third five-year review report for the bio-ecology … · damaged fence –portions of barbed wire...

THIRD FIVE-YEAR REVIEW REPORT FOR THE

BIO-ECOLOGY SYSTEMS, INC. SITE GRAND PRAIRIE, DALLAS COUNTY, TEXAS

September 2005

Prepared by:

REGION 6

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 1445 Ross Avenue

Dallas, TX 75202-2733

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Determinations

I have determined that the selected remedy for the Bio-Ecology Systems, Inc. site is protective of human

health and the environment and will remain so provided that the action items identified in the Five-Year

Review Report are addressed as described in the executive summary; the landfill cap is maintained;

leachate monitoring data are evaluated to determine if the leachate collection system is preventing lateral

migration of contaminants; ground water monitoring data are evaluated to determine if ground water

protection is occurring; and access restrictions are enforced.

___________________________________ ______________

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CONTENTS

Section Page ACRONYMS AND ABBREVIATIONS............................................................................................ vi EXECUTIVE SUMMARY........................................................................................................... ES-1 1.0 INTRODUCTION..................................................................................................................1 2.0 SITE CHRONOLOGY ...........................................................................................................2 3.0 BACKGROUND....................................................................................................................2

3.1 PHYSICAL CHARACTERISTICS .............................................................................2 3.2 LAND AND RESOURCE USE...................................................................................6 3.3 HISTORY OF CONTAMINATION............................................................................6 3.4 INITIAL RESPONSE.................................................................................................8 3.5 BASIS FOR RESPONSE............................................................................................8

4.0 REMEDIAL ACTIONS..........................................................................................................9

4.1 REMEDY SELECTION.............................................................................................9 4.2 REMEDY IMPLEMENTATION.............................................................................. 10 4.3 OPERATION AND MAINTENANCE...................................................................... 10 4.4 OPERATION AND MAINTENANCE COST............................................................ 12

5.0 FIVE-YEAR REVIEW PROGRESS...................................................................................... 13 6.0 FIVE-YEAR REVIEW PROCESS........................................................................................ 13

6.1 ADMINISTRATIVE COMPONENTS...................................................................... 13 6.2 COMMUNITY INVOLVEMENT............................................................................. 14 6.3 SITE INSPECTION.................................................................................................. 15 6.4 LOCAL INTERVIEWS............................................................................................ 16 6.5 ARAR REVIEW ...................................................................................................... 16

6.5.1 Chemical-Specific ARARs............................................................................ 17 6.5.2 Location-Specific ARARs............................................................................. 17 6.5.3 Action-Specific ARARs................................................................................ 18

6.6 DATA REVIEW ...................................................................................................... 19

6.6.1 Leachate Contamination................................................................................ 20 6.6.2 Leachate Volume .......................................................................................... 20 6.6.3 Groundwater Contamination.......................................................................... 24 6.6.4 Groundwater Elevation and Groundwater Flow .............................................. 27

7.0 TECHNICAL ASSESSMENT .............................................................................................. 27 8.0 ISSUES ............................................................................................................................... 28 9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS....................................................... 31 10.0 PROTECTIVENESS STATEMENTS ................................................................................... 30 11.0 NEXT REVIEW................................................................................................................... 30

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CONTENTS (Continued) Appendices A DOCUMENTS REVIEWED B SITE VISIT REPORT C PUBLIC NOTICE D SUMMARY OF LEACHATE LEVELS AND LEACHATE ELEVATION DATA E SUMMARY OF GROUND WATER ELEVATION DATA

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FIGURES

Figure Page 1 SITE LAYOUT MAP.............................................................................................................5

TABLES

Table Page 1 CHRONOLOGY OF SITE EVENTS.......................................................................................3 2 OPERATION AND MAINTENANCE COSTS...................................................................... 13 3 SUMMARY OF REPORTED ANALYTE CONCENTRATIONS IN LEACHATE.................. 21 4 SUMMARY OF LEACHATE COLLECTION VOLUMES.................................................... 23 5 SUMMARY OF REPORTED ANALYTE CONCENTRATIONS IN GROUNDWATER........ 25 6 ISSUES IDENTIFIED.......................................................................................................... 29 7 RECOMMENDATIONS AND FOLLOW-UP ACTIONS....................................................... 31

EXHIBITS

Exhibit A SITE VISIT PHOTOGRAPHS B SITE INVESTIGATION CHECKLIST C SURVEYS

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ACRONYMS AND ABBREVIATIONS

ALR Action leakage rate ARAR Applicable or relevant and appropriate requirements BES Bio-Ecology Systems, Inc. CA Cooperative Agreement CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COC Contaminant of concern EPA Environmental Protection Agency FS Feasibility study Geotech Geotech Environmental HASP Health and Safety Plan IRM Initial Remedial Measure LCS Leachate collection system Leigh Engineering Leigh Engineering, Inc. MCL Maximum contaminant levels mg/kg Milligram per kilogram (parts per million or ppm) MTBE Methyl tert-butyl ether MSL Mean sea level NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List O&M Operation and maintenance OU Operable units PCL Protective concentration level PRP Potentially responsible party RA Remedial action RAO Remedial action objective RCRA Resource Conservation and Recovery Act RES Rollins Environmental Services, Inc. RI/FS Remedial investigation/feasibility study ROD Record of decision RPM Remedial Project Manager SARA Superfund Amendments and Reauthorization Act SPLCS Southern primary leachate collection system TCEQ Texas Commission on Environmental Quality TDS Total dissolved solids TDWR Texas Department of Water Resources Tetra Tech Tetra Tech EM Inc. TNRCC Texas Natural Resource Conservation Commission TRRP Texas Risk Reduction Program URS URS Corporation VOC Volatile organic compounds WCC Woodward-Clyde Consultants, Inc.

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EXECUTIVE SUMMARY

The U.S. Environmental Protection Agency Region 6 (EPA) has conducted the third five-year review of

the remedial action (RA) implemented at the Bio-Ecology Systems, Inc. (BES) site. The purpose of this

five-year review was to determine whether the selected remedy for the site continues to protect human

health and the environment. This review was conducted in August and September 2005, and its findings

and conclusions are documented in this report. The first and second five-year reviews of the RA were

completed in December 1994 and September 2000, respectively. The third five-year review period

extended from September 2000 to August 2005.

Several documents were reviewed as part of this five-year review, including those containing the

following data: (1) leachate fluid levels and collection data, (2) leachate monitoring analytical data, (3)

ground water monitoring analytical data, and (4) ground water monitoring elevation data.

The BES site was listed on the National Priorities List (NPL) in September 1983. EPA signed the Record

of Decision (ROD) for the BES site on June 6, 1984. The ROD described the site remedy as follows:

(1) Raise the elevation of the site above the 100-year floodplain.

(2) Construct a Resource Conservation and Recovery Act (RCRA) compliant on-site disposal

cell with a synthetic liner and leachate collection system.

(3) Stabilize and place waste in an on-site RCRA landfill.

(4) Construct RCRA compliant final cover, and

(5) Install a groundwater monitoring system in accordance with standards promulgated under

40 Code of Federal Regulation (CFR) Part 264.

EPA determined that this remedy is protective of human health and the environment, attains federal and

state requirements that are applicable or relevant and appropriate, is cost-effective compared to equally

environmentally protective alternatives, and utilizes permanent solutions and alternative treatment

technologies to the maximum extent practicable.

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Construction and implementation of the selected remedy was completed for EPA, by Rollins

Environmental Services, Inc. (RES) on August 31, 1988. Monthly leachate recovery, quarterly/biannual

groundwater monitoring and analysis, quarterly/biannual leachate analysis, and monthly leachate

monitoring have been conducted on an intermittent basis since completion of the remedy.

This third five-year review focused on data obtained during the monthly leachate recovery, biannual

groundwater monitoring and analysis, biannual leachate analysis, monthly leachate monitoring, and

general landf ill maintenance performed from September 2000 through August 2005. At this time, the

selected remedy appears to be performing as intended.

The following issues were noted:

1. Damaged Fence –Portions of barbed wire along the northern fence line are in need of repair. Damaged fencing was observed along the northern portion of the site which appeared to be caused by empty 1,500-gallon polyethylene storage containers for purge water that had been pushed up against the fence line.

2. Heavy Vegetation/Tree Growth – A few trees (approximately 10 to 12 feet tall) were growing on top of the cap near several large poly tanks and 55-gallon poly drums. Brush and small trees were also observed around the risers on both sides of the cap. Established tree growth and other heavy vegetation growth with extensive root growth may affect the integrity of the site remedy.

3. Polyethylene Storage Tanks and Drums– Several unlabeled 55-gallon drums and polyethylene storage tanks were observed on the BES site. The majority of the storage containers were partially full with apparent purged ground water. Several of the drums and tanks were positioned on their sides and some were visibly damaged. A few of polyethylene storage tanks were located against the fence.

4. Exposed Monitoring Wells - None of the six monitoring wells were locked, and four did not contain caps. Two of the wells were completely open and exposed to the weather.

5. Cracking in Impoundment Cap – Several cracks approximately 2 inches deep and 15 feet long were observed along the southern fence line, but no cracks were observed in other areas.

6. Clogged SPLCS Sump – According to the 2004 Operations and Maintenance (O&M) Annual Report and conversations with the O&M contractor, the southern primary leachate collection system (SPLCS) line appears to be clogged or occluded. No leachate has been collected from the sump since August 2002.

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7. Ground Water Analysis - The 1984 ROD requires that ground water analysis should include at a minimum the following parameters; arsenic, barium, cadmium, chromium, lead, mercury, selenium, silver, cyanide, pH, specific conductance, total organic carbon, and total organic halogens. In addition, the ROD requires that one sample from a down-gradient well and one sample from an up-gradient well be analyzed for priority pollutants. These ROD requirements were not met during the five-year review period.

8. Deed recordation – BES is required to record a notation on the deed or any instrument normally examined during a title search, which will allow any potential buyer to be made aware of site conditions. It is unknown if deed recordation documents have been prepared for the site.

The following actions are needed in response to these issues:

1. Repair damage to fencing and barbed wire along the northern boundary of the site.

2. Remove established tree growth and other vegetation on top of the cap and around the risers on both sides of the cap. If removal activities impact the cap, proper measures should be taken to ensure the future integrity of the cap. Remove new tree growth and reduce height of vegetative growth during each scheduled landscaping maintenance event.

3. Removed unused and damaged drums and polyethylene storage tanks from the site. Place labels providing content and site contact information on all active drums and polyethylene storage tanks. Designate one or more staging areas for all active drums and polyethylene storage tanks.

4. Install new monitoring well caps on the four monitoring wells observed with missing caps. Install locks on all six monitoring wells. Ensure all locks are replaced on the monitoring wells after each sampling event.

5. Place clay-based fill material in the cracks that were observed on the landfill cap along the southern fence line. Place grass sod, plugs, or seeds over the repaired landfill cap surface.

6. Assess the SPLCS line for clogs or other blockages that may be preventing leachate collection. Conduct repairs as necessary to restore to working condition.

7. For all future ground water samples, analysis should include at a minimum the following parameters; arsenic, barium, cadmium, chromium, lead, mercury, selenium, silver, cyanide, pH, specific conductance, total organic carbon, and total organic halogen for all future ground water samples collected at the site. In addition, one sample from a down-gradient well and one sample from an up-gradient well should also be analyzed for priority pollutants.

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8. Determine if a notation on the deed or any instrument normally examined during a title search has been recorded for the BES property. If not, prepare and submit deed recordation documents as required.

At this time, based on the information available during the third five-year review, the selected remedy

appears to be protective of human health and the environment, and will remain so provided that the above

action items are addressed; the landfill cap is maintained; ground water monitoring data are evaluated to

determine if ground water protection is occurring; and access restrictions are enforced.

