mountains. As is typical of alluvial deposits, Ogallala internal stratigraphy varies vertically and horizontally over short distances.

Except where strongly cemented by calcium carbonate (caliche), the sediments of the Ogallala are loose and friable. Authigenic and allogenic clays are found as a trace to abundant matrix mineral (Class, et al. 1973 and Frye, et al. 1974). Frye, et al. (1974) distinguished five zones within the Ogallala of east central New Mexico on the basis of clay minerals. These zones are

illustrated in Figure 4. Sruectites (montmorillonites) and attapulgite (with sepeotite) are the dominant clays throughout the Ogallala. Illite is a lesser, but persistent clay, as is kaolinite. Smectite is a swelling clay, causing deep cracks to form in dry surface soils. Smectite in particular, and to a lesser extent attapulgite and illite, are clays with moderate to high cation exchange capacities (CEC) . The formation as a whole should therefore have a relatively high CEC, which should inhibit the migration of charged contaminants, and especially ionic forms of metals.

Caliche is a major feature of the Ogallala Formation, occurring as nearly continuous to discontinuous layers throughout (Figure 4). Caliche is hard, white to pale tan on fresh surfaces, weathering to gray, and has a chalky appearance. Caliche forms as calcium carbonate, leached from overlying sediments, precipitates in the pore space of the host sediments. Precipitation is caused by the evaporation of downward percolating water. The caliche may thus mark the position of ancient vadose zones. Frye, et al (1974) gives radiocarbon dates for the upper "climax" caliche ranging from -27,000 yrs B.P. to -42,000 yrs. B.P.

0050590 10

Deptri n Feet

Qi

i 00

200-

300

..... 400

500

700-

FOR M AT ION N AM E

.. L

D ES CR IPTON

e

GEOLOGIC AGE

- : _

. . .

C . .. . -

c . E . . Sand, Sandstone _-_ Tertiary

Figure 3. Geologic Column at Cannon AFB

DOO59O 11

: »

r Q, - :j o - -

- o .- r -Q u_c

.; -: ,..Q .

_z 5 2 r -t -- s .- .z L.

.- :.z2 :: : ;-

- _ < , = rii::--

-_J_-_.__. ____ =

: [

J_7 I I I

z 2::-2 = : = :

1_t I L±

:

;Í::iIT

t__:' o'--- -

T

ga !

i__ J

i.::..:..\ _

Figure 4. Generalized Lithology

D030590 12

RFIcAN . PMP

RFICAN. FMP

Caliche is relatively soluble in acidic water (pH<7) or in .,aters

containing dissolved CO2. The top surface of the upper "climax' caliche in fresh

outcrop shows solution etching.

The Ogallala has numerous continuous to discontinuous caliche layers

throughout its thickness. The uppermost caliche, termed the "climax" caliche

by Frye and Leonard (1972), is pisolitic. The pisolites are thought to have formed as the caliche was repeatedly chemically weathered and brecciated during Pliestocene pluvials and later recemented during drier intervals. This upper caliche outcrops around playas and the bounding escarpments of the Ogallala, and

is locally termed "caprock". Caliches which occur lower in the Ogallala are platy and harder. Caliche is commonly thin or absent below playas.

2.2.5 Hydrogeology

The lower portion of the Ogallala Formation is the primary regional aquifer for both potable and irrigation water. No deeper aquifers are utilized in the vicinity of Cannon AFB. The Ogallala aquifer is part of the High Plains Aquifer which extends continuously from Wyoming and South Dakota into New Mexico and Texas. In east central New Mexico, the Ogallala aquifer rests on Dockuni Group redbeds, which serve as the basal confining layer (aquaclude). The Ogallala is a water table, or unconfined, aquifer (Weeks and Cutentag 1981; erkstresser and Mourant, 1966). The Ogallala aquifer has a southeasterly regional gradient of about 13 ft/mile. Well yields vary from less than one gallon per minute (gpm)

in thin silts and sands up to 1600 gpm in thick sands and gravels (Berkstresser

..

and Mourant, 1966) . Water quality is generally good, with hardness and fluorides being somewhat high (ibid 1966).

At Cannon AF3 the Ogallala aquifer has an average saturated thickness of 120 fc (mid-1960's). Saturated thickness ranges from 93 to 143 feet, and is influenced by the configuration of the erosional unconformity surface marking the top of the Dockum Group. The local groundwater gradient is southeasterly at 7.5 ft/mile (Corps of Engineers, 1990). Figure 3 shows water table elevation contours for 1982. Flow within the saturated zone may be influenced by the

configuration of the top of the Dockuni Group. Yields in tests of Cannon AFB water wells have ranged from 776 L/min (205 gpm) to 4353 L/min (1150 gpm).

Specific capacities range from 0.14 m3/m (11.4 gal/ft.) to 0.35 mi/rn (27.9

gal/ft.)

Very rough estimates of hydraulic conductivity were made from well pump tests in water wells 5 and 9 using the Theis equation. An estimate of hydraulic conductivity for water well 8 was based on water level recovery data using the Rouwer and Rice (1976) approach. The data used in these calculations were obtained to evaluate pump rates, efficiency, and well yield, and were not intended for use in calculating aquifer properties. The results of these

calculations should therefore be considered as first approximations.

00505go 13

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--, j:- -' s -

LEGEND

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5CCO1ater Tab'e Contours Feet ms ; ; :/ : -

- -.- z '- Boundary f High Plains Aquifer

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Figure 5. Altitude and Configuration of the Water Table

DO5O9O 14

RFICM lP

.:>: Hydraulic conductivity values for water wells 5 and 9 were found to be

approximately 2.0 x 103cm/sec. Calculations for water well 8 results in a

hydraulic conductivity of 2.0 x 102 cm/sec. These estimates appear to be too

low when compared to published hydraulic conductivity data for sands and gravels.

Kearney (1987) indicates a groundwater flow velocity of about 45 rn/yr (150

ft/yr). This calculates out to an hydraulic conductivity of approximately 1.0

X io-i cm/sec. Again, this appears to be low when compared with published data.

The presence of interstitial clays may account for both the variability and low

values of hydraulic conductivities. Boring logs from Cannon AFB IRP projects

and published reports (Frye, et al. 1974; Glass, et al. 1973) indicated that

interstitial and interstratified clays are abundant in the Ogallala Formation.

Additional aquifer testing will be required in order to accurately determine hydraulic conductivity.

Recharge to the Ogallala is primarily through precipitation. Berkstresser

and Mourant (1966) report a recharge rate of 0.5 in./yr as calculated by Theis

(1936). Kearney (1987) indicates that the recharge rate may be as much as 1.0

in./yr. Due to the high evapotranspiration rate and low precipitation, recharge

will occur only during heavy rainfall events in which the infiltration capacity of the soil is exceeded and runoff occurs, or during cool months when

precipitation exceeds evapotranspiration. Runoff will flow to playas. The

concentration of water in playas will allow deep percolation to the aquifer.

