Popile, Inc. Site Union County El Dorado, Arkansas · 2019-12-16 · Shawn Ghose M.S., P.E. ASME...
Transcript of Popile, Inc. Site Union County El Dorado, Arkansas · 2019-12-16 · Shawn Ghose M.S., P.E. ASME...
Second Five-Year Review Report For
Popile Inc Site Union County
El Dorado Arkansas
^lt^^deg ^ ^ gt5
September 2011
Prepared By Region 6
United States Environmental Protection Agency Dallas Texas
644011
SECOND FIVE-YEAR REVIEW Popile Inc
ARD008052508 Union County Arkansas
This memorandum documents the United States Environmental Protection Agencys (EPA) approval of the Popile Second Five-Year Review Report prepared by United States Army Corps of Engineers New Orleans District (USACE-MVN) on behalf of EPA
Summary of Five-Year Review Findings Popile Inc a wood preservation facility where wood treatment processes and waste management (use of surface impoundments) resulted in soil groundwater surface water and sediment contamination Removal actions were conducted in the early 1990s The excavated sludge and contaminated soil were stabilized using rice hulls and fly ash and disposed of onsite in two clay-lined holding cells The 1993 ROD requires control of migration of the shallow groundwater contaminants to reduce or eliminate the threat of impacting Bayou de Loutre to the east and northeast of the contaminant plume A threat to the deeper drinking water aquifer was also identified as part of the 1993 ROD The goal of the remedy was to reduce the threat to Bayou Lotoure and restore the shallow aquifer to potential beneficial use The goal was to be met by use of a pump and treat system
In 1997 it was recognized that the subsurface groundwater flow was not properly characterized A Site Characterization and Analysis Penetrometer (SCAP) study by USACE in conjunction with detailed boring monitoring wells and sampling established that the contaminant plume was confined to the shallow Cockfield aquifer and the main deeper aquifer was separated from the shallow aquifer by a thick shale Moreover there was no threat that the shallow aquifer containing the pentachlorophenol (PCP) plume would discharge into Bayou De Loutre which is downgradient and east of the old impoundments A USACE groundwater model with better defined subsurface hydrology showed that the contaminant plume in the shallow aquifer was static for 40 years prior to the investigation and would remain static for the next 50 years Based on these findings the original ROD was amended in 2001The amended ROD recommended groundwater monitoring for the contaminants of concern and implementation of engineering and institutional controls The engineering controls included a small cap north of the plume fencing warning signs and erosion controls Three years of groundwater monitoring prior to the first Five-Year Review indicated that the contamination plume was static These findings supported the groundwater models prediction that the plume would be static for the next fifty years Also sampling results indicated that the area downgradient of the plume east of the railroad tracks was free of the contaminants of concern The first Five-Year Review conducted in September 2006 concluded that the site remedy was progressing as expected and site conditions were protective of public health and the environment
Institutional controls (land use restrictions) were implemented in 2008 Prior to implementation of the ICs the objectives of a deed restriction eg no use of shallow
groundwater no excavation activities onsite and no drilling into the shallow groundwater were effectively met by means of engineering controls including a fence with locked gates and warning signs
In 2010 the USACE New Orleans District contracted Strategic Planning Associates -Materials Management Group (SPA-MMG) for groundwater sampling^ The results indicated levels of contaminants consistent with levels from previous sampling events and signs of natural attenuation These groundwater sampling conclusions indicate that the remedies are continuing to serve as protective of public health and the environment
Actions Needed Institutional Controls Institutional Control Agreements between the landowners and the EPA were signed in 2008 Per the Institutional Control agreements the landowners shall maintain integrity of and access to the monitoring wells Currently there are no major deficiencies in the integrity of the monitoring wells Institutional controls need to be maintained
Engineering controls Portions of the perimeter fence have been taken down by the landowners and the main gate has been left open The EPA should take steps to have the fence restored and take other measures to prevent public access to the site
The main soil cells have young trees growing on the clay caps and minor erosion issues Currently the trees have not damaged the clay caps The EPA should remove the tree growth to ensure that the integrity of the clay caps is not compromised The EPA should monitor and remove future tree growth
Groundwater monitoring will be conducted on a yearly basis for the next five years to statistically evaluate the contamination plume and data at the next 5-Year Review report Natural attenuation is considered to be occurring but monitoring should continue to ensure that natural attenuation will continue to occur in the future
Determinations I have determined that the remedy for the Popile Inc site is protective of human health and the environment and will remain so provided the action items identified in the Second Five-Year Review Report are addressed as described above
sMu Samuel Coleman PE C^ Date Director Superftind Division US Environmental Protection Agency Region 6
CONCURRENCES SECOND FIVE-YEAR REVIEW
for the Popile Inc Superfund Site
Shawn Ghose MS PE ASME Remedial Project Manager ArkansasTexas Section Remedial Branch Superfund Division
Attorney Elizabeth Pletan Superfund Branch
Office of Regional Counsel
iCarlos Sanchez - 1mdash-^ iChief ArkansasTexas Section Remedial Branch Superfund Division
Charles Faultry Associate Director Remedial Branch Superfund Division
Mark Peycke Associate Dire6tor Superfund Branch Office of Regional Counsel
Pamela Phiflips Deputy Director Supbrfund Division
Date
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Second Five-Year Review Report
Table of Contents Table of Contents iii Executive Summary v Second Five-Year Review Summary Form vi I Introduction 1 II Site Chronology 2 III Background 2 IV Remedial Actions 3 V Progress Since the Last Review 4 VI Five-Year Review Process 5 VII Technical Assessment 16 Vm Issues 20 IX Recommendations and Follow-up Actions 20 X Protectiveness Statement 21 XI Next Review 21
Tables Table 1 ~ Chronology of Site Events Table 2 ~ Annual System OperationsOampM Costs Table 3 mdash Summary of 2010 Sampling Event Results Table 4 ~ Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results bull Table 5 mdash Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event Table 6 ~ Summary of Evidence of Natural Attenuation- 2010 Table 7 mdash Issues Table 8 - Recommendations and Follow-up Actions
bull
Appendices Appendix A Maps and Institutional Controls Appendix B El Dorado Times Public Announcement Appendix C Interview Documentation Appendix D Site Inspection Checklist Appendix E Site Photos Appendix F List of Documents Reviewed
111
Recommendations and Follow-up Actions
Issue
Institutional Controls
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA Region 6 ADEQ
EPA and then ADEQ when OampM starts
EPAEl Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
EPA
Milestone Date
Signed 2008
2012
2012
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
N
Y
Y
N
Y
Y
List of Acronyms
ACL ADEQ CERCLA
COC CSIA EPA IC GW LIF MCL MDL MMG NA NCP NOD NPL NR OifeM OU PAHs PCP RAO RCRA RIFS ROD SCAPS SVOCs TBC USACE
Alternate Concentration Limit Arkansas Department of Environmental Quality Comprehensive Environmental Response Compensation and Liability Act Contaminant of Concern Compound Specific Isotope Analysis Environmental Protection Agency Institutional Control Groundwater Laser-induced Fluorescence Maximum Contaminant Level Method Detection Limit Materials Management Group Inc Not Analyzed National Contingency Plan New Orleans District National Priorities List Not Reported Operations amp Maintenance Operable Unit Polycyclic Aromatic Hydrocarbons Pentachlorophenol Remedial Action Objective Resource Conservation and Recovery Act Remedial InvestigationFeasibility Study Record of Decision Site Characterization and Analysis Penetrometer System Semi-Volatile Organic Compounds To-Be Considered United States Army Corps of Engineers
IV
Executive Summary
The Amended Record of Decision (ROD) signed in September 2001 provided new remedial action objectives for the Popile Inc Superfund Site The 1993 ROD required control of migration of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the contaminant plume into Bayou de Loutre The shallow aquifer was to be restored to potential beneficial use by a pump and treat system A site investigation by USACE to characterize the shallow aquifer by means of SCAP and extensive boring monitoring wells and subsurface sampling established that the contaminant plume was static and immediately downgradient areas of the contaminant plume were clean (1997) The results of the site investigation were confirmed by a groundwater model of the shallow aquifer Since the groundwater modeling study confirmed the results of the site investigation by USACE ie the contamination plume was static (and unlikely to impact the deeper aquifer or Bayou de Loutre) the EPA determined that groundwater monitoring for the contaminants of concern and the implementation of engineering and institutional controls were adequate for the protection of public health Therefore the Amended ROD (2001) called for a five-year groundwater monitoring and engineering maintenance program Three years of this program had been implemented prior to the first Five-Year Review The results indicated that the groundwater contaminant plume was static (as predicted by the modeling study) natural attenuation was taking place at the site and engineering controls were being maintained In 2008 EPA and the landowners implemented institutional controls (land use controls) Groundwater monitoring was undertaken in 2010 Groundwater monitoring has shown that natural attenuation is occurring The site remedy is functioning as expected
Representatives of USACE ADEQ EPA and landovraers conducted the Five-Year Review site inspection on May 19 2011 Issues observed consisted mainly of security fencing issues and vegetation growth
Groundwater monitoring results from 2010 indicate the remedial actions at Popile Inc Superfund site are protective therefore the site is considered protective of human health and the environment
Second Five-Year Review Summary Form
SITE IDENTIFICATION
Site name Popi e Inc 1 1 EPA ID ARD008052508 |
Region 6 State AR CityCounty El DoradoUnion |
SITE STATUS
NPL status x Final Deleted Other (specify)
Remediation status (chioose all that apply) Under Construction X Operating Complete
Mult iple OUs YES XNO Construct ion complet ion date I I
Has site been put into reuse x YES NO
REVIEW STATUS
Lead agency X EPA State Tribe Other Federal Agency
Author name Shawn Ghose
Author t i t le Remedial Project Manager Author aff i l iat ion EPA Region 6
Review p e r i o d 0 3 2 4 2 0 1 1 to 0 6 1 5 2011
Date(s) of site inspect ion 05 1 9 2011
Type of review X Post-SARA Pre-SARA
Non-NPL Remedial Action Site Regional Discretion
NPL-Removal only NPL StateTribe-lead
R e v i e w n u m b e r 1 (first) X 2 (second) 3 (third) Other (specify)
Tr igger ing act ion Actual RA Onsite Construction at OU _
Construction Completion ^nd
Actual RA Start at 0U Previous Five-Year Review Report
X Other - 2 review - statutory requirement
Tr igger ing act ion date 09 26 2006
Due date (five years after triggering action date) 09 26 2011
[OU refers to operable unit] [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN] Since its Institutional Control Agreement with USEPA in 2008 El Dorado Timber Company has utilized its land within the Popile Inc site for storage of heavy equipment and has left the main gate to the site open for access El Ark Industries Inc has taken the western security perimeter fence down to adjoin its adjacent active timber operation with its land within the Popile inc site
VI
Second Five-Year Review S u m m a r y Fo rm con t d
Issues Inadequate access controls (security fencingdeficiencies) Inadequate operation and maintenance of physical remedial structures (vegetation growth on soil cell caps areas of minor erosion) Large machinery staging with corroding batteries small pool of standing water
Recommendations and Foilow-up Actions
Remedy inadequate access controls address issues with security fence and main gate Fence should be restored or other measures taken to prevent public access to the site
Remedy inadequate operation and maintenance of physical remedial structures address vegetation growth on clay caps and erosion to prevent breach
Maintain institutional controls which were signed and recorded in 2008
Maintain access to monitoring wells
Continue groundwater monitoring on a yearly frequency for five years
Continue monitoring of natural attenuation
Protectiveness Statement(s) Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite as downgradient migration off site is not evident Institutional controls have been implemented The results of this five-year review indicate that the remedy stated in the Amended ROD appears to be functioning as required
vn
Second Five-Year Review Report
I Introduction
The purpose of this five-year review is to determine whether the site remedy for the Popile Inc Superfiand site is protective of human health and the environment The remedy for the Popile site involved groundwater monitoring and maintenance of engineering controls as well as implementation of institutional controls (land use restrictions-Appendix A) including an Operation and Maintenance Plan to monitor the effectiveness of the institutional controls The methods findings and conclusions of the five-year review are documented in the Five-Year Review Report The report also highlights any issues identified and recommendations for further management The Envirormiental Protection Agency (EPA) is responsible for conducting the five-year review pursuant to CERCLA sect121 and the National Contingency Plan (NCP) CERCLA sect121 states
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 In addition if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106] the President shall take or require such action The President shall report to the Congress a list of facilities for which such review is required the results of all such reviews and any actions taken as a result of such reviews
The agency interpreted this requirement further in the NCP 40 CFR sect300430(f)(4)(ii) states
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
The US Environmental Protection Agency (EPA) Region 6 has conducted a five-year review of the remedial actions implemented at the Popile Inc site in El Dorado Arkansas The first review was conducted from August 2006 to September 2006 This is the second five year review which was conducted from March 2011 to June 2011 In 2010 the US Army Corps of Engineers (USACE) - New Orleans District (MVN) Materials Management Group Inc (MMG) provided a groundwater monitoring analysis The USACE-MVN along with USEPA and the Arkansas Department of Environmental Quality (ADEQ) conducted an inspection of the site in May 2011 in support of the five-year review
This is the second five-year review for the Popile Inc site following preparation of the Amended Record of Decision (ROD) The triggering action of the five-year reviews is the date of the Amended ROD as shown in EPAs Waste LAN database September 2001 the triggering action for this second review is the date of the first Five-Year Review in 2006
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
SECOND FIVE-YEAR REVIEW Popile Inc
ARD008052508 Union County Arkansas
This memorandum documents the United States Environmental Protection Agencys (EPA) approval of the Popile Second Five-Year Review Report prepared by United States Army Corps of Engineers New Orleans District (USACE-MVN) on behalf of EPA
Summary of Five-Year Review Findings Popile Inc a wood preservation facility where wood treatment processes and waste management (use of surface impoundments) resulted in soil groundwater surface water and sediment contamination Removal actions were conducted in the early 1990s The excavated sludge and contaminated soil were stabilized using rice hulls and fly ash and disposed of onsite in two clay-lined holding cells The 1993 ROD requires control of migration of the shallow groundwater contaminants to reduce or eliminate the threat of impacting Bayou de Loutre to the east and northeast of the contaminant plume A threat to the deeper drinking water aquifer was also identified as part of the 1993 ROD The goal of the remedy was to reduce the threat to Bayou Lotoure and restore the shallow aquifer to potential beneficial use The goal was to be met by use of a pump and treat system
In 1997 it was recognized that the subsurface groundwater flow was not properly characterized A Site Characterization and Analysis Penetrometer (SCAP) study by USACE in conjunction with detailed boring monitoring wells and sampling established that the contaminant plume was confined to the shallow Cockfield aquifer and the main deeper aquifer was separated from the shallow aquifer by a thick shale Moreover there was no threat that the shallow aquifer containing the pentachlorophenol (PCP) plume would discharge into Bayou De Loutre which is downgradient and east of the old impoundments A USACE groundwater model with better defined subsurface hydrology showed that the contaminant plume in the shallow aquifer was static for 40 years prior to the investigation and would remain static for the next 50 years Based on these findings the original ROD was amended in 2001The amended ROD recommended groundwater monitoring for the contaminants of concern and implementation of engineering and institutional controls The engineering controls included a small cap north of the plume fencing warning signs and erosion controls Three years of groundwater monitoring prior to the first Five-Year Review indicated that the contamination plume was static These findings supported the groundwater models prediction that the plume would be static for the next fifty years Also sampling results indicated that the area downgradient of the plume east of the railroad tracks was free of the contaminants of concern The first Five-Year Review conducted in September 2006 concluded that the site remedy was progressing as expected and site conditions were protective of public health and the environment
Institutional controls (land use restrictions) were implemented in 2008 Prior to implementation of the ICs the objectives of a deed restriction eg no use of shallow
groundwater no excavation activities onsite and no drilling into the shallow groundwater were effectively met by means of engineering controls including a fence with locked gates and warning signs
In 2010 the USACE New Orleans District contracted Strategic Planning Associates -Materials Management Group (SPA-MMG) for groundwater sampling^ The results indicated levels of contaminants consistent with levels from previous sampling events and signs of natural attenuation These groundwater sampling conclusions indicate that the remedies are continuing to serve as protective of public health and the environment
Actions Needed Institutional Controls Institutional Control Agreements between the landowners and the EPA were signed in 2008 Per the Institutional Control agreements the landowners shall maintain integrity of and access to the monitoring wells Currently there are no major deficiencies in the integrity of the monitoring wells Institutional controls need to be maintained
Engineering controls Portions of the perimeter fence have been taken down by the landowners and the main gate has been left open The EPA should take steps to have the fence restored and take other measures to prevent public access to the site
The main soil cells have young trees growing on the clay caps and minor erosion issues Currently the trees have not damaged the clay caps The EPA should remove the tree growth to ensure that the integrity of the clay caps is not compromised The EPA should monitor and remove future tree growth
Groundwater monitoring will be conducted on a yearly basis for the next five years to statistically evaluate the contamination plume and data at the next 5-Year Review report Natural attenuation is considered to be occurring but monitoring should continue to ensure that natural attenuation will continue to occur in the future
Determinations I have determined that the remedy for the Popile Inc site is protective of human health and the environment and will remain so provided the action items identified in the Second Five-Year Review Report are addressed as described above
sMu Samuel Coleman PE C^ Date Director Superftind Division US Environmental Protection Agency Region 6
CONCURRENCES SECOND FIVE-YEAR REVIEW
for the Popile Inc Superfund Site
Shawn Ghose MS PE ASME Remedial Project Manager ArkansasTexas Section Remedial Branch Superfund Division
Attorney Elizabeth Pletan Superfund Branch
Office of Regional Counsel
iCarlos Sanchez - 1mdash-^ iChief ArkansasTexas Section Remedial Branch Superfund Division
Charles Faultry Associate Director Remedial Branch Superfund Division
Mark Peycke Associate Dire6tor Superfund Branch Office of Regional Counsel
Pamela Phiflips Deputy Director Supbrfund Division
Date
^-U-Date
Date
Dati IL
Date
mte
Second Five-Year Review Report
Table of Contents Table of Contents iii Executive Summary v Second Five-Year Review Summary Form vi I Introduction 1 II Site Chronology 2 III Background 2 IV Remedial Actions 3 V Progress Since the Last Review 4 VI Five-Year Review Process 5 VII Technical Assessment 16 Vm Issues 20 IX Recommendations and Follow-up Actions 20 X Protectiveness Statement 21 XI Next Review 21
Tables Table 1 ~ Chronology of Site Events Table 2 ~ Annual System OperationsOampM Costs Table 3 mdash Summary of 2010 Sampling Event Results Table 4 ~ Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results bull Table 5 mdash Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event Table 6 ~ Summary of Evidence of Natural Attenuation- 2010 Table 7 mdash Issues Table 8 - Recommendations and Follow-up Actions
bull
Appendices Appendix A Maps and Institutional Controls Appendix B El Dorado Times Public Announcement Appendix C Interview Documentation Appendix D Site Inspection Checklist Appendix E Site Photos Appendix F List of Documents Reviewed