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Five-Year Review Summary Form

SITE IDENTIFICATION Site Name (from WasteLAN): Bio-Ecology Systems, Inc. (BES)

EPA ID (from WasteLAN): TXD980340889

Region: 06 State: TX City/County: Grand Prairie/Dallas

SITE STATUS NPL Status: 9 Final : Deleted 9 Other (specify)

Remediation Status (choose all that apply): 9 Under Construction : Operating 9 Complete

Multiple OUs?* 9 YES : NO Construction Completion Date: 8/31/88

Has site been put into reuse? 9 YES : NO

REVIEW STATUS

Reviewing Agency: : EPA : State 9 Tribe 9 Other Federal Agency

Author Name: Eric Johnstone

Author Title: Project Manager Author Affiliation: EPA Region 6 Contractor

Review Period:** 8/00 to 8/05

Date(s) of Site Inspection: 8/24/2005

Type of review:*** 9 Statutory SARA : Pre-SARA 9 NPL-Removal only 9 Non-NPL Remedial Action Site 9 NPL State/Tribe-

Review Number: 9 1 (first) 9 2 (second) : 3 (third) 9 Other (specify)

Triggering Action:**** 9 Actual RA Onsite Construction at OU # 9 Actual RA Start at OU # 9 Construction Completion : Previous Five-Year Review Report 9 Other (specify)

Triggering Action Date (from WasteLAN): September 2000

Due Date (Five Years After Triggering Action Date): September 2005

Notes: NPL – National Priority List OU – Operable Unit PRP – Primary Responsible Party RA – Remedial Action SARA – Superfund Amendments and Reauthorization Act

ES-6


Issues:





5. Cracking in Impoundment Cap – Several Cracks approximately 2 inches deep and 15 feet long were observed along the southern fence line, but no cracks were observed in other areas.

6. Clogged SPLCS Sump – According to the 2004 O&M Annual Report and conversations with the O&M contractor, the SPLCS line appears to be clogged or occluded. No leachate has been collected from the sump since August 2002.

7. Ground Water Analysis - The 1984 ROD requires that ground water analysis should include at a minimum the following parameters; arsenic, barium, cadmium, chromium, lead, mercury, selenium, silver, cyanide, pH, specific conductance, total organic carbon, and total organic halogen. In addition, the ROD requires that one sample from a down-gradient well and one sample from an up-gradient well be analyzed for priority pollutants. These ROD requirements were not met during the five-year review period.


Recommendations and Follow-up Actions:

1. Repair damage to fencing and barbed wire along the northern boundary of the site.

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2. Remove established tree growth and other heavy vegetation on top of the cap and around the risers on both sides of the cap. Remove new tree growth and reduce height of vegetative growth dur ing each regularly scheduled landscaping maintenance event.

3. Removed unused and damaged drums and polyethylene storage tanks from the site. Place labels providing content and site contact information on all active drums and polyethylene storage tanks. Designate one or more staging areas for all active drums and polyethylene storage tanks.

4. Install new monitoring well caps on the four monitoring wells observed with missing caps. Install locks on all six monitoring wells. Ensure all locks are replaced on the monitoring wells after each sampling event.

5. Place clay-based fill material in the cracks that were observed on the landfill cap along the southern fence line. Place grass sod, plugs, or seeds over the repaired landfill cap surface.

6. Assess the SPLCS line for clogs or other blockages that may be preventing leachate collection. Conduct repairs as necessary to restore to working condition.

7. For all future ground water samples, analysis should include at a minimum the following parameters; arsenic, barium, cadmium, chromium, lead, mercury, selenium, silver, cyanide, pH, specific conductance, total organic carbon, and total organic halogen for all future ground water samples collected at the site. In addition, one sample from a down-gradient well and one sample from an up-gradient well should be analyzed for priority pollutants.

8. Determine if a notation on the deed or any instrument normally examined during a title search has been recorded for the BES property. If not, prepare and submit deed recordation documents as required.

Protectiveness Statement(s): The remedy for the BES site continues to be protective of human health and the environment. The liner and leachate collection system have prevented lateral migration of contaminants from the site through the groundwater. Stabilization, burial, and elevation above the 100-year floodplain have prevented surface migration of the waste sludges.

Long-Term Protectiveness: At this time, the third five-year review indicates that the selected remedy appears to be performing as intended, and is protective of human health and the environment. For the site remedy to be protective in the long term, the landfill should continue to be inspected and operated and maintained in accordance with approved plans. Additionally, the leachate and ground water from the monitor wells established around the landfill will need to continue being monitored. Leachate and ground water samples will need to continue being collected and analyzed for the list of chemicals specified by the Operation and Maintenance plans.

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1.0 INTRODUCTION

The U.S. Environmental Protection Agency Region 6 (EPA), with assistance from Tetra Tech EM Inc.

(Tetra Tech), conducted a five-year review of the remedial action (RA) implemented at the Bio-Ecology

Systems, Inc. (BES) site in Grand Prairie , Texas. The purpose of a five-year review is to determine

whether the remedy at a site is protective of human health and the environment.

The five-year review process is required by federal statute. EPA must implement five-year reviews

consistent with the Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).

CERCLA Section (§)121(c), as amended, states the following:

“If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented.”

NCP §300.430(f)(4)(ii) states the following:

“If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.”

Because hazardous substances, pollutants, or contaminants remain at the Bio-Ecology site above levels

that allow for unlimited use and unrestricted exposure, a five-year review is required.

The period addressed by the five-year review for the Bio-Ecology site extended from September 2000 to

August 2005. The triggering action for this review was the completion of the second five-year review in

September 2000. The third five-year review was conducted during August and September 2005, and its

methods, findings, conclusions, and recommendations are documented in this report.

This report documents the five-year review for the Bio-Ecology site by providing the following

information: site chronology (Section 2.0), background information (Section 3.0), an overview of the

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EPA RA (Section 4.0), five-year review progress (Section 5.0), the five-year review process (Section 6.0),

technical assessment of the site (Section 7.0), issues identified (Section 8.0), and recommendations and

follow-up activities (Section 9.0). The report also provides a protectiveness statement (Section 10.0) and

discusses the next review (Section 11.0). Appendix A provides a list of documents reviewed, and

Appendix B is the site visit report. The public notice is provided in Appendix C, a summary table of

leachate levels and elevation data is provided in Appendix D, and a summary table of ground water

elevation data is provided in Appendix E.

2.0 SITE CHRONOLOGY

A chronology of site events for the BES site is provided in Table 1. Additional historical information for

the site is available on line at: http://www.epa.gov/earth1r6/6sf/pdffiles/0602464.pdf (EPA 2005).

3.0 BACKGROUND

This section discusses the site’s physical characteristics, land and resource use near the site, the

history of site contamination, the initial response to the site, and the basis for the response.

3.1 PHYSICAL CHARACTERISTICS

The BES site is located at 4100 East Jefferson Avenue within the city limits of Grand Prairie, Dallas

County, Texas (see Figure 1). The site occupies approximately 11.2 acres of land at the end of an

easement road that runs south through the Auto Parts House salvage yard. The landfill is located

approximately two miles south of Interstate Highway 30 between Dallas and Fort Worth on the south side

of Jefferson Avenue. The site is bounded in all directions by private property (automobile salvage yards)

and to the east and south by Mountain Creek. Mountain Creek Lake and the Trinity River are located

approximately 3/4 mile southwest and 2-1/2 miles north of the BES site, respectively.

BES is located within the 100-Year floodplain of Mountain Creek (Trinity River Basin) and has been

extensively flooded on at least two occasions in June 1973 and June 1974 when the facility was still

operational. The groundwater gradient, as defined in the ROD, trends from the northwest corner of the

site to the southeast corner of the site.

TABLE 1

CHRONOLOGY OF SITE EVENTS

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Date Event

April 24, 1972 BES issued a Class I industrial solid waste permit

June 3, 1973 State officials witness treatment basin flooding at the BES site

July 6, 1973 First issuance of court order for permit compliance

March 24, 1977 Second court order for permit compliance

June 13, 1978 BES files for Chapter XI bankruptcy

December 1979 Contract developed to partially close the BES site

November 1981 Cooperative Agreement filed with EPA Region 6 by TDWR

April 12, 1982 Cooperative agreement to conduct RI/FS approved

November 1982 WCC of Houston selected to conduct the RI/FS

January 1983 Remedial investigation complete

February 1983 Feasibility study initiated by WCC

July 1983 RI/FS completed by WCC

September 8, 1983 NPL listing

June 6, 1984 ROD signature

September 24, 1984 Remedial design start

1985 Agreement between State of Texas and EPA Region 6 to provide O&M activities at the BES site for 5 years after closure

May 12, 1986 Cooperative Agreement awarded to fund remedial action construction contract and engineering oversight contract

May 4, 1987 Mobilization of RA contractor

June 1988 TWC awarded funds to implement first year of O&M plan

June 27, 1988 Construction finish

August 1988 O&M plan completed by WCC

August 31, 1988 Construction completion

TABLE 1 (Continued)

CHRONOLOGY OF SITE EVENTS

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Date Event

September 29, 1988 Operational & Functional

March 30, 1993 Cooperative agreement between the EPA and the State of Texas is closed out

April 1993 Fluor Daniel Inc.’s contract with EPA closed out.

October 6,1993 TNRCC approves BES O&M scope of work and authorizes Intera, Inc. to implement the site operation, maintenance, sampling, and analysis plan

November 1994 First five-year review report

October 1999 Leigh Engineering, Inc. (Leigh) commences with first month of annually renewed contract with TNRCC to conduct O&M activities at the BES site

September 2000 Second five-year review report

August 2002 Operation and Maintenance Annual Report completed by Leigh.

August 2004 2004 Operation and Maintenance Annual Report completed by URS Corporation

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3.2 LAND AND RESOURCE USE

BES was permitted in 1972 as a Class I industrial solid waste management facility. Permitted activities

included the following: (1) incineration of combustible liquids, slurries and sludge; (2) chemical

treatment of acids, caustics, and other waste chemical solutions, including those containing heavy metals;

(3) biological oxidation of wastewater resulting from separation of mud-water and oil-water mixtures

from chemical treatment of other wastes; and (4) a modified landfill of solids resulting from the other

treatment processes.

3.3 HISTORY OF CONTAMINATION

BES actively operated from June 1972 to June 1978, during which time it was cited for a number of major

violations. Operations at the site faced frequent litigation filed by the Texas Department of Water

Resources (TDWR), now part of the Texas Commission on Environmental Quality (TCEQ), and its

predecessor agency, the Texas Water Quality Board. Both agencies attempted to achieve compliance

with permit standards through litigation.

The ROD stated that on June 3, 1973, approximately five inches of rain fell on the site over a 24-hour

period. Although the site was purported to have been designed to protect against a 24-hour, 25-year

rainfall event, state inspectors observed that approximately 90 percent of the Bio-Ecology facility was

inundated with floodwaters in several storage basins, causing wastewater runoff to flow into Mountain

Creek. Based on this information, the Texas courts rendered judgments on July 6, 1973 and March 24,

1977, requiring BES to comply with its permit and remedy the above-mentioned violations.

On June 13, 1978, BES filed for bankruptcy under the provisions of Chapter XI of the Federal

Bankruptcy Code. After payment of all priority creditors, TDWR was able to recover $28,870 from BES

for cleanup activities. In December 1979, a contract was entered to partially close the site. Under the

contract: (1) all open, receiving basins and pits were to be drained; (2) all contained wastes were to be

buried on site and covered with a pelletized lime blanket; and (3) sludges in various lagoons and landfills

were consolidated on site. Due to constraints in funding, a number of metal tanks containing oils,

solvents, and paint sludge remained at the site. Approximately $34,000 (including $28,870 obtained from

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the BES bankruptcy) was expended during the period from December 12, 1979 to February 15, 1980 for

the partial site cleanup.

In November 1981, TDWR filed an application with EPA Region 6 for a Cooperative Agreement (CA) to

conduct a Remedial Investigation and Feasibility Study (RI/FS) at the site. The CA between EPA and the

State of Texas was approved on April 12, 1982. EPA Region 6 authorized $328,000 to conduct a State-

lead RI/FS. The State of Texas awarded Woodward-Clyde Consultants (WCC) a contract to perform the

RI/FS. BES was proposed for addition to the NPL in a Notice of Proposed Rulemaking published on

December 30, 1982.

The site work for the investigation was completed in January 1983. Off-site contamination did not appear

to be severe at the time of the field investigation, and subsurface contamination appeared to be restricted

to areas near the waste deposits. However, on-site composite surface soil samples indicated high

concentrations of lead (1,100 milligrams per kilogram [mg/kg]), arsenic (210 mg/kg), cyanide (1,030

mg/kg), toluene (19 mg/kg), trichloroethylene (1,000 mg/kg), benzene (1.5 mg/kg), methylene chloride

(0.0878 mg/kg), and naphthalene (240 mg/kg). The volume of wastes and highly contaminated soils was

estimated to be 40,000 cubic yards. Although significant long-term migration pathways and mechanisms

to surface and subsurface waters existed, migration had been restricted to on-site locations, with the

exception of past surface off-site migration caused by flooding. Target receptors that were identified as

having been impacted included surface waters and dead and dying vegetation on adjacent lands. The

feasibility study (FS) began in February 1983 and was completed in July 1983. The BES site was added

to the NPL on September 8, 1983.

