FIVE-YEAR REVIEW REPORT FOR THE BAILEY WASTE … · 5.0 five-year review progress 15 6.0 five-year review process 15 6.1 administrative components 15 6.2 community involvement 16

FIVE-YEAR REVIEW REPORTFOR THE

BAILEY WASTE DISPOSAL SITEORANGE COUNTY, TEXAS

September 2005

Prepared for

U.S. ENVIRONMENTAL PROTECTION AGENCYREGION 6

DALLAS, TEXAS

Prepared by

TETRA TECH EM INCContract No. 68-W6-0037

Work Assignment No. GOODA11230477

195604

SECOND FIVE-YEAR REVIEW

Bailey Waste Disposal Site EPA ID#TXD980864649 Orange County, Texas

This memorandum documents the approval by the U.S. Environmental ProtectionAgency (EPA) of the second Bailey Waste Disposal Site Five-Year Review Report.

Summary of Five-Year Review Findings

The site remedy called for excavation and off-site disposal of the most problematic (i.e.,mobile) waste followed by the on-site consolidation and capping of the remaining contaminatedsoils. The site's construction activities were completed in August 1997. The site's caps areeffective ai containing contaminants by preventing infiltration of rainwater and by preventingdirect contact with contaminated soils. The site's caps, fences, and access bridge are in goodcondition. Minor erosion, small desiccation cracking, and animal activity (i.e., burrowing) wereobserved during the site inspection. The lack of institutional controls is a noted deficiency.

Actions Needed

To achieve the long-term effectiveness of the remedy, it will be necessary to maintain theintegrity and effectiveness of the final cover in accordance with approved plans, includingmaking repairs to the caps as necessary to correct the effects of erosion, desiccation cracking,and animal activities. Institutional controls ensuring the remedy's long-term protectiveness arecurrently being pursued by EPA through the Texas Commission on Environmental Quality'sTexas Risk Reduction Rules (§ 350.111).

Determinations

I have determined that the selected remedy for the Bailey Waste Disposal site isprotective of human health and the environment and will remain so provided the action itemsidentified in the Five-Year Review Report are addressed as described above.

CONCURRENCES:

SECOND FIVE-YEAR REVIEW FORBAILEY WASTE DISPOSAL SITE

EPA ID No. TXD980864649

Chris VillarrealRemedial Project Manager

Gus ChavarriaSection Chief

Date:

Date:

Anne FosterRegional_Cxatasel

! PeyckeChief, Regional Counsel

D john HepolaChief, AR/TX Branch

Da.e:

Dace: C"?

Date:

PanUla Phillips \ V.Deputy Division Director, Superfund Division

Date:

I

CONTENTS

Section Page

ACRONYMS AND ABBREVIATIONS iii 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 ACTION 9 4.1 SELECTED REMEDY 9 4.2 REMEDY IMPLEMENTATION 9 4.3 OPERATION AND MAINTENANCE 12 4.4 OPERATION AND MAINTENANCE COST 14

5.0 FIVE-YEAR REVIEW PROGRESS 15 6.0 FIVE-YEAR REVIEW PROCESS 15

6.1 ADMINISTRATIVE COMPONENTS 15 6.2 COMMUNITY INVOLVEMENT 16 6.3 SITE INSPECTION 16 6.4 LOCAL INTERVIEWS 17 6.5 ARAR REVIEW 18 6.6 DATA REVIEW 19

7.0 TECHNICAL ASSESSMENT 19 8.0 ISSUES 21 9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS 22 10.0 PROTECTIVENESS STATEMENT 24 11.0 NEXT REVIEW 24

Appendices

A DOCUMENTS REVIEWED B SITE VISIT REPORT C PUBLIC NOTICE

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FIGURES

Figure Page

1 SITE LOCATION MAP 5 2 SITE LAYOUT MAP 7

TABLES

Table Page

1 CHRONOLOGY OF SITE EVENTS 3 2 ANNUAL OPERATION AND MAINTENANCE COSTS 15 3 IDENTIFIED ISSUES 25 4 RECOMMENDATIONS AND FOLLOW-UP ACTIONS 26

EXHIBITS

Exhibit

A SITE VISIT PHOTOGRAPHS B SITE INVESTIGATION CHECKLIST C SURVEYS

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ACRONYMS AND ABBREVIATIONS

§ Section ARARs Applicable or relevant and appropriate requirements BWD Bailey Waste Disposal BSSC Bailey Site Settlor's Committee CD Consent Decree CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COC Contaminants of concern CWM Chemical Waste Management EPA United States Environmental Protection Agency ESD Explanation of Significant Differences FFS Focused Feasibility Study FS Feasibility Study GeoSyntec GeoSyntec Consultants HLA Harding Lawson Associates IMMP Inspection, Maintenance, and Monitoring Plan NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List OHM OHM Remediation Services O&M Operation and maintenance OSWER Office of Solid Waste and Emergency Response Parsons Parsons Engineering Science, Inc. PRP Potentially responsible party RAC Response Action Contract RCRA Resource Conservation and Recovery Act RI Remedial Investigation ROD Record of Decision USEPA United States Environmental Protection Agency TAG Texas Administrative Code TBC To be considered TCEQ Texas Commission on Environmental Quality Tetra Tech Tetra Tech EM Inc. TNRCC Texas Natural Resource Conservation Commission TSWQS Texas Surface Water Quality Standard TWC Texas Water Commission WCC Woodward-Clyde Consultants

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EXECUTIVE SUMMARY

The U.S. Environmental Protection Agency Region 6 (EPA) has conducted the second five-yearreview of the remedial action (RA) implemented at the Bailey Waste Disposal (BWD) Site,approximately 3 miles southwest of Bridge City in Orange County. Texas. The purpose of thisfive-year review was to determine whether the selected remedy for the site continues to protecthuman health and the environment. This review was conducted from June to September 2005,and its findings and conclusions are documented in this report. The first five-year review of theRA was completed in September 2000. The second five-year review period extended from 2000to 2005.

Several documents were reviewed as part of this five-year review: the 1989 Consent Decree, theEPA Preliminary Close Out Report, and Annual Site Inspection Reports for 2000 to 2004.

The site was initially defined by the EPA in the 1980s to include two rectangular ponds andoccupy approximately 280 acres. Based on the numerous years of site investigations andremedial activities, the actual area where contamination was identified and addressed byremedial activities was much smaller than the initial 280 acre site designation. The areas of thesite that required remediation included (1) the North Marsh Area (approximately 4 acres); (2) theNorth Dike Area (approximately 9 acres); and (3) the East Dike Area (approximately 6 acres).

In June 1988, the EPA selected in-situ stabilization and capping as the preferred alternative forcleanup. In December J996. due to demonstrated difficulties in achieving the project's in-situstabilization specifications and the fact that successful implementation of the original remedywould be significantly more difficult, more time-consuming, and more costly than wascontemplated at the time of the original Record of Decision, the EPA selected and approved arevised remedy consisting of the off-site disposal of the site's most problematic (i.e., mobile)waste, consolidating the remaining waste material into areas to be capped and constructinglightweight composite caps. The revised remedial action was completed in August 1997.

The long-term effectiveness and permanence of the remedy will be achieved by maintaining theintegrity of the caps. The caps are maintained by preventing desiccation and/or settlementcracking, penetration by plant roots, burrowing by animals, and erosion. The maintenance andmonitoring program for the site includes site inspections, site maintenance, and submission ofregularly scheduled reports to EPA.

Since hazardous substances remained at the site above health-based levels after the completionof the remedial action, the EPA must conduct a statutory review every five years, pursuant to theComprehensive Environmental Response, Compensation, and Liability Act (CERCLA) section121(c) and as provided in Office of Solid Waste and Emergency Response (OSWER) Directive9355.7-02, Structure and Components of Five-Year Reviews, May 23, 1991; OSWER Directive9355.7-02A, Supplemental Five-Year Review Guidance, July 26, 1994; Second SupplementalFive-Year Review Guidance dated December 21, 1996, and OSWER Directive 9355.7-03B-PDraft Comprehensive Five-Year Review Guidance, October 1999.

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EPA completed the second five-year review inspection of the BWD site on June 23, 2005, whichconsisted of the following activities: a review of relevant documents; interviews with localgovernment officials and representatives of the maintenance contractors; and a five-year reviewsite inspection. The inspection verified that the containment remedy was functioning asdesigned; overall, the caps are being maintained in an appropriate manner, with only a fewdeficiencies not expected to immediately impact the protectiveness of the remedy noted. Thesedeficiencies will be addressed. The remedy is protective of human health and the environment.Institutional controls that will help ensure protectiveness in the long term are currently beingpursued by EPA through the TCEQ Texas Risk Reduction Rules (TAG 350.111).

One other requirement of a five-year review is to determine if there are any new requirementsthat may pertain to the site. No newly promulgated requirements that pertain to the BWD sitewere identified.

The remedies at both the North Dike Area and the East Dike Area are protective of human healthand the environment. The caps are effective at containing contaminants by preventing infiltrationof rainwater and preventing direct contact with contaminated soils. The long-term effectivenessof the remedy will be contingent upon the implementation of all necessary institutional controls,which are currently being pursued by the EPA through the TCEQ Texas Risk Reduction Rules (§350.111). The legal and administrative institutional controls will assist in preventing exposure toconcentrations of contaminants above health-based risk levels that may remain at the site.

