GFI Atch for Bidders Inquiry 8319919 JBSA-FSH LF Insp TM 2018 Final.pdf

Memorandum

Brookhollow Park 911 Central Park North, Suite 425 San Antonio, TX 78232

USA

+ 01.210.494.0088 amy.wolff@jacobs.comwww.jacobs.com

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Subject

Version

Attention

From

Date

Contract No.

2018 Annual Site Inspections for Landfill Sites LF001 (FTSH-30), LF002 (FTSH-29), and LF003 (FTSH-26) at Joint Base San Antonio – Fort Sam Houston (JBSA-FSH), TX

Final

Air Force Civil Engineer Center (AFCEC)

CAPE Team

September 26, 2018

FA8903-09-D-8556, Task Order (TO) 0004

1. Introduction

The CAPE Team completed the 2018 annual site inspections at three landfill (LF) sites located at Joint Base San Antonio – Fort Sam Houston (JBSA-FSH) on June 26-27, 2018. Annual inspections are required for these sites as part of the approved regulatory closure requirements and to maintain institutional controls that are in place at each respective site. Table 1 summarizes the individual subset of landfill sites comprising each LF site. Figure 1 provides an aerial view of the locations of these landfill sites at JBSA-FSH. This technical memorandum (TM) summarizes the 2018 annual landfill site inspections completed as part of the JBSA Performance-based Remediation contract. In addition, results from the inspection are also used to evaluate the continued protectiveness of the remedy. A summary is provided within the conclusions at the end of the document.

In a letter dated September 25, 2013 (Attachment 1), the Texas Commission on Environmental Quality (TCEQ) approved a modification to the schedule for submitting the Post Response Action Care Reports (PRACRs) for Sites LF001, LF002, and LF003 (TCEQ, 2013). Based on TCEQ’s letter, the frequency for submitting the PRACR to the TCEQ for these sites changed from every 3 years to every 5 years. A PRACR encompassing the results from five annual inspections completed from 2012 through 2016 was submitted in March 2016. Results from the 2018 inspections documented in this TM need to be submitted to the TCEQ in the next PRACR in 2021.

According to the TCEQ, in response to the Affected Property Assessment Report (APAR; Shaw, 2005), annual inspections document that capped landfill wastes are managed in a manner that does not cause the discharge or imminent threat of discharge of waste into or adjacent to waters of the state. The objectives of the annual site inspections, as defined by the Response Action Plan (RAP; Shaw, 2006), Response Action Completion Report (RACR; Shaw, 2008a), and subsequent approvals by the TCEQ are as follows:

• Document the condition of in-place erosion control measures (ECMs), landfill cover integrity, and current land use.

Table 1. Sites and Landfills included in TO 0004 Site (Alias) Landfill (LF)

LF001 (FTSH – 30) LF2, LF3, LF4B, and LF5

LF002 (FTSH – 29) LF4A, LF6, and LF7

LF003 (FTSH – 26) LF8B (alias XE015)

2018 Annual Site Inspections for Landfill Sites LF001 (FTSH-30), LF002 (FTSH-29), and LF003 (FTSH-26) at Joint Base San Antonio – Fort Sam Houston (JBSA-FSH), TX

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• Inspect institutional controls such as signage is properly displayed for each unit, where applicable;

and fencing is secured and locked, where applicable.

2. Site Background

JBSA-FSH comprises approximately 2,935 acres of land in Bexar County, Texas. It is situated entirely within the city limits of San Antonio, Texas, and is located approximately 2.5 miles northeast of the downtown area. The installation has several missions organized around five functions: headquarters, logistics, garrison, mobilization, and medical support.

Following are brief background summaries for each landfill site included in this inspection report.

2.1 LF001 (FTSH-30)

The location of Site LF001 (LF2, LF3, LF4B, and LF5), including the boundaries of the four associated landfills, is shown on Figure 2. Portions of the site previously designated as LF2 and LF3 were in operation from 1954 to 1979. They are located adjacent to one another between Salado Creek and Pershing Road. LF5 was in operation from the mid-1950s through 1975; LF4B was in operation from 1960 to 1975 and is located between LF5 and the JBSA-FSH golf course north of Pershing Road and south of Salado Creek. The burial methods used during landfill operations for these units were reportedly trench and fill (Shaw, 2005). Material reportedly buried in the landfills included domestic waste, construction debris, and medical waste.

A response action was previously implemented to minimize surface runoff and exposure to landfill debris.

It included debris removal, clearing, re-grading, placement of soil cover and topsoil, and installation of ECMs. Periodic flooding from nearby Salado Creek eroded the northern flanks of LF2 and LF3. Geotextile and riprap were installed to minimize further erosion in this area (Shaw, 2008b; Figure 2). Permanent erosion-control matting was also placed along slopes of the drainage swales located between LF2 and LF5. Warning signs were installed along the edge of the golf course and LF4B.

2.2 LF002 (FTSH–29)

Site LF002 includes LF4A, LF6, and LF7. Each landfill is spatially separated (Figure 3). Based on previous investigations, each of the three landfills associated with this site is believed to contain domestic and construction debris (Shaw, 2005).

LF4A is located on the north side of Salado Creek, and within the eastern portion of the JBSA-FSH golf course. A portion of the golf course overlaps onto the landfill. An area-fill disposal method was reportedly used at LF4A from approximately 1960 until the landfill was closed in 1975.

LF6 is located east of Garden Avenue, west of Salado Creek, and primarily south of Binz-Engleman Road in the southeastern portion of JBSA-FSH. A medical waste incinerator was formerly located on the northwest corner of LF6 where Schofield Road crosses the northern end of the landfill boundary. The landfill was reportedly opened before 1954 and was closed after 1973. The trench-and-fill landfill contains debris reportedly consisting of primarily domestic waste and possibly medical waste. About one-fifth of the landfill area lies beneath a parking lot.