An Initial Remedial Measure (IRM) was concluded at the site in September 1983 to meet the

requirements of 40 CFR Section 300.65. This action was necessary because hazardous substances in

drums, barrels, tanks, or other bulk storage containers aboveground and contaminated soils at or near the

surface posed a threat to public health, the environment, or both.

The IRM activities included the following:

• Remove and dispose of approximately 80,000 gallons of hazardous liquids and sludge such as organics, PCBs, and heavy metals;

• Decontaminate and remove the fifteen storage tanks and other surface structures;

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• Remove and dispose of about thirty-five cubic yards of contaminated soil; and

• Surface cleanup of miscellaneous debris, site grading, etc.

The implementation of the remedial action specified in the 1984 ROD began in May 1987 and was

completed in June 1988. Operation and maintenance activities will continue for a minimum of 30 years

after the RA construction phase was completed as specified in the ROD.

3.4 INITIAL RESPONSE

Based on the results from preliminary assessments, TDWR (now TCEQ) initiated RI/FS activities at the

BES site to determine the nature and extent of the contamination. The RI/FS activities were completed in

September 1983. The BES site was added to the NPL on September 8, 1983. In June 1984, EPA

announced the ROD for the BES site.

3.5 BASIS FOR RESPONSE

Based on the data collected during the RI, EPA determined that if the remedy selected in the ROD was

not implemented, hazardous substances could be released from the BES site and endanger public health,

welfare, or the environment. The most significant risks to human health and the environment included the

following:

(1) Soils – ingestion of or absorption through the skin of contaminated surface soils posed potential health risks.

(2) Surface waters – ingestion of or absorption through the skin of contaminated surface

waters posed potential health risks. (3) Ground water – ingestion of or absorption through the skin of contaminated ground water

pumped to the surface by water supply wells posed potential health risks. (4) Ambient air – ingestion of or absorption through the skin of contaminated ambient air

posed potential health risks.

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4.0 REMEDIAL ACTIONS

This section discusses the selected remedy, remedy implementation, O&M activities, and O&M costs.

4.1 REMEDY SELECTION

EPA screened nine alternatives, referred to as Alternative 1 through 9, for performance, cost, and

environmental factors. Each remedy’s effectiveness was evaluated by assigning a numerical value or

ranking to each of four categories (human health impacts, feasibility and performance, environmental

impacts, and timeliness). The remedial alternatives with the highest effectiveness scores were then

compared by cost to select the most appropriate remedy.

The ROD for the BES site was signed on June 6, 1984. The ROD stated that in EPA’s judgment,

Alternative 8 appeared to meet more statutory selection criteria than the other remedies evaluated. The

ROD described the remedy as follows:

• Raise the elevation of the site above the 100-year floodplain;

• Construct an on-site disposal cell with a synthetic liner, final cover, and leachate collection and removal system in accordance with standards promulgated under 40 CFR Part 264 and applicable supplemental guidance;

• Stabilize the waste and place in on-site cell;

• Construct a fence with warning signs; and

• Install a groundwater monitoring system in accordance with standards promulgated under 40 CFR Part 264.

EPA determined that this remedy is protective of human health and the environment, attains federal and

state requirements that are applicable or relevant and appropriate, is cost-effective compared to equally

environmentally protective alternatives, and utilizes permanent solutions and alternative treatment

technologies to the maximum extent practicable.

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4.2 REMEDY IMPLEMENTATION

The TDWR was awarded approximately $266,000 on September 24, 1984, for remedial design. TDWR

contracted with WCC to develop the plans, specifications, and procurement package for implementation

of the remedy selected in the ROD. The design was completed and approved in May 1986.

EPA Region 6 signed a CA with TDWR on May 12, 1986 to fund the remedial action construction

contract and engineering oversight contract. The $4,143,790 provided to TDWR through the CA was

supplemented by $2,788,000 provided by the Air Force under the terms of an Inter-Agency Agreement

that was part of an Air Force settlement with EPA to pay for their contribution of wastes during site

operations. Rollins Environmental Services (RES) was awarded the contract on March 16, 1987. WCC

was retained as TDWR's oversight engineer. The Notice to Proceed was issued to RES on April 30, 1987,

and the contractor mobilized to the site on May 4, 1987. The RCRA cell was completed and closed in

April 1988. Prefinal inspection of the substantially completed work was held on June 27, 1988, with final

inspection of the completed work and issuance of the Certificate of Comple tion occurring on August 31,

1988.

4.3 OPERATION AND MAINTENANCE

In 1985, an agreement was drafted between EPA Region 6 and the State of Texas, stating that EPA would

conduct O&M activities at the BES site for five years after its closure. After the five year period, the

State would conduct the O&M activities for the remainder of the 30-year, post-closure monitoring period.

EPA selected Fluor Daniel Inc. to perform O&M activities for the site for the first five years. The O&M

contract was closed out by EPA in April 1993, finalizing EPA’s five year commitment to conduct O&M

activities. At that point, the Texas Natural Resource Conservation Commission (TNRCC), now TCEQ,

assumed full responsibility for conducting ongoing O&M at the BES site for the remainder of the 30-year,

post-closure monitoring period. The TNRCC contracted with Intera, Inc. in October 1993 to conduct

O&M. Work was initiated in November 1993, and Intera, Inc. retained the contract until October 1999,

when Leigh Engineering, Inc. (Leigh Engineering) then assumed the O&M responsibilities. URS

Corporation (URS) assumed O&M responsibilities in October 2003.

11

Currently, operations at the BES site are conducted in accordance with the approved O&M Plan. System

operations requirements for the BES site include:

• Conduct sampling and analysis semiannually from six groundwater monitoring wells and four leachate collection sumps;

• Measure groundwater elevations from monitoring wells on a semi-annual basis;

• Conduct pumping of leachate from sumps into on-site storage tanks at least monthly or

whenever the leachate level in the sumps exceeds one foot in depth;

• Dispose of leachate; and

• Mow the site three times per year and monitor and repair, if necessary the landfill cap, security fence, and other site features.

Cap system maintenance has generally been limited to mowing, and checking for erosion and any breach

of site security. No significant repairs of the cover system have been required since construction.

Dates and noted major observations from the O&M annual reports are as follows for the five-year review

reporting period:

• Fence Installation: The auto salvage yard located to the west of the BES site placed fill material onto their property. Placement of the fill material reduced the fence height, originally installed with a height of six feet above ground surface, to only four feet above ground surface on the western side of the BES site. New fencing was installed 10 feet to the east of the former fence. The former fence was left in place to prevent encroachment by the adjacent auto salvage yard onto the BES site.

• Monitoring Well Locks: According to the 2002 O&M annual report, Leigh Engineering placed locks on all six monitoring wells located at the site. However, during the site reconnaissance conducted on August 24, 2005, no locks were observed on any of the monitoring wells and four of the six wells did not have caps.

• Pump Replacement: According to the 2002 O&M annual report, Leigh Engineering replaced one on-site pump and control box.

• Damaged Equipment: According to the 2002 O&M annual report, the on-site equipment historically used for sampling the monitoring wells, including Well-Wizard pumps, controllers, and Air Compressors, were inoperable . In addition, the custom designed caps with fitted portals and attached poly-tubing were cracked and damaged.

12

• Clogged SPLCS: No leachate has been collected from sump SPLCS since November 2003. According to the 2004 O&M annual report, the SPLCS line appeared to be clogged or occluded.

• Equipment Repair Assessment: According to the 2004 O&M annual report, URS took the reportedly damaged equipment to a local vendor, Geotech Environmental (Geotech), to obtain a repair estimate. Geotech determined that four of the six Well-Wizard pumps were still in working conditions and required only moderate repairs. Two of the pumps were determined to be damaged beyond repair. Geotech also assessed four Redi-Flo® submersible pumps with 150-foot lead wire and control boxes historically used to sample leachate. Geotech determined that all four pumps were still in working condition and required only moderate repairs.

The first and second Five-Year Review Reports document that the contractors had not been able to meet

the provisions of the contract that called for monthly pumping of leachate collection sumps and

maintaining liquid levels in the collection system to less than one foot above the sump liner. This

requirement was also not consistently met during the current five-year review period. Leachate removal

operations were halted for consecutive months from September 2000 to May 2001, from September 2001

to February 2002, and from September 2002 to October 2003. Leigh Engineering, the O&M contractor

during these periods, attributed these instances to TCEQ funding problems. According to Ms. Sonya

Williams, the Program Manager at Leigh Engineering, Leigh Engineering completed all work for the BES

site on or before October 2002. URS took over O&M management in October 2003. The lack of

leachate removal operations during the period of September 2002 to October 2003 is likely attributed to

the change in O&M contractor from Leigh Engineering to URS.

4.4 OPERATION AND MAINTENANCE COST The O&M contractors provided approximate associa ted costs for the BES site. The costs include the

following:

• Conduct sampling and analysis semiannually from six groundwater monitoring wells and four leachate collection sumps;

• Measure groundwater elevations from monitoring wells on a semi-annual basis;

• Conduct pumping of leachate from sumps into on-site storage tanks at least monthly or

whenever the leachate level in the sumps exceeds one foot in depth;

• Dispose of leachate; and

• Mow the site three times per year and monitor and repair, if necessary the landfill cap, security fence, and other site features.

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Table 2 provides the approximate costs for the time periods stated. The reported total cost for March

2001 to October 2001 and for December 2001 to October 2002 was provided by Ms. Sonya Williams of

Leigh Engineering. The reported total costs for October 2003 to September 2005 were provided by Mr.

Tom Wiberg of URS.

TABLE 2

OPERATION AND MAINTENANCE COSTS

Period Total cost rounded to nearest $1,000 From To Reported Costs

March 2001 October 2001 $24,000 December 2001 October 2002 $14,000 October 2003 September 2004 $25,000-30,000 October 2004 September 2005 $25,000-30,000

5.0 FIVE-YEAR REVIEW PROGRESS

This is the third five-year review for the BES site. The first and second five-year reviews were conducted

in December 1994 and September 2000, respectively. The next five-year report will be conducted by September 2010.

6.0 FIVE-YEAR REVIEW PROCESS

This section presents the process and findings of the third five-year review. Specifically, this section

presents the findings of surveys, a site inspection, an applicable or relevant and appropriate requirements

(ARAR) review, and a data review.

6.1 ADMINISTRATIVE COMPONENTS

The BES site Five-year Review team was led by Mr. Ruben Moya of EPA, Remedial Project Manager for

the BES site. Mr. Eric Johnstone, Mr. Billy Bol, and Ms. Courtney Nichols, representatives from Tetra

Tech, assisted in the review process.

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In June 2005, the review team established the review schedule, which inc luded the following components:

• Community Involvement • Site Inspection

• Local Interviews

• ARAR Review

• Data Review

• Five-Year Review Report Development and Review

The following individuals were interviewed by telephone as part of the five-year review:

• Sonya Williams, Leigh Engineering, Inc. (Interviewed by phone on September 6, 2005);

• Tom Wiberg, URS (Interviewed by phone on September 6, 2005); • Arnold Sanchez, Auto Parts House (Interviewed by phone on September 6, 2005); and

• Julie Lozano, Dallas Import Auto (Interviewed by phone on September 6, 2005).

Based on these interviews, it appears that the site is operating smoothly and efficiently with no

measurable detrimental impact to the site, adjacent land, or adjacent landowners. A summary of the

interview dialogues is presented in Appendix C.

6.2 COMMUNITY INVOLVEMENT

Activities to involve the community in the five-year review were initiated with a public notice published

in the local daily newspaper, The Dallas Morning News. This notice informed the public that a five-year

review was to be conducted and that the results of the review would be made available to the public at the

information repository, the Grand Prairie Main Library. The 64-line by one-column notice ran for one

day, Wednesday, August 3, 2005. A copy of the public notice is available in Appendix C.

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6.3 SITE INSPECTION

A site inspection was conducted on August 24, 2005 to assess the condition of the site and the measures employed to protect human health and the environment from the contaminants still present at the site.