Since this is a statutory site that requires ongoing five-year reviews, the next review will beconducted within five years of the completion of this five-year review report. This secondfive-year review focused on data obtained during annual inspections conducted at the BWD site.This review included the general landfill maintenance performed from 2001 through 2004. Thefollowing issues were noted.

1. Minor erosion on north side of North Dike Cap Area - Storm water runofffrom the North Dike Cap toward the North Marsh has caused minor erosion alongthe northern edge of the North Dike Cap. The erosion has exposed the geotextilefabric underlying the cap at the point where it ties into the riprap.

2. Animal activity noted - Minor, shallow tunnels caused by burrowing animalswere noted on the top of the North Dike Cap Area.

3. Minor desiccation cracks - Discontinuous desiccation cracking was observed onthe North and East Dike Areas in areas of sparse vegetation. Vegetation is ingenerally good condition. However, the dry conditions occurring in June 2005appear to have lead to desiccation cracking of the topsoil and the discontinuousthinning of grass in some areas on the North and East Dike Area,

4. Institutional controls - No institutional controls are currently in place at the site.

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5. Debris on site - A debris pile exists on site, north of the East Dike Cap Area, andconsists of wood (some partially burned), abandoned water pipe, and metal.

The following actions are needed in response to these issues:

1. Monitor area of erosion and place hay bails in areas experiencing sediment loss.In areas of exposed geotextile fabric, cover with topsoil and reseed.

2. Remove burrowing animals and repair the burrowed cap areas. If exposed, inspectthe geotextile fabric for integrity and then backfill burrows with a competentbackfill material.

3. If a prolonged drought occurs throughout the summer months, watering of thelandfill caps should be considered to promote vegetation growth and minimizedesiccation cracking.

4. Institutional controls that would help ensure protectiveness for the property in thelong term are currently being pursued by EPA through the TCEQ Texas RiskReduction Rules (§ 350.111).

5. Even though the debris pile is not situated on the cap, it should be properlydisposed of off-site to eliminate any nuisances associated with it.

The Bailey Site Settlors Committee is primarily responsible for implementing these actions.

At this time, based on the information available during the second five-year review, the selectedremedy appears to be protective of human health and the environment, and will remain soprovided that the landfill caps are maintained, access restrictions are maintained, andinstitutional controls are put in place.

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Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name (from WasteLAN): Bailey Waste Disposal

EPA ID (from WasteLAN): TXD980864649

Region: 6 State: TX City/County: Orange County

SITE STATUS

NPL Status: £0 Final QDeleted D Other (specify)

Remediation Status (choose all that apply): l~l Under Construction Q Operating

Kl Complete

Multiple ous?* DYES ED NO Construction Completion Date: May 1998Has site been put into reuse? £3 Statutory

D Policy D Post-SARA Q Pre-SARA Q NPL-Removal only

D Non-NPL Remedial Action Site d NPL State/Tribe-lead

I | Regional Discretion

Review Number: Q 1 (first) [X] 2 (second) D 3 (third) D Other (specify)

Triggering Action:

D Actual RA On-site Construction at OU O Actual RA Start

Q Construction Completion £3 Previous Five-Year Review Report

I | Other (specify)

Triggering Action Date (from WasteLAN): 09/2000

Due Date (Five Years After Triggering Action Date): 09/2005

* "OU" refers to operable unit.

** The review period refers to the period during which the five-year review was conducted.

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Five-Year Review Summary Form (Continued)

Issues:

1. Minor Erosion on North Side of North Dike Cap Area - Storm water runoff from the North Dike Cap toward the North Marsh has caused minor erosion along the northern edge of the North Dike Cap. Geotextile fabric underlying the cap has been exposed.

2. Animal activity noted - Minor, shallow tunnels caused by burrowing animals were noted on the top of the North Dike Cap Area.

3. Minor desiccation cracks - Discontinuous desiccation cracking was observed on the North and East Dike Area in areas of sparse vegetation. Vegetation is in generally good condition. However, the dry conditions occurring in June 2005 appear to have lead to desiccation cracking of the topsoil and discontinuous thinning of grass in some areas on the North and East Dike Area.

4. Institutional controls absent - The long-term effectiveness of the remedy will be contingent upon the implementation of all necessary institutional controls.

5. Debris on site - A debris pile exists on site, north of the East Dike Cap Area, and consists of wood (some partially burned), abandoned water pipe, and metal.

Recommendations and Follow-up Actions:

1. Monitor area of erosion and place hay bails in areas experiencing sediment loss. In areas of exposed geotextile fabric, cover with topsoil and reseed.

2. Remove burrowing animals and repair the burrowed cap areas. If exposed, inspect the geotextile fabric for integrity and then backfill burrows with a competent backfill material.

3. If a prolonged drought occurs throughout the summer months, watering of the landfill caps is recommended in order to promote vegetation growth and minimize desiccation cracking.

4. Institutional controls that would help ensure protectiveness for the property in the long term are currently being pursued by EPA through the TCEQ Texas Risk Reduction Rules (§ 350.111).

5. Even though the debris pile is not situated on the cap, it should be properly disposed of off-site to eliminate any nuisances that may be associated with it.

Protectiveness Statement:

The protection of human health and the environment is currently being ensured by the remedy implementedat the BWD site. Institutional controls are currently being pursued for the property through the TCEQ TexasRisk Reduction Rules (§ 350.111) to help ensure the long-term protection of human health and theenvironment will continue to be met.

Long-Term Protectiveness:

For the remedy to be protective in the long term the landfill caps should continue to be inspected andmaintained in accordance with approved plans, and institutional controls should be put into place.

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1.0 INTRODUCTION

The U.S. Environmental Protection Agency Region 6 (EPA), with assistance from Tetra Tech EMInc. (Tetra Tech) and in coordination with Texas Commission on Environmental Quality (TCEQ),Parsons Engineering (Parsons), the Bailey Site Settlor's Committee (BSSC), and the landowner, Mr.Rodney Townsend, conducted a five-year review of the remedial action (RA) implemented at theBailey Waste Disposal site (BWD) in Orange County, Texas. The purpose of a five-year review is todetermine 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 reviewsconsistent 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 remedialaction no less often than each five years after the initiation of such remedial action to assurethat human health and the environment are being protected by the remedial action beingimplemented."

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

"If a remedial action is selected that results in hazardous substances, pollutants, orcontaminants remaining at the site above levels that allow for unlimited use and unrestrictedexposure, the lead agency shall review such action no less often than every five years alterthe initiation of the selected remedial action."

Because hazardous substances, pollutants, or contaminants remain at the BWD site above levels thatallow for unlimited use and unrestricted exposure, a five-year review is required.

The BWD site includes the North Dike Cap Area and the East Dike Cap Area. This second five-yearreview addresses the entire site. The period addressed by the five-year review for the BWD siteextended from 2000 to 2005. The triggering action for this review was the completion of the firstfive-year review in September 2000. The second five-year review was conducted from June toSeptember 2005. and its methods, findings, conclusions, and recommendations are documented inthis report.

This report documents the five-year review for the BWD site by providing the followinginformation: site chronology (Section 2.0), background information (Section 3.0), an overview of theEPA 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), andrecommendations and follow-up activities (Section 9.0). The report also provides a protectivenessstatement (Section 10.0) and discusses the next review (Section 11.0). Appendix A provides a list ofdocuments reviewed, and Appendix B is the site visit report. The public notice is provided inAppendix C, and a summary table of laboratory analytical results is provided in Appendix D.

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2.0 SITE CHRONOLOGY

A chronology of site events for the BWD site is provided in Table 1. Additional historicalinformation for the site is available on-line at: http://www.epa.gov/earthlr6/6sf/pdffiles/060291 l.pdf(EPA 2005).

3.0 BACKGROUND

This section discusses the site's physical characteristics, land and resource use near the site, thehistory of site contamination, the initial response to the site, and the basis for the response.

3.1 PHYSICAL CHARACTERISTICS

The BWD site is located approximately 3 miles southwest of Bridge City in Orange County, Texas(see Figure 1). The site was originally part of a tidal marsh near the confluence of the Neches Riverand Sabine Lake. The total site area includes two rectangular ponds and occupies approximately 280acres; however, numerous investigations provided the ability to minimize the areas of the site thatrequired remediation. These areas include: (1) the North Marsh Area (approximately 4 acres); (2) theNorth Dike Area (approximately 9 acres); and (3) the East Dike Area (approximately 6 acres) (seeFigure 1).