111
Recommendations and Follow-up Actions
Issue
Institutional Controls
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA Region 6 ADEQ
EPA and then ADEQ when OampM starts
EPAEl Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
EPA
Milestone Date
Signed 2008
2012
2012
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
N
Y
Y
N
Y
Y
List of Acronyms
ACL ADEQ CERCLA
COC CSIA EPA IC GW LIF MCL MDL MMG NA NCP NOD NPL NR OifeM OU PAHs PCP RAO RCRA RIFS ROD SCAPS SVOCs TBC USACE
Alternate Concentration Limit Arkansas Department of Environmental Quality Comprehensive Environmental Response Compensation and Liability Act Contaminant of Concern Compound Specific Isotope Analysis Environmental Protection Agency Institutional Control Groundwater Laser-induced Fluorescence Maximum Contaminant Level Method Detection Limit Materials Management Group Inc Not Analyzed National Contingency Plan New Orleans District National Priorities List Not Reported Operations amp Maintenance Operable Unit Polycyclic Aromatic Hydrocarbons Pentachlorophenol Remedial Action Objective Resource Conservation and Recovery Act Remedial InvestigationFeasibility Study Record of Decision Site Characterization and Analysis Penetrometer System Semi-Volatile Organic Compounds To-Be Considered United States Army Corps of Engineers
IV
Executive Summary
The Amended Record of Decision (ROD) signed in September 2001 provided new remedial action objectives for the Popile Inc Superfund Site The 1993 ROD required control of migration of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the contaminant plume into Bayou de Loutre The shallow aquifer was to be restored to potential beneficial use by a pump and treat system A site investigation by USACE to characterize the shallow aquifer by means of SCAP and extensive boring monitoring wells and subsurface sampling established that the contaminant plume was static and immediately downgradient areas of the contaminant plume were clean (1997) The results of the site investigation were confirmed by a groundwater model of the shallow aquifer Since the groundwater modeling study confirmed the results of the site investigation by USACE ie the contamination plume was static (and unlikely to impact the deeper aquifer or Bayou de Loutre) the EPA determined that groundwater monitoring for the contaminants of concern and the implementation of engineering and institutional controls were adequate for the protection of public health Therefore the Amended ROD (2001) called for a five-year groundwater monitoring and engineering maintenance program Three years of this program had been implemented prior to the first Five-Year Review The results indicated that the groundwater contaminant plume was static (as predicted by the modeling study) natural attenuation was taking place at the site and engineering controls were being maintained In 2008 EPA and the landowners implemented institutional controls (land use controls) Groundwater monitoring was undertaken in 2010 Groundwater monitoring has shown that natural attenuation is occurring The site remedy is functioning as expected
Representatives of USACE ADEQ EPA and landovraers conducted the Five-Year Review site inspection on May 19 2011 Issues observed consisted mainly of security fencing issues and vegetation growth
Groundwater monitoring results from 2010 indicate the remedial actions at Popile Inc Superfund site are protective therefore the site is considered protective of human health and the environment
Second Five-Year Review Summary Form
SITE IDENTIFICATION
Site name Popi e Inc 1 1 EPA ID ARD008052508 |
Region 6 State AR CityCounty El DoradoUnion |
SITE STATUS
NPL status x Final Deleted Other (specify)
Remediation status (chioose all that apply) Under Construction X Operating Complete
Mult iple OUs YES XNO Construct ion complet ion date I I
Has site been put into reuse x YES NO
REVIEW STATUS
Lead agency X EPA State Tribe Other Federal Agency
Author name Shawn Ghose
Author t i t le Remedial Project Manager Author aff i l iat ion EPA Region 6
Review p e r i o d 0 3 2 4 2 0 1 1 to 0 6 1 5 2011
Date(s) of site inspect ion 05 1 9 2011
Type of review X Post-SARA Pre-SARA
Non-NPL Remedial Action Site Regional Discretion
NPL-Removal only NPL StateTribe-lead
R e v i e w n u m b e r 1 (first) X 2 (second) 3 (third) Other (specify)
Tr igger ing act ion Actual RA Onsite Construction at OU _
Construction Completion ^nd
Actual RA Start at 0U Previous Five-Year Review Report
X Other - 2 review - statutory requirement
Tr igger ing act ion date 09 26 2006
Due date (five years after triggering action date) 09 26 2011
[OU refers to operable unit] [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN] Since its Institutional Control Agreement with USEPA in 2008 El Dorado Timber Company has utilized its land within the Popile Inc site for storage of heavy equipment and has left the main gate to the site open for access El Ark Industries Inc has taken the western security perimeter fence down to adjoin its adjacent active timber operation with its land within the Popile inc site
VI
Second Five-Year Review S u m m a r y Fo rm con t d
Issues Inadequate access controls (security fencingdeficiencies) Inadequate operation and maintenance of physical remedial structures (vegetation growth on soil cell caps areas of minor erosion) Large machinery staging with corroding batteries small pool of standing water
Recommendations and Foilow-up Actions
Remedy inadequate access controls address issues with security fence and main gate Fence should be restored or other measures taken to prevent public access to the site
Remedy inadequate operation and maintenance of physical remedial structures address vegetation growth on clay caps and erosion to prevent breach
Maintain institutional controls which were signed and recorded in 2008
Maintain access to monitoring wells
Continue groundwater monitoring on a yearly frequency for five years
Continue monitoring of natural attenuation
Protectiveness Statement(s) Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite as downgradient migration off site is not evident Institutional controls have been implemented The results of this five-year review indicate that the remedy stated in the Amended ROD appears to be functioning as required
vn
Second Five-Year Review Report
I Introduction
The purpose of this five-year review is to determine whether the site remedy for the Popile Inc Superfiand site is protective of human health and the environment The remedy for the Popile site involved groundwater monitoring and maintenance of engineering controls as well as implementation of institutional controls (land use restrictions-Appendix A) including an Operation and Maintenance Plan to monitor the effectiveness of the institutional controls The methods findings and conclusions of the five-year review are documented in the Five-Year Review Report The report also highlights any issues identified and recommendations for further management The Envirormiental Protection Agency (EPA) is responsible for conducting the five-year review pursuant to CERCLA sect121 and the National Contingency Plan (NCP) CERCLA sect121 states
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 In addition if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106] the President shall take or require such action The President shall report to the Congress a list of facilities for which such review is required the results of all such reviews and any actions taken as a result of such reviews
The agency interpreted this requirement further in the NCP 40 CFR sect300430(f)(4)(ii) states
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
The US Environmental Protection Agency (EPA) Region 6 has conducted a five-year review of the remedial actions implemented at the Popile Inc site in El Dorado Arkansas The first review was conducted from August 2006 to September 2006 This is the second five year review which was conducted from March 2011 to June 2011 In 2010 the US Army Corps of Engineers (USACE) - New Orleans District (MVN) Materials Management Group Inc (MMG) provided a groundwater monitoring analysis The USACE-MVN along with USEPA and the Arkansas Department of Environmental Quality (ADEQ) conducted an inspection of the site in May 2011 in support of the five-year review
This is the second five-year review for the Popile Inc site following preparation of the Amended Record of Decision (ROD) The triggering action of the five-year reviews is the date of the Amended ROD as shown in EPAs Waste LAN database September 2001 the triggering action for this second review is the date of the first Five-Year Review in 2006
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
groundwater no excavation activities onsite and no drilling into the shallow groundwater were effectively met by means of engineering controls including a fence with locked gates and warning signs
In 2010 the USACE New Orleans District contracted Strategic Planning Associates -Materials Management Group (SPA-MMG) for groundwater sampling^ The results indicated levels of contaminants consistent with levels from previous sampling events and signs of natural attenuation These groundwater sampling conclusions indicate that the remedies are continuing to serve as protective of public health and the environment
Actions Needed Institutional Controls Institutional Control Agreements between the landowners and the EPA were signed in 2008 Per the Institutional Control agreements the landowners shall maintain integrity of and access to the monitoring wells Currently there are no major deficiencies in the integrity of the monitoring wells Institutional controls need to be maintained
Engineering controls Portions of the perimeter fence have been taken down by the landowners and the main gate has been left open The EPA should take steps to have the fence restored and take other measures to prevent public access to the site
The main soil cells have young trees growing on the clay caps and minor erosion issues Currently the trees have not damaged the clay caps The EPA should remove the tree growth to ensure that the integrity of the clay caps is not compromised The EPA should monitor and remove future tree growth
Groundwater monitoring will be conducted on a yearly basis for the next five years to statistically evaluate the contamination plume and data at the next 5-Year Review report Natural attenuation is considered to be occurring but monitoring should continue to ensure that natural attenuation will continue to occur in the future
Determinations I have determined that the remedy for the Popile Inc site is protective of human health and the environment and will remain so provided the action items identified in the Second Five-Year Review Report are addressed as described above
sMu Samuel Coleman PE C^ Date Director Superftind Division US Environmental Protection Agency Region 6
CONCURRENCES SECOND FIVE-YEAR REVIEW
for the Popile Inc Superfund Site
Shawn Ghose MS PE ASME Remedial Project Manager ArkansasTexas Section Remedial Branch Superfund Division
Attorney Elizabeth Pletan Superfund Branch
Office of Regional Counsel
iCarlos Sanchez - 1mdash-^ iChief ArkansasTexas Section Remedial Branch Superfund Division
Charles Faultry Associate Director Remedial Branch Superfund Division
Mark Peycke Associate Dire6tor Superfund Branch Office of Regional Counsel
Pamela Phiflips Deputy Director Supbrfund Division
Date
^-U-Date
Date
Dati IL
Date
mte
Second Five-Year Review Report
Table of Contents Table of Contents iii Executive Summary v Second Five-Year Review Summary Form vi I Introduction 1 II Site Chronology 2 III Background 2 IV Remedial Actions 3 V Progress Since the Last Review 4 VI Five-Year Review Process 5 VII Technical Assessment 16 Vm Issues 20 IX Recommendations and Follow-up Actions 20 X Protectiveness Statement 21 XI Next Review 21
Tables Table 1 ~ Chronology of Site Events Table 2 ~ Annual System OperationsOampM Costs Table 3 mdash Summary of 2010 Sampling Event Results Table 4 ~ Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results bull Table 5 mdash Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event Table 6 ~ Summary of Evidence of Natural Attenuation- 2010 Table 7 mdash Issues Table 8 - Recommendations and Follow-up Actions
bull
Appendices Appendix A Maps and Institutional Controls Appendix B El Dorado Times Public Announcement Appendix C Interview Documentation Appendix D Site Inspection Checklist Appendix E Site Photos Appendix F List of Documents Reviewed
111
Recommendations and Follow-up Actions
Issue
Institutional Controls
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA Region 6 ADEQ
EPA and then ADEQ when OampM starts
EPAEl Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
EPA
Milestone Date
Signed 2008
2012
2012
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
N
Y
Y
N
Y
Y
List of Acronyms
ACL ADEQ CERCLA
COC CSIA EPA IC GW LIF MCL MDL MMG NA NCP NOD NPL NR OifeM OU PAHs PCP RAO RCRA RIFS ROD SCAPS SVOCs TBC USACE
Alternate Concentration Limit Arkansas Department of Environmental Quality Comprehensive Environmental Response Compensation and Liability Act Contaminant of Concern Compound Specific Isotope Analysis Environmental Protection Agency Institutional Control Groundwater Laser-induced Fluorescence Maximum Contaminant Level Method Detection Limit Materials Management Group Inc Not Analyzed National Contingency Plan New Orleans District National Priorities List Not Reported Operations amp Maintenance Operable Unit Polycyclic Aromatic Hydrocarbons Pentachlorophenol Remedial Action Objective Resource Conservation and Recovery Act Remedial InvestigationFeasibility Study Record of Decision Site Characterization and Analysis Penetrometer System Semi-Volatile Organic Compounds To-Be Considered United States Army Corps of Engineers
IV
Executive Summary
The Amended Record of Decision (ROD) signed in September 2001 provided new remedial action objectives for the Popile Inc Superfund Site The 1993 ROD required control of migration of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the contaminant plume into Bayou de Loutre The shallow aquifer was to be restored to potential beneficial use by a pump and treat system A site investigation by USACE to characterize the shallow aquifer by means of SCAP and extensive boring monitoring wells and subsurface sampling established that the contaminant plume was static and immediately downgradient areas of the contaminant plume were clean (1997) The results of the site investigation were confirmed by a groundwater model of the shallow aquifer Since the groundwater modeling study confirmed the results of the site investigation by USACE ie the contamination plume was static (and unlikely to impact the deeper aquifer or Bayou de Loutre) the EPA determined that groundwater monitoring for the contaminants of concern and the implementation of engineering and institutional controls were adequate for the protection of public health Therefore the Amended ROD (2001) called for a five-year groundwater monitoring and engineering maintenance program Three years of this program had been implemented prior to the first Five-Year Review The results indicated that the groundwater contaminant plume was static (as predicted by the modeling study) natural attenuation was taking place at the site and engineering controls were being maintained In 2008 EPA and the landowners implemented institutional controls (land use controls) Groundwater monitoring was undertaken in 2010 Groundwater monitoring has shown that natural attenuation is occurring The site remedy is functioning as expected
Representatives of USACE ADEQ EPA and landovraers conducted the Five-Year Review site inspection on May 19 2011 Issues observed consisted mainly of security fencing issues and vegetation growth
Groundwater monitoring results from 2010 indicate the remedial actions at Popile Inc Superfund site are protective therefore the site is considered protective of human health and the environment
Second Five-Year Review Summary Form
SITE IDENTIFICATION
Site name Popi e Inc 1 1 EPA ID ARD008052508 |
Region 6 State AR CityCounty El DoradoUnion |
SITE STATUS
NPL status x Final Deleted Other (specify)
Remediation status (chioose all that apply) Under Construction X Operating Complete
Mult iple OUs YES XNO Construct ion complet ion date I I
Has site been put into reuse x YES NO
REVIEW STATUS
Lead agency X EPA State Tribe Other Federal Agency
Author name Shawn Ghose
Author t i t le Remedial Project Manager Author aff i l iat ion EPA Region 6
Review p e r i o d 0 3 2 4 2 0 1 1 to 0 6 1 5 2011
Date(s) of site inspect ion 05 1 9 2011
Type of review X Post-SARA Pre-SARA
Non-NPL Remedial Action Site Regional Discretion
NPL-Removal only NPL StateTribe-lead
R e v i e w n u m b e r 1 (first) X 2 (second) 3 (third) Other (specify)
Tr igger ing act ion Actual RA Onsite Construction at OU _
Construction Completion ^nd
Actual RA Start at 0U Previous Five-Year Review Report
X Other - 2 review - statutory requirement
Tr igger ing act ion date 09 26 2006
Due date (five years after triggering action date) 09 26 2011
[OU refers to operable unit] [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN] Since its Institutional Control Agreement with USEPA in 2008 El Dorado Timber Company has utilized its land within the Popile Inc site for storage of heavy equipment and has left the main gate to the site open for access El Ark Industries Inc has taken the western security perimeter fence down to adjoin its adjacent active timber operation with its land within the Popile inc site
VI
Second Five-Year Review S u m m a r y Fo rm con t d
Issues Inadequate access controls (security fencingdeficiencies) Inadequate operation and maintenance of physical remedial structures (vegetation growth on soil cell caps areas of minor erosion) Large machinery staging with corroding batteries small pool of standing water
Recommendations and Foilow-up Actions
Remedy inadequate access controls address issues with security fence and main gate Fence should be restored or other measures taken to prevent public access to the site
Remedy inadequate operation and maintenance of physical remedial structures address vegetation growth on clay caps and erosion to prevent breach
Maintain institutional controls which were signed and recorded in 2008
Maintain access to monitoring wells
Continue groundwater monitoring on a yearly frequency for five years
Continue monitoring of natural attenuation
Protectiveness Statement(s) Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite as downgradient migration off site is not evident Institutional controls have been implemented The results of this five-year review indicate that the remedy stated in the Amended ROD appears to be functioning as required
vn
Second Five-Year Review Report
I Introduction
The purpose of this five-year review is to determine whether the site remedy for the Popile Inc Superfiand site is protective of human health and the environment The remedy for the Popile site involved groundwater monitoring and maintenance of engineering controls as well as implementation of institutional controls (land use restrictions-Appendix A) including an Operation and Maintenance Plan to monitor the effectiveness of the institutional controls The methods findings and conclusions of the five-year review are documented in the Five-Year Review Report The report also highlights any issues identified and recommendations for further management The Envirormiental Protection Agency (EPA) is responsible for conducting the five-year review pursuant to CERCLA sect121 and the National Contingency Plan (NCP) CERCLA sect121 states
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 In addition if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106] the President shall take or require such action The President shall report to the Congress a list of facilities for which such review is required the results of all such reviews and any actions taken as a result of such reviews
The agency interpreted this requirement further in the NCP 40 CFR sect300430(f)(4)(ii) states
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
The US Environmental Protection Agency (EPA) Region 6 has conducted a five-year review of the remedial actions implemented at the Popile Inc site in El Dorado Arkansas The first review was conducted from August 2006 to September 2006 This is the second five year review which was conducted from March 2011 to June 2011 In 2010 the US Army Corps of Engineers (USACE) - New Orleans District (MVN) Materials Management Group Inc (MMG) provided a groundwater monitoring analysis The USACE-MVN along with USEPA and the Arkansas Department of Environmental Quality (ADEQ) conducted an inspection of the site in May 2011 in support of the five-year review
This is the second five-year review for the Popile Inc site following preparation of the Amended Record of Decision (ROD) The triggering action of the five-year reviews is the date of the Amended ROD as shown in EPAs Waste LAN database September 2001 the triggering action for this second review is the date of the first Five-Year Review in 2006
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
CONCURRENCES SECOND FIVE-YEAR REVIEW
for the Popile Inc Superfund Site
Shawn Ghose MS PE ASME Remedial Project Manager ArkansasTexas Section Remedial Branch Superfund Division
Attorney Elizabeth Pletan Superfund Branch
Office of Regional Counsel
iCarlos Sanchez - 1mdash-^ iChief ArkansasTexas Section Remedial Branch Superfund Division
Charles Faultry Associate Director Remedial Branch Superfund Division
Mark Peycke Associate Dire6tor Superfund Branch Office of Regional Counsel
Pamela Phiflips Deputy Director Supbrfund Division
Date
^-U-Date
Date
Dati IL
Date
mte
Second Five-Year Review Report
Table of Contents Table of Contents iii Executive Summary v Second Five-Year Review Summary Form vi I Introduction 1 II Site Chronology 2 III Background 2 IV Remedial Actions 3 V Progress Since the Last Review 4 VI Five-Year Review Process 5 VII Technical Assessment 16 Vm Issues 20 IX Recommendations and Follow-up Actions 20 X Protectiveness Statement 21 XI Next Review 21
Tables Table 1 ~ Chronology of Site Events Table 2 ~ Annual System OperationsOampM Costs Table 3 mdash Summary of 2010 Sampling Event Results Table 4 ~ Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results bull Table 5 mdash Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event Table 6 ~ Summary of Evidence of Natural Attenuation- 2010 Table 7 mdash Issues Table 8 - Recommendations and Follow-up Actions
bull