Attendees included (1) Eric Johnstone of Tetra Tech; and (2) Billy Bol of Tetra Tech. The site visit

included evaluation of the landfill cap, including the monitoring wells, leak detection/clean out vaults,

postings, and site fencing. The site visit report, which includes a site inspection checklist (Exhibit A),

photographic log of the inspection (Exhibit B), and site survey forms (Exhibit C) is provided in

Appendix B.

The weather during the site visit was hot and dry with no cloud cover. No evidence of contamination was

visible at the site. The site was very overgrown with waist high flora. Trees and high brush were noted

along the fence line surrounding the site, with the densest growth noted along the northern and eastern

portions of the fence.

No evidence of contamination was visible at the site. The vegetation at the site appeared to be similar to

that in typical surrounding areas.

Landfill Cap

The landfill was in good condition with no evidence of ants or burrowing animals. A few trees

(approximately 10 to 12 feet tall) were growing on top of the cap near several large poly tanks and 55-

gallon poly drums. Several cracks approximately 2 inches deep and 15 feet long were also observed

along the southern fence line, but no cracks were observed in other areas.

Leachate Collection System

The eight on-site leachate collection system (LCS) risers were padlocked and appeared to be in good

condition, although brush and small trees were located around the risers on both sides of the cap.

Monitoring Wells

None of the six monitoring wells were locked, and four did not contain caps. Two of the wells were

completely open and exposed to the weather.

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Security Measures

Security measures at the site include an 8-foot high chain-link fence topped with four strands of barbed-

wire. Portions of barbed wire along the northern fence line are in need of repair. Tetra Tech also

observed damaged areas of the fence along the northern portion of the site, which appeared to be caused

by empty 1,500-gallon purge water containers that had been pushed up against the fence line.

6.4 LOCAL INTERVIEWS

In accordance with the community involvement requirements of the five-year review process, key

individuals to be surveyed were identified by EPA. Completed survey forms for the following people are

included in Appendix B, Exhibit B:

• Sonya Williams, Leigh Engineering, Inc. (Interviewed by phone on September 6, 2005);

• Tom Wiberg, URS (Interviewed by phone on September 6, 2005); • Arnold Sanchez, Auto Parts House (Interviewed by phone on September 6, 2005); and

• Julie Lozano, Dallas Import Auto (Interviewed by phone on September 6, 2005).

A list of continuing or unresolved issues discovered during the interview process are as follows:

• Mr. Tom Wiberg, of URS, stated that URS has previously informed TCEQ that the SPLCS leachate line is apparently clogged and that no leachate is being recovered from this line. According to Mr. Wiberg, no action has been taken to assess and repair the line as of September 2005.

• Mr. Tom Wiberg, of URS, stated that leachate and ground water monitoring data indicate stable and low concentrations of contaminants at the site. As such, Mr. Wiberg suggested that reducing the frequency of leachate and ground water monitoring could reduce the annual O&M costs.

6.5 ARAR REVIEW The ROD for the BES Site was issued in June 1984 and predates the statutory requirement to comply with

ARAR mandated in the Superfund Amendments and Reauthorization Act (SARA). However, the BES

ROD considered and adopted the following requirements:

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• Executive Order 11988 (Floodplain Management) – Action taken must avoid adverse effects and minimize potential harm to surrounding area;

• RCRA regulations (found at 40 CFR 264 Subpart F) for the monitoring of groundwater to

detect releases from the waste management unit; and • RCRA regulations for the design, construction, and operation of a hazardous landfill.

These regulations are found at 40 CFR 264 Subpart N. RCRA regulations for landfill construction also require compliance with RCRA regulations for closure and post-closure at 40 CFR 264.117 through 264.120.

One of the requirements of a five-year review is to determine if there are any new requirements that may

pertain to the site. No new requirements have been promulgated that pertain to the BES site remedy.

ARARs pertaining to remedial action activities at the BES site are divided into chemical-, location-, and

action-specific categories discussed below.

6.5.1 Chemical-Specific ARARs

Chemical-specific ARARs are usually health-or risk-based numerical values or methodologies that, when

applied to site-specific conditions, result in the establishment of numerical values. These values establish

the acceptable amount or concentration of a chemical that may remain in or be discharged to the ambient

environment (EPA 1988). If more than one chemical-specific requirement exists for a contaminant of

concern (COC), the most stringent level will generally be identified as an ARAR for the remedial action.

The BES remedial action relies on engineering controls to manage the waste at the site. Therefore, there

were no chemical-specific ARARs identified for the BES remedial action except those applicable to the

detection of releases from the waste management unit constructed as part of the remedy. These

requirements are discussed as action-specific requirements in Section 6.5.3.

6.5.2 Location-Specific ARARs

Location-specific ARARs are restrictions placed on the concentration of hazardous substances or the

conduct of activities solely because they are in special locations. Some examples of locations that might

prompt a location-specific ARAR include wetlands, sensitive ecosystems or habitats, flood plains, and

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areas of historical significance (EPA 1988). The ROD identified one location-specific guideline

pertaining to the BES site:

• Executive Order 11988 (Floodplain Management) – Action taken must avoid adverse effects and minimize potential harm to surrounding area.

The RCRA cell was raised above the 100-year floodplain as part of the design and construction of the

landfill. No new location-specific requirements that may affect the protectiveness of the BES remedial

action have been promulgated.

6.5.3 Action-Specific ARARs

Action-specific ARARs are usually: (1) technology- or activity-based requirements or limitations on

actions taken with respect to hazardous wastes or (2) requirements to conduct certain actions to address

particular site circumstances. These requirements are triggered by the particular remedial activities that

are selected to accomplish a remedy. Because there are usually several alternative actions for any

remedial site, very different requirements can come into play. These action-specific requirements do not

in themselves determine the remedial alternative; rather, they indicate how a selected alternative must be

achieved (EPA 1988).

The action-specific requirements identified in the BES ROD are the RCRA requirements at 40 CFR 264

Subpart F (pertaining to groundwater monitoring) and Subpart N (pertaining to design, construction, and

operation of a hazardous waste landfill). Portions of both regulations have been updated since the ROD

was signed. However, these regulations have not been changed in a way that would impact the remedial

action since the last five year review was conducted in 2000.

The BES remedial action complies with the groundwater monitoring portions of the RCRA regulations.

Monitoring results are compared to the Texas Risk Reduction Program (TRRP) Tier 1 protective

concentration levels (PCLs) and EPA maximum contaminant levels (MCLs) which comply with the

substantive requirement of RCRA groundwater protection standards. To date, no statistically significant

increase in hazardous constituents has been detected by the groundwater monitoring system.

19

Groundwater monitoring results from August 2004 indicate that no contaminants exceed the applicable

PCLs and MCLs.

The BES remedial action is operated and maintained in compliance with the approved plans and RCRA

requirements. The BES remedial action complies with the action leakage rate (ALR) of 300 gallons per

day or 9,000 gallons per month. Leachate collection data from June 1999 until May 2005 indicate that the

recommended ALR of 9,000 gallons per month has never been exceeded. From September 2003 until

August 2004 approximately 3000 gallons of leachate was collected and disposed of off-site, which is

significantly below the acceptable ALR. The leachate volume data from the secondary sumps indicate

that the BES remedial action continues to comply with the ALR provisions of RCRA.

The post-closure regulations of RCRA at 40 CFR 264.119 require certain post-closure notices. These

regulations were in effect when the BES ROD was signed. This provision requires the owner or operator

to record, in accordance with State law, a notation on the deed of the facility property or some other

instrument normally examined during the title search that will in perpetuity notify any potential purchaser

that the land has been used to manage hazardous wastes and its use is restricted under 40 CFR Part 264,

Subpart G regulations. These notices are necessary institutional controls to ensure that the property is not

used inappropriately in the future. To date, the property owner has not filed the appropriate deed notices.

6.6 DATA REVIEW

Information regarding the site activities, the leachate analytical data, leachate volume data, monitoring

well analytical data, and monitor well elevation data were summarized in the following reports:

• “Operations and Maintenance Annual Report, Conducted February 2002 – August, 2002, Bio-Ecology, Grand Prairie, Texas, SUP #025” (Leigh Engineering, 2002).

• “2004 Operations and Maintenance Annual Report, Bio-Ecology Superfund Site, SUP No.

025, Grand Prairie, Texas” (URS, 2004).

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6.6.1 Leachate Contamination

Leachate collection and analysis has been conducted four times during the five-year review reporting

period. Samples were submitted to a subcontracted laboratory for analysis of volatile organic compounds

(VOCs), chloride, nitrate, sulfate, alkalinity, and total dissolved solids (TDS). In all of the four sampling

events, contaminants were not found in the leachate at concentrations that would warrant reclassification

of the leachate to a hazardous material. Reported concentrations were compared to TRRP Tier 1 PCLs

and EPA MCLs. Among the leachate samples, only vinyl chloride was reported at levels that exceed the

TRRP Tier 1 PCL and MCL. Vinyl chloride was not detected in any ground water samples collected

during the five-year review period. Table 3 presents a summary of the analytes detected in the leachate

samples collected during the five-year review period.

A review of the leachate analytical data and discussions presented in the O&M annual reports indicate

that hydraulic communication exists between the primary and secondary leachate collection systems

(LCS). Evidence of communication is provided by the presence of primary LCS constituents present in

the secondary LCS leachate, albeit at predominantly lower concentrations. Anomalies do exist, however,

in the form of higher contaminant concentrations in the secondary LCS than in the primary LCS leachate.

6.6.2 Leachate Volume

A review of records and O&M annual reports for the five-year review reporting period, revealed that

approximately 9,339 gallons of leachate have been removed from the leachate collection system between

January 2000 and August 2004. Leachate was not collected during the periods of September 2000

through May 2001, September 2001 through February 2002, September 2002 through October 2003.

Leachate collection data indicates that the BES remedial action complies with the ALR of 300 gallons per

day or 9,000 gallons per month. The ALR has never been exceeded during the five-year review reporting

period. Table 4 provides a summary of the monthly leachate collection volumes from January 2000 to

August 2004. Appendix D provides a summary of leachate levels and leachate elevation data for the five-

year review reporting period.

TABLE 3

SUMMARY OF REPORTED ANALYTE CONCENTRATIONS IN LEACHATE

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Analyte TRRP PCL 1 NPLCS NSLCS SPLCS SSLCS 3/28/02

Alkalinity N/A 405 410 320 360 Chlorides N/A 1980 403 2080 80 Nitrates 10.0 <2.00 <2.00 <2.00 <2.00 Sulfates N/A 24 24 336 1070 TDS N/A 3980 3980 4260 1840 Chlorobenzene 0.10 0.023 <0.005 <0.005 <0.005 Chloroethane 29.0 0.012 <0.010 <0.010 <0.010 1,2-Dichlorobenzene 0.60 0.006 <0.005 <0.005 <0.005 1,1-Dichloroethane 0.005 0.006 0.039 0.053 0.146 cis-1,2-Dichloroethene 0.070 <0.005 <0.005 0.005 0.006 Vinyl Chloride 0.002 0.006 0.012 0.005 <0.002

8/15/02 Alkalinity N/A 351 366 354 344 Chlorides N/A 358 426 2650 107 Nitrates 10.0 <2.00 <2.00 <2.00 <2.00 Sulfates N/A 660 713 552 1020 TDS N/A 2080 2200 3960 1910 Chlorobenzene 0.10 0.021 <0.005 0.007 <0.005 Chloroethane 29.0 <0.010 <0.010 <0.010 <0.010 1,2-Dichlorobenzene 0.60 0.007 <0.005 0.006 <0.005 1,1-Dichloroethane 7.3 0.009 0.036 0.068 0.121 cis-1,2-Dichloroethene 0.070 <0.005 <0.005 <0.005 0.005 Vinyl Chloride 0.002 0.003 0.022 0.007 <0.002

1/27/04 Alkalinity N/A 380 B 356 B NA 309 B Chlorides N/A 1,770 443 NA 66.7 Nitrates 10.0 <0.0318 0.204 NA 1.2 Sulfates N/A 95.4 646 NA 988 TDS N/A 3.800 2,170 NA 2,020 Chlorobenzene 0.10 0.0318 0.00408 NA 0.000252 J Chloroethane 29.0 0.00461 <0.0005 NA <0.0005 1,2-Dichlorobenzene 0.60 0.0066 0.00128 NA 0.000758 1,1-Dichloroethane 7.3 0.00566 0.0274 NA 0.0845 cis-1,2-Dichloroethene 0.070 0.000543 0.00171 NA 0.00537 Vinyl Chloride 0.002 0.00566 0.0159 NA 0.00067