The occurrence of this process is evidenced by the presence of clay deposits in, and the lack of caliche directly below, playas. Caliche is soluble in acidic

.. . rain waters, and is leached over time to form percolation pathways.

from the Ogallala occurs through well pumping and springs along the eroded margins. Spring flow discharge does not occur on or near Cannon AFS. Domestic and irrigation water wells are common on and around the base, however.

The rate of discharge exceeds recharge. Water levels in the Ogallala have

declined steadily from the 1930's to the present. A decline of 50 to 100 ft.

has been observed in the area around Clovis, New Mexico for the period from the 1930's to 1980. Lukey, et al. (1981) states that "the largest area of water-

level decline exceeding 100 ft. occurs south of the Canadian River extending from Curry Co., New Mexico to Crosby Co., Texas."

2.2.6 Soils

Soils in che vicinity of Cannon AFß are classified as SM to SC under the Unified Classification Systems, and as aridisols (calciorthids) under the Soil Conservation Service Comprehensive Soil Classification System. The following summary is based on the Soil Conservation Service Curry County Soil Survey (1953)

The most common soil type on the base is the Amarillo fine sandy loam, O

to 2 percent slope phase (map symbol Ab). This soil consists of a thin sandy

A horizon, well defined clayey B13 horizons, with a calcic B3 horizon at depths below 40 inches. The calde ß horizon lies on a calcic C horizon, or on

caliche. The Amarillo fine sandy loam is present on all relatively flat surfaces at the base, but is also found on slopes associated with playas (Map symbol Ac).

0050590 15

1

Clovis fi 5 percent slope barns. In the

to 56 in. The sandy barns occ

In a fe

playas, Mauske 2 to 5 percent no B horizons the surface.

ne sandy barns, O-2 percent slope phase (map symbol Cb) and 2- phase (map symbol Cc) are very similar to Amarillo fine sandy

Cbovis soils, the depth to the calcic C horizon ranges from 28

depth to caliche exceeds 56 inches. Cbovis and Amarillo fine

ur in close association.

idy loam, O to 2 percent slope phase (map symbol Ma), and ap symbol M6) are found. Mausker fine sandy barns have ry calcareous. The calcic C horizon is within 2 ft. of

w limited .r fine sar : phase (ro.

and are ve

areas, particularly along the steeper slopes around

The A and B horizons of Amarillo and Clovis fine sandy loais are rapidly to moderately permeable. Mausker fine sandy loam A and Ac horizons are rapidly permeable. Permeabilities in calcic S and C horizons are moderate.

DO 30 5 90 16

PIICAN.PMP

3. INITIAL EVALUATION

Numerous SWMUS have been evaluated. under the Air Force Installation Restoration Program as to suggested remedial action. In fact, some remedial

actions have occurred and are considered complete. The conceptual design postulated in this section is applicable to all SWMUs should additional investigation be required.

3.1 Behavior of Contaminant Plumes

The behavior of contaminants in unsaturated clay-rich sediments and soils is a complex physicochemical process. Due to the depth to the water table (>200

fr) and lack of precipitation and water infiltration as a contaminant carrier, only large or continuous releases of liquid contaminants may be expected to reach

the water table. The presence of low permeability (but not impermeable) caliche layers, as well as chemically active (i.e., high CEC) clays, will also act to

impede contaminant migration. Capillarity will also have a role in attenuating

contaminant irrigation. As illustrated in Figure 6a, a relatively small

contaminant release will tend to form a "pendant plume". A pendant plume extends downward from the release site with little lateral spread. Downward migration will continue until capillarity and clay adsorption eliminates free liquids

(i.e., liquids which can be drained rapidly by gravity (Biswas et al. 1966).

Pendant plumes may spread laterally if low permeability layers are encountered

during downward movement. (Figure 6b) However, in the absence of a carrier fluid '

such as water, lateral spread will be severely limited.

Relatively large plumes may not be fully attenuated by caliche or clays and may reach the water table. Figure 6c illustrates this situation. In this

instance, the low gradient of the water table will limit the rate of migration.

Caliche, as a low-permeability barrier, will act to retard and spread a

downward moving contaminant plume. As a rule of thumb, a difference of permeability of two orders of magnitude or more will provide ari effective barrier in the absence of significant head differences. While the vertical migration pathway provides a significant change in head, the generally small quantities of liquids involved and the complex nature of flow in unsaturated porous media make it likely that only large plumes will penetrate competant caliche. Migration along fractures, where present, may allow passage in some locations.

Clays, zeolites (e.g., heolandite), metal oxides, andhumus are chemically active soil/sediment constituents which can impede or trap migrating contaminants. These particulates have large surface areas and slight to moderate electronegative surface and interlayer charges. Cationic contaminants in water

may partition and adsorb to clay or humus. The degree of partitioning depends on clay CEC; amount of humus; types and concentrations of natural and contaminant ions; ionic valency; and the presence of dissolved organic co-contaminants (Matthess 1984)

0050590 17

't

RFICAN.MP

This model of contaminant migration in a semi-arid region with a deep

unconfined water table forms the conceptual basis for soil and groundwater sampling (Kearney, 1987).

3.2 Solid Waste Management Units

At sites where relatively small amounts of liquid are known or suspected to have entered the soil, sampling will be limited to soils only. Depths of

sampling will depend on the relative amount of liquids released to the soil.

For example, samples will be collected to a depth of 10 ft at SWMU #86, Jet Engine Test Cell, where releases of contaminated water probably were less than a few tens of gallons per event. At Fire Protection Training Area 4, however, releases occurred in greater volumes. Soil sampling will extend to 100 ft. , and

if contaminants are detected at depth in field screening of soil samples, one or more monitoring wells will be installed. In areas such as playas and unlined drainage ditches, soils may be sampled to depths exceeding loo ft., and monitoring wells may be installed.

D050390 18

--t

CCl

4

RFCAN. P1P

Fig 6 A Pendant plume for relatively small release

Fig 6 Pendant plume for for larger release. Spreading will occur along flou barriers

Fig 6c Pendant plume reaching the water table

Figure 6. Pendant Plumes

- DO5O9O 19

RFIC.AN. PMP

4, WORK PLAN RATIONALK

To define the data (type, sampling location, number, and accuracy) to be

collected during a RFI, it is necessary to answer five sequential questions.

(1) What question must be answered, or what decision must be made at the end of the RFI? In general, this addresses whether it is necessary to remediate a site to protect human health and the environment.

(2) What requirements must be applied/met in order to ensure the

protection of human health and the environment? (3) What are the DQOs that must be specified in order to ensure that the

data obtained can provide the answer to (1)?

(4) What activities must be performed as part of the RFI to meet the

DQOs? (5) What type of data is necessary to perform the tasks identified in

(4) and determine if corrective measures are required?