Appendices Appendix A Maps and Institutional Controls Appendix B El Dorado Times Public Announcement Appendix C Interview Documentation Appendix D Site Inspection Checklist Appendix E Site Photos Appendix F List of Documents Reviewed
111
Recommendations and Follow-up Actions
Issue
Institutional Controls
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA Region 6 ADEQ
EPA and then ADEQ when OampM starts
EPAEl Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
EPA
Milestone Date
Signed 2008
2012
2012
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
N
Y
Y
N
Y
Y
List of Acronyms
ACL ADEQ CERCLA
COC CSIA EPA IC GW LIF MCL MDL MMG NA NCP NOD NPL NR OifeM OU PAHs PCP RAO RCRA RIFS ROD SCAPS SVOCs TBC USACE
Alternate Concentration Limit Arkansas Department of Environmental Quality Comprehensive Environmental Response Compensation and Liability Act Contaminant of Concern Compound Specific Isotope Analysis Environmental Protection Agency Institutional Control Groundwater Laser-induced Fluorescence Maximum Contaminant Level Method Detection Limit Materials Management Group Inc Not Analyzed National Contingency Plan New Orleans District National Priorities List Not Reported Operations amp Maintenance Operable Unit Polycyclic Aromatic Hydrocarbons Pentachlorophenol Remedial Action Objective Resource Conservation and Recovery Act Remedial InvestigationFeasibility Study Record of Decision Site Characterization and Analysis Penetrometer System Semi-Volatile Organic Compounds To-Be Considered United States Army Corps of Engineers
IV
Executive Summary
The Amended Record of Decision (ROD) signed in September 2001 provided new remedial action objectives for the Popile Inc Superfund Site The 1993 ROD required control of migration of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the contaminant plume into Bayou de Loutre The shallow aquifer was to be restored to potential beneficial use by a pump and treat system A site investigation by USACE to characterize the shallow aquifer by means of SCAP and extensive boring monitoring wells and subsurface sampling established that the contaminant plume was static and immediately downgradient areas of the contaminant plume were clean (1997) The results of the site investigation were confirmed by a groundwater model of the shallow aquifer Since the groundwater modeling study confirmed the results of the site investigation by USACE ie the contamination plume was static (and unlikely to impact the deeper aquifer or Bayou de Loutre) the EPA determined that groundwater monitoring for the contaminants of concern and the implementation of engineering and institutional controls were adequate for the protection of public health Therefore the Amended ROD (2001) called for a five-year groundwater monitoring and engineering maintenance program Three years of this program had been implemented prior to the first Five-Year Review The results indicated that the groundwater contaminant plume was static (as predicted by the modeling study) natural attenuation was taking place at the site and engineering controls were being maintained In 2008 EPA and the landowners implemented institutional controls (land use controls) Groundwater monitoring was undertaken in 2010 Groundwater monitoring has shown that natural attenuation is occurring The site remedy is functioning as expected
Representatives of USACE ADEQ EPA and landovraers conducted the Five-Year Review site inspection on May 19 2011 Issues observed consisted mainly of security fencing issues and vegetation growth
Groundwater monitoring results from 2010 indicate the remedial actions at Popile Inc Superfund site are protective therefore the site is considered protective of human health and the environment
Second Five-Year Review Summary Form
SITE IDENTIFICATION
Site name Popi e Inc 1 1 EPA ID ARD008052508 |
Region 6 State AR CityCounty El DoradoUnion |
SITE STATUS
NPL status x Final Deleted Other (specify)
Remediation status (chioose all that apply) Under Construction X Operating Complete
Mult iple OUs YES XNO Construct ion complet ion date I I
Has site been put into reuse x YES NO
REVIEW STATUS
Lead agency X EPA State Tribe Other Federal Agency
Author name Shawn Ghose
Author t i t le Remedial Project Manager Author aff i l iat ion EPA Region 6
Review p e r i o d 0 3 2 4 2 0 1 1 to 0 6 1 5 2011
Date(s) of site inspect ion 05 1 9 2011
Type of review X Post-SARA Pre-SARA
Non-NPL Remedial Action Site Regional Discretion
NPL-Removal only NPL StateTribe-lead
R e v i e w n u m b e r 1 (first) X 2 (second) 3 (third) Other (specify)
Tr igger ing act ion Actual RA Onsite Construction at OU _
Construction Completion ^nd
Actual RA Start at 0U Previous Five-Year Review Report
X Other - 2 review - statutory requirement
Tr igger ing act ion date 09 26 2006
Due date (five years after triggering action date) 09 26 2011
[OU refers to operable unit] [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN] Since its Institutional Control Agreement with USEPA in 2008 El Dorado Timber Company has utilized its land within the Popile Inc site for storage of heavy equipment and has left the main gate to the site open for access El Ark Industries Inc has taken the western security perimeter fence down to adjoin its adjacent active timber operation with its land within the Popile inc site
VI
Second Five-Year Review S u m m a r y Fo rm con t d
Issues Inadequate access controls (security fencingdeficiencies) Inadequate operation and maintenance of physical remedial structures (vegetation growth on soil cell caps areas of minor erosion) Large machinery staging with corroding batteries small pool of standing water
Recommendations and Foilow-up Actions
Remedy inadequate access controls address issues with security fence and main gate Fence should be restored or other measures taken to prevent public access to the site
Remedy inadequate operation and maintenance of physical remedial structures address vegetation growth on clay caps and erosion to prevent breach
Maintain institutional controls which were signed and recorded in 2008
Maintain access to monitoring wells
Continue groundwater monitoring on a yearly frequency for five years
Continue monitoring of natural attenuation
Protectiveness Statement(s) Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite as downgradient migration off site is not evident Institutional controls have been implemented The results of this five-year review indicate that the remedy stated in the Amended ROD appears to be functioning as required
vn
Second Five-Year Review Report
I Introduction
The purpose of this five-year review is to determine whether the site remedy for the Popile Inc Superfiand site is protective of human health and the environment The remedy for the Popile site involved groundwater monitoring and maintenance of engineering controls as well as implementation of institutional controls (land use restrictions-Appendix A) including an Operation and Maintenance Plan to monitor the effectiveness of the institutional controls The methods findings and conclusions of the five-year review are documented in the Five-Year Review Report The report also highlights any issues identified and recommendations for further management The Envirormiental Protection Agency (EPA) is responsible for conducting the five-year review pursuant to CERCLA sect121 and the National Contingency Plan (NCP) CERCLA sect121 states
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 In addition if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106] the President shall take or require such action The President shall report to the Congress a list of facilities for which such review is required the results of all such reviews and any actions taken as a result of such reviews
The agency interpreted this requirement further in the NCP 40 CFR sect300430(f)(4)(ii) states
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
The US Environmental Protection Agency (EPA) Region 6 has conducted a five-year review of the remedial actions implemented at the Popile Inc site in El Dorado Arkansas The first review was conducted from August 2006 to September 2006 This is the second five year review which was conducted from March 2011 to June 2011 In 2010 the US Army Corps of Engineers (USACE) - New Orleans District (MVN) Materials Management Group Inc (MMG) provided a groundwater monitoring analysis The USACE-MVN along with USEPA and the Arkansas Department of Environmental Quality (ADEQ) conducted an inspection of the site in May 2011 in support of the five-year review
This is the second five-year review for the Popile Inc site following preparation of the Amended Record of Decision (ROD) The triggering action of the five-year reviews is the date of the Amended ROD as shown in EPAs Waste LAN database September 2001 the triggering action for this second review is the date of the first Five-Year Review in 2006
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
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lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
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y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
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not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
rV -W^ I Jmii-Vi5poundV W I ^^^laquo
gt-i^
J V f
V
a L 1 1
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Second Five-Year Review Report
Table of Contents Table of Contents iii Executive Summary v Second Five-Year Review Summary Form vi I Introduction 1 II Site Chronology 2 III Background 2 IV Remedial Actions 3 V Progress Since the Last Review 4 VI Five-Year Review Process 5 VII Technical Assessment 16 Vm Issues 20 IX Recommendations and Follow-up Actions 20 X Protectiveness Statement 21 XI Next Review 21
Tables Table 1 ~ Chronology of Site Events Table 2 ~ Annual System OperationsOampM Costs Table 3 mdash Summary of 2010 Sampling Event Results Table 4 ~ Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results bull Table 5 mdash Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event Table 6 ~ Summary of Evidence of Natural Attenuation- 2010 Table 7 mdash Issues Table 8 - Recommendations and Follow-up Actions
bull
Appendices Appendix A Maps and Institutional Controls Appendix B El Dorado Times Public Announcement Appendix C Interview Documentation Appendix D Site Inspection Checklist Appendix E Site Photos Appendix F List of Documents Reviewed
111
Recommendations and Follow-up Actions
Issue
Institutional Controls
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA Region 6 ADEQ
EPA and then ADEQ when OampM starts
EPAEl Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
EPA
Milestone Date
Signed 2008
2012
2012
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
N
Y
Y
N
Y
Y
List of Acronyms
ACL ADEQ CERCLA
COC CSIA EPA IC GW LIF MCL MDL MMG NA NCP NOD NPL NR OifeM OU PAHs PCP RAO RCRA RIFS ROD SCAPS SVOCs TBC USACE
Alternate Concentration Limit Arkansas Department of Environmental Quality Comprehensive Environmental Response Compensation and Liability Act Contaminant of Concern Compound Specific Isotope Analysis Environmental Protection Agency Institutional Control Groundwater Laser-induced Fluorescence Maximum Contaminant Level Method Detection Limit Materials Management Group Inc Not Analyzed National Contingency Plan New Orleans District National Priorities List Not Reported Operations amp Maintenance Operable Unit Polycyclic Aromatic Hydrocarbons Pentachlorophenol Remedial Action Objective Resource Conservation and Recovery Act Remedial InvestigationFeasibility Study Record of Decision Site Characterization and Analysis Penetrometer System Semi-Volatile Organic Compounds To-Be Considered United States Army Corps of Engineers
IV
Executive Summary
The Amended Record of Decision (ROD) signed in September 2001 provided new remedial action objectives for the Popile Inc Superfund Site The 1993 ROD required control of migration of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the contaminant plume into Bayou de Loutre The shallow aquifer was to be restored to potential beneficial use by a pump and treat system A site investigation by USACE to characterize the shallow aquifer by means of SCAP and extensive boring monitoring wells and subsurface sampling established that the contaminant plume was static and immediately downgradient areas of the contaminant plume were clean (1997) The results of the site investigation were confirmed by a groundwater model of the shallow aquifer Since the groundwater modeling study confirmed the results of the site investigation by USACE ie the contamination plume was static (and unlikely to impact the deeper aquifer or Bayou de Loutre) the EPA determined that groundwater monitoring for the contaminants of concern and the implementation of engineering and institutional controls were adequate for the protection of public health Therefore the Amended ROD (2001) called for a five-year groundwater monitoring and engineering maintenance program Three years of this program had been implemented prior to the first Five-Year Review The results indicated that the groundwater contaminant plume was static (as predicted by the modeling study) natural attenuation was taking place at the site and engineering controls were being maintained In 2008 EPA and the landowners implemented institutional controls (land use controls) Groundwater monitoring was undertaken in 2010 Groundwater monitoring has shown that natural attenuation is occurring The site remedy is functioning as expected
Representatives of USACE ADEQ EPA and landovraers conducted the Five-Year Review site inspection on May 19 2011 Issues observed consisted mainly of security fencing issues and vegetation growth
Groundwater monitoring results from 2010 indicate the remedial actions at Popile Inc Superfund site are protective therefore the site is considered protective of human health and the environment
Second Five-Year Review Summary Form
SITE IDENTIFICATION
Site name Popi e Inc 1 1 EPA ID ARD008052508 |
Region 6 State AR CityCounty El DoradoUnion |
SITE STATUS
NPL status x Final Deleted Other (specify)
Remediation status (chioose all that apply) Under Construction X Operating Complete
Mult iple OUs YES XNO Construct ion complet ion date I I
Has site been put into reuse x YES NO
REVIEW STATUS
Lead agency X EPA State Tribe Other Federal Agency
Author name Shawn Ghose
Author t i t le Remedial Project Manager Author aff i l iat ion EPA Region 6
Review p e r i o d 0 3 2 4 2 0 1 1 to 0 6 1 5 2011
Date(s) of site inspect ion 05 1 9 2011
Type of review X Post-SARA Pre-SARA
Non-NPL Remedial Action Site Regional Discretion
NPL-Removal only NPL StateTribe-lead
R e v i e w n u m b e r 1 (first) X 2 (second) 3 (third) Other (specify)
Tr igger ing act ion Actual RA Onsite Construction at OU _
Construction Completion ^nd
Actual RA Start at 0U Previous Five-Year Review Report
X Other - 2 review - statutory requirement
Tr igger ing act ion date 09 26 2006
Due date (five years after triggering action date) 09 26 2011
[OU refers to operable unit] [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN] Since its Institutional Control Agreement with USEPA in 2008 El Dorado Timber Company has utilized its land within the Popile Inc site for storage of heavy equipment and has left the main gate to the site open for access El Ark Industries Inc has taken the western security perimeter fence down to adjoin its adjacent active timber operation with its land within the Popile inc site
VI
Second Five-Year Review S u m m a r y Fo rm con t d
Issues Inadequate access controls (security fencingdeficiencies) Inadequate operation and maintenance of physical remedial structures (vegetation growth on soil cell caps areas of minor erosion) Large machinery staging with corroding batteries small pool of standing water
Recommendations and Foilow-up Actions
Remedy inadequate access controls address issues with security fence and main gate Fence should be restored or other measures taken to prevent public access to the site
Remedy inadequate operation and maintenance of physical remedial structures address vegetation growth on clay caps and erosion to prevent breach
Maintain institutional controls which were signed and recorded in 2008
Maintain access to monitoring wells
Continue groundwater monitoring on a yearly frequency for five years
Continue monitoring of natural attenuation
Protectiveness Statement(s) Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite as downgradient migration off site is not evident Institutional controls have been implemented The results of this five-year review indicate that the remedy stated in the Amended ROD appears to be functioning as required
vn
Second Five-Year Review Report
I Introduction
The purpose of this five-year review is to determine whether the site remedy for the Popile Inc Superfiand site is protective of human health and the environment The remedy for the Popile site involved groundwater monitoring and maintenance of engineering controls as well as implementation of institutional controls (land use restrictions-Appendix A) including an Operation and Maintenance Plan to monitor the effectiveness of the institutional controls The methods findings and conclusions of the five-year review are documented in the Five-Year Review Report The report also highlights any issues identified and recommendations for further management The Envirormiental Protection Agency (EPA) is responsible for conducting the five-year review pursuant to CERCLA sect121 and the National Contingency Plan (NCP) CERCLA sect121 states
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 In addition if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106] the President shall take or require such action The President shall report to the Congress a list of facilities for which such review is required the results of all such reviews and any actions taken as a result of such reviews
The agency interpreted this requirement further in the NCP 40 CFR sect300430(f)(4)(ii) states
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
The US Environmental Protection Agency (EPA) Region 6 has conducted a five-year review of the remedial actions implemented at the Popile Inc site in El Dorado Arkansas The first review was conducted from August 2006 to September 2006 This is the second five year review which was conducted from March 2011 to June 2011 In 2010 the US Army Corps of Engineers (USACE) - New Orleans District (MVN) Materials Management Group Inc (MMG) provided a groundwater monitoring analysis The USACE-MVN along with USEPA and the Arkansas Department of Environmental Quality (ADEQ) conducted an inspection of the site in May 2011 in support of the five-year review
This is the second five-year review for the Popile Inc site following preparation of the Amended Record of Decision (ROD) The triggering action of the five-year reviews is the date of the Amended ROD as shown in EPAs Waste LAN database September 2001 the triggering action for this second review is the date of the first Five-Year Review in 2006
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
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Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Recommendations and Follow-up Actions
Issue
Institutional Controls
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA Region 6 ADEQ
EPA and then ADEQ when OampM starts
EPAEl Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
EPA
Milestone Date
Signed 2008
2012
2012
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
N
Y
Y
N
Y
Y
List of Acronyms
ACL ADEQ CERCLA
COC CSIA EPA IC GW LIF MCL MDL MMG NA NCP NOD NPL NR OifeM OU PAHs PCP RAO RCRA RIFS ROD SCAPS SVOCs TBC USACE
Alternate Concentration Limit Arkansas Department of Environmental Quality Comprehensive Environmental Response Compensation and Liability Act Contaminant of Concern Compound Specific Isotope Analysis Environmental Protection Agency Institutional Control Groundwater Laser-induced Fluorescence Maximum Contaminant Level Method Detection Limit Materials Management Group Inc Not Analyzed National Contingency Plan New Orleans District National Priorities List Not Reported Operations amp Maintenance Operable Unit Polycyclic Aromatic Hydrocarbons Pentachlorophenol Remedial Action Objective Resource Conservation and Recovery Act Remedial InvestigationFeasibility Study Record of Decision Site Characterization and Analysis Penetrometer System Semi-Volatile Organic Compounds To-Be Considered United States Army Corps of Engineers
IV
Executive Summary
The Amended Record of Decision (ROD) signed in September 2001 provided new remedial action objectives for the Popile Inc Superfund Site The 1993 ROD required control of migration of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the contaminant plume into Bayou de Loutre The shallow aquifer was to be restored to potential beneficial use by a pump and treat system A site investigation by USACE to characterize the shallow aquifer by means of SCAP and extensive boring monitoring wells and subsurface sampling established that the contaminant plume was static and immediately downgradient areas of the contaminant plume were clean (1997) The results of the site investigation were confirmed by a groundwater model of the shallow aquifer Since the groundwater modeling study confirmed the results of the site investigation by USACE ie the contamination plume was static (and unlikely to impact the deeper aquifer or Bayou de Loutre) the EPA determined that groundwater monitoring for the contaminants of concern and the implementation of engineering and institutional controls were adequate for the protection of public health Therefore the Amended ROD (2001) called for a five-year groundwater monitoring and engineering maintenance program Three years of this program had been implemented prior to the first Five-Year Review The results indicated that the groundwater contaminant plume was static (as predicted by the modeling study) natural attenuation was taking place at the site and engineering controls were being maintained In 2008 EPA and the landowners implemented institutional controls (land use controls) Groundwater monitoring was undertaken in 2010 Groundwater monitoring has shown that natural attenuation is occurring The site remedy is functioning as expected
Representatives of USACE ADEQ EPA and landovraers conducted the Five-Year Review site inspection on May 19 2011 Issues observed consisted mainly of security fencing issues and vegetation growth
Groundwater monitoring results from 2010 indicate the remedial actions at Popile Inc Superfund site are protective therefore the site is considered protective of human health and the environment
Second Five-Year Review Summary Form
SITE IDENTIFICATION
Site name Popi e Inc 1 1 EPA ID ARD008052508 |