LF7 is located south of LF6, east of Garden Avenue, and west of the Union Pacific Railroad line that forms the Post boundary. A relatively deep drainage divide separates LF7 from LF6. LF7 contains primarily construction debris from operations that took place from the 1950s until 1979. Debris consisting of roofing shingles and concrete was previously exposed by erosion at the eastern end of LF7, near Salado Creek.

The response action for LF7 included re-grading existing cover material followed by placement of additional soil cover and topsoil. L4A and LF6 had intact soil covers and no apparent erosional features according to the RACR (Shaw, 2008a). LF7 had a few areas of exposed landfill debris. During the

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response action, additional soil was brought onto the site and regraded such that landfill debris remaining in place was not exposed at the ground surface. Geotextile and riprap were also placed along sloped areas adjacent to Salado Creek to protect the landfill flank from eroding during flood events (Figure 3).

The site was then hydro-mulched and restored with native vegetation.

2.3 LF003 (FTSH-26)

The location of LF003 (LF8B) is shown on Figure 4. The LF003 designation also includes LF8A, LF10, and LF12 (SAIC, 2013); however, only LF8B is included in the Statement of Objectives (SOO) for this task order. The Enterprise Environmental, Safety, and Occupational Health – Management Information System also identifies LF8B as “Site XE015” under the Military Munitions Response Program (SAIC, 2013). For consistency with the SOO for this project, LF003 is referred to as LF8B in this TM. The site was originally used as a firing range in the 1960s and early 1970s. Subsequent to this, it was also used as a landfill for construction debris, and potentially, both detonated and unexploded ordnance (UXO) in the early and mid-1970s (TCEQ, 2006b).

Response actions completed at LF8B include debris removal, clearing, placement of additional soil cover, and regrading. Drainage patterns associated with a surface depression in the south-central portion of LF8B were also modified to promote positive drainage and decrease the potential for ponded water to accumulate. In combination, these actions reduced potential infiltration from precipitation and surface runoff. Native grasses were planted as an additional ECM following improvements to the soil cover.

Signage was installed at regular intervals along the surrounding perimeter fence. LF8B is designated as a waste control unit containing construction debris, exploded ordnance, and UXO. The site is not affected by flooding associated with Salado Creek.

3. Regulatory Status

Post-wide site investigations were initiated for landfill sites in the 1990s. Initial investigations evaluated landfill site status and developed baseline information (EA, 1996), such as onsite ground inspection, personnel interviews, interpretation of aerial photos and review of archived reports, collection of surface soil and surface water samples, geophysical surveying, and drilling of soil borings/installation of monitoring wells for the collection of subsurface soil samples and groundwater samples for analyses.

Preliminary Assessments/Site Inspections (PA/SIs) that were subsequently completed identified potential threats to human health and the environment (Weston, 1998). An APAR was completed that evaluated the individual landfills comprising Sites LF001, LF002, and LF003 (Shaw, 2005).

Groundwater was the only medium evaluated in the APAR. Buried and capped waste was not evaluated since the soil column below the waste was assumed to exceed the concentration levels that are protective of human health and the environment (Shaw, 2006). Thus, the soil is considered a protective concentration level exceedance zone. Results from the site investigations suggested that chemicals of concern (COCs) in groundwater posed no significant present or future risk to humans or the environment based on commercial/industrial (C/I) land use. The sites met the requirements for Texas Risk Reduction Program (TRRP) Remedy Standard B C/I land use. The APAR was approved by TCEQ in 2006 (TCEQ, 2006a).

A RAP (Shaw, 2006) was then developed based on TCEQ’s comments regarding the APAR. ECMs, land use controls (LUCs), groundwater monitoring, and a long-term landfill management plan were developed and implemented on a site-by-site basis as part of the RAP (Shaw, 2006). Following approval of the RAP (TCEQ, 2006b), quarterly groundwater monitoring was conducted in 2007 that demonstrated stable concentration trends were present at each landfill. TCEQ approved the discontinuation of groundwater and surface water sampling as part of post-response action care requirements (TCEQ, 2008). All monitoring wells at the sites were subsequently plugged and abandoned. Completion of the response actions were documented in the RACR (Shaw, 2008a).

Once the RACR was approved, the sites entered the post-response action care period. Ongoing post-closure requirements included annual site inspections, maintenance, and submittal of PRACRs. Prior to

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2013, the PRACRs were prepared and submitted to the TCEQ on a 3-year reporting schedule. Based on approval provided by TCEQ in a letter dated September 25, 2013 (TCEQ, 2013; Attachment 1), the frequency for submitting the PRACRs was revised to a 5-year schedule. Accordingly, the last PRACR for these three landfill sites was submitted to TCEQ in 2016. The next PRACR is scheduled to be submitted to TCEQ in 2021.

4. Site Inspections

4.1 Inspection Procedures

The site inspection process for Sites LF001, LF002, and LF003 included noting the condition of the landfill cover, changes in land-use, encroachment, access control with signage in some areas, as needed, and/or potential unauthorized dumping. Inspections were completed by a two-person team that walked each of the sites. Photographs and inspection checklists were used to document the conditions observed at the sites.

4.2 Inspection Findings

The CAPE Team inspected Sites LF001, LF002, and LF003 on June 26-27, 2018. Photographs are provided in Attachment 2 with the location of each photo marked on Figures 2, 3, and 4, as applicable.

Inspection checklists documenting site conditions are provided in Attachment 3. The following sections summarize the conditions noted at each of the landfill sites.

4.2.1 LF001 (FTSH–30)

Site LF001 consists of LF2, LF3, LF4B, and LF5 (Figure 2). These four landfills are located immediately adjacent to one another in the north-central portion of JBSA-FSH. The following sections summarize the results of the annual inspection of the individual landfills comprising Site LF001.