8/4/04 Alkalinity N/A 359 316 NA 296 Chlorides N/A 1,770 497 NA 102 Nitrates 10.0 <0.50 <0.50 NA 0.28 B Sulfates N/A 96 758 NA 956 TDS N/A 3.720 2,180 NA 1,910

TABLE 3 (Continued)

SUMMARY OF REPORTED ANALYTE CONCENTRATIONS IN LEACHATE

22

Analyte TRRP PCL 1 NPLCS NSLCS SPLCS SSLCS 3/28/02

Chlorobenzene 0.10 0.023 0.0013 NA <0.0010 Chloroethane 29.0 0.0059 0.00029 J NA 0.00038 J 1,2-Dichlorobenzene 0.60 0.0046 0.00047 J NA 0.00057 J 1,1-Dichloroethane 7.3 0.0084 0.022 NA 0.042 cis-1,2-Dichloroethene 0.070 0.0011 0.0066 NA 0.0055 Vinyl Chloride 0.002 0.011 0.051 NA 0.018 Notes: 1 TRRP Tier 1 PCLs are equivalent to EPA MCLs, where applicable. Number highlighted in bold exceed the TRRP Tier 1 PCL. J Qualified as estimated because the detected value is less than the reporting limit. NA Not analyzed N/A Not applicable NPLCS Northern primary leachate collection system NSLCS Northern secondary leachate collection system SPLCS Southern primary leachate collection system SSLCS Southern secondary leachate collection system

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TABLE 4

SUMMARY OF LEACHATE COLLECTION VOLUMES

Date Leachate Collection in Gallons NPLCS NSLCS SPLCS SSLCS Monthly Total

January 2000 20 56 25 175 276 February 2000 38 25 16 85 164 March 2000 88 51 25 150 314 April 2000 68 25 37 190 320 May 2000 50 25 25 150 250 June 2000 75 20 6 160 261 July 2000 60 25 35 186 306 August 2000 83 13 29 143 268 June 2001 0 100 0 200 300 July 2001 100 100 50 200 450 August 2001 5 100 5 200 310 August 27, 2001 0 20 10 200 250 March 28, 2002 150 100 50 100 400 April 26, 2002 50 200 50 200 500 May 8, 2002 100 250 100 250 700 June 11, 2002 75 200 50 200 525 July 17, 2002 50 200 50 200 500 August 15, 2002 10 75 15 70 170 November 26, 2003 200 35 0 30 265 December 29, 2003 150 100 0 170 420 January 27, 2004 100 90 0 210 400 February 25, 2004 98 70 0 110 278 March 30, 2004 140 80 0 210 430 April 30, 2004 60 38 0 175 273 May 21, 2004 105 40 0 190 335 July 2, 2004 99 30 0 180 309 August 3, 2004 110 50 0 205 365

Total from 1/00 to 8/04 2084 2118 578 4539 9,339

Notes: NPLCS – northern primary leachate collection system NSLCS – northern secondary leachate collection system SPLCS – southern primary leachate collection system SSLCS – southern secondary leachate collection system

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6.6.3 Groundwater Contamination

Ground water collection and analysis has been conducted four times during the 5 year review reporting

period. Samples were submitted to a subcontracted laboratory for analysis of VOCs only. The 1984

ROD requires that ground water analysis should include at a minimum the following parameters; arsenic,

barium, cadmium, chromium, lead, mercury, selenium, silver, cyanide, pH, specific conductance, total

organic carbon, and total organic halogen. In addition, the ROD requires that one sample from a down-

gradient well and one sample from an up-gradient well be analyzed for priority pollutants. These ROD

requirements were not met during the five-year review period.

VOC analytical results for the ground water samples were compared to the most current RCRA

groundwater protection standards, TRRP Tier 1 PCLs, and EPA MCLs. Laboratory analyses of

groundwater samples showed that all contaminants associated with the leachate were below the applicable

RCRA groundwater protection standards, PCLs, and MCLs. cis-1,2-Dichloroethene was reported at

concentrations below the standards in samples collected from monitoring well MW-2 in January and

August 2004. 1,1-dichloroethene was reported at concentrations below the standards in samples collected

from monitoring wells MW-2 and MW-3 in January and August 2004.

Some constituents not associated with historical contamination at the site were reported at concentrations

exceeding the applicable PCLs and MCLs. In March 2002, methyl tert-butyl ether (MTBE) was reported

above the PCL and MCL in samples collected from monitoring wells MW-3 and MW-4. In August 2002,

benzene was reported above the PCL and MCL in samples collected from monitoring wells MW-1, MW-

2, MW-3, and MW-4. Other constituents not associated with historical contamination were reported

above detection limits but at concentrations below the state and federal protective standards including

ethylbenzene, toluene, xylenes, 1,2,4-trimethylbenzene. Table 5 provides an overview of groundwater

data from the previous sampling activities.

In summary, the remedial action objective of preventing the surface and subsurface migration of

contaminants to surface and subsurface water and adjacent property has been met. Monitoring results

show rare occurrences of contaminants in groundwater being found at concentrations above state and

federal protective standards; but in all instances, the constituents are not associated with historical

contamination at the site and are likely from off-site sources.

TABLE 5

SUMMARY OF REPORTED ANALYTE CONCENTRATIONS IN GROUNDWATER

25

Analyte TRRP PCL 1

MW-1 MW-2 MW-3 MW-4 MW-5 MW-6

3/28/02 MTBE 0.240 0.006 <0.005 1.250 1.390 0.043 <0.005

8/15/02 MTBE 0.240 0.007 <0.005 0.018 0.006 0.008 <0.005 Benzene 0.005 0.012 0.008 0.008 0.016 <0.005 <0.005 Ethylbenzene 0.70 0.012 0.010 0.010 0.023 <0.005 <0.005 Toluene 1.0 0.009 0.007 0.007 0.016 <0.005 <0.005 1,2,4-Trimethylbenzene

0.070 0.009 0.009 0.009 0.021 <0.005 <0.005

o-xylene 10.0 0.009 0.008 0.008 0.019 <0.005 <0.005 M,p-xylene 10.0 0.025 0.021 0.022 0.047 <0.005 <0.005

1/28/04 1,1-Dichloroethane

2.40 <0.0005 0.00252 <0.0005 <0.0005 <0.0005 <0.0005

cis-1,2-Dichloroethene

0.07 <0.0000710 0.020 0.000183 J <0.0000710 <0.0000710 <0.0000710

MTBE 0.240 0.00401 <0.0000697 0.0279 0.0016 0.00403 <0.0000697 Benzene 0.005 0.000125 J 0.0000839

J <0.0000697 <0.0000697 <0.0000697 <0.0000697

Toluene 1.0 <0.000124 0.000199 J 0.000168 J 0.000153 J 0.000157 J 0.00159 8/03/04

Acetone 220 <0.005 <0.005 0.0025 J 0.0016 J <0.005 NA 1,1-Dichloroethane

2.40 <0.001 0.0018 <0.001 <0.001 <0.001 NA

cis-1,2-Dichloroethene

0.07 <0.001 0.013 0.00022 J <0.001 <0.001 NA

1,4-Dichlorobenzene

0.075 <0.001 <0.001 0.00029 J 0.00041 J <0.001 NA

Carbon Disulfide 2.4 <0.0002 <0.0002 <0.0002 <0.0002 0.00023 J <0.0002 MTBE 0.240 0.0039 <0.001 0.0033 0.0024 0.0045 NA Benzene 0.005 0.0012 J 0.00091 J 0.000080 J 0.00017 J <0.0001 NA Ethylbenzene 0.70 0.00069 J <0.001 <0.001 <0.001 <0.001 NA Toluene 1.0 0.00018 J 0.00046 J 0.00028 J 0.00056 J 0.00021 J NA o-xylene 10.0 0.00019 J <0.001 <0.001 <0.001 <0.001 NA M,p-xylene 10.0 0.0034 0.00066 J <0.001 0.00034 J <0.001 NA

TABLE 5 (Continued)

SUMMARY OF REPORTED ANALYTE CONCENTRATIONS IN GROUNDWATER

26

Notes: 1 TRRP Tier 1 PCLs are equivalent to EPA MCLs, where applicable. Number highlighted in bold exceed the TRRP Tier 1 PCL. EPA – U.S. Environmental Protection Agency J – Qualified as estimated because the detected value is less than the reporting limit. MCL – maximum concentration level NA – not analyzed N/A – not appicable PCL – protective concentration level TRRP – Texas Risk Reduction Program

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6.6.4 Groundwater Elevation and Groundwater Flow

Ground water elevation data for the five-year review period is provided in Appendix E. An examination

of groundwater elevation data and potentiometric maps in the annual O&M reports, show that

groundwater elevations have increased slightly since February 1994. The groundwater gradient map for

August 2004 shows a southerly to southeasterly groundwater flow direction across the site, which is

consistent with previously reported groundwater flow at the site.

7.0 TECHNICAL ASSESSMENT

The conclusions presented in this section support the determination that the selected remedy for the BES

site is currently protective of human health and the environment. EPA Guidance indicates that to assess

the protectiveness of a remedy, three questions shall be answered.

Question A: Is the remedy functioning as intended by the decision documents?

• Remedial Action Performance— Based on review of documents, ARARs, and the site inspection, the selected site remedy has been completed in accordance with the 1984 ROD. Cleanup goals and performance standards were achieved as documented by the annual operation and maintenance reports.

• Cost of System Operations and O&M — The O&M cost for December 2001 to

October 2002 was approximately $38,000. The O&M cost for the fiscal year 2004, was approximately $25,000-30,000. The O&M cost for the fiscal year 2005, is estimated to also be approximately $25,000-30,000.

• Opportunities for Optimization — Maintenance activities associated with the issues

identified during the site inspection should be conducted as summarized in Table 7. • Early Indicators of Potential Issues — There is no indication of remedy failure. The

landfill is inspected on a regular basis and O&M activities are performed on the landfill as required.

• Implementation of Institutional Controls and Other Measures—Access to the

property remains limited by fencing and a locked entry gate. Repairs to the fencing along the northern site boundary are required as summarized in Table 7.

Question B: Are the assumptions used at the time of remedy selection still valid?

• Changes in Standards and to be Considered—There have been no changes that bear on the protectiveness of the remedy.

28

• Changes in Exposure Pathways— There have been no changes that bear on the protectiveness of the remedy.

• Changes in Toxicity and Other Contaminant Characteristics— There have been no

changes that bear on the protectiveness of the remedy. • Changes in Risk Assessment Methodologies— There have been no changes that bear

on the protectiveness of the remedy.

• Expected progress toward meeting RAOs – The remedial action objectives (RAO) relating to contaminated soil have been met. The RCRA compliant liner, cover, and LCS have been effective in isolating waste and contaminants.

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

• No other information has been identified that calls the protectiveness of the

selected remedy into question.

Technical Summary

According to documents and data reviewed, the site inspection, and the interviews, the remedy appears to

be functioning as intended by the 1984 ROD. There have been no changes in the physical conditions of

the site that would affect the protectiveness of the remedy. The ARARs cited in the ROD have been met.

There have been no changes in toxicity factors for the primary contaminants of concern and there has

been no change to the standardized risk assessment methodology that could affect the protectiveness of

the remedy. There is no other information that calls into question the protectiveness of the remedy.

8.0 ISSUES

This section describes issues associated with the BES site identified during the five-year review.



29



5. Cracking in Impoundment Cap – Several cracks approximately 2 inches deep and 15 feet long were observed along the southern fence line, but no cracks were observed in other areas.

6. Clogged SPLCS Sump – According to the 2004 O&M Annual Report and conversations with the O&M contractor, the SPLCS line appears to be clogged or occluded. No leachate has been collected from the sump since August 2002.

7. Ground Water Analysis - The 1984 ROD requires that ground water analysis should include at a minimum the following parameters; arsenic, barium, cadmium, chromium, lead, mercury, selenium, silver, cyanide, pH, specific conductance, total organic carbon, and total organic halogen. In addition, the ROD requires that one sample from a down-gradient well and one sample from an up-gradient well be analyzed for priority pollutants. These ROD requirements were not met during the five-year review period.