The following section describes DQOs that have been identified for P.11

activities at Cannon AFS. SWMU-specific Sampling Plans will address these issues

in more detail and will demonstrate how the proposed RFI activities will satisfy the data needs.

4.1 APPLICABLE OR RELEVANT AND APPROPRIATE R.EQUIREHENTS

This section identifies ARARs for contaminated soils, sediments, and

groundwater at Cannon AFB. Applicable requirements are those cleanup standards,

standards of control, and other substantive environmental protection requirements, criteria, or limitations promulgated under federal or state law that specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance at a RFI site. Relevant and appropriate requirements are those cleanup standards, standards of control, and other

substantive environmental protection requirements, criteria, or limitations

promulgated under federal or state law that, while not "applicable" to a

hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance, address problems or situations sufficiently similar to those

encountered at the RFI site that their use is well suited to the particular site.

4.1.1. Tvies of ARARs

There are, in general, three different types of ARARs although some requirements do not fit neatly into these categories.

- Chemical-specific

- Location-specific

Activity-specific

D050390 20

RICALPMP

Chemical-specific (or ambient) ARARs are usually health- or risk-based

rtumerical values or methodologies that establish concentrations or discharge

limits for particular chemicals. Only a limited number have been promulgated.

The results of a risk assesstuent are used in establishing cleanup goals

that are protective. The total carcinogenic risk or hazard index for all

chemicals of concern in a medium is calculated in this risk assessment. As a

starting point for setting cleanup goals, the risk calculations are developed

using chemical-specific requirements. If there are no chemical-specific ARARs,

then specified federal or state "to be considered" (TBC) values are used in the

calculations. Examples of this type of an ARAR are RCRA Maximum Concentration

Limits (MCLs) , Safe Drinking Water Act (SDWA) Maximum Contaminant Levels (MCLs)

and Maximum Contaminant Level Goals (MCLCs) , and water quality criteria developed

under the Clean Water Act (CWA) . Other nonpromulgated values may also be used

in setting protective cleanup goals. An alternative type of guidance is a factor

TBC values. Where no ARAR of the above type exists, or where ARARs are not

sufficiently protective of human health and the environment, chemical-specific

TBC values are used to establish cleanup targets. Examples of TBCs include

health advisories, proposed rules, guidance materials, and policy documents.

In general, TECs are not formally promulgated criteria or standards, and are

developed, using the best professional judgement, based on the latest available

information.

Location-specific ARARs are restrictions placed on the concentration of

t

hazardous substances or the conduct of activities solely because they occur in

.- special locations. These may restrict or preclude certain remedial actions or

may apply only to certain portions of a site. RCRA location requirements, flood

plain management restrictions, and wetlands discharge restrictions are examples

of this type of ARAR.

Activity-specific (or performance or design) ARARs are usually technology-

or activity-based requirements or limitations on actions. Examples of this type

of ARAR are the RCRA Subtitle C requirements for hazardous waste management.

4.1.2. State Requirements as Potential ARARs

In order for a state requirement to be eligible to be an ARAR it must be

1) promulgated, and 2) more stringent than federal requirements. A state

requirement is promulgated if it is legally enforceable (i.e. , it is enforceable

through a general authority, or the enabling legislation contains specific

enforcement provisions) and if it is generally applicable. The evaluation of

stringency considers two types of regulations: 1) those for which there is a

federal counterpart (or program), and 2) those for which there is no federal

counterpart (or program).

For most federally authorized state programs (e.g. , RCRA, CWA, SDWA) , state

requirements are "at least as stringent" as federal requirements. Therefore,

state requirements under these programs do not require a comparison of

stringency. It must be determined, however, that the state has been authorized

to administer the program and to develop regulations under the authorized

a5o590 21

RFICAN PMP

d program. For nonauthorized state programs, the investigator must prepare a side-

by-side analysis of requirements to show that the state requirements are more

stringent than federal requirements. Regulations promulgated under state

programs that do not have a federal counterpart or a baseline of federal

regulations, but that address specific conditions within that state, are more

stringent than federal law because they add new or specific requirements to the

body of federal environmental regulations.

State requirements must also be substantive; that is, they must not impose

only administrative or procedural requirements or requirements that can be

substituted by established administrative procedures . Further, EPA will consider

state requirements to be ARARs only if they are "of general applicability." For

a state requirement to be a potential ARAR, it must be applicable to all remedial

situations described in the requirement. Also, the requirement must be

consistently applied to all sites. Local laws are generally not promulgated

state requirements and therefore, may or may not be ARARs. If the local

requirement is developed under explicit state authority or compliance is a

requirement of a promulgated state statute, the local requirement may be an ARAR.

4.1.3. Procedures for Determining ARARs

Compliance with other laws may be either "applicable" or "relevant and

appropriate" but not both, based on those cleanup standards, standards of control, and other substantive environmental protection requirements, criteria,

,

or limitations promulgated under federal or state law. ARARs will be determined

on an SWMtJ specific basis. Thus, each evaluation of a potential ARAR will

consist of a determination as to whether the requirement is applicable, or

whether it is relevant and appropriate.

The procedure for determining ARARs will be an ongoing process that takes

place throughout the RFI process. The determination of ARARs will progress from

this installation-wide site report, in which it will be indicated which

regulatory programs may impose requirements, to a determination of specific

criteria and standards that will become part of the response objectives.

In general, chemical-specific and location-specific potential ARARs will

be identified during each investigation. Later, as corrective measures

alternatives are developed, activity-specific ARARs will be identified.

ARARs may be waived under certain specific circumstances. The waivers

apply only to meeting ARARs with respect to remedial activities occurring onsite, and a waiver must be invoked for each ARAR that will not be attained or exceeded. Circumstances under which ARARs may be waived are as follows:

- Interim corrective measures - The action selected is only part of

a total remedial action that will attain such level or standard of

control when completed.

- Greater risk to health and the environment - Compliance with such

requirements at the facility will result in greater risk to human

.

OO5O9O 22

EFICAN - PMP

health and the environment than alternative options.

- Technical impracticability - Compliance with such requirements is

technically impracticable from an engineering perspective.

- Equivalent standard of performance - The corrective measures selected

will attain a standard of performance that is equivalent to that

required under the otherwise applicable standard, requirement,

criteria, or limitation, through use of another method or approach.

Inconsistent application of state requirements - With respect to a state standard, requirement, criteria, or limitation, the state has

not consistently applied (or demonstrated the intention to

consistently apply) the standard, requirement, criteria, or

limitation in similar circumstances for other remedial actions.