Region 6 State AR CityCounty El DoradoUnion |
SITE STATUS
NPL status x Final Deleted Other (specify)
Remediation status (chioose all that apply) Under Construction X Operating Complete
Mult iple OUs YES XNO Construct ion complet ion date I I
Has site been put into reuse x YES NO
REVIEW STATUS
Lead agency X EPA State Tribe Other Federal Agency
Author name Shawn Ghose
Author t i t le Remedial Project Manager Author aff i l iat ion EPA Region 6
Review p e r i o d 0 3 2 4 2 0 1 1 to 0 6 1 5 2011
Date(s) of site inspect ion 05 1 9 2011
Type of review X Post-SARA Pre-SARA
Non-NPL Remedial Action Site Regional Discretion
NPL-Removal only NPL StateTribe-lead
R e v i e w n u m b e r 1 (first) X 2 (second) 3 (third) Other (specify)
Tr igger ing act ion Actual RA Onsite Construction at OU _
Construction Completion ^nd
Actual RA Start at 0U Previous Five-Year Review Report
X Other - 2 review - statutory requirement
Tr igger ing act ion date 09 26 2006
Due date (five years after triggering action date) 09 26 2011
[OU refers to operable unit] [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN] Since its Institutional Control Agreement with USEPA in 2008 El Dorado Timber Company has utilized its land within the Popile Inc site for storage of heavy equipment and has left the main gate to the site open for access El Ark Industries Inc has taken the western security perimeter fence down to adjoin its adjacent active timber operation with its land within the Popile inc site
VI
Second Five-Year Review S u m m a r y Fo rm con t d
Issues Inadequate access controls (security fencingdeficiencies) Inadequate operation and maintenance of physical remedial structures (vegetation growth on soil cell caps areas of minor erosion) Large machinery staging with corroding batteries small pool of standing water
Recommendations and Foilow-up Actions
Remedy inadequate access controls address issues with security fence and main gate Fence should be restored or other measures taken to prevent public access to the site
Remedy inadequate operation and maintenance of physical remedial structures address vegetation growth on clay caps and erosion to prevent breach
Maintain institutional controls which were signed and recorded in 2008
Maintain access to monitoring wells
Continue groundwater monitoring on a yearly frequency for five years
Continue monitoring of natural attenuation
Protectiveness Statement(s) Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite as downgradient migration off site is not evident Institutional controls have been implemented The results of this five-year review indicate that the remedy stated in the Amended ROD appears to be functioning as required
vn
Second Five-Year Review Report
I Introduction
The purpose of this five-year review is to determine whether the site remedy for the Popile Inc Superfiand site is protective of human health and the environment The remedy for the Popile site involved groundwater monitoring and maintenance of engineering controls as well as implementation of institutional controls (land use restrictions-Appendix A) including an Operation and Maintenance Plan to monitor the effectiveness of the institutional controls The methods findings and conclusions of the five-year review are documented in the Five-Year Review Report The report also highlights any issues identified and recommendations for further management The Envirormiental Protection Agency (EPA) is responsible for conducting the five-year review pursuant to CERCLA sect121 and the National Contingency Plan (NCP) CERCLA sect121 states
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 In addition if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106] the President shall take or require such action The President shall report to the Congress a list of facilities for which such review is required the results of all such reviews and any actions taken as a result of such reviews
The agency interpreted this requirement further in the NCP 40 CFR sect300430(f)(4)(ii) states
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
The US Environmental Protection Agency (EPA) Region 6 has conducted a five-year review of the remedial actions implemented at the Popile Inc site in El Dorado Arkansas The first review was conducted from August 2006 to September 2006 This is the second five year review which was conducted from March 2011 to June 2011 In 2010 the US Army Corps of Engineers (USACE) - New Orleans District (MVN) Materials Management Group Inc (MMG) provided a groundwater monitoring analysis The USACE-MVN along with USEPA and the Arkansas Department of Environmental Quality (ADEQ) conducted an inspection of the site in May 2011 in support of the five-year review
This is the second five-year review for the Popile Inc site following preparation of the Amended Record of Decision (ROD) The triggering action of the five-year reviews is the date of the Amended ROD as shown in EPAs Waste LAN database September 2001 the triggering action for this second review is the date of the first Five-Year Review in 2006
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
List of Acronyms
ACL ADEQ CERCLA
COC CSIA EPA IC GW LIF MCL MDL MMG NA NCP NOD NPL NR OifeM OU PAHs PCP RAO RCRA RIFS ROD SCAPS SVOCs TBC USACE
Alternate Concentration Limit Arkansas Department of Environmental Quality Comprehensive Environmental Response Compensation and Liability Act Contaminant of Concern Compound Specific Isotope Analysis Environmental Protection Agency Institutional Control Groundwater Laser-induced Fluorescence Maximum Contaminant Level Method Detection Limit Materials Management Group Inc Not Analyzed National Contingency Plan New Orleans District National Priorities List Not Reported Operations amp Maintenance Operable Unit Polycyclic Aromatic Hydrocarbons Pentachlorophenol Remedial Action Objective Resource Conservation and Recovery Act Remedial InvestigationFeasibility Study Record of Decision Site Characterization and Analysis Penetrometer System Semi-Volatile Organic Compounds To-Be Considered United States Army Corps of Engineers
IV
Executive Summary
The Amended Record of Decision (ROD) signed in September 2001 provided new remedial action objectives for the Popile Inc Superfund Site The 1993 ROD required control of migration of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the contaminant plume into Bayou de Loutre The shallow aquifer was to be restored to potential beneficial use by a pump and treat system A site investigation by USACE to characterize the shallow aquifer by means of SCAP and extensive boring monitoring wells and subsurface sampling established that the contaminant plume was static and immediately downgradient areas of the contaminant plume were clean (1997) The results of the site investigation were confirmed by a groundwater model of the shallow aquifer Since the groundwater modeling study confirmed the results of the site investigation by USACE ie the contamination plume was static (and unlikely to impact the deeper aquifer or Bayou de Loutre) the EPA determined that groundwater monitoring for the contaminants of concern and the implementation of engineering and institutional controls were adequate for the protection of public health Therefore the Amended ROD (2001) called for a five-year groundwater monitoring and engineering maintenance program Three years of this program had been implemented prior to the first Five-Year Review The results indicated that the groundwater contaminant plume was static (as predicted by the modeling study) natural attenuation was taking place at the site and engineering controls were being maintained In 2008 EPA and the landowners implemented institutional controls (land use controls) Groundwater monitoring was undertaken in 2010 Groundwater monitoring has shown that natural attenuation is occurring The site remedy is functioning as expected
Representatives of USACE ADEQ EPA and landovraers conducted the Five-Year Review site inspection on May 19 2011 Issues observed consisted mainly of security fencing issues and vegetation growth
Groundwater monitoring results from 2010 indicate the remedial actions at Popile Inc Superfund site are protective therefore the site is considered protective of human health and the environment
Second Five-Year Review Summary Form
SITE IDENTIFICATION
Site name Popi e Inc 1 1 EPA ID ARD008052508 |
Region 6 State AR CityCounty El DoradoUnion |
SITE STATUS
NPL status x Final Deleted Other (specify)
Remediation status (chioose all that apply) Under Construction X Operating Complete
Mult iple OUs YES XNO Construct ion complet ion date I I
Has site been put into reuse x YES NO
REVIEW STATUS
Lead agency X EPA State Tribe Other Federal Agency
Author name Shawn Ghose
Author t i t le Remedial Project Manager Author aff i l iat ion EPA Region 6
Review p e r i o d 0 3 2 4 2 0 1 1 to 0 6 1 5 2011
Date(s) of site inspect ion 05 1 9 2011
Type of review X Post-SARA Pre-SARA
Non-NPL Remedial Action Site Regional Discretion
NPL-Removal only NPL StateTribe-lead
R e v i e w n u m b e r 1 (first) X 2 (second) 3 (third) Other (specify)
Tr igger ing act ion Actual RA Onsite Construction at OU _
Construction Completion ^nd
Actual RA Start at 0U Previous Five-Year Review Report
X Other - 2 review - statutory requirement
Tr igger ing act ion date 09 26 2006
Due date (five years after triggering action date) 09 26 2011
[OU refers to operable unit] [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN] Since its Institutional Control Agreement with USEPA in 2008 El Dorado Timber Company has utilized its land within the Popile Inc site for storage of heavy equipment and has left the main gate to the site open for access El Ark Industries Inc has taken the western security perimeter fence down to adjoin its adjacent active timber operation with its land within the Popile inc site
VI
Second Five-Year Review S u m m a r y Fo rm con t d
Issues Inadequate access controls (security fencingdeficiencies) Inadequate operation and maintenance of physical remedial structures (vegetation growth on soil cell caps areas of minor erosion) Large machinery staging with corroding batteries small pool of standing water
Recommendations and Foilow-up Actions
Remedy inadequate access controls address issues with security fence and main gate Fence should be restored or other measures taken to prevent public access to the site
Remedy inadequate operation and maintenance of physical remedial structures address vegetation growth on clay caps and erosion to prevent breach
Maintain institutional controls which were signed and recorded in 2008
Maintain access to monitoring wells
Continue groundwater monitoring on a yearly frequency for five years
Continue monitoring of natural attenuation
Protectiveness Statement(s) Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite as downgradient migration off site is not evident Institutional controls have been implemented The results of this five-year review indicate that the remedy stated in the Amended ROD appears to be functioning as required
vn
Second Five-Year Review Report
I Introduction
The purpose of this five-year review is to determine whether the site remedy for the Popile Inc Superfiand site is protective of human health and the environment The remedy for the Popile site involved groundwater monitoring and maintenance of engineering controls as well as implementation of institutional controls (land use restrictions-Appendix A) including an Operation and Maintenance Plan to monitor the effectiveness of the institutional controls The methods findings and conclusions of the five-year review are documented in the Five-Year Review Report The report also highlights any issues identified and recommendations for further management The Envirormiental Protection Agency (EPA) is responsible for conducting the five-year review pursuant to CERCLA sect121 and the National Contingency Plan (NCP) CERCLA sect121 states
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 In addition if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106] the President shall take or require such action The President shall report to the Congress a list of facilities for which such review is required the results of all such reviews and any actions taken as a result of such reviews
The agency interpreted this requirement further in the NCP 40 CFR sect300430(f)(4)(ii) states
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
The US Environmental Protection Agency (EPA) Region 6 has conducted a five-year review of the remedial actions implemented at the Popile Inc site in El Dorado Arkansas The first review was conducted from August 2006 to September 2006 This is the second five year review which was conducted from March 2011 to June 2011 In 2010 the US Army Corps of Engineers (USACE) - New Orleans District (MVN) Materials Management Group Inc (MMG) provided a groundwater monitoring analysis The USACE-MVN along with USEPA and the Arkansas Department of Environmental Quality (ADEQ) conducted an inspection of the site in May 2011 in support of the five-year review
This is the second five-year review for the Popile Inc site following preparation of the Amended Record of Decision (ROD) The triggering action of the five-year reviews is the date of the Amended ROD as shown in EPAs Waste LAN database September 2001 the triggering action for this second review is the date of the first Five-Year Review in 2006
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Executive Summary
The Amended Record of Decision (ROD) signed in September 2001 provided new remedial action objectives for the Popile Inc Superfund Site The 1993 ROD required control of migration of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the contaminant plume into Bayou de Loutre The shallow aquifer was to be restored to potential beneficial use by a pump and treat system A site investigation by USACE to characterize the shallow aquifer by means of SCAP and extensive boring monitoring wells and subsurface sampling established that the contaminant plume was static and immediately downgradient areas of the contaminant plume were clean (1997) The results of the site investigation were confirmed by a groundwater model of the shallow aquifer Since the groundwater modeling study confirmed the results of the site investigation by USACE ie the contamination plume was static (and unlikely to impact the deeper aquifer or Bayou de Loutre) the EPA determined that groundwater monitoring for the contaminants of concern and the implementation of engineering and institutional controls were adequate for the protection of public health Therefore the Amended ROD (2001) called for a five-year groundwater monitoring and engineering maintenance program Three years of this program had been implemented prior to the first Five-Year Review The results indicated that the groundwater contaminant plume was static (as predicted by the modeling study) natural attenuation was taking place at the site and engineering controls were being maintained In 2008 EPA and the landowners implemented institutional controls (land use controls) Groundwater monitoring was undertaken in 2010 Groundwater monitoring has shown that natural attenuation is occurring The site remedy is functioning as expected
Representatives of USACE ADEQ EPA and landovraers conducted the Five-Year Review site inspection on May 19 2011 Issues observed consisted mainly of security fencing issues and vegetation growth
Groundwater monitoring results from 2010 indicate the remedial actions at Popile Inc Superfund site are protective therefore the site is considered protective of human health and the environment
Second Five-Year Review Summary Form
SITE IDENTIFICATION
Site name Popi e Inc 1 1 EPA ID ARD008052508 |
Region 6 State AR CityCounty El DoradoUnion |
SITE STATUS
NPL status x Final Deleted Other (specify)
Remediation status (chioose all that apply) Under Construction X Operating Complete
Mult iple OUs YES XNO Construct ion complet ion date I I
Has site been put into reuse x YES NO
REVIEW STATUS
Lead agency X EPA State Tribe Other Federal Agency
Author name Shawn Ghose
Author t i t le Remedial Project Manager Author aff i l iat ion EPA Region 6
Review p e r i o d 0 3 2 4 2 0 1 1 to 0 6 1 5 2011
Date(s) of site inspect ion 05 1 9 2011
Type of review X Post-SARA Pre-SARA
Non-NPL Remedial Action Site Regional Discretion
NPL-Removal only NPL StateTribe-lead
R e v i e w n u m b e r 1 (first) X 2 (second) 3 (third) Other (specify)
Tr igger ing act ion Actual RA Onsite Construction at OU _
Construction Completion ^nd
Actual RA Start at 0U Previous Five-Year Review Report
X Other - 2 review - statutory requirement
Tr igger ing act ion date 09 26 2006
Due date (five years after triggering action date) 09 26 2011
[OU refers to operable unit] [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN] Since its Institutional Control Agreement with USEPA in 2008 El Dorado Timber Company has utilized its land within the Popile Inc site for storage of heavy equipment and has left the main gate to the site open for access El Ark Industries Inc has taken the western security perimeter fence down to adjoin its adjacent active timber operation with its land within the Popile inc site
VI
Second Five-Year Review S u m m a r y Fo rm con t d
Issues Inadequate access controls (security fencingdeficiencies) Inadequate operation and maintenance of physical remedial structures (vegetation growth on soil cell caps areas of minor erosion) Large machinery staging with corroding batteries small pool of standing water
Recommendations and Foilow-up Actions
Remedy inadequate access controls address issues with security fence and main gate Fence should be restored or other measures taken to prevent public access to the site
Remedy inadequate operation and maintenance of physical remedial structures address vegetation growth on clay caps and erosion to prevent breach
Maintain institutional controls which were signed and recorded in 2008
Maintain access to monitoring wells
Continue groundwater monitoring on a yearly frequency for five years
Continue monitoring of natural attenuation
Protectiveness Statement(s) Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite as downgradient migration off site is not evident Institutional controls have been implemented The results of this five-year review indicate that the remedy stated in the Amended ROD appears to be functioning as required
vn
Second Five-Year Review Report
I Introduction
The purpose of this five-year review is to determine whether the site remedy for the Popile Inc Superfiand site is protective of human health and the environment The remedy for the Popile site involved groundwater monitoring and maintenance of engineering controls as well as implementation of institutional controls (land use restrictions-Appendix A) including an Operation and Maintenance Plan to monitor the effectiveness of the institutional controls The methods findings and conclusions of the five-year review are documented in the Five-Year Review Report The report also highlights any issues identified and recommendations for further management The Envirormiental Protection Agency (EPA) is responsible for conducting the five-year review pursuant to CERCLA sect121 and the National Contingency Plan (NCP) CERCLA sect121 states
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 In addition if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106] the President shall take or require such action The President shall report to the Congress a list of facilities for which such review is required the results of all such reviews and any actions taken as a result of such reviews
The agency interpreted this requirement further in the NCP 40 CFR sect300430(f)(4)(ii) states
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
The US Environmental Protection Agency (EPA) Region 6 has conducted a five-year review of the remedial actions implemented at the Popile Inc site in El Dorado Arkansas The first review was conducted from August 2006 to September 2006 This is the second five year review which was conducted from March 2011 to June 2011 In 2010 the US Army Corps of Engineers (USACE) - New Orleans District (MVN) Materials Management Group Inc (MMG) provided a groundwater monitoring analysis The USACE-MVN along with USEPA and the Arkansas Department of Environmental Quality (ADEQ) conducted an inspection of the site in May 2011 in support of the five-year review
This is the second five-year review for the Popile Inc site following preparation of the Amended Record of Decision (ROD) The triggering action of the five-year reviews is the date of the Amended ROD as shown in EPAs Waste LAN database September 2001 the triggering action for this second review is the date of the first Five-Year Review in 2006
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Second Five-Year Review Summary Form
SITE IDENTIFICATION
Site name Popi e Inc 1 1 EPA ID ARD008052508 |
Region 6 State AR CityCounty El DoradoUnion |
SITE STATUS
NPL status x Final Deleted Other (specify)
Remediation status (chioose all that apply) Under Construction X Operating Complete
Mult iple OUs YES XNO Construct ion complet ion date I I
Has site been put into reuse x YES NO
REVIEW STATUS
Lead agency X EPA State Tribe Other Federal Agency
Author name Shawn Ghose
Author t i t le Remedial Project Manager Author aff i l iat ion EPA Region 6
Review p e r i o d 0 3 2 4 2 0 1 1 to 0 6 1 5 2011
Date(s) of site inspect ion 05 1 9 2011
Type of review X Post-SARA Pre-SARA
Non-NPL Remedial Action Site Regional Discretion
NPL-Removal only NPL StateTribe-lead
R e v i e w n u m b e r 1 (first) X 2 (second) 3 (third) Other (specify)
Tr igger ing act ion Actual RA Onsite Construction at OU _
Construction Completion ^nd
Actual RA Start at 0U Previous Five-Year Review Report
X Other - 2 review - statutory requirement
Tr igger ing act ion date 09 26 2006
Due date (five years after triggering action date) 09 26 2011
[OU refers to operable unit] [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN] Since its Institutional Control Agreement with USEPA in 2008 El Dorado Timber Company has utilized its land within the Popile Inc site for storage of heavy equipment and has left the main gate to the site open for access El Ark Industries Inc has taken the western security perimeter fence down to adjoin its adjacent active timber operation with its land within the Popile inc site
VI
Second Five-Year Review S u m m a r y Fo rm con t d
Issues Inadequate access controls (security fencingdeficiencies) Inadequate operation and maintenance of physical remedial structures (vegetation growth on soil cell caps areas of minor erosion) Large machinery staging with corroding batteries small pool of standing water