Table 6 is a summary table of issues and their effect on remedy protectiveness:

TABLE 6

IDENTIFIED ISSUES

Issue

Currently Affects Remedy Protectiveness

(Yes/No) Damaged Fence No

Heavy Vegetation/Tree Growth No

Polyethylene Storage Tanks and Drums No

Exposed monitoring wells No

Cracking in Impoundment Cap No

Clogged SPLCS Sump No

Ground Water Analysis No

Deed recordation No

30

9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS

Table 7 summarizes recommendations and follow-up actions for the BES site. TCEQ is responsible for

conducting follow-up actions.

10.0 PROTECTIVENESS STATEMENTS

Based on the information available during the third five-year review, the selected remedy for the

BES site appears to be performing as intended. The RA is protective of human health and the

environment.

11.0 NEXT REVIEW

The BES site requires ongoing five-year reviews. The next review will be conducted within the next 5

years, but no later than September 2010.

TABLE 7

RECOMMENDATIONS AND FOLLOW-UP ACTIONS

31

Issue Recommendations and

Follow-up Actions Party

Responsible Oversight Agency

Milestone Date

Follow-up Actions Affect Long-Term

Remedy Protectiveness (Yes/No)

Damaged Fence Repair damage to fencing and barbed wire along the northern boundary of the site.

TCEQ EPA Within 1 year of submittal of this report

No

Heavy Vegetation/Tree Growth

Remove established tree growth and other heavy vegetation on top of the cap and around the risers on both sides of the cap. Any damage to the cap during removal activities should be repaired. Remove new tree growth and reduce height of vegetative growth during each regularly scheduled landscaping maintenance event.

TCEQ EPA During next lawn maintenance event

No

Polyethylene Storage Tanks and Drums

Removed unused and damaged drums and polyethylene storage tanks from the site. Place labels providing content and site contact information on all active drums and polyethylene storage tanks. Designate one or more staging areas for all active drums and polyethylene storage tanks.


No

Exposed Monitoring Wells

Install new monitoring well caps on the four monitoring wells observed with no caps. Install locks on all six monitoring wells. Ensure all locks are replaced on the monitoring wells after each sampling event.

TCEQ EPA During next scheduled O&M site visit

No

TABLE 7 (Continued)

RECOMMENDATIONS AND FOLLOW-UP ACTIONS

32

Issue Recommendations and

Follow-up Actions Party

Responsible Oversight Agency

Milestone Date

Follow-up Actions Affect Long-Term

Remedy Protectiveness (Yes/No)

Cracking of Impoundment Cap

Place fill material in the cracks that were observed on the landfill cap along the southern fence line. Place grass sod, plugs, or seeds over the repaired landfill cap surface.


No

Clogged SPLCS sump

Assess SPLCS line for clogs or other blockages that may be preventing leachate collection. Conduct repairs as necessary to restore to working condition.


No

Ground Water Analysis

For all future ground water samples, analysis should include at a minimum the following parameters; arsenic, barium, cadmium, chromium, lead, mercury, selenium, silver, cyanide, pH, specific conductance, total organic carbon, and total organic halogen for all future ground water samp les collected at the site. In addition, one sample from a down-gradient well and one sample from an up-gradient well should also be analyzed for priority pollutants.

TCEQ EPA Prior to next ground water sampling event

No

Deed Recordation Determine if a notation on the deed or any instrument normally examined during a title search has been recorded for the BES property. If not, prepare and submit deed recordation documents as required.


No

Notes: EPA U.S. Environmental Protection Agency TCEQ Texas Commission of Environmental Quality

APPENDIX A

DOCUMENTS REVIEWED

(One Page)

A-1

DOCUMENTS REVIEWED

U.S. Environmental Protection Agency (EPA). 1988. CERCLA Compliance with Other Laws Manual. August.

EPA. 1984. CERCLA Record of Decision for Bio-Ecology Systems, Inc., EPA ID: TXD980340889, OU

01, Grand Prairie, Texas, June 6. Intera, Inc. 1993. “Specifications and Drawings for Site Operation and Maintenance Activities at the

Bio-Ecology Superfund Site, Grand Prairie, Texas.” November. Leigh Engineering, Inc. (Leigh Engineering). 1999. “Work Plan for the Operation and Maintenance of

the Bio-Ecology State Superfund Site for the time period of October 1999 through August 2000” prepared for TCEQ. October 7.

EPA. 2000. “Second Five-Year Review Report for the Bio-Ecology Systems, Inc. Site, Grand Prairie,

Dallas County, Texas.” September. Leigh Engineering. 2002. “Operations and Maintenance Annual Report Conducted February 2002 –

August 2002, Bio-Ecology, Grand Prairie, Texas, SUP #025” prepared for TCEQ. August. URS Corporation. 2004. “2004 Operations and Maintenance Annual Report, Bio-Ecology Superfund

Site, Sup. No. 025, Grand Prairie, Texas” prepared for TCEQ. August 31. EPA. 2005. “Bio-Ecology Systems, Inc., Texas, EPA ID#TXD980340889, Site ID: 0602464” fact sheet.

May 5.

APPENDIX B

SITE VISIT REPORT

(Seven Pages)

SITE VISIT REPORT FOR THIRD FIVE-YEAR REVIEW FOR

BIO-ECOLOGY SYSTEMS, INC. SUPERFUND SITE GRAND PRAIRIE, DALLAS COUNTY, TEXAS

Prepared for

United States Environmental Protection Agency Region 6

Dallas, Texas

Contract No. : 68-W6-0037 Work Assignment No. : 123-FRFE-0613 Date Prepared : August 29, 2005 Prepared by : Eric Johnstone, Tetra Tech EM Inc. Telephone No. : (214) 740-2001 EPA Remedial Project Manager : Mr. Ruben Moya Telephone No. : (214) 665-2755

B-1

CONTENTS

Section Page ACRONYMS AND ABBREVIATIONS.............................................................................................. B-2 1.0 INTRODUCTION .............................................................................................................. B-3 2.0 BACKGROUND ................................................................................................................. B-3 3.0 SITE VISIT ACTIVITIES ................................................................................................... B-4 4.0 FINDINGS ........................................................................................................................ B-4 REFERENCES ............................................................................................................................... B-6 Exhibit A PHOTOGRAPHS B SITE VISIT CHECKLIST

B-2

ACRONYMS AND ABBREVIATIONS BES Bio-Ecology Systems, Inc. EPA U.S. Environmental Protection Agency Region 6 LCS Leachate collection system RA Remedial action RAC Response Action Contract RCRA Resource Conservation and Recovery Act ROD Record of Decision Tetra Tech Tetra Tech EM, Inc.

B-3

1.0 INTRODUCTION

Tetra Tech EM Inc. (Tetra Tech) received Work Assignment No. 123-FRFE-0613 from U.S. Environmental

Protection Agency Region 6 (EPA) under Response Action Contract (RAC) No. 68-W6-037. Under this

work assignment, Tetra Tech was directed to conduct the third five-year review of the remedial action (RA)

implemented at the Bio-Ecology Systems, Inc. (BES) Superfund site in Grand Prairie, Texas.

Tetra Tech visited the site on August 24, 2005, to assess whether all components of the selected remedy are

operating in accordance with criteria established in the June 1984 Record of Decision (ROD). This report

provides background information on the site, summarizes site visit activities, and presents Tetra Tech’s

findings. References cited are listed at the end of this text. Exhibit A contains photographs taken during the

site visit, and Exhibit B contains the five-year review site visit checklist completed by Tetra Tech. Exhibit C

contains surveys that document interviews that were conducted during the site inspection and throughout the

five-year review process.

2.0 BACKGROUND

The BES site is located at 4100 East Jefferson Avenue in Grand Prairie, Dallas County, Texas. The site

consists of approximately 11.2 acres of land. The Bio-Ecology site is approximately 2 miles south of

Interstate Highway 30 between Fort Worth and Dallas, Texas. The site is bounded in all directions by private

property (automobile salvage yards) and also on the north, east, and south by some form of Mountain Creek.

Mountain Creek Lake and the Trinity River are located approximately ¾ mile southwest and 2 ½ miles north,

respectively. The Bio-Ecology site is located within the 100-year floodplain of Mountain Creek (Trinity River

Basin). The area surrounding the Bio-Ecology site is primarily used for commercial purposes, mainly auto

salvage yards.

BES is a former waste disposal facility, which occupied a majority of the 11.2-acre area. BES was originally

a Class I industrial solid waste facility (actively operated from June 1972 to June 1978). Permitted activities

included: (1) incineration of combustible liquids, slurries, and sludge; (2) chemical treatment of acids,

caustics, and other waste chemical solutions, some of which contained heavy metals; (3) biological oxidation

of wastewaters resulting from separation of mud-water and oil-water mixtures from chemical treatment of

other wastes; and (4) a modified landfill of solids resulting from the other treatment processes.

B-4

BES was added to the National Priorities List in September 1983. The remedy for the site included

stabilization and confinement of approximately 40,000 cubic yards of wastes and highly contaminated soils in

a Resource Conservation Recovery Act (RCRA) compliant cell above the 100-year flood level of Mountain

Creek. The RCRA cell was completed and closed in April 1988. In August 1988, the final inspection was

completed, resulting in the issuance of the Certificate of Completion.

3.0 SITE VISIT ACTIVITIES

A site visit was conducted on August 24, 2005, to assess the condition of the site and the protective measures

employed to protect human health and the environment from the contaminants still present at the site.

The following individuals participated in the site visit:

• Eric Johnstone, Tetra Tech • Billy Bol, Tetra Tech

The site visit included evaluation of the landfill cap, including the monitoring wells, leak detection/clean out

vaults, postings, and site fencing. Photographs taken during the site visit are presented in Exhibit A, the

completed five-year review site visit checklist is presented in Exhibit B, and survey forms are presented in

Exhibit C. The site visit findings are summarized below.

The weather during the site visit was hot and dry with no cloud cover. No evidence of contamination was

visible at the site. The site was very overgrown with waist high flora. Trees and high brush were noted

along the fence line surrounding the site, with the densest growth noted along the northern and eastern

portions of the fence.

4.0 FINDINGS

No evidence of contamination was visible at the site. The vegetation at the site appeared to be similar to that

in typical surrounding areas.

B-5

Landfill Cap

The landfill was in good condition with no evidence of ants or burrowing animals. A few trees

(approximately 10 to 12 feet tall) were growing on top of the cap near several large poly tanks and 55-gallon

poly drums. Several cracks approximately 2 inches deep and 15 feet long were also observed along the

southern fence line, but no cracks were observed in other areas.

Leachate Collection System

The eight on-site leachate collection system (LCS) risers were padlocked and appeared to be in good

condition, although brush and small trees were located around the risers on both sides of the cap.

Monitoring Wells

None of the six monitoring wells were locked, and four did not contain caps. Two of the wells were

completely open and exposed to the weather.

Security Measures

Security measures at the site include an 8-foot high chain-link fence topped with four strands of barbed-wire.

Portions of barbed wire along the northern fence line are in need of repair. Tetra Tech also observed

damaged areas of the fence along the northern portion of the site, which appeared to be caused by empty

1,500-gallon purge water containers that had been pushed up against the fence line.

Vehicular access is limited during non-business hours by a locked gate at the site, and a locked, 12-foot high

gate topped with razor wire that separates the auto salvage yard from Jefferson Avenue.

B-6

REFERENCES

U.S. Environmental Protection Agency (EPA). 1984. CERCLA Record of Decision Bio-Ecology System,

Inc. Site, Grand Prairie, Texas, June.

EXHIBIT A

PHOTOGRAPHS

(Nine Pages)

Photographic Documentation Client: U.S. EPA Prepared by: Tetra Tech EMI Location: Bio-Ecology Superfund Site Photographer: Billy Bol Photograph Date: August 24, 2005 Project Number: G00DA11230413

Page 1 of 9

Photograph No. 1 Direction: North

Description: Photograph of front gate of Bio Ecology Superfund Site.


Description: Photograph of poly tanks and drums at center of site.


Page 2 of 9

Photograph No. 3 Direction: North-northeast

Description: Debris and poly tank near MW-1.

Photograph No. 4 Direction: Northeast

Description: Photograph of damages fence along northern site boundary.


Page 3 of 9

Photograph No. 5 Direction: South

Description: Photograph of northern leachate collection system risers.

Photograph No. 6 Direction: Northeast Description: Photograph of tree growth along northern fence.


Page 4 of 9

Photograph No. 7 Direction: Northwest

Description: Photograph of MW-2.

Photograph No. 8 Direction: South-southwest

Description: Photograph of MW-3 and drums.