4.1.4. Review of Cannon AF ARARs

The following section presents a review of potential AltARs that may be

applied to the RFI at Cannon AFß. These ARARs are not all-inclusive, but they

do present the federal and state regulations that will be used to determine a

detailed list of ARARs after each SWMU investigation is completed. Detailed

chemical-specific ARAR standards have not been determined at this stage since this RFI addresses a large number of SWMUs at Cannon AFB. As more chemicals of potential concern are identified during the RFI and the requirement for

corrective measures is better defined, potential ARARs will be added to or

removed from the analysis.

4.1.4.1. Chemical-Siecific ARARs

Chemicals identified that are of concern include inorganic chemicals,

volatile and semi-volatile organic chemicals, and pesticides. Table IV.l and

1V2 identify general chemical-specific federal and state ARARs for Cannon APE. These ARARs are based on current, publicly available information and do not reflect the administrative discretion that may be exercised in the future by federal and state authorities.

Cleanup criteria will be established at later stages of the RFI process for the contaminants presently thought to be of concern and will be presented

in appropriate SWMU-specific documents. Cleanup criteria will be developed after risk assessment and will include a cost-benefit analysis for risk and dose

reduction. Cleanup criteria will be based on federal and state ARARs.

4.1.4.2. Location-Specific ARARs

There are only a few federal location-specific regulations that establish

location standards. Table IV.3 lists those ARARs that address the issues of

locating hazardous waste management units in fault zones, flood plains, or in

salt dome formations. The state location-specific ARARs that may apply to Cannon AFE are identified in Table IV.4.

0050590 23

-

RPICAN.PMP

4.1.4.3. Action-St,ecific ARARs

Table IV.5 and IV.6 list federal and state general action-specific ARARs, respectively. These tables present the regulations that way require action- specific ARARs for activities generally encountered in hazardous waste site

remediation (e.g. , generation, transportation, storage, onsite disposal, capping,

etc. ) . Additional requirements address worker health and safety, general closure standards, and the need to manage contaminated vastes and wastes generated during site activities. An analysis of these requirements will be performed and refined as the RFI progresses. Action-specific ARARs will be either applicable or relevant and appropriate, depending on the corrective measures that may be considered for Cannon AFB.

Doo3go 24

t'

RFICAN. PMP

Table IV.l. Potential Federal Chemical-Specific ARARs for Cannon AFB

R.u1.tory

Citatton________________________ C1.an Wat.r Acut. CWA fr.shw.tsr critsrion (CWP 1304)

Chronic CWA frs.hw.t.r toxicity critsrion (CWA 1304)

EPA .mbi.nt witar qutlity crit.rta (.c) for prot.ctlon of htan h.alth aquatic or;anL.ma, md driok- ii w.t.r st..ndtxts (CW& I 304) CEPA) 1986).

EPA ambient for ht.n h..tth CC): .djust.d for drinkin8 wst.r only (CWA 1304) epa 1986).

Safe Drinkth; Cts (40 CFR $141.11 and 141.51) Wat.r Act (SDWA)

t'cts (40 CR $14t.0)

Rssoirc. Con- RRA m.xi concantration of s.rvation and contamin.nts for the charact.ristic Recov.ry Act of xtrsction poc.dur. (E? (RCRA) toxicity (40 CTR 1261.24)

RcRA CLs (40 CFR 1264.94)

Clean Aiz Act (CA)

Toxic Substance. Control Act (ISCA)

0050590

RcRA lend disposal restrictions and tr.etaent standards (40 CT 1268)

National priiary and s.condary aubi.nt air qa1ity standard. (40 CER 150)

National emission standards for hazardous air pollutants (40 CFR 150)

Potychiorinated biph.nyls (?CBs) cleanup Levels (40 dR 1761)

25

TBC

Requirements

SOWA proposed t'Ct. (draft proposed valu.. a. of July 1988) (AWWA 1988).

SDWA proposed CW. (draft Proposed velu.. a. of July 1988) (AMiA 1988).

Oraft RcRA corrective action proposed .dia protection standards for car- carcinogens in soil, water, and air (draft proposed values as of April 1988 in 40 CTR 264. Subpart S) (Aspen ?ubtish.ra 1988).

TSCA chemical advisori.. and health data. Also, AISDR toxicological profile..

U'ICAN

Table IV.].. (continued)

R.5u1.tory TBC

CLtatioi ARARs R.quireiiets

Occupational P.ri3tbLs rpcsurs Limits Safety and (PEL) and abort tarm .xpaauz. ..1th AJ.ni- Limiti (STEt) for worksrs

itration (OSHA) involved in hsza.rdou. wait. op.ration.

G.a.rsL induitry utindards (29 cFR 11910)

P.d.rai. crit.ria. E.altb Iff.cts Aaa.asm.nts .dvtsoriss, and (HEAS) Sfld Propcs.d EZAs

procsdur.s (EPA 1985)

RFV-Veift.d R.f.renc. Dos. o USEPA' (ECA-CIN-475, January 1986).

Csrcinog.n Pot.ncy Factors (CPFs) - Tabu lt. "H.altb Ass.sso.nt Oocum.nt for T.trachloco.thyl.n. (P.rchloro.thyl.n.) , tJSEPA

OBZA/6008821005P, July 1985.

"Guidanc. on Rso.dial Actions for Contaminat.d Gxomdwter at Sup.rfwd SLt.s' Ctntarim

'.'

Final. D.camb.r 1988) .stabtish.s crit.ria for the us. of backlround concentrations and ACts (EPAIS4O/G-88/003.

osw Dir. 9283.1-2).

0050590 26

- RFICAN.PMP -k

t

' -t,

Table IV.2. Potential State Chamical-Specifi ARARs for Cannon AlB

R.uLatoiy TBC

Citt ion ARJRs

N.w H.xtco H.zaxdous Wast. Mana8..nt R.gulatioria

M.w M.xico Water Quaiity Standards

D050590 27

RFXCAN. FMP

Table IV.3. Potential Federal Location-Specific ARARs for Cannon AlB

R.uJ.atary mC Citation Recxuireaents

R.aourc. Fault zon.s (40 cYR 1254.18(a)I Cona.rv.tion and R.cov.i Flood plains t40 cPR 1264.lBCb)j Act (A)

satt doca foations. aaZ.t bad iorm*tiocs, tdsrground minsa or c&v.' (40 CYR I264.1CC)1

Endani.rsd Action to conasry. indaa.r.d species Species Act or thr.st.n.d sp.ci.s d pr.s.rv.

th.ir h.bitat (O cYR *S200, aIOZI

National Action to tek. into sccowt ff.cta Historic on properties incLuded in or Preservation .tiibts for tb. istiona1. R.ist.r Act (NEPA) of Historic PLtc.s and to inimiz.

her to National Eistoric Lsnón&rks &650I. Also ti CFR *6501. Also incltid.s archa.oLoicsL zssoucss unifori reulaticna.