Recommendations and Foilow-up Actions
Remedy inadequate access controls address issues with security fence and main gate Fence should be restored or other measures taken to prevent public access to the site
Remedy inadequate operation and maintenance of physical remedial structures address vegetation growth on clay caps and erosion to prevent breach
Maintain institutional controls which were signed and recorded in 2008
Maintain access to monitoring wells
Continue groundwater monitoring on a yearly frequency for five years
Continue monitoring of natural attenuation
Protectiveness Statement(s) Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite as downgradient migration off site is not evident Institutional controls have been implemented The results of this five-year review indicate that the remedy stated in the Amended ROD appears to be functioning as required
vn
Second Five-Year Review Report
I Introduction
The purpose of this five-year review is to determine whether the site remedy for the Popile Inc Superfiand site is protective of human health and the environment The remedy for the Popile site involved groundwater monitoring and maintenance of engineering controls as well as implementation of institutional controls (land use restrictions-Appendix A) including an Operation and Maintenance Plan to monitor the effectiveness of the institutional controls The methods findings and conclusions of the five-year review are documented in the Five-Year Review Report The report also highlights any issues identified and recommendations for further management The Envirormiental Protection Agency (EPA) is responsible for conducting the five-year review pursuant to CERCLA sect121 and the National Contingency Plan (NCP) CERCLA sect121 states
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 In addition if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106] the President shall take or require such action The President shall report to the Congress a list of facilities for which such review is required the results of all such reviews and any actions taken as a result of such reviews
The agency interpreted this requirement further in the NCP 40 CFR sect300430(f)(4)(ii) states
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
The US Environmental Protection Agency (EPA) Region 6 has conducted a five-year review of the remedial actions implemented at the Popile Inc site in El Dorado Arkansas The first review was conducted from August 2006 to September 2006 This is the second five year review which was conducted from March 2011 to June 2011 In 2010 the US Army Corps of Engineers (USACE) - New Orleans District (MVN) Materials Management Group Inc (MMG) provided a groundwater monitoring analysis The USACE-MVN along with USEPA and the Arkansas Department of Environmental Quality (ADEQ) conducted an inspection of the site in May 2011 in support of the five-year review
This is the second five-year review for the Popile Inc site following preparation of the Amended Record of Decision (ROD) The triggering action of the five-year reviews is the date of the Amended ROD as shown in EPAs Waste LAN database September 2001 the triggering action for this second review is the date of the first Five-Year Review in 2006
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Second Five-Year Review S u m m a r y Fo rm con t d
Issues Inadequate access controls (security fencingdeficiencies) Inadequate operation and maintenance of physical remedial structures (vegetation growth on soil cell caps areas of minor erosion) Large machinery staging with corroding batteries small pool of standing water
Recommendations and Foilow-up Actions
Remedy inadequate access controls address issues with security fence and main gate Fence should be restored or other measures taken to prevent public access to the site
Remedy inadequate operation and maintenance of physical remedial structures address vegetation growth on clay caps and erosion to prevent breach
Maintain institutional controls which were signed and recorded in 2008
Maintain access to monitoring wells
Continue groundwater monitoring on a yearly frequency for five years
Continue monitoring of natural attenuation
Protectiveness Statement(s) Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite as downgradient migration off site is not evident Institutional controls have been implemented The results of this five-year review indicate that the remedy stated in the Amended ROD appears to be functioning as required
vn
Second Five-Year Review Report
I Introduction
The purpose of this five-year review is to determine whether the site remedy for the Popile Inc Superfiand site is protective of human health and the environment The remedy for the Popile site involved groundwater monitoring and maintenance of engineering controls as well as implementation of institutional controls (land use restrictions-Appendix A) including an Operation and Maintenance Plan to monitor the effectiveness of the institutional controls The methods findings and conclusions of the five-year review are documented in the Five-Year Review Report The report also highlights any issues identified and recommendations for further management The Envirormiental Protection Agency (EPA) is responsible for conducting the five-year review pursuant to CERCLA sect121 and the National Contingency Plan (NCP) CERCLA sect121 states
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 In addition if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106] the President shall take or require such action The President shall report to the Congress a list of facilities for which such review is required the results of all such reviews and any actions taken as a result of such reviews
The agency interpreted this requirement further in the NCP 40 CFR sect300430(f)(4)(ii) states
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
The US Environmental Protection Agency (EPA) Region 6 has conducted a five-year review of the remedial actions implemented at the Popile Inc site in El Dorado Arkansas The first review was conducted from August 2006 to September 2006 This is the second five year review which was conducted from March 2011 to June 2011 In 2010 the US Army Corps of Engineers (USACE) - New Orleans District (MVN) Materials Management Group Inc (MMG) provided a groundwater monitoring analysis The USACE-MVN along with USEPA and the Arkansas Department of Environmental Quality (ADEQ) conducted an inspection of the site in May 2011 in support of the five-year review
This is the second five-year review for the Popile Inc site following preparation of the Amended Record of Decision (ROD) The triggering action of the five-year reviews is the date of the Amended ROD as shown in EPAs Waste LAN database September 2001 the triggering action for this second review is the date of the first Five-Year Review in 2006
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Second Five-Year Review Report
I Introduction
The purpose of this five-year review is to determine whether the site remedy for the Popile Inc Superfiand site is protective of human health and the environment The remedy for the Popile site involved groundwater monitoring and maintenance of engineering controls as well as implementation of institutional controls (land use restrictions-Appendix A) including an Operation and Maintenance Plan to monitor the effectiveness of the institutional controls The methods findings and conclusions of the five-year review are documented in the Five-Year Review Report The report also highlights any issues identified and recommendations for further management The Envirormiental Protection Agency (EPA) is responsible for conducting the five-year review pursuant to CERCLA sect121 and the National Contingency Plan (NCP) CERCLA sect121 states
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 In addition if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106] the President shall take or require such action The President shall report to the Congress a list of facilities for which such review is required the results of all such reviews and any actions taken as a result of such reviews
The agency interpreted this requirement further in the NCP 40 CFR sect300430(f)(4)(ii) states
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
The US Environmental Protection Agency (EPA) Region 6 has conducted a five-year review of the remedial actions implemented at the Popile Inc site in El Dorado Arkansas The first review was conducted from August 2006 to September 2006 This is the second five year review which was conducted from March 2011 to June 2011 In 2010 the US Army Corps of Engineers (USACE) - New Orleans District (MVN) Materials Management Group Inc (MMG) provided a groundwater monitoring analysis The USACE-MVN along with USEPA and the Arkansas Department of Environmental Quality (ADEQ) conducted an inspection of the site in May 2011 in support of the five-year review
This is the second five-year review for the Popile Inc site following preparation of the Amended Record of Decision (ROD) The triggering action of the five-year reviews is the date of the Amended ROD as shown in EPAs Waste LAN database September 2001 the triggering action for this second review is the date of the first Five-Year Review in 2006
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
The Amended ROD from 2001 set out alternate concentration limits (ACLs) to replace the remedial goals identified in the original ROD (1993) However in 2001 the EPA determined that the remedial goals for site contaminant levels and the ACLs were not feasible and granted a Technical Impractibility Waiver Therefore contaminants were left onsite above typical standards (eg MCLs etc) and a Five-Year Review is necessary to ensure that the remedy remains protective of human health and the environment
11 Site Chronology
Important site events and the relevant dates are summarized in the following table It is important to note that this table is not necessarily comprehensive of all site events
Table 1 Chronology of Site Events
Event RCRA closure of site impoundments Inifial discovery of the problem (EPA site assessment) Pre-NPL responses (removal actions) NPL listing RIFS complete ROD signature USACE Phase I SCAPS investigation USACE Phase II and GW modeling study Amended ROD First Year GW Monitoring Second Year GW Monitoring Third Year GW Monitoring First Five-Year Review Institutional Controls signed by owner 2010 GW Monitoring Second Five-Year Review
Date 1984 1989 1990 1991 1992 1992 1993 1997 1998 September 2001 January amp November 2004 April 2005 May 2006 September 2006 2008 October 2010 June 2011 -
III Background
The site is located on 41 acres VA mile south of El Dorado in Union County Arkansas The site is bordered by South West Avenue (also Southfield Road) the Ouachita Railroad Bayou de Loutre and a forested highland area Although the area is rural residentialcommercial no homes are located along the site perimeter There is no proposed future use of the subject site at the time of this review Previous site uses include oil field storage operations and wood preservation operations The first wood treatment facility by the El Dorado Creosote Company began operations at the site in 1947 Property ownership was transferred to El Dorado Pole and Piling Company in 1958 It was during these wood treatment operations that surface impoundments were constructed to store process wastewater and sludge Over time a sludge pit and additional process impoundments were added During the 1970s surface pits were used for part of the plants waste treatment processes Wood treatment operations at the site stopped in July 1982 In
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
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j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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5 I
1 bull
f
- t
Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
September of 1982 Popile Inc purchased 75 acres of the site including the surface impoundments The remaining 34 acres were purchased by El Ark Industries The impoundments and pits were closed under the Resource Conservation and Recovery Act (RCRA) in 1984
In 1989 the EPA conducted a site assessment and determined that contamination from pentachlorophenol (PCP) and creosote compounds had leaked from the impoundments The contarhinated media included surface and subsurface soils groundwater surface water and sediments The EPA conducted a Removal Action in 1990 and 1991 to address the releases from the impoundments this consisted of excavation of sludge and contaminated soils from the impoundment areas The excavated material was stabilized using rice hulls and fly ash and was disposed of onsite in two clay-lined holding cells a small soil cell north and a larger soil cell south of the former impoundment areas The excavated areas were backfilled with clean soil and drainage ditches and other erosion controls were constructed Approximately 500000 gallons of contaminated water was pumped from trenches treated and discharged into adjacent Bayou de Loutre
Following the removal action exposure to groundwater contamination was the primary health threat for the site
IVRemedial Actions
The EPA proposed the site for the National Priorities List (NPL) in February 1992 and the site was listed in October 1992 Following the Remedial InvestigationFeasibility Study (RIFS) conducted in 1992 the EPA issued a ROD in 1993 The 1993 ROD specified the in-situ treatment of contaminated groundwater extraction and offsite disposal of free phase PCP and creosote and onsite biological land treatment of contaminated soil and sludge However the EPA concluded that the 1992 RIFS did not adequately characterize subsurface conditions in order to implement the ROD Therefore a more detailed site investigation was conducted by the USACE under contract to the EPA
The USACE investigation included two components a Phase I Site Characterization and Analysis Penetrometer System (SCAPS) completed in 1997 and a Phase II Groundwater Investigation and Modeling analysis completed in 1998 The SCAPS investigation evaluated in-situ geophysical soil properties while detecting contamination with laser-induced fluorescence (LIF) technology The Phase II investigation defined the shallow subsurface geology and hydrology by extensive boring monitor wells and sampling of the monitor wells
The results of the Phase I (SCAPS) and Phase II investigations indicated that the majority of PCP and polycyclic aromatic hydrocarbon (PAH) contamination is contained within the old impoundments and within the upper 30 feet of the shallow aquifer Because of its higher than PAH water solubility PCP was the only contaminant of concern (COC) with a spatially distributed contamination plume concentrations of the other COCs (PAHs) dropped off sharply away from the contamination source (due to low solubilities) Based on the PCP plume dissolved phase groundwater contamination is limited to 160 feet from the contamination source (process impoundments) The modeling investigation indicates that the PCP plume has remained
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
more or less immobile over the past 40 years and based on biodegradation from aerobic (and possibly anaerobic) organisms and adsorption to natural carbon in the shallow aquifer the plume is likely to remain static for the next 50 years Figures illustrating the modeling study results are included in Appendix A
Based on the results of these investigations the EPA developed an Amended ROD in September 2001 The 1993 ROD requires control of the shallow groundwater contaminants to reduce or eliminate the threat of impacting the deeper drinking water aquifer and discharge of the shallow groundwater contaminant plume into the Bayou de Loutre located in the downgradient direction The 1993 ROD recommended a pump and treat system to restore the shallow aquifer to potential future beneficial use The site investigation between 1997 and 1999 indicted that the contaminant plume was static and the contaminants of concern were absent in the immediate downgradient direction of the contaminant plume Groundwater modeling of the shallow aquifer indicated the contamination plume is static The EPA determined that groundwater nionitoring for the contaminants of concern and the implementation of engineering and institutional controls is adequate for the protection of public health
The first three years of the first five-year groundwater monitoring and engineering maintenance program were implemented (in 2004 2005 and 2006) Groundwater monitoring was again conducted in 2010 in relation to the second five-year review The results from the groundwater monitoring indicate that the contamination plume is not migrating offsite In addition groundwater monitoring included evaluation of natural attenuation at the site the results indicate biodegradation of the contaminants is taking place Institutional controls (land use restrictions) were implemented in 2008 The costs of site maintenance (groundwater monitoring and engineering maintenance) are summarized below
Table 2 Annual System Operations0laquoampM Costs
Dates
From
January 2004
January 2005
January 2006
September 2010
To
December 2004
December 2005
September 2006
February 2011
Total Cost rounded to nearest $1000
$13800000
$4500000
$4400000
$5200000
According to ADEQ and EPA OampM has not occurred since the first Five-Year Review in 2006
V Progress Since the Last Review
The first Five-Year Review in 2006 determined the site to be protective of human health and the environment In 2008 the institutional controls land use restrictions were signed and implemented by the landowners In 2010 the USACE New Orleans District contracted Strategic Plarming Associates - Materials Management Group (SPA-MMG) for groundwater sampling and testing and minor maintenance of monitoring wells The results indicated signs of natural
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
--ri-i
1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
bull-raquovAraquo3g|Ev-v^r^
Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
lt bull bull
5 I
1 bull
f
- t
Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
rV -W^ I Jmii-Vi5poundV W I ^^^laquo
gt-i^
J V f
V
a L 1 1
bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
attenuation This report is the second Five-Year Review
VIFive-Year Review Process
The five-year review process is described in the following paragraphs
Administrative Components At the start of the five-year review potentially interested parties were notified These included the Arkansas Department of Environmental Quality (ADEQ) USACE as well as various offices of the EPA The schedule for the five-year review was from March2011 to June 2011
Community Notification and Involvement There are no community groups interested in activity associated with this site therefore no groups were notified However during the interview process the Mayor of El Dorado as well as representatives from the facility neighboring the site were notified of the review and interviewed for their opinions before and during the site inspection on May 19 2011 A public announcement was also placed in the El Dorado Times Newspaper on April 20 2011 (Appendix B)
Document Review Various documents were reviewed during the five-year review The documents reviewed are listed in Appendix F These included the Amended ROD the Technical Impracticability Waiver the 1998 Phase II Groundwater Investigation and Modeling study (Morrison Knudsen) the 1999 Groundwater Model Study of Natural Attenuation (Morrison Knudsen) the Groundwater Monitoring and Site InspectionRepair Reports for the completed three years of monitoring and maintenance the first Five-Year Review in 2006 the 2008 Institutional Control Agreements between USEPA and landowners and the 2010 Groundwater Monitoring Report Remedial action objectives and discussions regarding action levels and alternate concentration limits (ACLs) were identified from the Amended ROD and Technical Impracticability Waiver
Data Review The data reviewed were the results from the three years of groundwater monitoring in 2004 2005 and 2006 and the recent monitoring conducted in October 2010 Summaries of the results from the 2004 2005 and 2006 monitoring events are available in the First Five-Year Review for the Popile Inc Site (see Appendix F - References) Copies of the 2008 institutional control agreementbetween the landowners within the security perimeter fence of the Popile Inc site are provided in Appendix A The 2008 institutional control actions as well as the 2010 groundwater monitoring event are summarized below
2008 Institutional Control Agreements
The Summary of the First Five-Year Review Findings in the First Five-Year Review Report for Popile Inc Site (ARD008052508) Union County Arkansas released in September 2006 indicated that The site remedy is progressing as expected and site conditions are protective of public health and the environment On the Actions Needed paragraph of the above-mentioned report it is stated that No major deficiencies were noted To ensure future protectiveness in the long term institutional controls will be implemented by deed restrictions as soon as possible
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
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Instilutional Control EPA IDlaquo ARO008052508
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Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
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ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
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Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
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13 June 2008
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-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
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FIGURE 6 SECONDARY CAP
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PCP plume in ppb with time
Year 1958
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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- t
Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
rV -W^ I Jmii-Vi5poundV W I ^^^laquo
gt-i^
J V f
V
a L 1 1
bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Appendix A provides the institutional control agreements that the US E P A and the landowners at the Popile Inc site signed in 2008 following the First Five-Year Report Institutional Control Document EPA ID008052508 1 lO Congressional District 4 2936 acres was signed by El Ark Industries Inc and the US EPA on April 14 2008 Appendix A shows that the land west south and east within the security perimeter fence of the Popile Inc site is largely owned by El Ark Industries Inc This 2936 acre area includes the large or main soil cell south of the former impoundment areas as well as possibly a portion of the former impoundment areas original wood treating facility This institutional control states that the shallow Cockfield aquifer should not be used monitoring wells must be maintained excavation must be restricted to less than three feet and the soil cell should be off limits to any activity which may compromise its integrity
Institutional Control Document EPA ID008052508 110 Congressional District 4 73 acres was signed by El Dorado Timber Co Inc and US EPA on March 18 2008 Appendix A shows that the land at the northern portion within the security perimeter fence of the Popile Inc site is largely owned by EI Dorado Timber Co Inc This 73 acre area includes the former impoundment area original wood treating facility the small soil cell located northeast of the Popile Inc site as well as the main gate at the northern security perimeter fence and the gate at the eastern security perimeter fence This institutional control states that the shallow groundwater should not be used the integrity of the monitoring wells must be maintained and remain accessible and excavation must be restricted to less than three feet
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 3 was signed by Great Lakes Chemical Corporation and the US EPA on June 2 2008 Appendix A shows that a small portion of the land at the northeastern tip within the security perimeter fence of the Popile Inc site as well as areas across the railroad tracks are largely owned by Great Lakes Chemical Corporation The areas owned by Great Lakes Chemical Corporation within the security perimeter fence and outside the fence and across the RR tracks are located downgradient as well includes the northern portion of Bayou de Loutre This institutional control states the shallow Cockfield aquifer should not be used and the integrity of the monitoring wells must be maintained and remain accessible
Institutional Control Document EPA ID008052508 1 lO Congressional District 4 Tract 2 and Tract 1 was signed by Mayor Mike Dumas and the EPA on June 13 2008 The areas addressed by this Institutional Control lie adjacent to the Popile site across the eastern perimeter fence and south of the lands owned by Great Lakes Chemical Corporation downgradient towards Bayou de Loutre This institutional control document states that the shallow Cockfield aquifer should not be used It also states the integrity of the monitoring wells must be maintained and remain accessible
The institutional control documents are recorded in Deed Book 2008 at pages 3816 3529 and 3530 Union County Arkansas Clerk Office
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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5 I
1 bull
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
October 2010 Groundwater Monitoring (Sampling and Testing)
The objectives included assessment of the dissolved phase contamination plume with regard to migration (or stabilization) and evaluation of natural attenuation (biodegradation) With regard to the primary objective the sampling results suggest that the plume is not migrating down gradient towards Bayou de Loutre With regard to the objective of natural attenuation the sampling results show that natural attenuation is occurring at the site
The analytical results indicate the following
bull Although the concentrations of Pentachlorophenol and naphthalene (COCs) are higher in the source monitoringwells results in the other wells did not change The increase may be attributed to the dry conditions at the site (based on observations of concentration changes from previous sampling events during dry and wet seasons) PCP and naphthalene were not detected in any of the sentry wells Decisions for continued monitoring should focus on any naphthalene (as well PCP) concentration changes at downgradient and sentry wells Currently (2010) and based likewise on the earlier three-year period (2004 2005 and 2006) of monitoring results for naphthalene and PCP the plume appears to be stable as suggested in the modeling study
The natural attenuation parameters suggest that biodegradation is continuing at the site with reductive dechlorination being the primary means of biodegradation Lines of evidence include the dissolved oxygen concentration range the oxidation-reduction potential values (in conjunction with the sulfate and methane results) the dissolved hydrogen concentration range the methane concentrations the total organic carbon concentrations in conjunction with other natural attenuation parameter results and the high chloride concentrations Nitrate nitrite and sulfate sulfide data indicate that the incidence of denitrification and sulfate reduction have decreased at the site A comparison to current background data was not possible as upgradient wells were dry
Considering the results of the 2010 sampling event and the earlier three years of monitoring it appears that the plume is stable As previously discussed in the 2006 Five-Year Review the naphthalene concentrations detected in the downgradient monitoring well MW-PZ02 may be attributed to other site activities (such as oilfield operations) and were not identified (MW-PZ02 is a relatively new well installed in 2004 similar concentrations were previously detected in PZ-04 (the nearest monitoring well from the Phase II investigation)) in the past Historical data indicates that the naphthalene is more likely associated withhistorical oil and gas operations (pre-wood treatment operations) east of the railroad tracks Naphthalene was selected as a COC under the monitoring program based on solubility as it is the most soluble among the PAHs and naphthalene is monitored as an indicator element wherein a significant increase in concentrations as well with concomitant increases in PAH and PCP at downgradient wells will trigger important information on groundwater plume contaminant migration There is no equivocal and significant evidence to indicate that naphthalene and any PCP concentration in monitoring wells east of the impoundments (and small soil cell) and the railroad tracks are
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
--ri-i
1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
bull-raquovAraquo3g|Ev-v^r^
Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
lt bull bull
5 I
1 bull
f
- t
Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
rV -W^ I Jmii-Vi5poundV W I ^^^laquo
gt-i^
J V f
V
a L 1 1
bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
indicative of migration of groundwater contaminants from the source area (ie former impoundment area) PCP has not been detected downgradient of the plume and significant naphthalene concentrations have not been detected with concomitant increases of other PAHs in any other downgradient or sentry monitoring wells A definitive conclusion carmot be made and additional sampling is needed for an evaluation
2010 and 2011 Site Inspections
Four site inspections were conducted prior to and for the first Five-Year Review Descriptions of those inspections can be found in the first Five-Year Review Report in 2006 Since the first review the site has been visited three times in August 2010 by the Arkansas Department of Environmental Quality in October 2010 by SPA-MMG a contractor for USACE-MVN and in May 2011 by representatives of the US EPA ADEQ and USACE-MVN
August 2010 On 11 August 2010 ADEQ visited the Popile site to perform the annual evaluation ADEQ investigated accessibility and vegetation growth at the site as well as the integrity of the monitoring wells security and fencing ADEQ found
bull Front gate insecure bull Fencing separating El Ark Industries and El Dorado Timber (two separate landowners)
incomplete bull El Dorado Timber equipment on top of one of the surface impoundments bull The access road was eroded in one area bull Monitoring wells accessible however hard to locate bull ADEQ key did not work for fences or monitoring wells bull Tall shrubbery (up to 6 tall) on landfill cap bull Semi-mature trees present on the surface impoundment bull Geo-textile fabric has been exposed on the road going to the top of the landfill
October 2010 In October 2010 SPA-MMG visited the site for groundwater monitoring
bull Groundwater samples were taken bull No other assessment was within the scope of the 2010 groundwater sampling and testing
task bull SPA-MMG conducted minimal site inspection focusing on the integrity of the
monitoring wells including lock boxes locks and labels bull The monitoring wells were re-developed during the sampling and testing events The
development-related sediment and wastewater were stored and disposed of according to investigative derived waste (IDW) regulatory protocols (see 2010 Ground Water Monitoring Report)
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
--ri-i
1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
bull-raquovAraquo3g|Ev-v^r^
Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
lt bull bull
5 I
1 bull
f
- t
Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
rV -W^ I Jmii-Vi5poundV W I ^^^laquo
gt-i^
J V f
V
a L 1 1
bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Table 3 Summary of October 2010 Sampling Event Results
Parameter
Well Depth (ft)
Screened Interval (ft)
ly-Trichloroticnzene
t2-Dichiorcenzene
12-Diphenv(hydrazine
13-UichloroDenzene
lADichlorcfcenzene
245-Trictilorophenol
246-Trichlorophenol
24-Dichlorcph8nd
24-Diniethvlphend
24-Dinitroi)hend
24 Oinitrotolucnc
26-DinitrotDluene
2ltMoronaphlhdene
2ltNorophonol
2-Methvlnaphthne
2+litroaniline
Z-NitioptKiiul
3J-Oictlorobcnzidine
3Nitroaniline
46-Diiiiliu-2-iiBllivlplEnur
4-8ronioptienyl phenyl ether
4-Chloro-3-methylphenol
4^hloroanillne
4HnrnphRnyl phpnyl fither
4-Nilroaniline
4Nitrophenor
Acenaphthene
tonaphthylene
Aniline
Anthracene
Benzlalanlhracene
Ben2o(a)pyrene
Benzob)nuaanthcnc
Benzo(ghi)perytene
BenzoOiWuoranthene
Dcnzoic add
Benzyl alcohol
Bis(2^loroethoxy)melhane
Bib(2-d(uiUBlliynellBi
Bis (2-cHoroiso()ropl tether
Bis(2-elhylhexyt)phthalalE
Butyl bervyl phthalaie
Carbazole
Chrysene
Dibenz(ah)anthracene
Oibenzcuran
Analysis Result (iigli
Near SourceDowngradient
Mw-sr
32 295-32
^2000
lt2100
lt1800
lt2UUU
lt2000
lt1300
lt1700
1800
lt2000
lt7900
1000
lt1900
lt1800
lt2000
24000000
lt1600
-bull1700
lt750
lt5600
lt1900
lt1600
lt1600
lt850
lti9nn
lt940
lt22U0
lt1800
910000J
lt1200
7600000
5300000
1700000
2S000O0
440OOOJ
1200000
lt2C00
lt2100
lt1800
-ISOO
lt1900
lt1900
lt1700
3800OO0J
5200000
lt2000
22000000
MW41
30 20-30
^ 0 lt50 lt50 lt6U lt50 11J 93J
50 1700
lt59
bull50
lt50 120 bull550
360 lt50 v57
lt50 50
150 lt50 lt50 lt50
lt5n lt50 lt42
300 74J
34J 50 17 J
lt13
lt13
lt50 lt17
75
lt66
lt50 -50
lt50 lt50 lt50 260 lt15
lt19
180
MW-33
33 23-33
50 lt50 lt50 50 50 99J
50 bull
75J
2200
lt59
50 50 50 OU 440 lt50 bull57
50 50 bull^9
50 50 50
ltm 50 4 2
300 89J
80 17J 75J
2J 35J 50 17
lt75
lt66
50 5 0
50 50 50 270 49J
19
WO
MW-PZ02
3285
22-32
SO 50 50 SO 50 lt50 50 60 220 5 9
60 50 50 lt50 53 50 lt07
50 50 bull ^ 9
lt50 50 50 50 lt50 lt42
38J 50 50 SO lt11
1 3
1 3
50 1 7
75 6 6
50 50 50 50 50 50J lt15
1 9
10J
MW-27
2982
23^28
5 0
5 0
50
5 0
lt50
lt50
5 0
5 0
5 0
0 5 9
SO 5 0
5 0
50
5 0
lt50
057
5 0
5 0
^49
lt50
50
5 0
SO 5 0
042
50
5 0
5 0
5 0
02J
0 1 3
013
5 0
0 1 7
075
066
5 0
5 0
5 0
50
50
5 0
015
0 1 9
5 0
MW-27-QA
2982
23-28
10 10 10 10 10 10 50 10 10 50 10 10 10 10 10 50 10 20 50 50 10 20 20 10 50 50 10 10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 10 10 10
MWJ7
3155
20-30
50
50
lt50
50
50
50
50
50
50
059
lt50
50
50
lt50
50
50
bull057
50
50
-49
50
50
50
5 0
50
042
50
50
50 bull
50
011
013
013
50
0 17
075
066
lt50
50
50
50
50
50
015
019
50
MW-37a
3155
20-30
50
50
50
50
50
50
50
50
50
059
lt50
50
lt50
50
50
50
057
50
50
49
50
50
50
5 0
50
042
50
50
50
50
011
013
013
lt50
017
075
066
50
lt50
50
50
50
50
015 019 50
MW-39
3209 20-30 50 50 60 bU 60 50 50 60 50 059 60 50 50 50 lt60 50 057 50 50 49 50 50 50 50 50 042 50 50 60 50 011 013 OI 3 50 017 075 066 50 50 50 5 0 50 60 015 019 60
MW40
3195 20-30 50 50 50 50 50
50 50 50 700 059 lt60 50 lt50 50 50 lt50 bull057 50 50 ^49 lt50 50 50 50 50 lt042 50
50 50 50 011 lt013 013 lt50 017 075 066 50 50 lt50 50 lt50 50 015 019 50
MW-40a
3195 20-30 50 50 lt50 60 50 50 50 50 50 059 60 50 50 50 lt50 50 057 lt50 50 49 lt50 50 50 SO 50 042 50
50 lt50 50 O i l 013 013 lt50 017 075 066 50 50 lt50 50 50 50 lt015 019 50
MW-40-QA
3195 20-30 10 10 10 10 10 10 50 10 537 50 10 10 lt10 10 lt10 lt50 10 lt20 50 50 lt10 lt20 20 10 50 50 10 lt10 10 10 10 10 10 10 10 50 20 10 10 10 10 10 10 lt10 10 10
DowngradientfSentry
MW-05
2583 14-24 50 50 50 50 50 50 50 50 50 059 bull50 50 lt50 50 50 50 bull057 50 50 49 50 50 50 SO lt50 042 50 50 50 50
011 013 OI 3 50 017 075 066 50 50 50 50 50 50 015 019 lt50
MW-28
3656 25-35 50 50 lt50 lt50 50 lt50 lt50 50 50 lt059 -50 lt50 50 50 lt50 50 057 lt50-50 -49 50 lt50 50 5 0 50 042 lt50 50 lt50 50 O i l 013 013 lt50 OI 7 075 066 lt50 50 50 lt50 lt50 5 0 OI 5 019 5 0
MW-32
30 20-30 50 50 60 50 50
50
lt5a 50 50 059 50 50 60 50 50 50 057 50 50 45 50 50 50 SO lt50 042 50 60 50 50 011 OI 3 013 50 OI 7 075 066 50 50 50 lt50 50 50 015 019 50
Soil Cells
MW-10
1919 7-17 50 50 50 50 50
50 50 50 50 059 50 50 50 50 50 50 057 50 50 -49 50 50 50 SO 60 042 50 50 50 50 012J OI 3 013
lt50 017 075 066 50 50 50 2J 50 50 015 019 50
MW-09
51 41-51 50 50 50 60 50 50 50 50 50 059 50 50 50 50 50 lt50 057 50 50 49 60 50 50 50 50 042 50 50 50 50 012J 013 013 50 017 075 066 50 50 50 12J lt50 50 015 019 50
MW-09-Ee
51 41-51 50 50 50 50 50 50 50 50 50 lt059 50 50 50 50 50 50 057 50 60 49 50 60 50 5 0 50 042 50 60 50 50 O i l 013 013 60 017 075 066 50 50 60 60 50 50 015 019 50
PZ-09
133 125-15 50 50 50 50 50 50 50 50 50 059 50 60 lt60 50 50 50 057 50 50 49 50 lt50 tSO SO 50 042 50 50 50 50 011 013 013 lt50 017 075 066 50 50 50 lt50 50 50 015 019 50
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
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State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
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[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
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14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
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Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
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y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
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-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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Institutional Control EPA ID ARD008052508
110th Congressional District 4
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
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FIGURE 6 SECONDARY CAP
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PCP plume in ppb with time
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Table 3 Summary of October 2010 Sampling Event Results (cont)
Parameter
Well Depth (ft)
Screened Interval (ft)
Dieth^ phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Di-nK)ctvl phtialate
Fluoranthene
Fluorene
Hexachlaobenzene
Hexachlorobutadiene
Hexaohlorocydopentadiene
Hexachlcroelhane
lndeno(123-cd)pvrene
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
N-Nlirosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
2-Methylphenol
mp-Cresots
Rcporl
Analysis Resu It (pgl)
Near SourceDowngradient
MW-31
32 295-32
1900
1700
1800
1900
41000000
27000000
1700
2100
1400
2100
450000J
2000
89000000
1900
1800
1700
3000000J
790)0000
2200
25000000
1200
1800
cd at MD
MW41
3D 20-30
50 50 50 50 23J 160 50 lt60 lt43
lt50 50 bO 5500
50 50 50 160 200 54 15J 320 440
to ma
MW-33
33 23-33
50 50 50 50 68 140 60 lt60 lt43
50 50 50 5600
50 50 50 290 190 110 35J 260 520
ting rcr
MW-
PZ02
3285
22-32
50 50 50 50 19
11J 50 50 43
50 50 50 1000
50 50 50 57 27J
50 50 50 lt50
orting
MW-27
2982
23-28
50 50
50
50
0 1 9 011
50
60 043
50
50
60
015J
50
50 50
0 5 7
045J
50
027J
50 50
iniit rcqui
MW-27-
QA
2982
23-28
10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 50 10 10 10 10 10
cnicnLs
MW-37
3155
20-30
50
50
50
60
0 1 9
0 11
60
60
0 43
50
50
50
052J
50
50
50
0 57
50
50
50
50
lt50
MW-37a
3155
20-30
50
50
5 0
5 0
0 1 9
0 1 1
50
5 0
0 4 3
5 0
50
50
052J
lt50
lt50
lt50
057
5 0
60
50
50
5 0
MW-39
3209
20-30
5 0
5 0
5 0
lt50
0 19
0 11
50
50
0 4 3
50
50
50
014J
50
lt50
50
057
5 0
60
-50
50
50
MW-40
3195
20-30
50
50 50
50
019
011
50
50
043
50
50
60
16 5 0
5 0
50
0 67
50
50
50
22J
50
MW-40a
3195
20-30
50 50
50
50
0 1 9
O i l
60
5 0
0 43
5 0
5 0
lt50
17 50 50 50 0 5 7
5 0
5 0
50
5 0
5 0
MW-
40-QA
3195
20-30
10 10 10 10 10 10 10 lt10 10 10 10 10
105
10 10 10 50 10 10 10 10 10
DowngradientSentry
MW-05
2583
14-24
60
50
50
50
0 19
0 11
50
50
0 43
50
50
60
50
50
50
50
057
50
50
50
50
50
MW-28
3656
25-35
50
50 50
50 019
011
50 60 043
60
50
50
50
50 50
50 067
50 50 50
50 50
MW-32
30 20-30
60
60
60
50
019
011
50
50
043
50 50 60
50
50
50
50 057
lt50 50
50 50
50
Soil Cells
MW-IO
1919
7-17
60
50
50
lt50
0 19
011
50
50
0 43
50
50
60
028J
lt50
lt50
50
0 57
50
60
50
lt50
50
MW-09
51 41-51
50
50
50
50
0 19
0 11
50
50
043
50
50
60
028J
50
50
50
0 57
50
50
-50
60
lt50
MW-09-
EB
51 41-51
50
50
50
50
0 19
011
50
50
043
50
50
lt60
032J
50
50
50
0 57
50
50
50
50
50
PZ-09
133
125-15
50
50
50
50
0 19
0 11
50
50
043
lt60
50
lt50
026J
50
5 0
5 0
0 67
lt50
50
50
50
50
Analysis run as waste dilution - analyzed by weight and J = est imated concentrat ion (between MDL and report ing lt = less than specif ied report ing limit
reported at iVIDL in ppb for all COCs limit)
10
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
--ri-i
1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
bull-raquovAraquo3g|Ev-v^r^
Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
lt bull bull
5 I
1 bull
f
- t
Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
rV -W^ I Jmii-Vi5poundV W I ^^^laquo
gt-i^
J V f
V
a L 1 1
bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Table 4 Comparison of Phase II Groundwater Investigation Results and Groundwater Monitoring Results Monitoring Well Phase II Result (ugl)
PCP Naphthalene
January 2004 Result (ugl)
PCP Naphthalene
November 2004 (ugl)
PCP Naphthalene
April 2005 (ugl)
PCP Naphthalene
May 2006 (ugl)
PCP Naphthalene
October 2010 (ugl)
PCP Naphthalene Soil Cells HfW-12 PZ-09 MW-10 MW-09
NR NR NR NR
NR NR NR NR
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
lt05 lt05 lt05 NA
053 J lt50 lt50 NA
lt05 lt05 lt05 NA
025J 052J 023J NA
lt05 lt05 lt05 NA
lt50 lt50 lt50 NA
NA lt057 lt057 lt057
NA 025J 028J 028J
Upgradient MW-08 MW-24
NR NR
NR NR
NA lt05
NA 0088J
lt05 lt05
021 lt50
lt05 lt05
032J 039J
NA NA
NA NA
NA NA
NA NA
Source Plume MW-42 MW-33 MW-31 MW-41
150 3 590 99J
7400 2600 2600 970
NA lt100 NA 38J
NA 4400 NA 5800
37000 lt99 11000 24J
5100000 3400 1400000 4700
NA lt250 17000 100
NA 4200 470000 3800
NA NA NA NA
NA NA NA NA
NA 290 300000J 150
NA 5600 89000000 5500
Downgradient Plume MW-40 MW-37 MW-39 MW-27 MW-PZ02
NR NR NR 14J NR
NR NR NR 220 NR
lt10 lt05 NA lt05 NA
20J lt50 NA 15 NA
lt24 lt05 lt05 lt05 lt19
lt24 lt50 lt50 012J 700
lt10 lt05 lt05 lt05 lt10
33J 018J 040J 028J 770980
lt10 lt05 lt05 ltD5 lt20
30J lt50 40J lt50013J 860
lt057 lt057 lt057 lt057 lt57
16 052J 014J 015J 1000
Sentry MW-04 MW-05 MW-28 MW-32
NR NR NR
NR NR 27
lt50 NA lt05 NA
160 NA 0069J NA
lt10 lt05 lt05 NA
28 013 0075J NA
NA lt05 lt05 NA
NA lt50 019J NA
NA lt05 lt05 lt05
NA 070J lt50 lt50
NA lt057 lt057 lt057
NA lt50 lt50 lt50
NR = not reported - there are no reported results for these monitoring wells NA = not analyzed These monitoring wells can tie used to monitor the soil cells as well as for upgradient monitoring These monitoring wells can be used for upgradient monitoring of the dissolved phase plume as well as lo monitor the soil cells Two samples were collected at different times from MW-PZ02 both results are reported here
J = estimated concentration (between MDL and reporting limit) lt = less than specified reporting limit
11
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
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Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
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[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
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14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
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Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
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lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
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y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
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-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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Institutional Control EPA ID ARD008052508
110th Congressional District 4
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
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FIGURE 6 SECONDARY CAP
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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gt-i^
J V f
V
a L 1 1
bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Table 5 Summary of Natural Attenuation (Laboratory Analyzed) Results - 2010 Sampling Event
Parameter
Well Depth (ft) Screened Interval (ft) Chloride bull Nitrate Nitrite Sulfate Sulfide Total Alkalinity Total Organic Carbon Total Iron Total Inorganic Carbon Dissolved Hydrogen (nM) Methane (ugL)
Analysis Results (mgL- unless otherwise specified) Near SourceDowngradlent
MW-31
32 295-32
138 lt001 lt001 953
lt005 80 166 434 280
0710 44
IVIW-41
30 20-30
241 lt001 lt001 789 133 18
206 64 420 22
1900
MW-33
33 23-33
621 lt025 561
lt125 00385J
80 358 136 670 17
6400
MW-PZ02
3285 22-32 577
lt005 178
0778 0340
60 363 225 430 22
3700
MW-37
3155 20-30 216
lt005 106 428 lt005 lt50 lt10 123 280 10 20
MW-27
2982 23-28 860
lt001 lt001 lt50
00350J lt50 lt1
266 230 lt12 250
MW-39
3209 20-30 155
lt001 lt001 642 lt005 lt50 lt1
248 300 14 20
MW-40
3195 20-30 241
lt001 lt001 lt50 0864 lt50 231 392 420 18
3000
MW-40a
3195 20-30 241
lt001 lt001 lt50 0881 lt50 244 384 420 26
3900
MW-40QA
3195 20-30 235
lt010 lt010 lt10
lt050 lt20 lt1
428 NA NA NA
Dowrngrad lentSentry MW-05
2583 14-24
122 0073 107 588
lt005 lt50 lt1
255 270
0990 20
MW-28
3656 25-35
122 lt005 0975 723
00224J lt50 lt1
235 280 12 12
MW-32
30 20-30
155 lt005 122 335
0329 lt50 lt1
498 300 15 360
NA = not analyzed (or not applicable for QA sample for TIC H2 and CH4)
12
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
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FIGURE 6 SECONDARY CAP