Page 5 of 9

Photograph No. 9 Direction: South Description: Photograph of MW-4 and drum

.

Photograph No. 10 Direction: NA

Description: Photograph of wide crack in impoundment cap.


Page 6 of 9


Description: Photograph of southern leachate collection system risers.

Photograph No. 12 Direction: Southeast

Description: Photograph of MW-5 and drum.


Page 7 of 9

Photograph No. 13 Direction: East

Description: Photograph of MW-6.


Description: Photograph of vegetative growth along eastern fence.


Page 8 of 9


Description: Northern view of site from center of site.

Photograph No. 16 Direction: East

Description: Eastern view of site taken from center of site.


Page 9 of 9

Photograph No. 17 Direction: South

Description: Southern view of site taken from center of site.

Photograph No. 18 Direction: West

Description: Western view of site taken from center of site.

EXHIBIT B

SITE VISIT CHECKLIST

(Ten Pages)

1

FIVE-YEAR REVIEW SITE VISIT CHECKLIST

I. SITE INFORMATION

Site Name: Bio-Ecology Systems, Inc. Site Date of Inspection: 8-24-05

Location and Region: Grand Prairie, Texas / Region 6 EPA ID: TXD980340889

Agency, office, or company leading the five-year review: Tetra Tech EM Inc.

Weather/temperature:

Hot, humid, and sunny, with highs in the upper 90s

Remedy Includes: (Check all that apply) Landfill cover/containment Ground water pump and treatment Access controls Surface water collection and treatment Institutional controls Other-Leachate collection and treatment

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (Check all that apply)

1. O&M Site Manager ___X___ Name: Michael J. Wisniowiecki, Conestoga-Rovers & Associates Title: Project Manager Date: 7/29/05

Interviewed: by mail at site by phone Phone no. Problems, suggestions: None.

Report attached

2. O&M Staff X Name: Adolfo Cepeda, Hatch Mott MacDonald Title: Operator Date: 7/29/05

Interviewed: by mail at site by phone Phone no. Problems, suggestions: Sludge out clarifier pipeline in the GWTP is corroded and needs to be

replaced.

Report attached

3. Local regulatory authorities and response agencies (i.e.; State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.). Fill in all that apply.

Agency

Contact Name Title Date Phone no.

Problems, suggestions: Report attached

2

4. Other interviews (optional): Report attached

III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1. O&M Documents O&M manual (long term monitoring plan) Readily available Up to date N/A As-built drawings Readily available Up to date N/A Maintenance logs

(annual inspection reports) Readily available Up to date N/A Remarks:

2. Site-Specific Health and Safety Plan Readily available Up to date N/A Contingency plan/emergency response plan Readily available Up to date N/A

Remarks:.

3. O&M and OSHA Training Records Readily available Up to date N/A Remarks: At Corporate office of Hatch Mott MacDonald.

4. Permits and Service Agreements Air discharge permit Readily available Up to date N/A Effluent discharge Readily available Up to date N/A Waste disposal, POTW Readily available Up to date N/A Other permits Readily available Up to date N/A

Remarks:

5. Gas Generation Records Readily available Up to date N/A

6. Settlement Monument Records Readily available Up to date N/A

7. Ground Water Monitoring Records Readily available Up to date N/A Remarks: Available from URS

8. Leachate Extraction Records Readily available Up to date N/A

9. Discharge Compliance Records Air Readily available Up to date N/A Water (effluent) Readily available Up to date N/A

Remarks:.

10. Daily Access/Security Logs Readily available Up to date N/A Remarks:

IV. O&M COSTS

3

1. O&M Organization

State in-house Contractor for State PRP in-house

Contractor for PRP Other

2. O&M Cost Records

Readily available Up to date Funding mechanism/agreement in place

Original O&M cost estimate Breakdown attached

Total annual cost by year for review period, if available

Date Date Total Cost

From: March 2001 October 2001 $24,000 estimate Breakdown attached From: Dec. 2001 October 2002 $14,000 estimate Breakdown attached From: Oct. 2003 September 2004 $25,000 – 35,000 Breakdown attached From: Oct. 2004 September 2005 $25,000 – 35,000 Breakdown attached

Remarks: Estimated O&M costs provided by Sonya Williams of Leigh Engineering and Tom Wiberg of URS

3. Unanticipated or Unusually High O&M Costs During Review Period

None.

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing

1. Fencing damaged Location shown on site map Gates secured N/A

Remarks: Fence line damaged at northern boundary of property.

B. Other Access Restrictions

1. Signs and other security measures Location shown on site map N/A

Remarks:

4

C. Institutional Controls

1. Implementation and enforcement Site conditions imply ICs not properly implemented Yes No N/A Site conditions imply ICs not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by) Site Inspections Frequency Quarterly Responsible party/agency URS / TCEQ Contact Tom Wibery, Project Manager, 972-406-6950 Name Title Date Phone no.

Reporting is up-to-date Yes No N/A Reports are verified by the lead agency Yes No N/A Specific requirements in deed or decision documents have been met Yes No N/A Violations have been reported Yes No N/A

Other problems or suggestions: Report attached 2. Adequacy ICs are adequate ICs are inadequate N/A

Remarks:

D. General 1. Vandalism/trespassing Location shown on site map No vandalism evident

Remarks: No trespassing or vandalism was present within the fenced compounds.

2. Land use changes onsite N/A Remarks:

3. Land use changes offsite N/A Remarks:

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A Remarks: In good condition, no pot holes or major structural problems observed.

B. Other Site Conditions Remarks:

VII. LANDFILL COVERS - monofill Applicable N/A A. Landfill Surface – (monofill surface) 1. Settlement (Low spots) Location shown on site map Settlement not evident

Areal extent Depth Remarks:

2. Cracks Location shown on site map Cracking not evident Lengths Widths Depths Remarks: Cracks noted along the southern boundary at the bottom of the landfill cap

5

3. Erosion Location shown on site map Erosion not evident Areal extent Depth Remarks:

4. Holes Holes evident Holes not evident Areal extent Depth Remarks:

5. Vegetative Cover Grass Cover properly established No signs of stress Trees/Shrubs (indicate size and locations on a diagram) (None)

Remarks: Several ruts were observed in the grass surface cover that appear to be caused by the landscaping maintenance vehicles that mowed the grass the week prior to the site visit.

6. Alternative Cover (armored rock, concrete, etc.) N/A Remarks:

7. Bulges Location shown on site map Bulges not evident Areal extent Depth Remarks:

8. Wet Areas/Water Damage Wet areas/water damage not evident Wet areas Location shown on site map Areal extent Ponding Location shown on site map Areal extent Seeps Location shown on site map Areal extent Soft subgrade Location shown on site map Areal extent

Remarks:

9. Slope Instability Slides Location shown on site map No evidence of slope instability Areal extent

Remarks:

B. Benches Applicable N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench Location shown on site map N/A or okay Remarks:

2. Bench Breached Location shown on site map N/A or okay Remarks:

3. Bench Overtopped Location shown on site map N/A or okay Remarks:

C. Letdown Channels Applicable N/A (Channel lined with erosion control mats, rip rap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

1. Settlement Location shown on site map No evidence of settlement Areal extent Depth Remarks:

2. Material Degradation Location shown on site map No evidence of degradation

6

Material type Areal extent Remarks:

3. Erosion Location shown on site map No evidence of erosion Areal extent Depth Remarks:

4. Undercutting Location shown on site map No evidence of undercutting Areal extent Depth Remarks:

5. Obstructions Type No obstructions Location shown on site map

Areal extent Size Remarks:

6. Excessive Vegetative Growth Type No evidence of excessive growth Vegetation in channels does not obstruct flow Location shown on site map Areal extent

Remarks: D. Cover Penetrations Applicable N/A 1. Gas Vents Active Passive Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs O&M N/A

Remarks: 2. Gas Monitoring Probes

Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs O&M N/A

Remarks: 3. Monitoring Wells (within surface area of landfill)

Evidence of leakage at penetration Needs O&M N/A Remarks:

4. Leachate Extraction Wells Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs O&M N/A

Remarks: 5. Settlement Monuments Located Routinely surveyed N/A

Remarks: E. Gas Collection and Treatment Applicable N/A 1. Gas Treatment Facilities

Flaring Thermal destruction Collection for reuse Good condition Needs O&M

Remarks: 2. Gas Collection Wells, Manifolds, and Piping Good condition Needs O&M

Remarks: 3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

Good condition Needs O&M N/A

7

Remarks: F. Cover Drainage Layer Applicable N/A 1. Outlet Pipes Inspected Functioning N/A

Remarks: 2. Outlet Rock Inspected Functioning N/A

Remarks:

G. Detention/Sedimentation Ponds Applicable N/A 1. Siltation Areal extent Size

N/A Siltation not evident Remarks: 2. Erosion Areal extent Depth

Erosion not evident Remarks:

3. Outlet Works Functioning N/A Remarks:

4. Dam Functioning N/A Remarks:

H. Retaining Walls Applicable N/A 1. Deformations Location shown on site map Deformation not evident

Horizontal displacement Vertical displacement Rotational displacement Remarks:

2. Degradation Location shown on site map Degradation not evident Remarks:

I. Perimeter Ditches/Off-Site Discharge Applicable N/A 1. Siltation Location shown on site map Siltation not evident

Areal extent Depth Remarks:

2. Vegetative Growth Location shown on site map N/A Vegetation does not impede flow

Areal extent Type Remarks:

3. Erosion Location shown on site map Erosion not evident Areal extent Depth Remarks:

4. Discharge Structure Functioning N/A Remarks:

VIII. VERTICAL BARRIER WALLS Applicable N/A 1. Settlement Location shown on site map Settlement not evident

Areal extent Depth

8

Remarks: 2. Performance Monitoring Type of monitoring

Performance not monitored Frequency Evidence of breaching Head differential

IX. GROUND WATER/SURFACE WATER REMEDIES Applicable N/A A. Ground Water Extraction Wells, Pumps, and Pipelines Applicable N/A 1. Pumps, Wellhead Plumbing, and Electrical

Good condition All required wells located Needs O&M N/A Remarks:

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs O&M

Remarks: Need to vaccum or evaporate standing water in vaults. 3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided Remarks: Some parts are readily available, most parts are ordered on an as needed basis.

B. Surface Water Collection Structures, Pumps, and Pipelines Applicable N/A 1. Collection Structures, Pumps, and Electrical

Good condition Needs O&M Remarks:

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs O&M

Remarks: 3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided Remarks:

9

C. Treatment System Applicable N/A

1. Treatment Train (Check components that apply) Metals removal Oil/water separation Bioremediation Air stripping Carbon absorbers Filters Additive (e.g., chelation agent, flocculent) Others Good condition Needs O&M Sampling ports properly marked and functional Sampling/maintenance log displayed and up to date Equipment properly identified Quantity of ground water treated annually Quantity of surface water treated annually

Remarks:

2. Electrical Enclosures and Panels (Properly rated and functional) N/A Good condition Needs O&M

Remarks:

3. Tanks, Vaults, Storage Vessels N/A Good condition Proper secondary containment Needs O&M

Remarks: 4. Discharge Structure and Appurtenances

N/A Good condition Needs O&M Remarks:

5. Treatment Building(s) N/A Good condition (esp. roof and doorways) Needs repair Chemicals and equipment properly stored

Remarks: 6. Monitoring Wells (Pump and treatment remedy)

Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs O&M N/A

Remarks:

D. Monitored Natural Attenuation Applicable N/A 1. Monitoring Wells (Natural attenuation remedy)

Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs O&M N/A

Remarks:

X. OTHER REMEDIES If there are remedies applied at the site that are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS

10

A. Implementation of the Remedy Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.).

The synthetic lined cap is designed to contain contaminated soils. Some small trees are growing on the top center of the cap, near the purge water tanks. The root system could potentially damage the cap liner. The fence needs repair on the northern boundary. Small trees and brush are around the leachate risers. Most of the monitoring wells were open, without caps.

B. Adequacy of O&M

O&M activities at the site are adequate, except for some damage to the fenceline and small trees growing on top of the cap and along the fenceline.

C. Early Indicators of Potential Remedy Failure

There is no indication of remedy failure. The remedies are being implemented effectively and are functioning as designed.

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. Routine maintenance activities associated with the issues discussed in the 5-Year Review Report should be conducted.