TABLE 1 CHRONOLOGY OF SITE EVENTS

Date Event

1950s-1960s Industrial wastes, primarily organics, were disposed of along the north and eastmargins of Pond A

1979 EPA released a report stating that industrial wastes were disposed of at the site

1980 Texas Water Commission did a preliminary assessment of the site

1981-1982 Gulf States Utility (landowner at the time) investigated dimension and chemicalcharacteristics of the waste pits

October 1984 BWD site proposed for the National Priorities List

December 1984 State of Texas entered into a cooperative Agreement with EPA to conduct a RemedialInvestigation and Feasibility Study

1986 Site included on the National Priorities list

October 1987 Remedial investigation completed by Woodward-Clyde Consultants

April 25, 1988 PRP's feasibility study completed by Engineering-Science

June 28, 1988 Record of Decision (ROD) signed

April 30, 1990 Consent Decree (CD) signed

November 1991 Remedial Design for the Original Remedy is completed by Harding LawsonAssociates

September 1992 Chemical Waste Management mobilizes to implement Original Remedy

January 1994 Initial RA (Original Remedy) is halted when stabilization requirements prove to beunattainable

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TABLE 1 (Continued) CHRONOLOGY OF SITE EVENTS

Date Event

November 1994 North Marsh Design (Interim RD) Completed by HLA

June 1995 EPA recommends a Focused Feasibility Study (FFS)

June 1995 Chemical Waste Management demobilizes from the site

June 1995 GeoSyntec begins FFS and associated studies (i.e.; North Dike TechnicalMemorandum and East Dike Technical Memorandum); Parsons ES assumes ContractAdministration/Construction Management (CA/CM) Services

November 1995 Modified North Marsh Design (Interim RD) is completed by GeoSyntec, whichrevised the technical specifications of the North Marsh Design

January 1996 OHM mobilizes to conduct the Interim Remedial Action (RA)

February 8, 1996 Explanation of Significant Differences (ESD) issued by EPA for the treatment andhandling of the North Marsh Wastes

May 1, 1996 ESD issued by EPA for remedial actions associated with Pit B

September 1996 OHM completes Interim Remedial Action Activities

October 24, 1996 Event FFS Report approved by EPA

December 1996 ROD Amended

December 1996 Revised RD completed by GeoSyntec

January 1997 OHM mobilizes to conduct Final RA (i.e.; begin construction of two separatelightweight composite caps, one each over the North and East Dike Areas

August 1997 Revised RA completed

September 1998 Preliminary Close Out Report

September 2000 First Five Year Review completed

July 2000 Annual Site Inspection Report by Parsons Engineering Science, Inc.

September 2001 Annual Site Inspection Report by Parsons Engineering Science, Inc.

April 2002 Annual Site Inspection Report by Parsons Engineering Science, Inc.

September 2003 Annual Site Inspection Report by Parsons Engineering Science, Inc.

September 25,2003

North and East Dike Cap Areas surveyed for the purpose of implementinginstitutional controls

May 2004 Annual Site Inspection Report by Parsons Engineering Science, Inc.

December 2004 Follow-up to Annual Site Inspection by Parsons Engineering Science, Inc. Notes:

HLA Harding Lawson Associates RA Remedial action OHM OHM Remediation Services

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3.2 LAND AND RESOURCE USE

Two ponds, A and B, were constructed on the property by the landowner, Mr. Joe Bailey, as part ofthe Bailey Fish Camp in the early 1950s by dredging the marsh and piling the sediments to formlevees which surround the ponds. The fish camp was active until September 1961, when it wasdestroyed by Hurricane Carla, which introduced saline waters into the ponds, killing the freshwaterfish (GeoSyntec and Parsons Oct. 1997).

Mr. Bailey operated the site pursuant to his ownership and leasehold interests from the early 1950sthrough March or April 1971. Following the hurricane, Mr. Bailey allowed the disposal of industrialand municipal waste within the levees along the north and east margins of Pond A (the North DikeArea and the East Dike Area, respectively). In addition to the waste located within the North DikeArea (which includes waste contained in Pits A-l, A-2, A-3, and B) and East Dike Area, waste wasalso present in the North Marsh Area. Waste disposal operations at the BWD site ceased in 1971 andthe BWD site was purchased by Gulf State Utilities.

Mr. Rodney Townsend of R&R Recreation currently owns the North Dike Area. Mr. Townsendmanages the property as a Texas Prairie Wetlands Project in cooperation with the Texas Parks &Wildlife, Ducks Unlimited, the U.S. Department of Agriculture - Natural Resources ConservationService, and the U.S. Fish and Wildlife Service.

The BWD site is situated in a marsh area, which is sparsely populated. Beyond the BWD site thesurrounding area is primarily industrial. A site layout map is available as Figure 2.

3.3 HISTORY OF CONTAMINATION

A remedial investigation (RI) was conducted in 1987 consisting of a surface and subsurface fieldinvestigation to assess the distribution of waste materials and to evaluate the potential for themigration of chemical constituents away from the waste locations outlined above. The RI identifiedcontaminants such as ethylbenzene, styrene, benzene, chlorinated hydrocarbons and polynucleararomatic hydrocarbons, and industrial wastes and debris.

3.4 INITIAL RESPONSE

Based on the results from preliminary assessments, the site was placed on the NPL in 1986, with theTexas Water Commission (TWC) as the lead agency. TWC initiated RI/FS activities at the BWD siteto determine the nature and extent of the contamination. After the RI was completed. EPA look overas the lead agency. Under the terms of an administrative order on consent, a group of potentiallyresponsible parties (PRPs) conducted a feasibility study (FS). Engineering Science completed theFS, in April 1988. Prior to the selection of the remedy. EPA provided members of the public,including the PRPs, an opportunity to comment on the RI, FS, and the preferred alternative forcleanup. EPA selected an in-situ stabilization and capping remedy and issued the Record of Decision(ROD) for the entire site in June 1988. In July 1988, EPA, pursuant to section 122 of CERCLA,issued special notice letters to the PRPs providing them an opportunity to enter into an agreement toperform the remedial action. On September 30, 1988. the Bailey Site Settlor's Committee (BSSC)submitted to EPA its "Good Faith Offer." As a result, an agreement in principle to conduct theremedial action was reached. This agreement provided that the Settlors, as defined in the ConsentDecree, would carry out the remedy selected by EPA, and that EPA would reimburse the Settlors fora portion of the costs to implement the remedy.

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BERMBREACH

MATERIALSTORAGEAREA

WASTEWATER TREATMENT SYSTEMCONTAINMENT AREA

RIP RAF PLACED OVER CAPON NORTH SIDE SLOPE

SOURCE: MODIFIED FROM GGOSYNTGC CONSULTANTS PROTECT RECORD DRAWING, 1997

SCALE IN FEET(APPROXIMATE)

BAILEY TASTE DISPOSAL SITEORANGE COUNTY, TEXAS

FIGURE ZSITE PLAN

&EPA

3.5 BASIS FOR RESPONSE

Based on the data collected during the RI, it was determined that hazardous substances, could bereleased from the BWD site that could endanger public health, welfare, or the environment. Themost significant risks to human health and the environment included the following:

(1) Direct contact - many of the organic compounds and heavy metals found on the sitehave been determined to be carcinogens. Absorption through the skin or other routesof inadvertent ingestion therefore poses potential health risks.

(2) Air emissions - consisting of volatile organic compounds that may pose potentialhealth threats.

(3) Surface waters - Marsh was directly impacted from the waste, which had migratedinto it, including organic compounds and heavy metals.

(4) Ground water- shallow ground water directly beneath the waste was contaminatedwith organic compounds and heavy metals.

Harding Lawson Associates (HLA) completed the Original Remedy RD in November J991.Chemical Waste Management (CWM) was contracted as the remediation contractor, and mobilizedto the site in September J992 to implement the original remedy. Because of demonstrated difficultiesin achieving the project's in situ stabilization specifications and the fact that successfulimplementation of the original remedy would, if possible at all, be significantly more difficult, moretime-consuming, and more costly to implement than was contemplated at the time the original RODwas issued, EPA requested that the BSSC conduct a Focused Feasibility Study (FFS). FFS activitiescommenced in June 1995 and were completed in October 1996. Based on the conclusions presentedin the FFS, an Amended ROD (EPA 1996) was completed in December 1996, and the revisedremedial action was completed in August 1997. In September 1998, EPA issued the PreliminaryClose Out Report slating that on May 29, 1998, the remedy had been constructed in accordance withthe remedial design plans and specifications and is operational and functional.

4.0 REMEDIAL ACTION

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

4.1 SELECTED REMEDY

According to the Remedial Action Statement of Work (Appendix E of the 1990 Consent Decree),the objectives of the remedial action were as follows:

(1) minimize the potential for waste migration; (2) protect human health and the environment; (3) prevent future contamination of surface water and groundwater; and (4) minimize the potential short-term air emissions resulting from remedial activities.

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4.2 REMEDY IMPLEMENTATION

The remedial action was conducted in three phases: (1) implementation of some components of theOriginal Remedy, (2) the Interim Remedial Action (mainly remediation of the North Marsh Areaand Pit B), and (3) the Final Revised Remedial Action. Each phase is described below.

Phase 1: Implementation of Original Remedy According to the ROD, the original remedy consisted of the following three components:

(1) Consolidation of affected sediments from the marsh, drainage channel, drum disposal,and Pit A-3 sectors into the Waste Channel (North Dike Area) sector;

(2) In situ stabilization of the waste in the Waste Channel sector and the sector East ofPond A (East Dike Area); and

(3) Construction of a cover on top of the stabilized waste.

HLA performed the remedial design and construction oversight. The design of the original remedy ispresented in the document entitled "Technical Specification" (HLA, 1992). After numerous in-situstabilization attempts, subsequent investigations, and a stabilization field pilot study, it wasdetermined that the waste stabilization performance standards established in the ROD and theremedial design would, if possible at all, be significantly more difficult, more time-consuming, andmore costly to implement than was contemplated at the time the original ROD was issued. Due tothese difficulties, as outlined in the Amended ROD (EPA 1996), implementation of the originalremedy was not completed. The following components, however, were accomplished during thelimited implementation of the original remedy:

(1) Waste/soil interface evaluation; (2) Consolidation and relocation of shallow wastes within the East Dike Area; (3) Construction of clay dikes around the East Dike Area; (4) Construction of access roads and support laydown area; (5) Stabilization of approximately one-third of the East Dike Area on the southern end; (6) South drum disposal area remediation; (7) Closure of wells and piezometers; (8) Construction of a wastewater treatment plant to treat potentially contaminated water

generated during the construction operations, including decontamination water,stormwater from active areas, and ground water from dewatering operations, and

(9) Air monitoring to ensure action levels on site were not exceeded.