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Table 6 Summary of Evidence of Natural Attenuation-2010
Parameter
Dissolved Oxygen Oxi(Jation-Reduction Potential Nitrate Nitrite Manganese Ferric Iron Ferrous Iron Su fate Sulfide Carbon Dioxide Total Alkalinity Dissolved Hydrogen Methane Total Organic Carbon Total Inorganic Carbon Chloride
Evidence of Natural Attenuation Occurring
October 2010 X X
-
X bull1
X X X X X
13
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
May 2011 On May 19 2011 representatives of the USACE-MVN US EPA and ADEQ conducted a site inspection The inspection team consisted of Dr George Baeuta (USACE-MVN) Mr Shawn Ghose (US EPA) Mr Clay McDaniel (ADEQ) and Ms Ann Wiley (ADEQ) The inspection team did a site walk to inspect the general condition of the site including the vegetation security perimeter fences and gates monitoring wells integrity of the soil cells and their clay caps erosion and other issues related to the maintenance of protectiveness at the site The inspection team used a site inspection checklist (see Appendix D) to document their observations In addition to the site walk the inspection team interviewed Mr Bob Stephenson an agent of Mr Jerry Blackman who is one of the owners of El Ark Industries Mr Bob Stephenson manages the current timber logging operation on El Ark Industries property adjacent to the Popile Inc Site (see Appendix C - Interview Documentation) Dr Baeuta interviewed Mr Max Dollar who is a representative of the business facility Lee Trucking across the street and the main gate neighboi-ing the Popile Superfund Site (see Appendix C - Interview Documentation)
The following are significant findings
bull The Main Gate was open upon arrival of the USACE-MVN US EPA and ADEQ inspection team The main gate area is largely under the ownership and institutional control of El Dorado Timber Co Inc
bull Within the security perimeter fencing of the Popile Inc site the former impoundment areas which are also largely under the ownership and institutional control of El Dorado Timber Co Inc (see Appendix E -Reference Institutional Control Documents EPA ID008052508 1 lO Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008) there is heavy equipmentmachinery stored on the site indicating activity at the site by El Dorado Timber Co Inc Close-up photos of one heavy equipment show deteriorating batteries that may add new contamination in soil and groundwater unrelated to the Popile Inc Site (see Appendix D - Site Inspection Checklist)
bull The security perimeter fencing on the northern eastern and southern portions of the Popile Inc Site is intact including the access gate along the eastern perimeter fencing The western security perimeter fencing separating El Ark Industries active operations area and the main soil cell are incomplete The fence poles are standing while the wire nets have been taken down and stored on the adjacent ground surface (see field photos in Appendix D - Site Inspection Checklist) The incorriplete fence starts at the intersection of the southern perimeter fence and western perimeter fence and continues towards the north The western perimeter fence separates the active operation area of El Ark Industries and the western and southern portions of the Popile Inc Site that include the main soil cell El Ark Industries has ownership and Institutional Control of the main soil cell (see Appendix F -Reference Institutional Control Documents EPA ID008052508 110 Congressional District 4 2936 acres - El Ark Industries Inc April 142008)
bull Inspection of the vegetation at the site show low grass at the former impoundment areas as well as young and maturing trees (mostly pine trees) on top of the main soil cell area
14
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
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i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
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M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
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^
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i i X
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^ib^
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bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
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bull bull gt
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h
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bull bull
Vx bull iX bull I
i
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1
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1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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5 I
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
bull
bull
located south of the former impoundment areas A small soil cell on the northeast portion of the Popile Superfund Site north of the former impoundment areas is vegetated largely with low grass Inspection of erosion of the clay cover at the soil caps indicate insignificant or minor erosional surfaces such as found near or on the small soil cell (see photo attachments in Appendix D - Site Inspection Checklist)
The area across the railroad (RR) tracks east of the perimeter fence of the Popile Inc Site shows a small pool of standing water along a narrow area between the RR tracks and the perimeter fence fronting the main soil cell Vegetation is characterized by low grass and few trees with more robust trees towards east to Bayou de Loutre (see photos attachments in Appendix D - Site Inspection Checklist)
The keys provided by SPA-MMG work on the gates as well as in all the monitoring well lock boxes
The integrity of the groundwater wells used for monitoring activities related to the Five-Year Reviews remain intact Minor repairs were recently undertaken by SPA-MMG in 2010 including replacement of deteriorating or frozen locks vegetation clearing as well as concrete pad label and bollard inspection These monitoring wells remain accessible as well as un-vandalized during the May 19 2011 site inspection
Interviews
Several individuals were interviewed as part of the five-year review These included representatives from US EPA Region 6 (Remedial Project Manager) and ADEQ the Mayor of El Dorado and representatives from neighboring facilities such as Lee Trucking and the TimberLogging Company adjacent to the site The interviews are summarized below Copies of the interview documentation are included in Appendix C
EPA Region 6 Mr Shawn Ghose Remedial Project Manager EPA Region 6 42111
The EPA believes the site remedies to be functioning properly there are no signs of contaminant migration and Bayou de Loutre is protected EPA recommends that OampM are continued and include implementation of the Institutional Control agreements (ICs) which were signed and recorded in 2008 The EPA recommends that sampling occur on a yearly basis for the next five years to ensure that the (PCP-Naphthalene) contaminant plume remains stable
ADEQ
Mr Clay McDaniel Engineer ADEQ 41811
ADEQ concerns with the site are detailed in Appendix C
Mayor of El Dorado Arkansas Mr Frank Hash Mayor City of El Dorado 41411
15
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
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tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
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not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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Institutional Control EPA ID ARD008052508
110th Congressional District 4
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
The site has been completely overgrown and forgotten by the community The mayor is unaware of any issues
Nearest Neighbors
Mr Max Dollar Supervisor Lees TruckingResidential neighbor 51911
There have been no problems or concerns with the site Not aware of land use restrictions
Mr Bob Stephenson Agent for Jerry Blackman 51911 There have been no problems with the site commented on good advance notice of activities at the site as well as advance public notice in local newspaper regarding the Second Five-Year Review of the Popile Inc site He also indicated that the community does not seem to be concerned with the Popile Inc site at this time Mr Stephenson and his employees are very aware of land use restrictions including non-use and limited use of certain areas at the site Mr Jerry Blackman one of the major owners of the land on the western and southern portion of the Popile Inc site has provided Mr Stephenson copies of the Institutional Control documents that El Ark Industries Inc has signed with representative of the US EPA
VII Technical Assessment
The technical assessment section of the five-year review involves asking three questions The questions and their answers are discussed below
Question A Is the remedy functioning as intended by the decision documents
Answer Yes the remedy is functioning as expected based on the Amended ROD
The following sections provide further explanation
Remedial Action Performance The remedial action involved monitoring to ensure that the groundwater contamination plume remained static and did not migrate It also included engineering controls and institutional controls at the site Three years of groundwater sampling and analysis prior to the first Five-Year Review indicated that the plume was static and has not migrated and furthermore that natural attenuation was occurring at the site
Between the first Five-Year Review in 2006 and 2010 there was no activity at the site Site OampM has not been continuous nor has groundwater monitoring Groundwater monitoringwas conducted in October 2010 Institutional Control Agreements were pursued in 2008 and implemented by the EPA with the landowners of the Popile Inc site The Amended ROD of 2001 states that the primary objective of the monitoring program is to monitor PCP and PAH concentrations to ensure that migration was not occurring off-site The 2010 results showed that concentrations at the downgradient wells are significantly lower than at the source wells By comparing 2010 results with the 2004 2005 and 2006 data the EPA concluded that migration of contaminants is not occurring (Table 4)
16
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
0
bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
--ri-i
1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
bull-raquovAraquo3g|Ev-v^r^
Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
lt bull bull
5 I
1 bull
f
- t
Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
rV -W^ I Jmii-Vi5poundV W I ^^^laquo
gt-i^
J V f
V
a L 1 1
bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
The secondary objective of the Amended ROD was to confirm plurrie stability and presence of natural attenuation By comparing the natural attenuation parameter results from the 2010 monitoring event to the 2004 2005 and 2006 data the EPA concluded that natural attenuation is continuing at the site through reductive de-chlorination (Tables 5 and 6) An in-depth discussion of results and comparisons can be found in the GW Summary and Site Inspection Groundwater Monitoring - 2010 Report
Overall the groundwater monitoring from 2010 has shown that the remedy as detailed in the 2001 Amended ROD - TI Waiver document remains effective
System Operations0laquoampM ADEQ has indicated that the site has been unattended since the first Five-Year Review in 2006 The site has become overgrown with vegetation and some large trees have grown on the large soil cell southwest of the former impoundment areas The security fence separating this soil cell from the other areas owned by El Ark Industries are now missing Timber cuttinglogging in areas outside the security perimeter fence owned by El Ark Industries is in active operation the operators and its employees are aware of the Institutional Control restrictions at the site (such as the soil cells and impoundment areas) Interview of the site operator Mr Bob Stephenson indicates that they are aware of non-use and limited use areas included in the Institutional Control document of the Popile site signed by El Ark Industries and the EPA
Institutional Controls and Other Measures Institutional controls (land use restrictions) were implemented in 2008 and must be maintained and audited by the regulatory agencies (EPA andor ADEQ) The site visit on May 19 2011 indicated that El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation
No significant erosion was observed indicating that the integrity of the soil cells is intact Vegetation is robust with low grass dominating the former impoundment area and small soil cell as well as maturing pine trees dominating the large soil cell Despite robust vegetation the monitoring wells are clear and accessible The monitoring well lockboxes including their concrete pads locks poundind labels are intact
Public access controls including portions of fencing (not taken dovra by the landowner) locks and warning signs are in place to prevent public exposure and should be utilized and maintained
Opportunities for Optimization Based on the analytical results opportunities to reduce cost by reducing the sampling effort (based on consistent results) arose and were realized In addition the changes to the sampling program allowed for focusing on the primary area of the concern downgradient migration of the contamination plume
17
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
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y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
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PAGES r -
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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a L 1 1
bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
The EPA recommends that sampling is continued on a yearly basis for the next five years The EPA also recommends that all wells sampled for the natural attenuation parameters including wells PZ-02 MV-37 MW-27 MW-39 and MW-40 is continued for the next five years to ensure that biodegradation is taking place based on indicator elements analyzed for monitored natural attenuation (MNA) per the selected remedy EPA further observed and interpreted the indirect lines of evidence for natural attenuation (eg possible daughter products of PCP as well as aerobic anaerobic condition interpretation) that the rate of natural attenuation is very slow
Early Indicators of Potential Issues Signs of engineering control issues such as vegetation and any significant erosion should be addressed to ensure the remedies integrity will not be compromised The found-condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie EI Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site
Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Answer Yes all risk assessment data cleanup levels and RAOs are still valid
The following sections provide fiarther explanation
Changes in Standards and TBCs (To-Be Considered) Currently there are no new standards in place that affect the protectiveness of the remedy for the Popile Inc site
Changes in Exposure Pathways Except for the found activities by the landowners of the Popile Inc site observed on May 19 2011 by the joint USACE-USEPA-ADEQ site inspection team overall land use has not changed at or near the site and Institutional Controls (land restrictions) have been implemented Exposure routes and receptors (human or ecological) have not changed to affect the remedys protectiveness New contaminants or sources of contamination have not been identified (Machinery batteries were observed and noted during the site visit as a possible source of contamination unrelated to the current issues at Popile) There are no unanticipated toxic byproducts of the remedy
Any changes in physical site conditions (such as fencing and erosion) have been identified during the site inspections there have been no changes significant enough to affect the protectiveness of the remedy Those that affect the security and integrity of the monitoring wells have been addressed by the EPA during the 2010 Groundwater Monitoring Sampling and Testing survey The monitoring well locks labels and vegetation surrounding the wells were addressed with minor repairs that preserve the integrity of the groundwater monitoring wells
Changes in Toxicity and Other Contaminant Characteristics Toxicity factors associated with the contaminants of concern have not changed to affect the remedys protectiveness Furthermore contaminant characteristics have not changed in any way
18
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
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18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
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State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
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Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
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Commission Expires ^ ^ V
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
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Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
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fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
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i COfnfTiission ExRiresj-^
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
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I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
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M l
1106000 1106300 1107000
Year 2018
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^ib^
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bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
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h
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bull bull
Vx bull iX bull I
i
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1
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1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
bull-raquovAraquo3g|Ev-v^r^
Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
lt bull bull
5 I
1 bull
f
- t
Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
that could affect the protectiveness of the remedy
Changes in Risk Assessment Methods Standard risk assessment methodologies have not changed in any way to alter the protectiveness of the remedy
Expected Progress Towards Meeting RAOs The contamination plume is behaving as predicted by the groundwater modeling study (the plume is not migrating) The Institutional Controls have been implemented which restrict land use and mandate that the monitoring wells remain accessible and that their integrity remains intact Overall the remedy is progressing as expected
Question C Has any other information come to light that could call into question the protectiveness of the remedy
Answer No there has been no new information that would call into question the effectiveness of the remedy
Other Information There are no newly identified ecological risks There have been no impacts from natural disasters There has been no new information that may affect the protectiveness of the remedy
Technical Assessment Summary
The three questions of the technical assessment were answered yes yes and no
Question A Is the remedy functioning as intended by the decision documents
Yes Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid
Yes
Question C Has any other information come to light that could call into question the protectiveness of the remedy
No
The groundwater contamination plume appears to be stable the monitoring wells are being maintained land use has not changed at or near the site Institutional Controls have been implemented and no wells have been drilled (other than for monitoring at the site) in the area to anyones knowledge This information supports the statement that the remedy is protective
19
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
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18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
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State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
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Commission Expires ^ ^ V
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
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ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
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^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
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Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
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^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
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bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
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X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
VIII Issues
El Dorado Timber Co has been storing equipment and machinery within the security perimeter fence and utilizes the main gate to the Popile Inc site for access at the time of the site visit the main gate was wide open El Ark Industries has taken down the fence net along the western security perimeter to join its Popile site land to its adjacent lands where timberlogging activities are in operation The condition of the western security perimeter fence and the main gate may compromise the public particularly those who are not employees of the landowners (ie El Dorado Timber Company and El Ark Industries) and are not knowledgeable of the land use restrictions existing at the Popile Inc site The remedy is currently protective but if left unaddressed these issues may affect the remedys future protectiveness
There are maturing pine trees and minor erosion on the soil cells The remedy is currently protective but these issues should be monitored to ensure they do not affect the remedys future protectiveness
Table 7 Issues
Issues
Fencing Gate
Large MachineryBatteries
Minor erosion
Small pool of standing water
VegetationTrees
Affects Current
Protectiveness (YN)
N
N
N
N
N
Affects Future Protectiveness
(YN)
N
N
Y
N
Y
IXRecommendations and Follow-up Actions
Table 8 Recommendations and Follow-up Actions
Issue
Institutional Controls
Recommendat ions and
Follow-up Actions
Have been implemented but should be maintained
Party Responsible
EPA Region 6 ADEQ
Oversight Agency
EPA
Milestone Date
Signed 2008
Affects Protectiveness
(YN)
Current Future
N Y
20
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
-iO5 mi ~^-x 02OT3 Yahoo be ^ S l O J Nitvl i tal lon Te^clmftlogti- bullJ^^V-^ t - B C H I
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