EXHIBIT C

SURVEYS

(Seven Pages)

C-1

INTERVIEW RECORD

The following is a list of individuals interviewed for this five-year review. See the attached contact record(s) for a detailed summary of the interviews. Sonya Williams Previous O&M Program Manager Leigh Engineering, Inc. 9/6/05 Name Title/Position Organization Date Tom Wiberg O&M Program Manager URS Corporation 9/6/05 Name Title/Position Organization Date Arnold Sanchez Office Manager Auto Parts House 9/6/05 Name Title/Position Organization Date Julie Lozano Unknown Dallas Import Auto 9/6/05 Name Title/Position Organization Date

C-2

INTERVIEW RECORD

Site Name: Bio-Ecology Systems, Inc. EPA ID No.: TXD980340889

Subject: 5-Year Review Time: afternoon Date: 9/8/05

Type: : Telephone 9 Visit 9 Other Location of Visit: N/A

9 Incoming : Outgoing

Contact Made By:

Name: Courtney Nichols Title: Environmental Scientist Organization: Tetra Tech EM Inc.

Individual Contacted: Name: Alvie Nichols Title: Remedial Project

Manager Organization: TCEQ

Telephone No.: (512) – 239-2439 Fax No.: N/A E-Mail Address: N/A

Street Address: N/A City, State, Zip: N/A

Summary of Conversation Ms. Nichols contacted Mr. Alvie Nichols regarding the BES site. Mr. Nichols informed Ms. Nichols that he was just assigned as the RPM for the project that same day. Mr. Nichols informed Ms. Nichols that he needed additional time to review the project before he could provide any information.

C-3

INTERVIEW RECORD

Site Name: Bio-Ecology Systems, Inc. EPA ID No.: TXD980340889 Subject: 5-Year Review Time: morning Date: 9/6/05 Type: : Telephone 9 Visit 9 Other Location of Visit: N/A


Contact Made By: Name: Courtney Nichols Title: Environmental Scientist Organization: Tetra Tech EM Inc.

Individual Contacted: Name: Sonya Williams Title: Previous Project

Program Manager Organization: Leigh Engineering,

Inc. Telephone No.: (214)-630-9745 Fax No.: N/A E-Mail Address: N/A

Street Address: 4100 E. Jefferson City, State, Zip: Grand Prairie, Texas

Summary of Conversation Ms. Nichols asked Ms. Williams five questions. The questions and answers are summarized below. 1. From what period of time was Leigh Engineering, Inc. the O&M Contractor during the 5-Year review reporting period? – Ms. Nichols Answer: From 1999 until approximately October 2002 – Ms. Williams 2. Did you notice any changes at the site during the period in which Leigh Engineering managed the site O&M activities? – Ms. Nichols Answer: Only that frequency of groundwater monitoring was reduced from quarterly to semi-annual. There was also a period of time, approximately 6 months, in which no operations were conducted due to TCEQ budget issues. – Ms. Williams. 3. Do you have any observations or suggestions that could improve the O&M of the site remedy? – Ms. Nichols Answer: None, frequency of monitoring was already reduced to cut O&M costs. – Ms. Nichols 4. What were the O&M costs per year when Leigh Engineering managed the site O&M activities? Answer: March 2001 to October 2001 – approx. $23,800 and December 2001 to October 2002 – approx. $14,000 These are the only cost estimates available for the reporting period. 5. Did you have any problems with tree or heavy vegetation growth on the cap? Answer: Yes, that was an issue. I can see the need for more frequent lawn maintenance events.

C-4

INTERVIEW RECORD




Individual Contacted: Name: Tom Wiberg Title: Project Manager Organization: URS Corporation Telephone No.: (972) 406-6950 Fax No.: N/A E-Mail Address: N/A

Street Address: City, State, Zip:

Summary of Conversation Ms. Nichols asked Mr. Wiberg five questions. The questions and answers are summarized below. 1. How long as URS been the O&M contractor for the BES site? – Ms. Nichols Answer: Since the beginning of fiscal year 2004 – Mr. Wiberg 2. Have you noticed any changes at the site since taking over the site O&M management? – Ms. Nichols Answer: No, monitoring data has been consistent. One of the leachate lines appears to be clogged because in the past year, less and less leachate has been recovered and now no leachate is getting through the clogged line. We have notified TCEQ of the issue but no assessment or repairs have been conducted yet. – Mr. Wiberg. 3. Do you have any observations or suggestions that could improve the O&M of the site remedy? – Ms. Nichols Answer: We could consider reducing the frequency of sampling from semi-annually to annually since the concentrations are low enough and have remained stable over time. – Mr. Wiberg 4. What has been the O&M costs annually since URS took over management O&M activities? – Ms. Nichols Answer: Approximately $25,000-30,000 annually – Mr. Wiberg 5. Are you aware of the heavy vegetation growth and tree growth on and near the cap? – Ms. Nichols Answer: I don’t think there is any tree growth on the cap, but there is tree growth along the fenceline that may eventually lead to damage to the fenceline. I recommend beyond just conducting the usual lawn maintenance that we schedule a heavy cutting and clearning event to remove the tree growth. – Mr. Wiberg

C-5

INTERVIEW RECORD




Individual Contacted: Name: Arnold Sanchez Title: Office Manager Organization: Auto Parts House Telephone No. : (972) 263-0397 Fax No.: E-Mail Address:


Summary of Conversation Ms. Nichols asked Mr. Sanchez two questions. The questions and Mr. Sanchez’s responses are summarized below. 1. Have you had any problems with site operations or with any of the contractors? Answer: None. – Mr. Sanchez 2. Have you had any problems with contractors using the site access road that runs through your property? Answer: No, the contractors come every once in a while and request access to the property and there have never been any problems.

C-6

INTERVIEW RECORD




Individual Contacted: Name: Julie Lozano Title: unknown Organization: Dallas Import Auto Telephone No.: (972) – 642-2222 Fax No.: E-Mail Address:


Summary of Conversation The Dallas Import Auto facility is located adjacent to the BES site. Ms. Nichols asked Ms. Lozano one question regarding the BES site. The question and Ms. Lozano’s answer are summarized below. 1. Have you had any problems with site operations or with any of the contractors with work at the adjacent BES site? Answer: We are not aware of the site being adjacent to our facility and do not have any issues with the property. – Ms. Lozano

APPENDIX C

PUBLIC NOTICE

(One Page)

BIO-ECOLOGY SYSTEMS INC. SUPERFUND SITE PUBLIC NOTICE

U.S. EPA Region 6 Begins Third Five-Year Review of Site Remedy

The U.S. Environmental Protection Agency (EPA) Region 6 is conducting a third Five-Year Review of the remedy for the Bio-Ecology Systems Inc. Superfund Site (site). The site is located at 4100 East Jefferson Avenue in Grand Prairie, Dallas County, Texas. The purpose of the Five-Year Review is to evaluate if the site remedy is still protective of human health and the environment. The selected site remedy included consolidating and capping contaminated soils on-site in a synthetic/clay lined cell and cap to prevent direct contact and rainwater infiltration. The report summarizing the Five-Year Review is scheduled to be completed by September 2005. Once completed, the results of the Five-Year Review will be made available to the public at the following location:

Grand Prairie Library -Main Library 901 Conover Drive, Grand Prairie, Texas 75051

For more information about the Site, contact: Mr. Ruben Moya - Remedial Project Manager

U.S. Environmental Protection Agency, Region 6, (Mail Code 6SF-LP) 1445 Ross Avenue, Suite 1200, Dallas, Texas 75202-2733

[email protected] (214) 665-2755 or you may call EPA’s toll free number in Dallas at (800) 533-3508

Information about the Site also is available on the Internet at www.epa.gov/region6/superfund.

APPENDIX D

SUMMARY OF LEACHATE LEVELS AND LEACHATE ELEVATION DATA

(One Page)

D-1

SUMMARY OF LEACHATE LEVELS AND LEACHATE ELEVATION DATA

Date NPLCS NSLCS SPLCS SSLCS Leachate

Depth (ft) Elevation (ft MSL)

Leachate Depth (ft)

Elevation (ft MSL)

Leachate Depth (ft)

Elevation (ft MSL)

Leachate Depth (ft)

Elevation (ft MSL)

January 2000 3.6 409.1 2.8 405.7 2.9 409.0 3.4 405.8 February 2000 4.0 409.2 2.9 405.7 3.6 409.2 3.3 405.8 March 2000 4.0 409.2 3.0 405.7 3.6 409.2 3.3 405.8 April 2000 3.3 409.0 2.7 405.7 3.0 409.0 3.0 405.7 May 2000 4.0 409.2 4.0 406.0 4.3 409.3 3.3 405.8 June 2000 4.1 409.2 3.0 405.7 2.7 409.0 1.4 405.3 July 2000 4.0 409.2 3.1 405.7 3.8 409.2 3.0 405.7 August 2000 3.8 409.1 3.2 405.8 3.5 409.1 3.0 405.7 June 2001 1.1 408.5 3 405.7 3.3 409.1 3.8 405.9 July 2001 5.0 409.4 6 406.5 1.8 408.7 5.1 406.2 August 2001 1.50 408.6 3.25 405.8 3.5 409.1 4.1 406.0 August 27, 2001 3.90 409.1 2.9 405.7 4.0 409.3 3.9 405.9 March 28, 2002 4.70 409.3 3.5 405.8 3.6 409.2 4.2 406.0 April 26, 2002 7.6 410.0 2.0 405.5 2.1 408.8 4.0 406.0 May 8, 2002 7.9 410.1 2.2 405.5 2.9 409.0 8.2 407.0 June 11, 2002 3.3 409.0 6.5 406.6 2.9 409.0 6.3 406.5 July 17, 2002 4.00 409.2 7.08 406.7 3.17 409.1 6.83 406.7 August 15, 2002 2.00 408.7 5.17 406.2 3.50 409.1 5.75 406.4 October 29, 2003 1.5 ND 3 ND 0 ND 2 ND November 26, 2003 5 ND 3.7 ND 3.5 ND 4 ND December 29, 2003 4 ND 3 ND 0.5 ND 4 ND January 27, 2004 3 ND 3.5 ND 1.3 ND 3.5 ND February 25, 2004 2.5 ND 2 ND 0 ND 2.5 ND March 30, 2004 4.5 ND 3 ND 2 ND 4 ND April 30, 2004 2.8 ND 2.5 ND 0,3 ND 2.9 ND May 21, 2004 4 ND 2 ND 2.2 ND 3.5 ND July 2, 2004 4 ND 1.4 ND 1.8 ND 4.4 ND August 3, 2004 3.8 ND 2 ND 2.3 ND 4.4 ND Notes: ft – Feet MSL – Mean sea level ND – Not determined NPLCS – Northern primary leachate collection system NSLCS - Northern secondary leachate collection system SPLCS – Southern primary leachate collection system SSLCS - Southern secondary leachate collection system

APPENDIX E

SUMMARY OF GROUNDWATER ELEVATION DATA

(One Page)

E-1

SUMMARY OF GROUNDWATER ELEVATION DATA

Date

Elevation of TOC (ft MSL)

Depth to Groundwater

Elevation (ft MSL)

MW-1 5-3-01 22.12 416.11 8-27-01 22.38 415.85 3-28-02 21.93 416.30 8-15-02 21.96 416.27 1-27-04 21.45 416.78 8-3-04

438.23

21.09 417.14 MW-2

5-3-01 25.90 412.93 8-27-01 25.87 412.96 3-28-02 25.92 412.91 8-15-02 25.90 412.93 1-27-04 26.35 412.48 8-3-04

438.83

25.12 413.71 MW-3

5-3-01 41.17 397.10 8-27-01 41.72 396.55 3-28-02 40.94 397.33 8-15-02 41.04 397.23 1-27-04 40.95 397.32 8-3-04

438.27

40.34 397.93 MW-4

5-3-01 41.37 397.11 8-27-01 42.05 396.43 3-28-02 41.16 397.32 8-15-02 41.33 397.15 1-27-04 41.17 397.31 8-3-04

438.48

40.58 397.90 MW-5

5-3-01 40.95 397.33 8-27-01 41.50 396.78 3-28-02 40.75 397.53 8-15-02 40.78 397.50 1-27-04 40.64 397.64 8-3-04

438.28

40.31 397.97 MW-6

5-3-01 32.95 403.79 8-27-01 33.24 403.50 3-28-02 32.51 404.23 8-15-02 32.84 403.90 1-27-04 32.20 404.54 8-3-04

436.74

31.99 404.75

Notes: ft – Feet MSL – Mean sea level TOC – Top of casing