4.2.1.1 LF2, LF3, and LF5

The Medical Education and Training Campus (METC) Outdoor Fitness and Training Complex was constructed across portions of LF2, LF3, and LF5 (Figure 2 and Attachment 2, Photos 1 through 18). The METC Outdoor Fitness and Training Complex consists of four athletic fields with surrounding bleachers, parking areas, facilities building, and an asphalt path around the perimeter of the fields (Photos 1, 2, 7, 13, 17, and 18). Prior to construction of the athletic fields, approximately 8 to 12 feet of soil was placed over the existing landfill cover in 2010 to level the site (Shaw, 2011). Construction of the METC Outdoor Fitness and Training Complex began in 2011 and was completed prior to the July 2014 inspection (CAPE Team, 2014).

The conditions of the landfills and areas comprising the METC Outdoor Fitness and Training Complex during the June 2018 inspections appeared similar to those noted during the annual landfill inspections since July 2014 (CAPE Team, 2014; 2015; 2016; 2017). Landfill areas surrounding the METC Outdoor Fitness and Training Complex are characterized by various native grasses, shrubs, and trees (Photos 3, 6, and 10). Riprap, installed as part of the response action, remains along the northern slope of LF2 and LF3 adjacent to Salado Creek. The riprap serves as an ECM that limits potential impacts from flooding and erosion. During the inspection, the riprap was intact and providing slope stability (Photo 9). Newly installed fencing was observed along the northern boundary of LF2 and LF3, and along the western boundary of LF5 (Photos 9 and 14, respectively). The damaged fencing and the remains of orange construction fencing observed in previous inspections were still in place in the eastern portion of LF3 (Photo 8). Stockpiled sand and silt fencing remained in place near the southwestern boundary of LF5 (Photo 15). The concrete gabion located in the southwest corner of LF5 was still in place during the inspection (Photo 16).

A drainage swale is located at the northern boundary between LF2 and LF5. Drainage outfalls and a concrete gabion that appears to be a component of the permanent stormwater management structure are

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present near the southern (top) portion of the swale (Photo 6). A large portion of the swale was covered in dense vegetation to provide stability and prevent erosion along the swale. Visible erosion control matting was observed along the slope of the swale in the northwestern portion of LF2, which is being used as an equestrian trail (Photos 4 and 5). Although the matting to support grass growth was partially visible along the trail, there was no evidence of exposed landfill debris or substantial erosion. Additionally, an old concrete post, small debris (such as aluminum cans), and rocks were observed near the bottom of the trail (Photo 5). The small debris appears to be flood-related debris from the creek and is not considered evidence of dumping. The rocks observed toward the bottom of the trail are providing stability to the area.

Repairs are not considered necessary at this time and the area will be monitored during the next inspection.

Drainage outfalls that help convey surface runoff away from the athletic fields in the northern areas of the landfills were observed during the 2018 inspection (Photos 6 and 12). The discharge outlets were clear of debris and were functioning as intended. The engineered drainage in the northern portion of LF5 noted since the 2014 inspection (CAPE Team, 2014) was intact. No significant changes to the drainage feature, including the piece of small debris observed in the drainage channel, were documented during the 2018 inspection (Photos 10 and 11). The debris was not interpreted as landfill material. The existing vegetation is providing stability to the soil cover and preventing erosion from run-off. No exposed landfill debris was encountered at LF2, LF3, and LF5.

4.2.1.2 LF4B

LF4B is located along the active JBSA-FSH golf course and shares a boundary with LF5 (Figure 2 and Attachment 2, Photos 19 through 25). A large portion of LF4B is used as part of the JBSA-FSH golf course and is maintained by golf course personnel (Photos 19 and 23). Thinning vegetation and bare soil were noted along portions of the golf course (Photos 21, 22, 24, and 25). The sparsely vegetated areas appeared to be a result of frequent use of by golf carts on non-paved portions of the course; however, in addition to the small posts observed during the 2017 inspection to divert cart traffic from these areas, newly installed posts and ropes were observed during the 2018 inspection (21, 24, and 25). The remainder of LF4B is characterized by trees and dense vegetation that appears to provide soil stability and limits the potential for erosion (Photo 20). There was limited access to the densely vegetated area during the inspection; however, there was no indication that conditions observed during the 2017 LF4B inspection had changed. One sign along the eastern boundary of the golf course warning against entering LF5 from LF4B was observed. The remaining signage was not observed due to the dense vegetation. No exposed landfill material was identified at LF4B during the 2018 inspection.

4.2.2 LF002 (FTSH–29)

Site LF002 consists of landfills LF4A, LF6, and LF7 (Figure 3). Each is spatially separated from the other.

4.2.2.1 LF4A

LF4A is located just north of Site LF001 along the JBSA-FSH golf course (Figure 3 and Attachment 2, Photos 26 through 38). A majority of the landfill is covered with grass, shrubs, and trees and, to a lesser extent, the active JBSA-FSH golf course (Photo 29). A pump station is present on the southwestern side of the landfill (Photo 26). The large black tank and backup generator, noted annually since the 2015 inspection, were in place during the 2018 inspection. The area where ponded water was observed in front of the pump station during the 2017 inspection, due to a leaking pipe according to JBSA-FSH staff, was dry (Photo 26).

During the 2015 inspection, a large area of subsidence was observed in between the southeastern side of the pump station and the creek. The subsidence was not visible during the 2017 and 2018 inspections due to overgrown vegetation (Photo 27). Although the area beyond the vegetation could not be visually observed, the vegetation likely provides additional stability to prevent further erosion. ECMs in place along the northern side of the pump station were intact (Photo 28). Exposed landfill debris was not encountered in this area during the inspection. The area will continue to be monitored during future inspections to confirm that conditions remain stable.