Flood PLath Exscttiv. orders U988 (flood PLain Manaso.nt Msna&aent) and 1L990 (Pot.ction and WetLands of Wetlands) (40 CV?. 6, Appendix AI Central

Wilderness Establishes nortd.grstion. axiu Act restoration, ard protection of

wilderness areas as priciar7 ana5anetlt principal3 (L6 U.S.C. 11311.

Fish and abitst protection standards and Wildlife addresses inputs to wetlands. Coordination Act (16U5C561), Fish and Wildlif. Improvement Act (16U5C742). and Fth and Wildlife Cons.rvation Act

C 15U5C2901)

e

0050590 28

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t. -.

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Table IV.4

Regulatory Citation

RICAN

Potential State Location-Specific ARARs for Cannon AFB

29

TBC

R.ciuir..nts

/ R.FICAN.PMP

Table IV.5. Potential Federal Action-Specific ARARs for Cannon AFB

Rsulatory Citation ARRa

BcRA R.quirsia.nt. IncLudi d.inttiou and idintificatlon ei s haxardoua wsits; &Sfl.r$tiafl of a haiardo, w.at.; tranapotation of a hazard- oua Wast.; trsath.nt of a hazard- oui Waits; includin oaite and oUsit. incin,r.tion; tr.sth.nt b.Zor. a wazt. nay b. land d.ispo..d; tr.atm.nt of contLnat.d 5round- wtt.r; storal. of a hazardous wait., which thclud.a contain.r and tank r.quir.msnti; disposaL of a hazard- eus Wait., which inc.ud.s capping. ci..an cloaurs, and cLo.r. with wait. in plac.; consoLidation b.tw..n unita .xcavation: op.ration and maint.nanc.; groundwat..r nønitoririg r.quir..nts incLudtn8 poat-ctoaur. groundwatar nonitoring reçuirs.nts; and surface wat.r contrat (40 CFH 11260-25e)

CERCLA

CWA R.quir.anti include discharg. of stern wat.rs. disohar;. of wat.r into surface water bodies. effLuent guidelines and standards. pretreat- n.nt standards, and discharge of treatcient systiw effluent (CWAS3O4,

40 CR $1122, 123, 125. 13., 230. 231, 233. and 400-46g, 33 CFR 11320-329)

EPA Growdwater Protection Strategl

DO 50 590 30

mc R.cuirewents

Sup.rfund offstte policy (EPA 198Th) states that wastes may onLy b. taken to facilities in compliance with their RCEA permit (40 CPR 1300)

The protection strategy doei not include appLicabLe ARAR but does contain policy state- nents to be considered. The strategy includes uideLins on classifying groundwater for EPA decisions affecting ground- water protection and corrective actions. Criteria include ecolog- icai. importano., replaceability, and vulnerability consideration.

Table IV.5. (continued)

R.8ulatory C1tat1or ARARs

C.AA R.quirua.nta includ. Ntion.1 Mi.nt Air Quality Stndazds an new souxcs p.reranc.

tandacd (ø OER %50 md 40 CFR 161)

iationa1. Emii,ion Stand.rdi for Razadotas Air Pollutanta for construction ox modification projects

ISCA PCB oleanup criteria (40 CFR *761)

Federal Reqti±remet,ts Include disposal Insecticide, a storage of p.aticid.- Fngicid., and :.tat.d wastes. (40 CFR $165) Rodanticid. Act (PIFRA)

osaA Rairaa.ts includ. g.n.rsl standards fo worker protection. workers involved in hazardous Wast. operations, PEt, and STEt (29 CZR 11910)

Hazardous Transportation of hazardous Hat.rials at.ria1s (9 CPR 11107. Transportation 171, and 172) Act (MTA)

NERA Envir000.nta1 iipact of federal actions (42 risc 1*4321-4370e)

SD*JA Prohibits federal fdin of projects that, nay contaminate a desi8nated sole-source aquifer. (An aquifer is d.sinated as sole source by the EPA Admini- strator if it is the sole or princip1 drinMng water source for the ares it serves. Contamj- nation of a sol. source aif.r can rezlt in a significant hazard to public health.> EPA Office of Groundwater must review projects with potential ïmpacts. (SDWA 1$1'.24).

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Recuirenents

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Table IV. 6. Potential State Action-Specific ARARs for Cannon AFB

RauLtory Citfttioz ARAR3

Naw M.xico Hazardous Req.ir.cents irc1ud. dsflnitio and Wast. H.naesnt idantification o a b.z.rdcua Wast.: ReuLationa gsn.ration 0E a hazardous wait.;

tranaportatton o a bazardou. wastø. tr.ata,..nt oe a hazardous wait., inclu dicç oniiti and offait. incth.ratioo; tr,atiii.nt oi ccntiiiinatsd gromd.cat.r; atora$ of a has&rdOUs wait., whicb incLudes contain.r and tank require- n.flt3; dispoiel of i aza.rdoui Waite; cp.ratton and iatht.nanc.; and sur- sac. wmt.r contrai.

New lexico SaUd Requtreents include authorized ioiid Waste Regulations Waite diipcaal. ri.thoda, operational

requirewents Cor ictid wait. disposal faciliti.s, and closure r.quireaents.

New Mexico NPDES IncLudes p.nit r.qutresnts. Pernit R.uiations Ne,. Mexico Water R.quireoants incLud. water ass designa- Quality Standards tian and criteria, anttde8radation

pctici. New Nexico General Require.nts include easurec.nt a and MJ.sc.liateous emissions or air contaminants, Air Pollution scheduled aintenanc., reportin and ReguLations malfunction o qui.nt. New Mexico Particulate Maasurenent o anbient air quality Matter Standards and allowabl. wiission standaxds.

New Mexico R.ulations Ambient air quality standards and for carbon monoxide, 5uidetines for antrol of siisions photo-chemically reac- oC organic netarials and carbon tive nat.rials, hydra- monoxide fro stationary sources. carbons, and related materials

New Mexico Regulations Ambient air quality standards. or oxides of nitrogen

New Mexico Regulations for lead

New Mexico Reguistions for Preventjøn of Air pollution Emergency Episodes

New Mexico Regulations on Air Permits to Op erate and Variances

New Mexico Open Burri Regulation

Ambient air quality standards.

Episodes crttaria, air poLlutiot emergency definition, and emission reduction objectives.

Perurit requirements, variances, and operational. requirements.

Definitions, requirements, and proiibitions

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Requirements

RPICAN.

4.2 DATA QUALITY OBJECTIVES

4.2.1 Purtose of DQOs

DQOs are quantitative and qualitative statements specified to ensure that data of known and appropriate quality are obtained during the remedial investigation activities to support the selection of a remedial action alternative. DQOs are selected based on the end uses of the data to be collected. The resulting analytical levels can typically be described as falling into five levels (Table 1) (EPA 1987a). DQOs for all phases of the RFI at Cannon AFE will be determined based on the end uses of the data to be collected. DQOs will also be developed to provide statements on the level of uncertainty that Cannon AFE or EPA Region VI are willing to accept results derived from environmental data. Although the term connotes quality, the DQOs also clarify the objectives of RFI activities. The objectives of the DQO process are to

provide a process for obtaining data of sufficient quality to support decisions regarding corrective measures, to reduce overall costs of sampling and to

analytical activities, and to accelerate project planning and implementation.