Project record drawings of the original remedy are presented in Part J of Appendix A of GeoSyntecConsultants' and Parsons Engineering Science, Inc.'s October 1997 "Remedial Action Report For theBailey Superfund Site, Orange County. Texas" Volume 1.

Phase II: Interim Remedial Action GeoSyntec conducted the Interim RD during the FFS. which is presented in the document entitled"Construction Specifications, Modified North Marsh Waste Remediation" (GeoSyntec J995). TheInterim remedial Actions taken at the site are discussed in an Explanation of Significant Differences(ESD) dated February 8, 1996, and another ESD dated May 1, 1998. The following activities wereaccomplished during the Interim Remedial Action:

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(1) Excavation of waste and affected sediments from the North Marsh Area and Pit B andtransportation of this material to an off-site industrial landfill for solidification anddisposal;

(2) Excavation and on-site relocation of waste and affected sediments from pits A-1, A-2and A-3;

(3) Verification (to a visually clean performance standard) that waste and affectedsediments from the drainage channel and the south drum disposal area were removedduring the original remedy;

(4) Waste and affected sediment relocation from the drum disposal area located on theNorth Dike Area to the East Dike Area;

(5) Placement of interim soil cover over the south portion of the East Dike Area, whichhad waste material exposed (active area);

(6) Closure of an existing water supply well on site: and

(7) Air monitoring during intrusive activities to ensure that on-site action levels were notexceeded.

Project record drawings of the Modified North Marsh Waste Remediation. Pit B Waste Removal,and East Dike Area Interim Closure are presented in Part 2 of Appendix A of GeoSyntecConsultants' and Parsons Engineering Science's, Inc. October 1997, "Remedial Action Report Forthe Bailey Superfund Site. Orange County, Texas" Volume 1.

Phase III: Revised Remedial Action The Revised Remedial Action was developed as a result of the FFS and is presented in the documententitled "Bid Form and Construction Specifications - Revised Remedial Design." (GeoSyntec 1996).The FFS is presented in a document entitled " Focused Feasibility Study Report. Revision 1."[GeoSyntec 1996). The ROD was amended in December 1996 (EPA 1996) consistent with theconclusions of the FFS. The amended ROD replaced the in-situ stabilization component of theoriginal remedy with lightweight composite caps over the current North Dike and East Dike areas ofthe site. Major activities performed during the revised Remedial Action are summarized below:

(1) Relocation and consolidation of surficial waste from the south edge of the North DikeArea to a location within the limits of the area to be capped;

(2) Relocation and consolidation of bulk waste from the area adjacent to the former Pit Barea to a location within the limits of the area to be capped;

(3) Installation of a water collection system to intercept and remove ground water thatwas elevated in the short term (i.e. during construction of the cap) due toconsolidation of the waste (this water was taken off-site for disposal);

(4) Construction of a lightweight composite cap over the East and North Dike Areas;

(5) Installation of riprap along the cap perimeter for erosion and scour protection;

9

(6) Installation of storm water management controls to route storm water runoff fromdisturbed areas during construction to the treatment system, and divert storm waterrunoff from inactive or completed areas of the site away from the active areas of thesite;

(7) Construction of maintenance roads;

(8) Air monitoring during intrusive activities to ensure action levels on site were notexceeded; and

(9) Installation of a passive gas venting system on both the North and East Dike Areas.

Photographs taken during the Interim Remedial Action and the Revised Remedial Action showingthe various phases of construction work are presented in Appendix B, and project Record Drawingsof the Revised Remedial Action are presented in Part 3 of Appendix A of GeoSyntec Consultants’and Parsons Engineering Science, Inc.’s, October 1997 "Remedial Action Report For the BaileySuperfund Site, Orange County, Texas" Volume 1.

4.3 OPERATION AND MAINTENANCE

The BSSC agreed lo perform the remedies in the original and amended ROD pursuant to a judicialconsent decree. The long-term effectiveness and permanence of the remedy, as outlined in theAmended ROD, will be achieved by maintaining the integrity of the cap through efforts targeting theprevention of desiccation or settlement cracking, penetration by plant roots, or erosion. Themaintenance and monitoring requirements to be completed by the BSSC are outlined in the EPAapproved Final Inspection, Maintenance, and Monitoring Plan (IMMP) submitted by Parsons(Parsons 1997). The maintenance and monitoring program for the site includes site inspections, sitemaintenance, and submission of regularly scheduled reports to the EPA. A visual inspection of thesite was completed every quarter during the first year and annually since that time.

O&M activities for the landfill include the following activities:

1. Inspect the landfill cap and side slopes for physical deformities and vegetative cover;

2. Inspect the perimeter roads, security fence, and warning signs; and

3. Inspect the landfill vents.

Maintenance

Maintenance of the cap generally consists of quarterly mowing, minor erosion repair of the caps,side slopes and access roads, and maintenance of the access controls, including the perimeter fenceand warning signs. . Contractors for the BSSC conduct these quarterly maintenance activities andsubmit annual inspection reports to EPA. Dates and noted major observations from the O&M annualinspection reports are as follows for the years 2000 to 2004:

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• July 10, 2000. Condition of Gates: The chain and lock on the southern gate of theEast Dike Cap not installed properly. Surface Vegetation: Woody plants were noted .growing along the edges of both caps. Other observations of the landfill, orsurrounding area that may impact the landfill: General dry conditions resulting insome stressed vegetation and minor soil desiccation. Access Roads: Off-site road nearthe northeast corner of the access bridge is showing initial signs of storm watererosion.

• August 22, 2001. Access Controls: Signs missing on outer gate and on east fence,just south of the gate. Approach to bridge from Hwy 87 needs fill in gap betweenroad and bridge. Surface Vegetation: Minimal areas of thin vegetation. Weed controlmay be needed on the onsite access roads. Evidence of Burrowing Animals: Twoholes burrowed next to gas vents on East Dike Cap. Other observations of the landfill,or surrounding area that may impact the landfill: Minor settling and/or movement ofriprap on the southern side of the North Dike Cap Area.

• April 24, 2002. Access Controls: The barbed wire extension at the south side of theouter gate appears to have been pushed from its original location but is still intact.Both approaches to the bridge are experiencing minor erosion. Surface Vegetation:Minimal areas of thin vegetation located on both caps. Evidence of BurrowingAnimals: Two holes burrowed next to gas vents on East Dike Cap. Otherobservations of the landfill, or surrounding area that may impact the landfill: EastDike Cap Area experiencing very minor settlement.

• May 19, 2003. Access Controls: The barbed wire extension at the south side of theouter gate appears to have been pushed from its original location but is still intact.Both approaches to the bridge are experiencing minor erosion. Surface Vegetation: Aminimal area of thin vegetation located on the East Dike Cap. Evidence of BurrowingAnimals: Several apparent holes burrowed next to gas vents on the North and EastDike Caps. Other observations of the landfill, or surrounding area that may impact thelandfill: East Dike Cap Area experiencing very minor settlement.

• May 20, 2004. Access Controls: The barbed wire extension at the south side of theouter gate appears to have been pushed from its original location but is still intact.The eastern approach to the bridge is significantly lower than the wood decking.Other observations of the landfill, or surrounding area that may impact the landfill:Potential erosion on North Dike Cap Area and potential differential settlement on thewestern end of the North Dike Cap Area.

• December 14, 2004. Access Controls: Warning sign along the North Dike Capdamaged and needs replacement. Other observations of the landfill, or surroundingarea that may impact the landfill: Potential livestock grazing occurring on the caps.Recommended re-seeding at area of erosion on North Dike Cap Area. Previouslymentioned area of erosion in May 2004 determined not significant.

4.4 OPERATION AND MAINTENANCE COST

BSSC provided approximate associated costs for the BWD site through letters of payment to theEPA submitted by Debra Baker of Connelly, Baker, Wotring & Jackson. The costs include thefollowing:

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• Quarterly mowing, maintenance of the caps, fence and sign repair, bridgemaintenance, road maintenance, and contractor oversight;

• Annual site inspections and reporting; and

• Additional labor costs (outside normal operating conditions).

Table 2 provides the approximate costs for the years stated. Total costs were provided by the BSSC.Costs for 2003 and 2004 were not available at the time Tetra Tech prepared this report.

TABLE 2 ANNUAL OPERATION AND MAINTENANCE COSTS

Dates Total cost rounded to nearest $100

September 1999 - August 2000 $30,400

September 2000 - August 2001 $47,700

September 2001 - August 2002 $9,300

September 2002 - August 2003 $3,700

5.0 FIVE-YEAR REVIEW PROGRESS

This is the second five-year review for the BWD site. The first five-year report was conducted inSeptember 2000. The site appears to have been properly maintained during the period betweenreports. 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 second five-year review. Specifically, thissection presents the findings of site inspections, an applicable or relevant and appropriaterequirements (ARAR) review, and a data review.

6.1 ADMINISTRATIVE COMPONENTS

The BWD site Five-year Review team was lead by Mr. Chris Villarreal of EPA, Remedial ProjectManager for the BWD site. Mr. Eric Johnstone and Ms. Aubrey Waddail, representatives from TetraTech, assisted in the review process.