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A small area of thinning vegetation and exposed soil was observed along the boundary between the golf course and the landfill (Photo 29); it appears the thinning vegetation has resulted from the area being repeatedly used as a cart path. No impact to the landfill cover was observed; however, JBSA-FSH should consider installing barriers to divert cart traffic away from this area.

Access and visibility was limited in portions of the landfill due to dense vegetation that may be providing stability to the landfill (Photo 31, 36, and 38). During the 2016 inspection it was noted that the southeastern portion of the concrete drainage pathway to the creek at LF4A had collapsed. There was limited visibility of the collapsed portion of the drainage pathway during the 2017 inspection and no visibility during the 2018 inspection due to dense vegetation and fallen trees limbs (Photo 30). The current condition of the drainage pathway is unknown, but the vegetation may be providing slope stability to the collapsed portion of the pathway. Erosion was observed along slopes leading downwards to the creek (Photos 32, 33, and 35). Although visibility was limited due to vegetation, no landfill debris was observed in these areas. Continued monitoring of these locations is recommended.

A large piece of metal debris was observed near one of the slopes during the landfill inspection (Photo 34). The metal debris was not interpreted as landfill material. A pile of discarded aluminum cans and other small debris were observed in the vegetated area of LF4A during the inspection (Photo 37). The small debris was not interpreted as landfill material; however, due to the location of the small debris and proximity of the items to one another, the debris may be indicative of littering. JBSA-FSH may want to consider monitoring the area for trespassers.

4.2.2.2 LF6

LF6 is located southwest of LF4A and directly north of LF7 (Figure 3 and Attachment 2, Photos 39 through 50). A parking lot (approximately 4.7 acres) is constructed across the western portion of LF6. The parking lot is used by facility workers and military personnel associated with the Warrior in Transition building (Photo 39). The parking lot was constructed on top of the existing landfill cover and provides an additional barrier to erosion and/or infiltration of surface runoff.

ECMs near the parking lot include riprap and gabions that are in place to mitigate potential erosion that could result from surface runoff (Photos 40 and 50). Construction materials that appear to be related to the installation of a small-diameter polyvinyl chloride pipe were observed near the riprap adjacent to the southeast corner of the parking lot (Photo 41). It appeared that a small quantity of riprap may have been moved during construction; however, no exposed landfill debris was observed in this area. Storage sheds observed during the 2017 inspection were still staged in the southeast corner of the parking lot (Photo 42). There was limited access to the eastern portion of LF6 due to dense vegetation consisting of native grasses, shrubs, and trees (Photos 43 and 44). The dense vegetation is providing stability to the landfill cover.

Construction activities observed in the eastern portion of the landfill included work on the overhead power lines and a newly installed fence in the eastern area of the landfill. Silt fencing was observed along the cleared area where the power lines are located (Photo 44). The riprap near the bridge was intact and functioning as intended (Photo 46). A fence was installed along the road near the creek in the northeastern area of the landfill (Photo 47). The previously noted construction appeared to be complete and there was no indication that these activities impacted the landfill cover.

The erosional rill located south of Schofield Road was in similar condition to that observed in the during the 2017 inspection (Photo 45). Exposed landfill material was not observed in the rill and the downcutting did not appear to impact the landfill cover. The drainage culverts were clear of debris and functioning as intended (Photo 48). Two posts with a wire-attached board documented since the 2015 inspection near the northeast corner of the parking lot were still in place (Photo 49). A sign is not attached to the posts and the purpose of the board is unknown. Exposed landfill material was not observed at LF6 and the vegetative cover and ECMs appear to be functioning as intended.

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4.2.2.3 LF7

LF7 is located immediately south of LF6 (Figure 3). The photos in Attachment 2 (Photos 51 through 62) present conditions observed at LF7 during the inspection. The drainage between LF6 and LF7 which appears to convey surface runoff from a large portion of JBSA-FSH into Salado Creek is not within the boundary of either site. The inspection team coordinated with the JBSA-FSH Restoration Program Manager to obtain access to LF7.

Upon entering LF7, sand stockpiles and an abandoned guard station were observed near the entrance to LF7 (Photos 51 and 52). The silt fencing, concrete traffic barricades, and concrete cylinders noted since the 2015 inspection remain onsite near the entrance gate (Photos 53 and 54).

Large portions of the southern area of the landfill where large piles of debris primarily consisting of brick have been observed since the 2015 inspection could not be accessed during the 2018 inspection due to dense vegetation (Photo 55). The thick vegetation provided limited visibility to stockpiles in the eastern area of LF7 where construction debris, asphalt, and railroad ties have been observed since the 2012 inspection (Photo 56). This debris was not interpreted as landfill material and remains consistent with findings from previous inspections. The vegetative cover at LF7 appears to be inhibiting erosion.

A cleared area along the power lines toward the southeast in the eastern area of the landfill was observed during the 2018 inspection (Photo 57). The riprap installed in the northeastern portion of the site near Salado Creek remains intact (Photo 58). The remains of weathered silt fencing located near the path on the eastern side of LF7 remains in place (Photos 59). The silt fencing may have been historically used as part of surface water pollution prevention procedures during the original landfill repairs and were not intended to be permanent structures. The end of the fence line between the southeastern portion of LF7 and the railroad tracks was observed (Photo 60). The fence was likely removed as part of the above-ground clearing necessary to facilitate access to the overhead power lines. JBSA-FSH may want to consider replacing the fence because it represents the southeastern boundary of the installation. Rocks and small construction debris were observed north of the fence line (Photo 61). Washout under the rock material was noted; however, no impact to the landfill cover was observed. Signage was intact on the LF7 entry gate and the gate was locked upon departure (Photo 62). No indications of exposed landfill debris were observed at LF7.