4.2.2 DOS Development Process

DQOs will be identified as appropriate for individual sampling events or data collection activities , and will be presented in sampling and analysis plans.

:t: DQOs will be developed through a three-stage process, as illustrated in Figure -_:' 4.1. The DQO process is integrated with development of the sampling and analysis

plans and will be revised, as needed, based upon the results of each data collection activity. This process is outlined below.

4.2.2.1 Stage 1 - Identify Decision Types

Stage i of the DQO process identifies the individuals responsible for decisions, data uses, and available data; determines if additional data is

needed; and identifies the types of decisions which will be made regarding site remediation. Available information on each SWMU at Cannon AFE will be compiled and analyzed to describe suspected sources, contaminant pathways, and potential receptors. Stage 1 results in the specification of the decision making process, identification of why additional data is needed, and sets the foundation for Stages 2 and 3 of the DQO development process as shown in Figure 7.

4.2.2.2 Stage 2 - Identify Data Uses/Needs

Stage 2 specifies the data (quantity/quality) necessary to meet the objectives set in Stage 1. This stage stipulates criteria for determining data adequacy. Stage 2 includes selection of the sampling approaches and the

analytical options used for the site.

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Table 1. St»»mry of Analytical Levels Appropriate to Data Uses

Cii, Un, L= Tt t Sflt¼,. 12".tlt-cr1 Ca_p Cua.tv

Site Cacerizton, Inrurnents rescord to mc(o:ing during natutady occurfu tTuamentatIan compounds

SII. characterization, evauat!aon of alterna- tives, enneerinç desçn monitoring ductng implementation

;sk asessrnent, site cnaracterzation. eai- uacion of alternatives, ençineerin design. monitoring during imoementation

s* assessment. eval- uation of alternatives, ençineerng design

i5l assesrnent

oc - ovneto.ony - arrt aoto,

n. - X-* acea,ce ' - - ,o.a"eu c - Od P"* A Açenc

- Cm.t Lecoy Pren caA - n.ce

rAI. - Tvge Malyt. L

îcl_ - TQe( L ?A ige7

Total organic/inorganic Level I vaoor detection usrg

pertaIe inttuments

Feld test kite

Variety of organica y GC. inorganics by AA, XPF

Level Il

Tentative identification, analyte-soecific

Detection lisnits vary from low ppm to ow OOD

Crgancs/nor;anics usig E?A Drocedures otrter tilart CL? can be analyte-

Level III soec1ic

CRA ciaractenistic tests

l'CL organics/TAL morgan- Lsvel IV ics y CCMS, AA, IC?

Low peo detection' lisTht

Ncnconventionat Le.el V

Parameters

Me tflOd-Weciiic detection limits

Mocification o

existinç mettrcds

00505go 34

Tentative dentifidation

Tectinicues/instnurnents rimited mostly to vclatites, metals

Tentative identification ini same cases

Can rovide data of same quality as Leves IV

Tentative identification of nan-TCL. parameters, Some time maoy e reOuired or validatiOn Of packages.

May require rnetrtod develOc- ment moiftcatiort

Mecntansm to obtain 3ervices requires Special lead time

If instruments Oalibrated and data intereoreted correctly, can provide indication of contamination

Dependent on guality as,surance/guality control steps employed

Cala typicafy reported 1 concentration ranges

Simitr detection ismt$ to CL?

i

Less rigorous quality asaurance/cuaity control

Coal is data of known .puality

Rigorous quaity assurance/ guality control

Me trtcd-sQec tic

RFICAN.

STAGE I

IDENTIFY DECISION TYPES

Id.ntLy and involve data ua.ra

Evaluat. available data

Develop conceptual d.l Specify obJ.ctiv.a/d.cisicn

STASE 2

IDEIIFY DATA USES/NEEDS

Identify data aces

Identify data types

Id.ntiy data quality needs

Identify data quantity needs

Evaluate 3awplinß/anaLysis options

Review PARCC parameters

STAGE 3

DESIGN DATA COLLECTIO4 PRRJM

Assemble data collection coaponents

Develop data collection documentation

Figure 7. D three-staa process

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4.2.2.3 Stage 3 - Design Data Collection Program

Stage 3 specifies how to assemble data collection components and develop data collection documentation. Methods have been specified by which acceptable data will be obtained to make decisions. This information will be provided in the sampling and analysis plans.

4.2.3 Integration of DOOs with the SamDling and Analysis Plan and the Quality Assurance Plan

During Stage 2 of the DQO process, specific DQOs will be developed based on inedia or sample activity. The intent of Stage 3 is to compile the information and DQOs developed for specific tasks into a comprehensive data collection prograni. The output of the DQO process is a well-defined sampling and analysis plan with summary information provided in the work plan. The saipling and analysis plan will identify the individuals responsible and the procedures for field activities and sample analysis.

The DQO process also develops the requirements for assessing the quality of any data in the RFI program and determines data acceptability according to the RFI requirements. This review is the process of data acceptance and will be addressed in the Data Collection Plan.

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5. RCRA FACILITY INVESTIGATION TASKS

The RFI process at each SWMU also involves the identification of the tasks that will be performed. These include the tasks identified in the Data Collection Quality Assurance Plan (QAP), in the Field Sampling Plan (FSP), and the tasks tentatively identified to be conducted after site characterization. The following sections describe standard work plan tasks. These tasks are only briefly described here since most will be documented in the SWMU-specific plans, as appropriate.

The following are some specific comments applicable to the tasks described in subsequent sections of this Program Management Plan:

- All standard tasks or all work activities under each task need not be used for every SWMtJ. Only those that are relevant to a given SWMTJ will be used.

- Tasks include both draft and final versions of deliverables unless otherwise noted.

- Because this RFI concerns individual SWHTJs, most SWMUs will be monitored and reported separately. However, whenever it is iot

possible to differentiate SWMU locations or functions, a common analysis will be performed.

Task 1. Project Planning

This task includes efforts related to initiating the RFI as directed by the regulatory agency. The project planning task is defined as complete when this RFI Management Plan and supplemental plans are approved (in whole or in part). The following typical elements are included in this task:

Site visit/meeting.

A site visit will be performed at the start of RFI/SWMU work plan document preparation. The purpose of these visits will be to interview Cannon AFB personnel, obtain additional data/information, and visually assess the SWMUs.

- Obtaining easements/permits/site access.