In March 2005, the review team established the review schedule, which included the followingcomponents:

• Community Involvement • Site Inspection • Local Interviews • ARAR Review • Data Review • Five-Year Review Report Development and Review

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6.2 COMMUNITY INVOLVEMENT

Activities to involve the community in the five-year review were initiated with a public noticepublished in the local weekly newspaper, The Orange Leader, located in Orange, Texas. This noticeinformed the public that a five-year review was to be conducted and that the results of the reviewwould be made available to the public at two information repositories. These are the Marion and EdHughes Public Library in Nederland, Texas and City of Orange Public Library in Orange, Texas.The 1 ½-inch by 7-inch notice ran for one day, Friday, July 1, 2005. A copy of the public notice andthe Affidavit of Publication is available in Appendix C.

6.3 SITE INSPECTION

A site inspection was conducted on June 23, 2005, to assess the condition of the site and themeasures employed to protect human health and the environment from the contaminants still presentat the site. Attendees included (1) Chris Villarreal of EPA; (2) Charles Orwig of Dupont CorporateRemediation Group; (3) Julie Larson of Parsons Engineering Science; (4) Keith Ganze of ParsonsEngineering Science; (5) Rodney Townsend, the landowner; (6) Debra Baker of Connelly, Baker,Wotring & Jackson, and (7) Eric Johnstone and Aubrey Waddail of Tetra Tech. The site visit report,which includes a site inspection checklist (Exhibit A), photographic log of the inspection (ExhibitB), and site survey forms (Exhibit C), is provided in Appendix B.

No evidence of contamination was visible at the site. The site's general appearance is good. Theinspection team investigated the perimeter and top of the caps including the perimeter roads, the ventcaps, and the access controls, including fences, warning signs, and gates.

The vegetation at the site appeared to be in good condition. However, the month of June wasextremely dry, causing minimal discontinuous thin patches of vegetation and desiccation cracks onthe landfill caps. Site access appeared to be sufficiently restricted because no vandalism wasobserved and the locks, gates. and perimeter fences were in good condition. According to Mr.Townsend, he had removed an abandoned water pipe from the City of Port Arthur that ranperpendicular to the access bridge. According to previous inspection reports and interview with Mr.Townsend, the pipe had been used to access the bridge from the side and was removed to helpprevent trespassers. The gravel road around the edge of the caps was also in good condition. Bothapproaches to the access bridge appeared to have been filled in with asphalt.

Some minor tunneling activities by burrowing animals were noted around the top portion of thelandfill causing small holes in the topsoil. According to previous inspection reports, tunneling byburrowing animals was isolated near the gas vents. To help remedy the situation, in May 2004, theBSSC installed animal barriers around the gas vents. The animal barriers consisted of clearing a10-foot by 10-foot area of vegetation and placing a 10-foot by 10-foot chain link fence horizontallyaround. the gas vent. Sod was then placed over the chain link fences to replace the vegetative cover.The animal control barriers have helped prevent tunneling by burrowing animals in the vicinity ofthe gas ve its. Minor erosion was noted on the north side of the North Dike Cap Area, where thegeotextile fabric was exposed in the area where the cap and rip rap meet. The BSSC placed hay bailsin these areas to help prevent erosion of the soil and vegetation and promote the growth of grass. Adebris pile was noted north of the East Dike Cap Area and contained wood (partially burned),abandoned water pipe, and metal.

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6.4 LOCAL INTERVIEWS

In accordance with the community involvement requirements of the five-year review process, keyindividuals to be surveyed were identified by EPA. Completed survey forms for the followingpeople are included in Appendix B, Exhibit B:

• Ben Shields, TCEQ • Julie Larson, Parson Engineering Science • Charles Orwig, DuPont Corp., Remediation Group • Debra Baker, Connelly, Baker, Wotring, Jackson • Rodney Townsend, Owner (North Dike Area) • Leslie Appely, Owner (East Dike Area)

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

• Ms. Debra Baker, counsel for PRP Group (Bailey Site Settlors Committee) stated thatthe remaining item that needs attention from the EPA and the State is to ensure thatthey work with the landowner to ensure that proper institutional controls in the formof deed recordation and restrictive covenants are promptly put into place to ensure thelong-term integrity of the remedy.

• Mr. Shields also stated that institutional controls should be completed for the site.

• Mr. Orwig stated that it is his understanding that the EPA has been in contact with theState of Texas and that the State will work with the landowner to ensure that thelandowner puts into place the appropriate institutional controls in compliance withSection 350.111 of the Texas Risk Reduction Rules.

• Mr. Townsend stated that the site needs to be maintained on a quarterly basis (grass,roads, etc.). He also stated that debris left from site cleanup needs to be removed.

6.5 ARAR REVIEW

The original 1988 ROD and the amended 1996 ROD identified the following applicable and relevantand appropriate requirements (ARARs) for the BWD site remedial action:

• 40 CFR 264.18(b) (RCRA)- Facilities in the 100-year flood plain must be designed,constructed, operated, and maintained to avoid washouts.

• Executive Order 11988 (Flood Plain Management)- Action taken must avoid adverse effectsand minimize potential harm to the surrounding area.

• 40 CFR 246 (RCRA) constructions requirements for hazardous waste storage facilities.

• Texas Surface Water Quality Standards (TSWQS) 30 Texas Administrative Code (TAC)Chapter 307 for establishing surface water discharge criteria.

The amended ROD identified the following criteria or guidance to be considered (TBC):

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• EPA's Design and Construction of RCRA/CERCLA Final Covers, May 1991, for thedesign and construction of the lightweight composite cap.

One of the requirements of a five-year review is to determine if there are any new requirements thatmay pertain to the site. No newly promulgated requirements that pertain to the BWD site wereidentified.

6.6 DATA REVIEW

A review of the previous five inspection reports through July 2000 to May 2004 indicate that theprocedures outlined in the IMMP have ensured, up to the time of this review, that the remedialaction for the BWD site as designed and as constructed is being maintained.

There is no method established in the IMMP for long-term assessment of the remedial actionobjective of preventing future contamination of surface water or ground water. No data is beingcollected at this site as part of the operations and maintenance (O&M) requirements. However, itwas determined in the December 1996 Record of Decision Amendment that the 25 to 35 feet of"very soft gray clay to silty clay" underlying and surrounding the cap provides adequate containmentagainst vertical and lateral migration.

Information on the site activities was summarized in the following reports:

• "Annual Inspection Report for the Bailey Superfund Site" (Parsons 2000). • "Annual Inspection Report for the Bailey Superfund Site" (Parsons 2001). • "Annual Inspection Report for the Bailey Superfund Site" (Parsons 2002). • "Annual Inspection Report for the Bailey Superfund Site" (Parsons 2003). • "Annual Inspection Report for the Bailey Superfund Site" (Parsons 2004).

7.0 TECHNICAL ASSESSMENT

The conclusions presented in this section support the determination that the selected remedy for theBWD site is currently protective of human health and the environment. EPA Guidance indicates thatto assess the protectiveness of a remedy, three questions shall be answered.

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

• RA performance - The landfill cover system has been effective in isolating wasteand contaminants. As previously discussed, some minor erosion and tunneling byburrowing animals has occurred on the cap, but it does not affect the performance orintegrity . of the cover system. There is no evidence of wetland deterioration at thesite. Conversely, due to the current ownership of the property by R&R Recreation,Inc. and use of the property by Ducks Unlimited, the wetland environment hasproliferated at the Site. Only a minimal amount of settling has been observed. Areasin the cap with thin vegetation and tunneling by burrowing animals will continue toneed attention. Overall, the remedial action continues to be effective.

• Cost of system and O&M - O&M cost information for the fiscal years 2000 through2004, ranged from approximately $47,700 to $3,700, annually.

15

• Opportunities for optimization - Activities at the site as mandated in the MMP arealready minimal. However, as mentioned above, areas in the cap with thin vegetationand affected by tunneling of burrowing animals will continue to need attention.Efforts to address burrowing animals may be required. Also, seeding, fertilizing, andwatering the cultivated areas of vegetation combined with erosion protection may berequired to minimize future costs and maintenance associated with the landfill caps.

• Early indicators of potential issues - There is no indication of remedy failure. Thelandfill caps are inspected annually and O&M activities are performed on the landfillcaps as required.

• Implementation of institutional controls and Other Measures- The securityfencing around the site is intact. Gates remain locked when the site is unattended andonly authorized personnel are provided access to the site. Warning signs are clear andabundant around the perimeter of the property to prevent access. Warning signs arealso located at the entrance of each landfill cap prohibiting vehicles from driving onthe cap. Institutional controls are currently being pursued by the EPA through TCEQTexas Risk Reduction Rules (§ 350.111) to help prevent exposure to contaminants atconcentrations above health-based risk levels that may remain at the site in the longterm and limit activities at or near the site through a deed recordation.

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

• Changes in standards and to be considered - This five-year review did not identifyany new requirements that would pertain to the BWD site.

• Changes in exposure pathways - No changes in the site conditions that affectexposure pathways were identified as part of the five-year review. First, there are nocurrent or planned changes in land use. Second, no new contaminants, sources, orroutes of exposure were identified as part of this five-year review. Because of theunique hydrogeological features at the site, ground water was not a media of concernand is not monitored as part of the remedial action. The RI concluded that the site hashad no impact on drinking water and in the unlikely event that site constituents wereto migrate via a ground water pathway, it would take more than 800 years for them toreach potable ground water. The shallow ground water beneath and adjacent to thesite is saline and not suitable for human consumption. The hydrogeologicalconditions at the site have not changed.