4.2.3 LF003 (FTSH–26)

LF003 comprises LF8B (Figure 4 and Attachment 2, Photos 63 through 78). An 8-foot-tall chain-link fence with regularly spaced warning signs surrounds the perimeter of Site LF003. The entrance gate to LF8B is located south of the CPS Energy Holbrook Station gate at the intersection of Holbrook Road and Petroleum Drive. To gain access into LF8B, the CAPE Team coordinated with CPS Energy to open the Holbrook Station gate. The inspection team included the CAPE Team’s Senior UXO technician, who provided UXO avoidance support during the landfill inspection. As observed during previous inspections, the entrance gate to LF8B was not locked upon arrival to the site. Although the actual gate to LF8B was not locked, the area is secure based on the limited access afforded by the Holbrook Station gate maintained (secured and locked) by CPS Energy.

The “WARNING! RESTRICTED AREA KEEP OUT!” signs posted along the outer perimeter of the fence were intact during the inspection; however, a number of signs were no longer visible due to fading or coverage from dense vegetation (Photos 63, 68, and 70). The fence surrounding the western side of LF8B was intact and functioning as intended during the inspection. Minor damage, including a bent barbed wire support, was observed (Photo 64).

The entirety of LF8B was covered with overgrown vegetation consisting of native grass, shrubs, and trees (Photos 65 and 67). Although the vegetation appears to be providing stability and preventing further erosion of LF8B, the dense vegetation is growing through large sections of the northern and southeastern fence lines causing damage to the fence (Photos 70 through 78). Deformation of the fence was observed along the northern and southeastern fence lines as a result of the vegetation growing through the fence

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(Photos 71 and 76). A small section of the chain-link on the southeastern fence line has been knocked down by a fallen tree (Photo 77).

Access inside the fenced area at LF8B was limited during the 2018 inspection due to the dense vegetation. A small drainage pathway, which may have formed following multiple rainfall events, was observed in the accessible portion of LF8B (Photo 66). This drainage pathway was observed during previous inspections and does not appear to be impacting the landfill cover. Additionally, the drainage pathways between the road and the west and north fence lines noted during the 2017 inspections were observed. The drainage pathway along the western fence line was in similar condition to that observed during the previous inspection (Photo 69). The drainage area along the northern fence line appeared to have increased in depth (Photo 75). The drainage pathways did not appear to be impacting the landfill cover. No landfill debris was observed.

Evidence of dumping was observed adjacent to the LF8B boundary. Discarded furniture and flooring slats were observed between the northern LF8B fence line and Petroleum Road (Photos 73 and 74). These items are not related to landfill material and are located on public right-of-way beyond the installation boundary. Neither exposed landfill debris nor potential UXO were noted during the inspection.

5. Conclusions and Recommendations

The CAPE Team performed the 2018 annual site inspection at three landfill sites LF001, LF002, and LF003 that collectively comprise eight separate landfills. The landfill inspections were conducted on June 26-27, 2018. The team documented the observed condition of the landfill sites, such as the conditions of the soil cover, in-place ECMs, and physical controls. The physical controls appeared to be functioning as intended and specified in the RAP (Shaw, 2006). Soil cover was intact at all three sites and there was no evidence of exposure of buried landfill material.

Further, the following questions regarding the protectiveness of the remedies for each site can be addressed based on results of the site inspections presented in this document:

Question 1: Are the remedies functioning as intended?

Response: Despite the need for minor repairs noted in the sections below, the overall inspection findings indicate the remedies for Sites LF001, LF002, and LF003 are functioning as intended.

Question 2: Are the exposure assumptions, toxicity data, cleanup levels, and response action objectives used at the time of remedy implementation still valid?

Response: The exposure assumptions, toxicity data, cleanup levels, and response action objectives originally used to evaluate the site and ultimately define the response actions in accordance with TRRP are still valid.

Question 3: Has any other information come to light that could call into question the protectiveness of the remedy?

Response: No additional information was identified during the site inspections that could question the protectiveness of the remedy. Overall, the landfill cover, ECMs, signage, and access limitations collectively continue to provide protection of human health and the environment for each site. Minor sign and fencing repairs are recommended based on the inspection findings and do not jeopardize current or future protectiveness of the remedy implemented for each site.

Findings from the 2018 annual landfill inspections and recommendations for Sites LF001, LF002, and LF003 are summarized in the following sections.

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5.1 Site LF001

5.1.1 LF2, LF3, and LF5

• No landfill debris was observed. Visibility was limited in some areas due to dense vegetation. The vegetation is providing stability to the drainage swale and the northern edge of the landfills.

• The riprap along the northern boundary of LF2 and LF3 is intact and functioning as intended.

• Drainage outfalls were clear of debris and appeared to be functioning as intended.

• Erosion control matting was visible in localized areas along the horse trail/swale in the northern portion of LF2. The remainder of swale is covered in dense vegetation that appears to be providing stabilization. No landfill debris was observed. Conditions will be monitored and documented during future inspections. If repairs are warranted, they will be recommended to maintain the integrity of the cover.

• A small amount of erosion along the drainage channel at LF5 was observed but it did not appear to be affecting the integrity of the landfill given the stability afforded by the vegetative growth. Continued monitoring is recommended.

• New fencing was observed around northern area of LF2/LF3 and the western area of LF5.

• A small amount of residual materials including stockpiled dirt and construction fencing from past construction activities noted during previous inspections remained onsite.

• The conditions at LF2, LF3 and LF5 will continue to be evaluated; however, no repairs are recommended at this time based on the findings of the 2018 inspections.

5.1.2 LF4B

• Landfill material was not observed during the inspection.

• There was limited visibility and access along eastern portion of landfill due to the dense vegetation.

• Ropes and posts have been installed along the golf course to prevent cart traffic where bare spots have formed along the golf course.

• No repairs are recommended at LF4B at this time based on the findings of the 2018 inspection.