It will be necessary to obtain permits for contractor work and site access at Cannon AFS. This will include obtaining vehicle passes, digging/excavation (utilities clearance) permits, and Cannon AFB health and safety training for contractors. Arrangements for these permits, monitoring, and training will be made with the appropriate Cannon AFB personnel at least one week before field work is

performed. The SM1J-specific work plans will detail Cannon AFE personnel to be contacted concerning these activities and give a

rough schedule as to when they will be performed.

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- Site reconnaissance and liniited field investigation. Field investigations will be necessary to facilitate project scop Ing.

- Site survey/review of topographic maps and existing aerial photographs.

Existing site maps and photographs will be reviewed during the preparation of SWHU-specific work plans. Additional maps will be prepared with these documents, as necessary.

- Collection and evaluation of existing data. The existing data have been briefly summarized in this Plan. The data will be -presented more extensively in the SWNIJ-specific plans.

- Identification of data needs and DQOs.

The DQOs and data needs for the RFI have been identified on a generic, facility-wide basis and are presented in section 4 of this Plan. These will be expanded/refined in each of the SWMU-specífic work plans.

- Preparation of supplemental plans (e.g. HSP, QAP, DMP, CR2 and FSP)

:;5 Preparation of supplemental plans, such as the liSp, the FSP, and the ,,. QAP, may be tiered to the facility-wide plans presented here.

- Initiation of subcontract procurement.

Subcontractors will be used to perform several portions of the RFI, including the field work (such as drilling) and the laboratory analyses. A search for subcontractors for work at each of the SWMUs will be initiated as soon as the SOW is approved.

- Initiation of coordination with analytical laboratories. Coordination with the analytical laboratories will be initiated when specific documents are submitted to EPA.

- Task management.

Task management is described in Section 8 of this plan.

Task 2. Community Relations

This task incorporates all efforts related to the preparation and implementation of the community relations plan for the Site and is initiated during the scoping process. It includes time expended by both technical and community relations personnel. The following are typical elements included in this task:

- Preparing a community relations plan.

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- Preparing fact sheets.

- Implementing community relations.

A facility-wide community relations plan has been prepared by Cannon AFB and is included as a companion document to this Plan.

Task 3, Field Investigation

This task involves efforts related to field work in conducting the RFI. It includes the procurement of subcontractors related to field efforts, The task begins when any element, as outlined in the work plan, is approved (in whole or in part) and field work is authorized. Field investigation is defined as complete when the contractor and subcontractors are demobilized from the field. The following activities are typically included in this task:

- Procurement of subcontracts.

- Mobilization

- Media sampling.

- Source testing.

.'-:' Geology/hydrogeological investigations.

- Geophysics.

- Site survey/topographic mapping (if not performed in project planning task).

- Field screening/analyses.

- Procurement of subcontractors.

- RFI waste disposal.

- Task management and quality control.

Field investigations will be performed according to the F5?. Investigations will be performed according to Standard Operating Procedures (SOPs). The SOPs applicable to Cannon AFB field activities are given in the QAP .

Task 4. Sample Analysis/Validation

This task includes efforts relating to the analysis and validation of samples after they leave the field. Separate monitoring of support laboratories may be required. Any efforts associated with laboratory procurement are also

O5O59O 39

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included in this task. The task ends on the date that data validation is

complete. The following typical activities are usually included in this task:

- Sample management.

- Use of mobile laboratories.

- Testing of physical parameters.

- Data validation.

- Task management and quality control.

Procedures and specifications for sample analysis and validation are given in the QAP. For analytes included in the CLP, this includes detection limits, precision, accuracy, and recovery limits. For analytes not addressed by this program, analytical parameters will be established according to industry standards. If additional analytes are added at a later date, the analytical parameters will be addressed in the SWMU-specific QAPs.

Task 5. Data Evaluation

This task includes efforts related to the analysis of data once it has been verified that the data are of acceptable accuracy and precision. The task begins

: on the date that the first set of validated data is received by the project team

-. --.. and ends during preparation of the PII report when it is deemed that no additional data are required. The following are typical activities:

- Data evaluation.

- Data reduction and tabulation.

- Task management and quality control.

- Task management responsibilities (discussed in Section 8, Project Management, of this Plan).

- Quality control procedures are specified in the facility-wide QAP and will also be addressed in any specific QAP.

Task 6. Assessment of Risks

This task includes work to assess the potential human health and environmental risks associated with the site. Work will begin during the site visit and will be completed once the baseline risk assessment is completed. The following are typical activities:

- Identification of contaminants of concern (or indicator chemicals).

- Exposure assessment (including any modeling performed specifically

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for this function).

- Toxicity assessment.

- Risk characterization.

- Task management and quality control.

Task 7. Reiorts

This task covers all efforts related to the preparation of the findings once the data have been evaluated under Tasks 5 and 6. The task covers all draft and final RFI reports as well as task management and quality control. The task ends when the last PSI document is approved by EPA. The following are typical activities.

- Preparation of a preliminary site characterization summary.

- Data presentation (formatting tables, preparing graphics).

- Writing the report.

- Reviewing and providing quality control efforts.

Printing and providing quality control efforts.

- Holding review meetings.

- Revising the report on the basis of agency comments.

- Providing task management and control.

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6. FUNDING SOURCE, AUTHORITIES, MD RESTRICTIONS

The Air Force has a 5-year budget cycle which governs the allocation of operations and maintenance (O & M) funds. The Air Force provides input to the Department of Defense which, in turn, provides input to Congress. Congress distributes a litnited funding base so not all desirable activities will necessarily be fully funded in any given fiscal year. Notwithstanding the availability of funds, any Federal Facilities Agreements that may influence this RCRA Facility Investigation can not contain provisions that represent a commitment of funding beyond that authorized under current public law.

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7. SCHEDULE OF INVESTIGATION

The activities discussed in this Program Management Plan for the sites

listed in Table 1.1 will occur from approximately October 1990 through September 1992 (Figure 1.2).

DOO59O 43

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CAN .PI4P

Task

Duration

1990

1991

1992

Name

(Days)

O

N

C)

J

F

N

A

H

J

J

A

S

O

N

D

J

F

H

A

H

J

J

A

S

O

FieLd SaiipL Ing

Sançte AnaLysis

i

Sa«te A

naLysis

VaLidation

Data Interpretation

RFI Report

CIlS

i

FIGURE 1.2. CANNON AFB RCRA SITES BASELINE SCHEDULE

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8. PROJECT MANAGEIOENT

8.1 Program Responsibility

The installation commander has ultimate responsibility for the conduct of all RCRA programs at Cannon AFB.