• Changes in toxicity and other contaminant characteristics - The remedial actionrelies on containment of contaminants rather than cleanup or removal ofcontaminants. Therefore, changes in toxicity or other factors for contaminants ofconcern do not impact the protectiveness of the remedial action.

• Changes in risk assessment methodologies - The remedial action relies oncontainment of contaminants rather than cleanup or removal of contaminants to arisk-based concentration. Therefore, changes in risk assessment methodologies sincethe time of the ROD do not impact the protectiveness of the remedial action.

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• Expected progress toward meeting RAOs - The remedial action objectives (RAO)relating to isolating wastes and contaminants have been met. Institutional controls,currently being pursued by EPA through TCEQ Texas Risk Reduction Rules, willhelp prevent exposure to contaminants at concentrations above health-based risklevels that may remain at the site in the long term and limit activities at or near thesite through a deed recordation.

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

No other information has been identified that calls the protectiveness of the selected remedy intoquestion.

Technical Summary

According to documents and data reviewed, the site inspections, and the interviews, the remedyappears to be functioning as intended by the 1988 and 1996 RODs. There have been no changes inthe physical conditions of the site that would affect the protectiveness of the remedy. The ARARscited in the RODs have been met. There have been no changes in toxicity factors for the primarycontaminants of concern and there has been no change to the standardized risk assessmentmethodology that could affect the protectiveness of the remedy. There is no other information thatcalls into question the protectiveness of the remedy.

8.0 ISSUES

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

1. Minor Erosion on North Side of North Dike Cap Area - Storm water runoff fromthe North Dike Cap toward the north Marsh has caused minor erosion along thenorthern edge of the North Dike Cap. The erosion has exposed the geotextile fabricunderlying the landfill cap where the cap toe ties into the perimeter rip rap.

2. Animal Activity Noted - Minor, shallow tunnels caused by burrowing animals werenoted on the top of the North Dike Cap Area.

3. Minor Desiccation Cracking and Sparse Vegetation - Discontinuous desiccationcracking was observed on the North and East Dike Cap Areas in areas of sparsevegetation. Vegetation is in generally good condition. However, dry conditions thatprevailed during June 2005 may have lead to the desiccation cracking of the topsoiland the discontinuous thinning of grass in some areas on the North and East Dike CapAreas.

4. Institutional Controls - No institutional controls are currently in place at the site.

5. Debris On Site - Debris pile exists on site, north of the East Dike Cap Area, andconsists of wood (partially burned), abandoned water pipe, and metal.

A summary table of issues identified and if they currently affect the remedy protectiveness isprovided in Table 3.

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TABLE 3 IDENTIFIED ISSUES

IssueCurrently Affects Remedy

Protectiveness (Yes/No)

Minor Erosion on North Side of North Dike Cap Area No

Animal Activity Noted No

Minor Desiccation Cracking and Sparse Vegetation No

Institutional Controls Absent No

Debris On Site No

9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS

Table 4 summarizes recommendations and follow-up actions for the BWD site. The BSSC isresponsible for conducting follow-up actions, and EPA will provide oversight.

10.0 PROTECTIVENESS STATEMENT

Based on the information available during the second five-year review, the selected remedy for theBWD site appears to be performing as intended. Because the remedial actions at the BWD site areprotective of human health and the environment, the remedy for the site is expected to be protectiveof human health and the environment assuming the actions detailed in this review are taken. Thecaps are effectively containing contaminants by preventing infiltration of rainwater and preventingdirect contact with contaminated soils. EPA is currently pursuing institutional controls of the landfillcaps under TCEQ Texas Risk Reduction Rules (§ 350.111). These institutional controls will help toensure the long-term protectiveness of the caps.

11.0 NEXT REVIEW

The BWD site requires ongoing five-year reviews. The next review will be conducted within thenext five years, but no later than September 2010.

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TABLE 4 RECOMMENDATIONS AND FOLLOW-UP ACTIONS

Issue Recommendations and Follow-up Actions PartyResponsible

OversightAgency

Milestone Date Follow-up Actions AffectLong-Term Remedy

Protectiveness (Yes/No)

Minor Erosion on NorthSide of North Dike Cap

Monitor areas of erosion and place hay bails in areasexperiencing sediment loss. In the areas of exposed geotextilefabric, cover with topsoil and reseed.

BSSC EPA Within 1 year of submittalof this report

Yes

Area Animal ActivityNoted

Remove burrowing animals and repair burrowed cap areas. Ifexposed, inspect the geotextile fabric for integrity and thenbackfill tunnels with a competent backfill material.

BSSC EPA Within 1 year of submittalof this report

Yes

Minor DesiccationCracking and SparseVegetation

If a prolonged drought continues throughout the summer,BSSC should consider watering the landfill caps in order topromote vegetative growth and minimize desiccationcracking.

BSSC EPA Within 1 year of submittalof this report

Yes

Institutional Controls Institutional controls that would help ensure protectivenessfor the property in the long term are currently being pursuedby EPA through the TCEQ Texas Risk Reduction Rules (§350.111).

EPA EPA Within 1 year of submittalof this report

Yes

Debris On Site Even though the debris pile is not situated on the landfill cap,it should be properly disposed of off-site to eliminate anynuisances that may be associated with it.

BSSC EPA Within 1 year of submittalof this report

No

Notes:

EPA U.S. Environmental Protection Agency

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APPENDIX A

DOCUMENTS REVIEWED

(One Page)

DOCUMENTS REVIEWED

EPA. 1988. "Record of Decision, Bailey Waste Disposal Site, Orange County, Texas." June 28.

EPA. 1996. "EPA Superfund Record of Decision Amendment: Bailey Waste Disposal. EPA ID:TXD980864649. OU1. Bridge City, TX." December 16.

EPA. 1998. "Preliminary Close Out Report Bailey Waste Disposal Site, Orange County Texas."September.

EPA. 2000. "First Five-Year Review Report for Bailey Waste Disposal Site, Orange County, Texas"September.

EPA. 2005. "Bailey Waste Disposal, EPA ID#TXD980864649, Site ID: 0602911."On-line Addresshttp://www.epa.gov/earthlr6/6sf/pdffiles/0602911.pdf. Accessed July 1,2005. Publication date:

May 5.

In the United States District Court Eastern District of Texas. 1989. "Consent Decree."

Parsons Engineering Science. 2000. "Annual Site Inspection Report for the Bailey Superfund Site."July.

Parsons Engineering Science. 2001. "Annual Site Inspection Report for the Bailey Superfund Site."August.

Parsons Engineering Science. 2002. "Annual Site Inspection Report for the Bailey Superfund Site."April.

Parsons Engineering Science. 2003. "Annual Site Inspection Report for the Bailey Superfund Site."September.

Parsons Engineering Science. 2004. "Annual Site Inspection Report for the Bailey Superfund Site."May.

A-l

APPENDIX B

SITE VISIT REPORT

(Five Pages)

SITE VISIT REPORT FOR SECOND FIVE-YEAR REVIEW BAILEY WASTE DISPOSAL SUPERFUND SITE

ORANGE COUNTY, TEXAS

Prepared for

United States Environmental Protection Agency Region 6

Dallas, Texas

Contract No. : 68-W6-0037 Work Assignment No. : 123-FRFE-06ZZDate Prepared : June 23, 2005Prepared by : Aubrey Waddail, Tetra Tech EM Inc. Telephone No. : (332) 251-5186 EPA Remedial Project Manager : Mr. Chris VillarrealTelephone No. : (214) 665-6758

CONTENTS

Section Page

ACRONYMS AND ABBREVIATIONS B-i

1.0 INTRODUCTION B-l

2.0 BACKGROUND B-l

3.0 SITE VISIT ACTIVITIES B-2

4.0 FINDINGS B-3

REFERENCES B-3

Exhibit

A PHOTOGRAPHS B SITE VISIT CHECKLIST C SURVEYS

ACRONYMS AND ABBREVIATIONS

BWD Bailey Waste Disposal Site CERCLA Comprehensive Environmental Response, Compensation, and Liability Act EPA United States Environmental Protection Agency FFS Focused Feasibility Study FS Feasibility Study GeoSyntec GeoSyntec Consultants IMMP Inspection, Maintenance, and Monitoring Plan OSWER Office of Solid Waste and Emergency Response Parsons Parsons Engineering Science, Inc. RAC Response Action Contract RI Remedial investigation ROD Record of decision Tetra Tech Tetra Tech EM Inc.

B-i

1.0 INTRODUCTION

Tetra Tech EM Inc. (Tetra Tech) received Work Assignment No. 123-FRFE-0677 from the 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 second five-yearreview of the remedial action (RA) implemented at the Bailey Waste Disposal (BWD) Superfundsite in Orange County, Texas.

Tetra Tech visited the site on June 23, 2005, to assess whether all components of the selectedremedy are operating in accordance with criteria established in the June 1988 and December 1996Records of Decision (ROD). This report provides background information on the site, summarizessite visit activities, and presents Tetra Tech's findings. References cited are listed at the end of thistext. Exhibit A contains photographs taken during the site visit, and Exhibit B contains the five-yearreview site visit checklist completed by Tetra Tech. Exhibit C contains surveys that documentinterviews that were conducted during the site inspection and throughout the five-year reviewprocess.