5.2 Site LF002

5.2.1 LF4A

• No landfill debris was observed during the inspection.

• Access and visibility was limited in the densely vegetated area present within the landfill boundary.

• Erosion was observed along the slopes in the middle section of the landfill. Landfill debris was not observed during the inspection. Continued observation is recommended.

• Visibility of the concrete drainage pathway was blocked by vegetation. The current condition could not be determined during the inspection.

• A pile of cans and some additional debris was noted in the eastern portion of LF4A and may be evidence of littering.

• A bare spot was noted in a small area on the golf course at LF4A; however, it was not impacting the landfill cover. JBSA-FSH may want to consider installing barriers to direct cart traffic away from the area.

• No repairs are recommended at LF4A; however, site conditions will continue to be monitored and evaluated.

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5.2.2 LF6

• Landfill debris was not observed during the LF6 inspection.

• Visibility and access were limited in the densely vegetated area of landfill.

• Construction that has taken place since the last inspection included the following:

– A new fence between the roadway and creek in the northern portion of LF6

– Updates or replacement of power lines/poles

– Construction debris and possible pipe installation were observed in the riprap area near the southeast corner of the parking lot; riprap was otherwise intact and functioning as intended

• The drainage conveyances were clear of debris and appeared to be functioning as intended.

• Downcutting resulting from road drainage south of Schofield Road observed during the 2017 inspection was in similar condition and did not appear to be impacting the landfill cover.

• Site conditions at LF6 will continue to be evaluated; however, based on the findings of the 2018 inspection, no repairs are recommended at this time.

5.2.3 LF7

• Landfill debris was not observed during the inspection.

• Visibility and access were limited in the densely vegetated eastern portion of the landfill.

• Signs were intact on the entrance gate to LF7 and the gate was locked.

• Riprap was intact and functioning as intended.

• Evidence of recent work at the site was observed and included stockpiled dirt and a small guard station near the entry gate to LF7.

• Based on observations made during the 2018 inspection, no repairs are recommended for LF7.

5.3 Site LF003

5.3.1 LF8B (alias XE015)

• No landfill debris was observed during the inspection.

• Access within the LF8B fence was limited due to dense and overgrown vegetation.

• Vegetation has grown through large portions of the northern and southeastern fence lines, causing damage to the fence. A small section of the southeastern fence line is down due to vegetation overgrowth. The damaged portion of the fence should be repaired. Vegetation near the fence line should be cleared to prevent further damage to the fence.

• Warning signs were posted but several are no longer legible due to fading from prolonged exposure to sunlight, or visible due to overgrown vegetation. Illegible signs will be replaced, and vegetation removed so that signs are visible.

• Erosion from runoff under the fence line was visible but does not appear to be impacting the landfill.

Continued observation is recommended.

• Evidence of dumping (flooring and furniture) was observed adjacent to LF8B between Petroleum Road and the northern fence line. However, these materials appear to have been illegally dumped on the public right-of-way and outside the installation property boundary. These items are located entirely outside the fence surrounding LF8B and are not a result of activities at JBSA-FSH.

AX0822181347SAN 11

6. References

CAPE Environmental, Inc. and CH2M HILL (CAPE Team). 2014. “2014 Annual Site Inspections for Landfill Sites LF001 (FTSH 30), LF002 (FTSH-29), and LF003 (FTSH-26) at Joint Base San Antonio – Fort Sam Houston, TX.” Final. October.

CAPE Environmental, Inc. and CH2M HILL (CAPE Team). 2015. “2015 Annual Site Inspections for Landfill Sites LF001 (FTSH 30), LF002 (FTSH-29), and LF003 (FTSH-26) at Joint Base San Antonio – Fort Sam Houston, TX.” Final. June.

CAPE Environmental, Inc. and CH2M HILL (CAPE Team). 2016. “2016 Annual Site Inspections for Landfill Sites LF001 (FTSH 30), LF002 (FTSH-29), and LF003 (FTSH-26) at Joint Base San Antonio – Fort Sam Houston, TX.” Final. March.

CAPE Environmental, Inc. and CH2M HILL (CAPE Team). 2017. “2017 Annual Site Inspections for Landfill Sites LF001 (FTSH 30), LF002 (FTSH-29), and LF003 (FTSH-26) at Joint Base San Antonio – Fort Sam Houston, TX.” Final. September.

EA Engineering, Science, and Technology, Inc. (EA) 1996. Fort Sam Houston and Camp Bullis Landfill Assessment Report, San Antonio, Texas.

Science Applications International Corporation (SAIC). 2013. Draft First Five-Year Review Report, JBSA Fort Sam Houston, Texas. March.

Shaw Environmental, Inc. (Shaw). 2005. Affected Property Assessment Report, Landfills 2, 3, 4A, 4B, 5, 6, 7, and 8B, Fort Sam Houston, Texas, San Antonio, Texas.

Shaw Environmental, Inc. (Shaw). 2006. Draft Final Response Action Plan, Landfills 2, 3, 4A, 4B, 5, 6, 7, and 8B, Fort Sam Houston, Texas, San Antonio, Texas. May.

Shaw Environmental, Inc. (Shaw). 2008a. Response Action Completion Report, Landfills 2, 3, 4A, 4B, 5, 6, 7, and 8B, San Antonio, Texas.

Shaw Environmental, Inc. (Shaw). 2008b. Technical Memorandum – Quarterly Monitoring Summary, Fort Sam Houston Landfills 2, 3, 4A, 4B, 5, 6, 7, and 8, Houston, Texas.

Shaw Environmental, Inc. (Shaw). 2011. Final First Periodic Response Review Report for Multiple Sites:

FTSH-26 (Landfill 8B), FTSH-29 (Landfills 4A, 6, and 7) and FTSH-30 (Landfills 2, 3, 4B, and 5) Fort Sam Houston, Texas. November.