Daily management of RCRA activities is vested in the 27 CSG/DEV section of Civil Engineering. These are the responsibility of Mr. Jim Richards, Chief, Environmental Planning. The specific work to be performed to fully characterize the various SWMUs will be performed under contract with a qualified firm. This firm will be responsible for acquiring laboratory services from a laboratory qualified under the EPA Certified Laboratory Program (CLP) . All contractor and subcontractor personnel will be responsible for complying with the technical provisions of the Cannon AFB PSI Work Plan which consists of:

- Project Management Plan

- Site-Wide Quality Assurance Plan

- Data Management Plan

:::: Health and Safety Plan

.-

Field Sampling Plan

- Community Relations Plan

8.1.1 Technical Approach

8.1.1.1 Policy

The policy of the Air Force is to achieve and maintain compliance with applicable HSWA regulations. This includes investigation of potential environmental Contamination and implementing corrective measures as necessary and appropriate.

8.1.1.2 Solid Waste Management Units

Potential release sites at Cannon APR include areas with a range of potential contaminants including metals, volatile and semivolatile organic chemicals, pesticides, and PCBs. Not all of these are expected in any one SWMU.

The specific differences between the SWMTJs include the type of contamination, the location of the potential release site, and the potential threat to human health and the environment.

0050590 45

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The technical approach of this Project Managemett plan has been to include appropriate technologies for site

characterizations protection of health and safety, and obtaining valid data for determining if corrective measures are required.

8.2 COORDINATION

8 .2.1 Organizational

Several organizations or entities have direct responsibilities for the investigation activities at the various SWMUs. The organizational relationships are shown in Figure 8, and their functions are described below.

HO TAC. Headquarters, Tactical Air Command is responsible for the conduct of environmental programs at each of the Coands installations. This includes administrative, policy, and funding issues.

Cannon AFB. Cannon AFB is responsible for sound environmental management of hazardous waste and compliance with appropriate regulations and guidelines. By direction, the Installation Commander (27 CSC/CC) is the responsible individual. Program management responsibility for the RFI is delegated to the Chief, Environmental Planning Section (27 CSG/DEV). The 27 CSG/LCC (Contracts Branch) has administrative control and responsibility for the contractor who will conduct

the RFI field investigation. Technical oversight of the contractor is delegated the 27 CSG/DEV who acts as the Contracting Officer's Representative (COR).

. The Medical Group/SCPB and 27 CSC/SE provide health and safety oversight to the COR before and during contract performance.

Contractor. The contractor is to perform work as designated in accordance with the approved RFI work plan and as directed by the Contracting Officer. The contractor is also responsible for obtaining subcontractor laboratory support from a laboratory participating in the EPA CLP. All contractors are responsible for coniplying with the Site-wide Quality Assurance Plan, internal QA/QC plans, and the EPA CLP Statement of Work.

Do5asga 46

27 CSG/LCC (CONTRACTS)

HQ TAC

CANNON AFB 27 CSG/CC

27 csc,'ogv

(COR)

CONTRACTOR

LAB i LAB 2

SGPB

( HEALTh)

Figure 8. Organizational Relationships

00590 47

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27 CSG/SE (SAFETY)

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8.2.2 Project File Reujrements

Explicit data collection, management, and reporting requirements are covered in separate documents. However, in general, these requirements apply to this RFI:

All raw data, s.tch as laboratory reports, drilling logs, bench-scale or pilot-scale data, and other supporting information gathered or generated during activities undertaken pursuant to this RFI shall be maintained at Cannon AFB during the term of this Permit, including any reissued Periits.

An outline of project file requirements is as follows.

Communications

Internal External

Quality assurance/quality control

Procedures Tracking

-. Audit reports Deviation notification

Technical information

Analytical data Field data Graphic resources Data quality acceptance Calculations/evaluations Regulatory compliance

Management

Schedule Budget Release site database

Health and Safety

Plans/procedures Audit reports Documents Plans Reports

References

D050590 48

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8.2.4 Prozress Reporttnz Recjuirements

The RFI contractor will develop reports of progress for presentation at monthly status review meetings. These monthly reports include

activities in the preceding month for each S(U including status of docunients, including plans or reports delivered; ongoing field activities; laboratory work in progress; laboratory reports delivered; arid

ongoing studies

activities due in the forthcoming month for each SWMU including status of document, including plans or reports to be delivered; due dates for regulatory review comments; ongoing field activities or planned start-up; laboratory work in progress; laboratory reports to be delivered; ongoing studies or planned start-up; and

- problem areas.

In addition to the record of the SWMTJ status, the RFI contractor will iaintain a monthly conpendium of significant contacts and events during the preceding month including

- records of telephone conversations, - summaries of public meetings. - quality assurance audit reports and responses, and - notification logs for deviations from RFI plans.

The deviation notification log is presented in Figure 8.2.

Activities during this RFI could cause other reporting requirements which shall be observed as evidence of regulatory compliance. These requirements are summarized below:

Facility Submission Requirements

Notification of newly-identified SWMUs

Notification of newly-discovered releases

SWMU Assessment Plan for newly- identified SWtUs

Due Date

fifteen (15) calendar days after discovery

fifteen (15) calendar days after discovery

ninety (90) calendar days after receipt of request

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Facility Submission Requirements Due Date

Revised SNU Assessment Plan as determined

SWMU Assessment Report sixty (60) calendar days after completion of Implementation of SWMU Assessment Plan

Revised RFI Workplan as determined by Administrative Authority usually within 30 days of receipt of NOD

RFI Report and Summary Report sixty (60) calendar days after completion of RFI

Revised RFI Report and Summary thirty (30) calendar days after notification of deficiency

Interim Measures Plan for interim thirty (30) calendar days measures required after permit after notification

!

issuance

Interim Measure Plan as determined

CMS Plan ninety (90) calendar days after notification of requirement to perform CMS

Revised CMS Plan as determined

cMs Report sixty (GO) calendar days after completion of CMS

Revised CMS Report thirty (30) calendar days after notification of deficiency

DOO59O 50

DEVIATION NOTIFICATION LOG

DOCUMENT/PLAN/SOP:

SE CIlO N:

DEVIATION ORIGINATED BY:

PERSONS CONTACTED:

DATE

DESCREE PLANNED DEVIATION AND EXPLAIN JUSTIFICATION FOR DEVIATION

ORIGINATORS SIGNATURE

DISTRIBUTION:

D90

PROJECT DIRECTOR PROJECT MANAGER SIrE MANAGER

DATE

QUALITY ASSURANCE MANAGER PROJECT FILE OTHER

Figure 8.2. Deviation notification log.

51

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8.3. STAFFING

The following is a description of the qualifications of personnel directing the RFI at Cannon AFB.

Jim Richards Chief, Environmental Planning (27 CSG/DEV) USAS BS, Agricultural Economics (Water Resources) Years of Professional Responsibility: Program Responsibility: Program Management

Rick Crow Environmental Coordinator (27 CSC/DEV) USAS BS, Agricultural Business Years of Professional Responsibility: Program Responsibility: Program Support/Management

Contractor Personnel To Be Determined

Subcontractor (Laboratory) To Be Determined

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ADMINISTRATIVE RECORD

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ADMINISTRATIVE RECORD

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