2.0 BACKGROUND

The BWD site is located approximately 3 miles southwest of Bridge City in Orange County, Texas.The site was originally part of a tidal marsh near the confluence of the Neches River and SabineLake. Mr. Joe Bailey operated the site pursuant to his ownership and leasehold interests from theearly 1950s through March or April 1971. Mr. Bailey allowed the disposal of industrial andmunicipal waste within the levees along the north and east margins of one of the ponds. Those areasare now respectively referred to as the North Dike Area and the East Dike Area. In addition to thewaste located within the levees, which includes waste contained in Pits A-l, A-2, A-3, and B, wastewas also present north of the pond in what is now known as the North Marsh Area. Waste disposaloperations at the BWD site ceased in 1971.

In 1979, EPA first released a report stating that industrial wastes were disposed of on site. The totalsite area includes two rectangular ponds and occupies approximately 280 acres. Based on thenumerous years of site investigations and remedial activities, the actual area where contaminationwas identified and addressed by remedial activities was much smaller than the initial 280-acre sitedesignation. The areas of the site that required remediation comprised (1) the North Marsh Area(approximately 4 acres); (2) the North Dike Area (approximately 9 acres); and (3) the East DikeArea (approximately 6 acres).

A remedial investigation (RI) was conducted in 1987 consisting of a surface and subsurface fieldinvestigation to assess the distribution of waste materials and to evaluate the potential for themigration of chemical constituents away from the waste locations outlined above. The RI identifiedcontaminants such as ethylbenzene, styrene, benzene, chlorinated hydrocarbons and polynucleararomatic hydrocarbons, and industrial wastes and debris.

Harding Lawson Associates (HLA) completed the Original Remedy RD in November 1991.Chemical Waste Management (CWM) was contracted as the remediation contractor, and mobilizedto the site in September 1992 to implement the original remedy. Because of demonstrated difficultiesin achieving the project's in situ stabilization specifications and the fact that successfulimplementation of the original remedy would, if possible at all, be significantly more difficult, more

B-1

time-consuming, and more costly to implement than was contemplated at the time the original RODwas issued, EPA requested that the BSSC conduct a Focused Feasibility Study (FFS). In conjunctionwith the FFS, interim remedial actions that addressed the most problematic (i.e., mobile) site wasteoccurred. The interim remedial actions included remediation of Pits A-l, A-2, A-3, and B, whichwere located within the North Dike Area. Wastes from the North Marsh Area and Pit B weredisposed of off-site, and Pit A wastes (including Pits A-l, A-2, and A-3) were conditioned andrelocated to the East Dike Area.

EPA selected and approved a revised remedy consisting of consolidating the remaining wastematerial into areas to be capped and constructing a lightweight composite cap. The revised remedialaction was completed in August 1997. Some of the major activities performed during the revisedremedial action were (1) relocation and consolidation of surficial waste from the south edge of theNorth Dike Area to a location within the limits of the area to be capped; (2) relocation andconsolidation of bulk waste from the area adjacent to the former Pit B area to a location within thelimits of the area to be capped; (3) installation of a water collection system to intercept and removeground water that was elevated in the short term (i.e. during construction of the cap) due toconsolidation of the waste (this water was taken off-site for disposal); (4) construction of alightweight composite cap over the East and North Dike Areas; (5) installation of riprap for erosionand scour protection around the perimeter of the capped areas; (6) installation of storm watermanagement controls to route storm water runoff from disturbed areas during construction to thetreatment system, and divert storm water runoff from inactive or completed areas of the site awayfrom the active areas of the site; (7) construction of maintenance roads; and (8) installation of apassive gas venting system on both the North and East Dike Areas.

3.0 SITE VISIT ACTIVITIES

A site visit was conducted on June 23, 2005, to assess the condition of the site and the protectivemeasures employed to protect human health and the environment from the contaminants still presentat the site.

The following key individuals identified by EPA participated in the site visit:

• Chris Villarreal, EPA • Rodney Townsend, R&R Recreation • Chuck Orwig, DuPont Corporation • Julie Larson, Parsons Engineering Science • Debra Baker, Connelly, Baker, Wotring & Jackson • Eric Johnstone, Tetra Tech • Aubrey Waddail, Tetra Tech

The site visit included an evaluation of the landfill caps and slopes, passive gas vents, access roadsand bridge, sign postings, site fencing, and gates. Photographs taken during the site visit arepresented 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 weather during the site visit was partly sunny, hot, humid, and with calm winds. The site'sgeneral appearance was good, with cap vegetation green and in fairly good condition. The site hadrecently been mowed and conditions were dry.

B-2

4.0 FINDINGS

No evidence of contamination was visible at the site. The vegetation was green and in fairly goodcondition, with minor sparsely vegetated areas occurring throughout with minor, discontinuousdesiccation cracking observed in these areas due to dry conditions at the site. Site access appeared tobe sufficiently restricted because no vandalism was observed. Gates, fencing, and signs were in goodcondition. The gravel access roads were in good condition as well. Some minor tunneling activitiesby burrowing animals were noted around the top portion of the landfill causing small holes in thetopsoil. However, tunneling activities were not noted in the vicinity of the vent caps due toreinforcement of the vegetative cover installed by Parsons Engineering Science in the areas of thevent caps. Minor erosion, exposing the geotextile fabric underlying the landfill cap, was noted on thenorth side of the North Dike Area at the toe of the landfill cap. Hay bails are currently placed inthese areas to prevent further sediment loss and promote vegetative growth. A debris pile was alsonoted south of the East Dike Cap Area, consisting of wood (partially burned), metal, and anabandoned water pipe. Because the site is experiencing significantly dry conditions, evidence ofprolonged ponding greater than 2-inches was difficult to assess. However, no obvious areas ofdifferential settlement were observed.

REFERENCES

U.S. Environmental Protection Agency. (EPA). 1998. "Preliminary Close Out Report Bailey WasteDisposal Site, Orange County Texas." September.

EPA. 2000. "First Five-Year Review Report for Bailey Waste Disposal Site, Orange County, Texas"September.

EPA. 2005. "Bailey Waste Disposal, EPA ID#TXD980864649, Site ID: 0602911."On-line Addresshttp://www.epa.gov/earthlr6/6sf/pdffiles/0602911.pdf. Accessed July 1,2005. Publicationdate: May 5.

In the United States District Court Eastern District of Texas. 1989. "Consent Decree."

Parsons Engineering Science. 2000. "Annual Site Inspection Report for the Bailey Superfund Site."July.

Parsons Engineering Science. 2001. "Annual Site Inspection Report for the Bailey Superfund Site."August.

Parsons Engineering Science. 2002. "Annual Site Inspection Report for the Bailey Superfund Site."April.

Parsons Engineering Science. 2003. "Annual Site Inspection Report for the Bailey Superfund Site."September.

Parsons Engineering Science. 2004. "Annual Site Inspection Report for the Bailey Superfund Site."May.

B-3

EXHIBIT A

PHOTOGRAPHS

(Eight Pages)

EXHIBIT B

SITE VISIT CHECKLIST

(11 Pages)

FIVE-YEAR REVIEW SITE VISIT CHECKLIST

I. SITE INFORMATION

Site Name: Bailey Waste Disposal Site

Location and Region: Orange County, Texas

Agency, office, or company leading the five-yearreview:

EPA Region 6

Date of Inspection: June 23, 2005

EPA ID: TXD980864649

Weather/temperature:

Partly Sunny, winds calm, 90 -95°F

Remedy Includes: (Check all that apply)^ Landfill cover/containmentIXI Access controls1X1 Institutional controls

I I Ground water pump and treatmentI I Surface water collection and treatmentI I Other-Leachate collection and treatment

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (Check all that apply)

1. O&M Site Manager Chuck Orwig. Remediation Manager, DuPont CorporationName Title

Interviewed: 1X1 by mail I I at site I I by phone Phone no.Problems, suggestions: IXI Report attached Survey form

Date

2. O&M Staff Julie Larson. Project Manager, Parsons Environmental ScienceName Title Date

Interviewed: IXI by mail I I at office I I by phone Phone no.Problems, suggestions: IXI Report attached

3. Local regulatory authorities and response agencies (i.e.; State and Tribal offices, emergencyresponse 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 Texas Commission on Environmental Quality (TCEQ)

Contact Ben Shields Engineer 6/28/2005 (405)702-5125Name

Problems, suggestions:

Title

Report attached Survey form

Date Phone no.

4. Other interviews (optional): Report attached Survey forms (2)

Doug Wall, American Remediation Response, remediation contractor, survey form attached

Rodney Townsend, R & R Recreation, property owner, survey form attached

Debra Baker, Connelly, Baker, Wotring, Jackson, PRP attorney, survey form attached

Les Appelt, Landowner, survey form attached

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

1. O&M Documents[XJ O&M manual (long term monitoring plan)

1X1 As-built drawings

£3 Maintenance logs(annual inspection reports) [X] Readily available

Remarks: O&M manual kept at Parsons Engineering Science office.

Readily availableReadily available

Up to date G N/AUp to date D N/A

Up to date D N/A

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

Remarks: Contingency plan/emergency response plan not made available at site visit.

3. O&M and OSHA Training Records I I Readily available

Remarks: O&M and OSHA Training Records not made available at site visit.

Up to date N/A

4. Permits and Service AgreementsI I Air discharge permitI I Effluent dischargeD Waste disposal, POTWI I Other permits

I I ReadilyI I ReadilyD ReadilyG Readily

availableavailableavailableavailable

DDD

Up to dateUp to dateUp to dateUp to date

N/AN/AN/AN/A

Remarks: No permits or Service Agreements associated with site.