Texas Commission on Environmental Quality (TCEQ). 2006a. Approval Letter for Affected Property Assessment Report for Landfills 2, 3, 4A, 4B, 5, 6, 7, and 8B. May.

Texas Commission on Environmental Quality (TCEQ). 2006b. Approval Letter for Draft Final Response Action Plan for Landfills 2, 3, 4A, 4B, 5, 6, 7, and 8B. June.

Texas Commission on Environmental Quality (TCEQ). 2008. Approval Letter of Draft Final Response Action Completion Report for Landfills 2, 3, 4A, 4B, 5, 6, 7, and 8B [and approval of “discontinuation of surface water and ground monitoring program”]. July.

Texas Commission on Environmental Quality (TCEQ). 2013. Approval Letter of Revised Schedule for Filing Once Every Five Years of the Post-Response Action Care Report (PRACR). September.

Texas Commission on Environmental Quality (TCEQ). 2015. Conditional Approval of Post-Response Action Care Reporting, dated June 24, 2015 Landfill Sites LF001 (LF2, LF3, LF4B and LF5); LF002 (LF4A, LF6 and LF7); and, LF003 (LF8B- alias XE105). November.

12 AX0822181347SAN

Texas Commission on Environmental Quality (TCEQ). 2016. Comments to Post-Response Action Care Reporting, dated March 25, 2016; and Technical Memorandum Landfill Sites LF001 (LF2, LF3, LF4B and LF5); LF002 (LF4A, LF6 and LF7); and, LF003 (LF8B- alias XE105), dated. March 25, 2016. April.

Weston, Inc. 1998. Preliminary Assessment/Site Inspection, Fort Sam Houston, Texas, San Antonio, Texas.

Figures

Site LF002

Site LF002

Site LF001

Site LF003

Landfill 3 Landfill 2

Landfill 5

Landfill 4B

Landfill 6

Landfill 7

Landfill 8B

Landfill 4A

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Legend Creek Ft. Sam Houston Boundary Landfill Boundary

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AIR FORCE CIVIL

ENGINEER CENTER

911 Central Parkway North, Suite 425

San Antonio, TX 78232

(210) 494-0088

REVISIONS:

No. Date Remarks

CONTRACT NO:

FA8903-09-D-8556

JOB NO:

98556.004

CHECKED BY:

W. LYNCH

DRAWN BY;

G. TWIGG

DATE:

JULY 2018

FILE NAME:

...new_LFbounds.mxd

SHEET NUMBER:

FIGURE 1

0 1,000 2,000500

Feet 1 inch = 1,000 feet

Image Source: ESRI World Imagery online mapping service.

Photo taken October 12, 2017

Pershing Rd.

Petroleum Dr.

FSH Golf Course (Active)

Salado Creek

Photo 18

Photo 2

Photo 8

Photo 13

Photo 15

Photo 16

Photo 9

Landfill 3

Landfill 2

Landfill 5

Landfill 4B

Photo 23 Photo 24

Photo 21

Photo 12

Photo 5Photo 22

Photo 25

Photo 17

Photo 14

Photo 19

Photo 20

Photos 10,11

Photo 3

Photo 6

Photo 4

Photo 1

Photo 7

HOU J:\FT_SAM_HOUSTON\Lackland\Mapfiles\LF2-4_sitemap_Jul2018_photolocs.mxd gtwigg 8/21/2018 3:23:52 PM

Legend Photo Location Direction of Photo Salado Creek Landfill Boundary Geotextile and Riprap Permanent Erosion Control Matting Temporary Erosion Control Matting

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ENGINEER CENTER

911 Central Parkway North, Suite 425

San Antonio, TX 78232

(210) 494-0088

REVISIONS:

No. Date Remarks

NOTES:

1) Figure from Response Action Completion Report (Shaw, 2008).

2) Landfill 5 is not part of the Landfill Inspections SOW.

CONTRACT NO:

FA8903-09-D-8556

JOB NO:

98556.004

CHECKED BY:

W. LYNCH

DRAWN BY;

G. TWIGG

DATE:

JULY 2018

FILE NAME:

LF2-4_sitemap_Jun2017_photolocs.MXD

SHEET NUMBER:

FIGURE 2Image Source: ESRI World Imagery online mapping service.

Photo taken October 12, 2017.

0 200 400100 Feet

1 inch = 200 feet

Ga rde n A ve

Binz-Engleman Rd.

Ww White Rd.

Wi llia ms R d.

Binz Engleman Rd

Zinn Rd.

McIdoe Rd.

Salado Creek

Photo 48

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Photos 40,41

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Landfill 6

Landfill 7

HOU J:\FT_SAM_HOUSTON\Lackland\Mapfiles\LF6-7_sitemap_Jul2018_photolocs.mxd gtwigg 8/21/2018 3:30:24 PM

Legend Photo Location Direction of Photo Salado Creek Landfill Boundary Permanent Erosion Control (Riprap) Surface Debris Removal

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AIR FORCE CIVIL

ENGINEER CENTER

911 Central Parkway North, Suite 425

San Antonio, TX 78232

(210) 494-0088

REVISIONS:

No. Date Remarks

NOTE:

1) Figure from Response Action Completion Report (Shaw, 2008).

CONTRACT NO:

FA8903-09-D-8556

JOB NO:

98556.004

CHECKED BY:

W. LYNCH

DRAWN BY;

G. TWIGG

DATE:

JULY 2018

FILE NAME:

LF6-7_sitemap_Jul2018_photolocs.MXD

SHEET NUMBER:

FIGURE 3

Landfill 4A Nurs ery Rd.

See Inset

Photo 36

Photo 37

Photo 30

Photo 38

Photo 34

Photo 35

Photo 33

Photo 32 Photo 31

0 550275 Feet

Landfill 4A

Landfills 6 and 7

Image Source: ESRI World Imagery online mapping service.

Photo taken November 1, 2017.

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Photo 29

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Railroad

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Landfill 8B

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Legend Photo Location Direction of Photo Salado Creek Landfill Boundary Backfilled Area

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AIR FORCE CIVIL

ENGINEER CENTER

911 Central Parkway North, Suite 425

San Antonio, TX 78232

(210) 494-0088

REVISIONS:

No. Date Remarks

NOTE:

1) Figure from Response Action Completion Report (Shaw, 2008).

CONTRACT NO:

FA8903-09-D-8556

JOB NO:

98556.004

CHECKED BY:

W. LYNCH

DRAWN BY;

G. TWIGG

DATE:

JULY 2018

FILE NAME:

LF8b_sitemap_Jul2018_photolocs.MXD

SHEET NUMBER:

FIGURE 4

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Image Source: ESRI World Imagery online mapping service.

Photo taken January 7, 2016

Attachment 1 TCEQ PRACR Letter for

Revised Filing Frequency

Attachment 2 2018 Site Photographs

Photo Log

Joint Base San Antonio – Fort Sam Houston:

2018 Annual Landfill Inspections

June 26-27, 2018

Jacobs Engineering Group Inc.

AX0822181347SAN 1

Project Title Joint Base San Antonio – Fort Sam Houston: 2018 Annual Landfill Inspections

Location Fort Sam Houston, San Antonio, TX

Date June 26-27, 2018

LF001 (FTSH – 30): Photos 1 through 25 (LF2; LF3; LF4B; and LF5)

Photo 1: Landfill 2 – View is to the northeast, taken near the southern boundary of LF2. In view are portions of LF2 and LF3, which are covered by the parking lot associated with the Medical Education and Training Campus (METC) Outdoor Fitness and Training Complex.

Photo 2: Landfill 2 – View is to the northwest overlooking the playing field that covers a portion of LF2.

Joint Base San Antonio – Fort Sam Houston: 2018 Annual Landfill Inspections

2 AX0822181347SAN

Photo 3: Landfill 2 – View is to the north of new fencing along the northern boundary of LF2.

The drainage pathway is in view.

Photo 4: Landfill 2 – View is to the southeast of the green matting along the equestrian trail in the northwestern corner of LF2. Note, the horse trail runs along the drainage swale. The dense vegetative cover over the remainder of the swale is providing stabilization. No visible landfill debris was observed.

AX0822181347SAN 3

Photo 5: Landfill 2 and Landfill 5 – View is to the south-southeast of an old metal post, a small quantity of green matting, and small amount of debris (mostly aluminum cans). The material appears to be flood-related debris from the creek and is not indicative of landfill material.

Photo 6: Landfill 2 and Landfill 5 – View is to the northeast overlooking the drainage swale at LF2 and LF5. A drainage pathway and concrete gabion are in view.

4 AX0822181347SAN

Photo 7: Landfill 3 – View is to the west of ball field at LF3.

Photo 8: Landfill 3 – View to west of old chain link fence that is damaged and remnants of orange construction fencing. Note that this fencing is not part of the security measures to prevent access to the site.

AX0822181347SAN 5

Photo 9: Landfill 3 – View is to the northwest. In view of intact riprap and newly installed fencing along the northern border of LF3.

Photo 10: Landfill 5 – View is to the northwest. A drainage channel within the backfill material at LF5 is in view. The arrow denotes the location of unknown debris shown in the following photo.

6 AX0822181347SAN

Photo 11: Landfill 5 – A piece of debris observed during previous inspections is still in place.

The debris is within the backfill material and is not interpreted as landfill debris.

Photo 12: Landfill 5 – View is to the southwest of drainage culverts at LF5.

AX0822181347SAN 7

Photo 13: Landfill 5 – View is to the southeast across the landfill. In view of ball fields in the southern portion of LF5.

Photo 14: Landfill 5 – View is to the southwest of newly installed fence along the western edge of LF5.

8 AX0822181347SAN

Photo 15: Landfill 5 – View is to the south. Stockpiled sand and silt fencing (located behind the sand) left onsite from the past construction activities are still in place in the southwestern area of LF5.

Photo 16: Landfill 5 – A concrete gabion in the southwest corner of LF5. View is to the north.

AX0822181347SAN 9

Photo 17: Landfill 5 – View is to the east of sheds located in the grassy area south of the LF5 ball field.

Photo 18: Landfill 5 – View is to the northwest of one of the two LF 5 ball fields.

10 AX0822181347SAN

Photo 19: Landfill 4B – View is to the north across the golf course at LF4B.

Photo 20: Landfill 4B – View is toward the south of vegetation line along the east side of the golf course at LF4B.

Jun 26, 2018 at 2:26:15 PM San Antonio

Jun 26, 2018 at 2:23:07 PM

AX0822181347SAN 11

Photo 21: Landfill 4B – View is to the north of bare spots that have resulted from golf cart traffic along golf course at LF4B.

Photo 22: Landfill 4B – View is toward the south of the eastern portion of the golf course at

LF4B.

Jun 26, 2018 at 2:32:27 PM

12 AX0822181347SAN

Photo 23: Landfill 4B – View is to the south across LF4B from the northern boundary of the landfill.

Photo 24: Landfill 4B – View is toward the southwest of bare spots along the eastern portion of the golf course. Note that the blue arrow denotes the location of newly installed posts to prevent cart traffic.

AX0822181347SAN 13

Photo 25: Landfill 4B – View is toward the south across LF4B. The arrow denotes the location of newly installed posts to redirect cart traffic.

LF002 (FTSH-29): Photos 26 through 62 (LF4A, LF6, and LF7)

Photo 26: Landfill…