5. Gas Generation Records Readily available G Up to date [X] N/A

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

7. Ground Water Monitoring Records D Readily available D Up to date g

Original O&M cost estimate I I Breakdown attached

Total annual cost by year for review period, if available

2000

2001

Date

From 1999

From

From

From

From.

From,

From

From

2002

Date

to 2000

to 2001

to 2002

to 2003

_to

_to

_to

to

Total Cost

$30.400

$47.700

$9.300

$3.700

I I Breakdown attached

I I Breakdown attached

I I Breakdown attached

I | Breakdown attached

I I Breakdown attached

I | Breakdown attached

I | Breakdown attached

I | Breakdown attached

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

O&M cost records not available during inspection.

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing

1. Fencing damaged I I Location shown on site map [X] Gates secured I I N/A

Remarks: The landfill is surrounded by chain link fence topped with 3-strand barbed wire except inareas where marsh prohibits access. All gates were closed and locked at the time of the site inspection.

B. Other Access Restrictions

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

Remarks: Signs were posted on all gates, along fences, and in marsh surrounding landfill caps.

C. Institutional Controls

1. Implementation and enforcement

Site conditions imply ICs not properly implemented I I Yes Q No ^ N/ASite conditions imply ICs not being fully enforced | | Yes Q No IXl N/A

Type of monitoring (e.g., self-reporting, drive by) Annual site inspectionsFrequency AnnuallyResponsible party/agency Parsons Engineering Science

Contact Julie Larson Project Manager 6/23/05 713-599-3606Name Title Date Phone no.

Reporting is up-to-date IXl Yes d No I I N/AReports are verified by the lead agency 1X1 Yes O No I I N/ASpecific requirements in deed or decision documents have been met I I Yes ^ No I I N/AViolations have been reported I I Yes ^ No I I N/A

Other problems or suggestions: I I Report attachedInstitutional controls are currently being pursued by the EPA through TCEQ Texas Risk ReductionRules (§350.111) to help prevent exposure to contaminants at concentrations above health-based risklevels that may remain at the site in the long term and limit activities at or near the site through a deedrecordation.

2. Adequacy I I ICs are adequate I I ICs are inadequate IXl N/ARemarks: Institutional controls are currently being pursued by the EPA through TCEQ Texas RiskReduction Rules (§350.111) to help prevent exposure to contaminants at concentrations abovehealth-based risk levels that may remain at the site in the long term and limit activities at or near

thesite through a deed recordation.

D. General

1. Vandalism/trespassing I I Location shown on site map IXl No vandalism evidentRemarks:

2. Land use changes onsiteiAl N/ARemarks: Landowner in association with Duck Unlimited using site as hunting preserve whilepreserving wetland environment.

3. Land use changes offsite 1X1 N/ARemarks:

VI. GENERAL SITE CONDITIONS

A. Roads [X] Applicable D N/A

Remarks: Gravel roads around landfill caps in good condition.

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS Applicable DN/AA. Landfill Surface

1. Settlement (Low spots) I I Location shown on site mapAreal extent DepthRemarks:

Settlement not evident

2. CracksLengths

Location shown on site map I I Cracking not evidentWidths Depths

Remarks: Minor and discontinuous desiccation cracking of topsoil evident on North and EastDike Areas due to dry conditions.

Location shown on site map QErosion not evidentDepth

3. ErosionAreal extentRemarks: Isolated area of erosion along north side of North Dike Area where landfill cap meets riprap covered slope and geotextile fabric is exposed.

4. HolesAreal extent

Holes evident Holes not evidentDepth

Remarks: Minor holes caused by burrowing animals were evident near the top of the cap.

5. Vegetative Cover 1X1 Grass IXI Cover properly established d]No signs of stressI I Trees/Shrubs (indicate size and locations on a diagram) (None)Remarks: Vegetative cover generally in good condition with discontinuous areas of sparse vegetationapparent due to dry conditions.

6. Alternative Cover (armored rock, concrete, etc.) [X] N/ARemarks: Rip rap on landfill slopes in good condition with no obvious signs of erosion orvegetation.

7. BulgesAreal extentRemarks:

I I Location shown on site mapDepth

Bulges not evident

8. Wet Areas/Water Damage

I I Wet areasI I PondingI I SeepsI I Soft subgrade

Remarks:

lAl Wet areas/water damage not evident

I I Location shown on site mapI I Location shown on site mapI | Location shown on site mapI I Location shown on site map

I I Areal extentI I Areal extentI | Areal extentI I Areal extent

9. Slope Instability Q Slides

^ No evidence of slope instability

Remarks:

Location shown on site map

Areal extent _

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

1. Flows Bypass BenchRemarks:

Location shown on site map N/A or okay

2. Bench BreachedRemarks:

Location shown on site map I I N/A or okay

3. Bench OvertoppedRemarks:

I I Location shown on site map N/A or okay

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

1. SettlementAreal extent.Remarks:

I I Location shown on site map I I No evidence of settlementDepth

2. Material Degradation I I Location shown on site map I I No evidence of degradationMaterial type Areal extentRemarks:

3. ErosionAreal extent.Remarks:

Location shown on site map I I No evidence of erosionDepth

4. UndercuttingAreal extentRemarks:

Location shown on site mapDepth

No evidence of undercutting

5. Obstructions TypeNo obstructions I | Location shown on site map

Areal extent.Remarks:

Size

6. Excessive Vegetative Growth TypeCD No evidence of excessive growthI I Location shown on site mapRemarks:

I I Vegetation in channels does not obstruct flowAreal extent

D. Cover Penetrations [XJ Applicable I I N/A1. Gas Vents 1 1 Active IXl Passive

1 1 Properly secured/locked I I Functioning | | Routinely sampled IXl1 1 Evidence of leakage at penetration I I Needs O&M 1 1Remarks:

2. Gas Monitoring Probes1 1 Properly secured/locked 1 1 Functioning 1 1 Routinely sampled 1 11 1 Evidence of leakage at penetration 1 1 Needs O&M IXlRemarks:

Good conditionN/A

Good conditionN/A

3. Monitoring Wells (within surface area of landfill)1 1 Evidence of leakage at penetration Q Needs O&M IXlRemarks:

4. Leachate Extraction Wells|~~l Properly secured/locked 1 1 Functioning QRoutinely sampled 1 11 1 Evidence of leakage at penetration | | Needs O&M IXlRemarks:

5. Settlement MonumentsRemarks:

| Located | | Routinely surveyed 1X1

N/A

Good conditionN/A

N/A

E. Gas Collection and Treatment1. Gas Treatment Facilities

CD Flaring1 1 Good conditionRemarks:

D Applicable [El N/A

HI Thermal destruction 1 1 Collection for reuseH Needs O&M

2. Gas Collection Wells, Manifolds, and Piping | | Good condition IIRemarks:

Needs O&M

3. Gas Monitoring Facilities (e.g.,1 1 Good conditionRemarks:

gas monitoring of adjacent homes or buildings)HI Needs O&M D N/A

F. Cover Drainage Layer D Applicable |E1 N/A1. Outlet Pipes Inspected | | Functioning | | N/A

Remarks:

2. Outlet Rock InspectedRemarks:

G. Detention/Sedimentation Ponds

_| Functioning | | N/A

D Applicable £

1. Siltation Areal extent Size1 1 N/A | | Siltation not evidentRemarks:

2. Erosion Areal1 1 Erosion not evidentRemarks:

extent Depth

3. Outlet WorksRemarks:

1 1 Functioning ^N/A

4. DamRemarks:

1 1 Functioning ^N/A

H. Retaining Walls

1. DeformationsHorizontal displacementRotational displacementRemarks:

[D Applicable £3 N/A

I | Location shown on site map 1 1 Deformation not evidentVertical displacement

2. DegradationRemarks:

1 1 Location shown on site map 1 1 Degradation not evident

I. Perimeter Ditches/Off-Site

1. SiltationAreal extentRemarks:

Discharge [~] Applicable ^

1 1 Location shown on site mapDepth

N/A

1 1 Siltation not evident

2 . Vegetative Growth I I Location shown on site map1 1 Vegetation does not impede flowAreal extent TypeRemarks:

G N/A

3. ErosionAreal extentRemarks:

1 1 Location shown on site mapDepth

1 1 Erosion not evident

4. Discharge StructureRemarks:

VIII. VERTICAL

1. SettlementAreal extent

1 1 Functioning |~| N/A

BARRIER WALLS D Applicable (El N/A

I | Location shown on site mapDepth

I | Settlement not evident

Remarks:

2. Performance Monitoring Type of monitoringI I Performance not monitored Frequency I I Evidence of breachingHead differentialRemarks:

IX. GROUND WATER/SURFACE WATER REMEDIES D Applicable |E1 N/AA. Ground Water Extraction Weils, Pumps, and Pipelines I I Applicable IXI N/A1. Pumps, Wellhead Plumbing, and Electrical

I I Good condition I I All required wells located I I Needs O&M I I N/ARemarks:

2. Extraction System Pipelines, Valves, Valve Boxes, and Other AppurtenancesI I Good condition I I Needs O&MRemarks:

3. Spare Parts and EquipmentI I Readily available I I Good condition I I Requires upgrade I I Needs to be providedRemarks:

B. Surface Water Collect