fay E M Racial e 0)S 6uppoit
knags tram QlabaXplorar
tan7aoraquo I-TSOO ^
State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
l i imgo t iom GloboXtilorci 02072006 17000
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bull t i ^ i t ^ bull Z008031SliL01
bull bull bullgt
Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
^_^otary PAWics Sigr^^^^^^ bull - bull bullbull-bullbull bull by
Commission Expires ^ ^ V
-i j i Wiraquojgti y -^
As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
- I- n p n n rmdashimdashcmdashmdashn n n bull C D V u n 1 J I u J u^
Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
^
fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
-Jr^ l^D^LJ^JLv pNpteQaibliltg^nature
i COfnfTiission ExRiresj-^
Kpoundi^NJSlt3^ w-
As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
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bull bull gt
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h
f X4
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bull bull
Vx bull iX bull I
i
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1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Issue
Minor erosion on soil cells
Missing fence unattended main gate
Trees
Monitoring
Recommendat ions and
Follow-up Actions
Need to be addressed
Need to be addressed
Remove trees that comprise protective cap or other remedy
Yearly monitoring
Monitoring for natural attenuation
Party Responsible
EPA and then ADEQ when 0laquoampM starts
EPAEI Dorado Timber Co
EPA and then ADEQ when OampM starts
EPA and then ADEQ when OampM starts
Oversight Agency
EPA
EPA
EPA
EPA
Milestone Date
2012
2012
1
2012
2012
Affects Protectiveness
(YN)
Current Future
N
N
N
N
Y
N
Y
Y
X Protectiveness Statement
Because the remedial actions at Popile Inc Superfund site are protective the site is protective of human health and the environment Groundwater monitoring data indicates that the plume is stable and is not migrating offsite The analytical results indicate that natural attenuation is occurring onsite Institutional controls were implemented in 2008 The results of this five-year review indicate that the remedy stated in the Amended ROD is functioning as required
XINext Review
Another five-year review will be conducted subsequent to completion of this five-year review The report for that review will be due five years after signing the Second Five Year Review in September 2016 This review will evaluate site conditions and any actionsmonitoring conducted at the site prior to the review
21
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
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18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
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State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
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Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
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Commission Expires ^ ^ V
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
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ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
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13 June 2008
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Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
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i COfnfTiission ExRiresj-^
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
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FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
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X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
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BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
lt bull bull
5 I
1 bull
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Appendix A Site Maps (Location Secondary Cap GW Model Plumes)
and Institutional Control Agreements
Popile Inc Superfund Site Location Map
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18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
Page
Map Created 03A362008
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State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
CSI^Gho6ltZ^S fi^
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
lt^lt^^-^^^A- d N
^ ^
Instilutional Control EPA IDlaquo ARO008052508
nOlh CcrtgrossionalDistricl
Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
Map Created 03182008 by EPA Rctjlon 6 G13 Siipporl
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Stale olArkansasCounlyof k This-inslrument was ncknm3Sdo6tiJ(Sfoj^iJiicicf
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Commission Expires ^ ^ V
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
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ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
- f i
^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
bull lt l h i t l raquo
13 June 2008
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Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
s - ^
Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
^^^^ivvwiiiiiiiww
pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
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fSl|jet5Aricaf^^^^ct^nty of J t bullv^ B- j TJiisinstcyrnerit Wa^tttfiowledged before me on bull ^Ihis i^Q ^ ^ J C X ^ 2008
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
liiJUUUlU
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
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1500500-
1500000
V ^
bull bull - laquo
V
bull
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amp t
1i106000
w rr- bull1106500 1107000
1501000
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bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
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1107000
1501000-
1500500-
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bull
Ui
bull bull - bull
Year 1998
XY
V
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Av
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1106000 1106300 1107000
Year 2018
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Year 2048
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1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
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Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Popile Inc Superfund Site Location Map
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18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
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[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
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Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
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Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
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Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
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y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
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not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
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FIGURE 6 SECONDARY CAP
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PCP plume in ppb with time
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
^ ^ i ^ ^ t r ^ ltmm^ m
18 Mar 2008
Institutional Gontrol Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow groundwater at approximately 20 feet belowground surface should not be used
The integrity of monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited to less than 3 feet
Institutional Control EmiDARO00S05i2508
110th Congressional District 4
M Michael D Owner El Dorado Umber Co Inc 1948 South West Avenue El Dorado AR 71730 as recorded In deed file number Volume filed for record in the Union County Arkansas Clerks Oflioe
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State of Arkansas County of Ult - v lt r This instrument was acknowledged before me on this date Afotfc^ i ^ 2008
NotaiyPublics Signature bull CommissionExpireB 7 - J ^ O 1
[ve the US Environmental Protection Agency I hereby and infomfiation co i^ned herein are truthiiii and of my knowledge and that the filing of this notioe is A
remedial Project Manager
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14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
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Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
L ^ - ^ QS-K-GJ^p i ^ M -
lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
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y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
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13 June 2008
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-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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Institutional Control EPA ID ARD008052508
110th Congressional District 4
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
bull bull
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FIGURE 6 SECONDARY CAP
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PCP plume in ppb with time
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
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Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
14 April 2008 2 0 0 8 3 8 1 7
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
BURIED CONTAMINANTS STOP BEFORE YOU DIG The shallow Cockfield aquifer at approximalely 20 Teel below ground surface sliouldnol be used
The integrity of the monitor wells located on the property must be maintained and must remain accessible Excavation for buildings should be limited lo less than 3 feet The soil cell in the middle bull of the property should be off limits lo any activity which may threaten the integrity of the cell
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Instilutional Control EPA IDlaquo ARO008052508
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Owners JS Beebo Jr Jiarry Dkickman and John Lowory ElArk Induslries Inc 203 Neel SiEl DoradaAR 7t730(87p)-862-1884 as recorded In deed (ile number i2CCLVolumo3poundiS Pago laquoMfe filed for record in Iho Union Counly Arkansas Clerks Olfico M i ~ 0 9 y
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As a roprosenlative o( the US Environmenlnl Protection Agency I hereby alfirni ihal Ihe (actsand information contained herein arc Irulhlul and accurate (o Ihs b^sl of my knowledge and that Iho niing of Ihis notice is required IjyJhg^USEPA
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lti^Shawn GhdfifiJJeniedial Project Manager l l - J
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
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ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
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Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
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-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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Institutional Control EPA ID ARD008052508
110th Congressional District 4
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Map Created 05202008 by EPA Region 6 GIS Support
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
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FIGURE 6 SECONDARY CAP
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PCP plume in ppb with time
Year 1958
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
2 June 2008
Institutional Control Area - Popile Inc Superfund Site Union County Arkansas
The shallow Cockfield aquifer at approximately 20 feet below ground surface should not be used to avoid pulling in contaminants from upgradient areas The integrity of the monitor wells located on the property must be maintained and must remain accessible
Institutional Control EPA IDARD008052508
lioth Congressronal District 4
James Scroggins Great L^es Chemical COP) 2226 Haynesviiie Hwy El Dorado R 71730
as recorded in deed file number _ Volume Page
Map Created 05202008 bull reg ii by EPARoflion GGiSSupport l i j ^ i ^ j
filed for record in tfio Union County Arkansas Clerks Office Imago frcxn GlobeXpforor
02072006 17000 200S052(1ML02
7 ^
ILiLi LU^-Slate of Arkansas County of This instrument was acknowledged tiefore rngJory this date
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^ J - 2008
Notary^Publics Sigifaiire ~ ^ Commission Expires^ c^o0--c--^ U n
y t^a representative of the US Environmental Protection Agency I hereby t5apnTViJhat the facts^riSThformaiioncontained herein aretoithful and
agcural to I f i e t i e ^ f my knowledge and that the filing of this notice is
I Sli^wnGhoso RemediarProject hAanager
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13 June 2008
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Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
Lisa
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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pound ^ M ^ ^ M M M pound j S ^ i l Z i ^ ^
Institutional Control EPA ID ARD008052508
110th Congressional District 4
Page
Map Created 05202008 by EPA Region 6 GIS Support
Image from GlotwXploref 02072006 17000 20OBOS20MI01
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
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FIGURE 6 SECONDARY CAP
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PCP plume in ppb with time
Year 1958
1501000
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Year 1978
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Year 1998
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Year 2018
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
13 June 2008
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Institutional Control Area - Popile Inc SuperfuSfi^fe15l690 _ ^ J ^ - bull RECORDED ON Union County Arkansas 06232008 024048PM
-ru 1 M ^ u- ^ -f bull bull 1 or^r K A ^CHERYL COCHRAN-WILSON The shallow Cockfield aquifer at approximately 20 feet below ground surface snouja nnniiTy
not be used to avoid pulling in contaminants from upgradient areas The n^sgri^oi|f|ieg p monitor wells located on the property must be maintained and must remain ac^ssmfe r QQ
PAGES r -
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Mike Djomas Mayor
City of El Dorado Artltansas 204 Northwest Avenue El Dorado AR 71731
Owner City of El Dorado El Dorado AR 71730 as recorded in deed file number Volume filed for record in the Union County ArkansasClerks Office
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Institutional Control EPA ID ARD008052508
110th Congressional District 4
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As a representative of the US Environmental Protection Agency I hereby affirni that the facts and infomnajionconlained herein are truthful and accurate to the best of my kngjWedge and that the filing of this notice is required by the USEPA
M Shawn GhoseK(emedial Prbjectlvlanager
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FIGURE 6 SECONDARY CAP
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PCP plume in ppb with time
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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5 I
1 bull
f
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
FIGURE 6 SECONDARY CAP
[VIMMLltailaquo
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
~-mdash
X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
PCP plume in ppb with time
Year 1958
1501000
irll
i f
I
1500500-
1500000
V ^
bull bull - laquo
V
bull
y ((
amp t
1i106000
w rr- bull1106500 1107000
1501000
WO
1500500-
bull1500000-
Year 1978
iimx gt^^ltB^ ^
1106000
X
kX
x
1107000
1501000-
1500500-
isooooO
bull bull
bull
Ui
bull bull - bull
Year 1998
XY
V
A-^^^ - 1 0 0 ^
Av
ampraquo-gt-
1 t
x y J
nSlOWiLtrade X
M l
1106000 1106300 1107000
Year 2018
1501000-
ir-^-
1500500^
77=77 V
^
^i f-
i i X
bullbull^|l -^ gt ) x ^ ^ XJX -X gt X
^ib^
bull bull bull ^ v
bull laquo - bull 5
bull bull bull - 1
Year 2048
1501000-
-
1500500-
1500000-
X-^v l 11NX
HwtX
bull bull gt
-il
h
f X4
X ^
bull bull
Vx bull iX bull I
i
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X X
1
1
( 1
(X
1
1
1106000 1106500 1107000
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
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Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
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us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
us Army Corps of Engineers^ New Orleans Dbrict
Appendix B El Dorado Times Public Announcement (4202011)
Building Strong reg The US Arniy Coips of Engineers New Orleans District is perfomiing the US Environmental Protection Agency Region 6 second Five-Year Review of the Popile Inc El Dorado Superfiihd Site
The Superflmd Site previously a wood preservation facility is located in Union County Arkansas 34 mile south of IfWY 82 off of South Fields Road Remediation of site contaminates began in the 1990s and included removal of principal health threats and tlireats to the surrounding environshyment Institutional and engineering controls ground^vvater monitoring and general maintenance have been put in place to monitor the site The first Five -Year Review conducted in 2006 concluded that the site remedy was proshygressing as expected and site conditions are protective of public health and the environment Groundwater Monitoiing in 2010 indicated tliat remedies (institutional and engineered controls) are remaining effective To further ensure protection of the environment and public health a second Five-Year Review is underway which will be made public upon completion (http cfpubepagovsupercpadcursitescsitinfocfmid=0603790) and also at pubshylic repositories
Please provide any questions in regards to the Five-Year Review and the Superfund Site no later than May 20 2011
Conlacl John Templelon (504) 862-1021
johiiateinpIetonusacearmyiiiil
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Appendix C Interview Documentation
INTERVIEW DOCUMENTATION FORM
The following is a list of individuals interviewed for this five-year review contact record(s) for a detailed summary of the interviews
Frank Hash Name
Max Dollar Name
Bob Stephenson Name
Clay McDaniel Name
Shawn Ghose - Name
Mayor TitlePosition
Supervisor TitlePosition
Agent for Mr Jerry Blackman
TitlePosition
Engineer Supervisor TitlePosition
Regional Project Manager
TitlePosition
City of El Dorado Organization
Lees Trucking Inc Organization
El Ark Industries Inc
Organization
Arkansas DEO Organization
USEPA Organization
See the attached
041411 Date
051911 Date
051811 Date
041811 Date
090606 Date
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
INTERVIEW RECORD 1
Site-Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit email
EPA ID No ARD008052508
Time 0912 Date 041411
Incoming Outgoing
Contact Made By
Name John Templeton Title Technical Manager Organization USACE-MVN
Individual Contacted
Name Bobby Beard Title Mayor
Telephone No 870-862-7911 Fax No 870-881-4164 E-Mail Address mayoreldoradoarorg
Organization City of El Dorado
Street Address 204 NW Ave City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
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Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time 1005 Date 051911
Type Visit Location of Visit At Lees Trucking Office
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Max Dollar Title Supervisor Organization Lees Trucking Inc
Telephone No 870-862-5477 Fax No 870-862-1946 E-Mail Address
Street Address 2054 S Field Rd City State Zip El Dorado Arkansas 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
INTERVIEW RECORD
Site Name Popile Inc Superfund Site EPA ID No ARD008052508
Subject Five-Year Review Time Date 051911
Type Phone Call Location of Visit
incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Bob Stephenson Title Agent for Jerry Blackman Organization El Ark Industries
Telephone No Fax No E-Mail Address
Street Address 1300 Crestwood Drive City State Zip El Dorado AR 71730
Summary Of Conversation
See attached interview form
Page 1 of 1_
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Email Location of Visit Email
EPA ID No ARD008052508
Time 1617 Date 041811
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Clay McDaniel Title Engineer Supervisor
Telephone No 501-682-0836 Fax No 501-682-0565 E-Mail Address mcdanieladeqstatearus
Organization Arkansas DEQ
Street Address 8001 National Drive City State Zip Little Rock Arkansas 72219-8913
Summary Of Conversation
See attached interview form
Page 1 of ]__
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
INTERVIEW RECORD
Site Name Popile Inc Superfund Site
Subject Five-Year Review
Type Visit Location of Visit At Popile Superfund Site
EPA ID No ARD008052508
Time 1245 Date 042111
Incoming Outgoing
Contact Made By
Name Dr George Baeuta Title Technical Manager Organization USACE - MVN
Individual Contacted
Name Shawn Ghose Title Project Manager
Telephone No 214-665-6782 Fax No 214-665-6660 E-Mail Address ghoseshawnepagov
Organization USEPA
Street Address 1445 Ross Ave (6SF-AP) City State Zip Dallas Texas 75202-2733
Summary Of Conversation
See attached interview form
Page 1 of 1_
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
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j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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5 I
1 bull
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Local AuthoritiesNearest neighbor(s)
Name Frank Hash Company City of El Dorado
Date Completed April 142011
Interviewer USACE New Orleans
1) What is your overall impression of this project The site is almost totally overgrown with trees and grasses h is a forgotten site
to the community
2) What effects have site operations had on the surrounding community To my knowledge absolutely none
3) Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
4) Are you aware of any events Incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
5) Do you feel well informed about the sites activities and progress
Yes
6) Do you have any comments suggestions or recommendations regarding the sites management or operation
None
extra space is required please attach on a separate piece of paper and note the responses question
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
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Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Max Dollar Company Lees Trucking Inc
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was taken care of
What effects have site operations had on the surrounding community
Not to his knowledge None in the past five years
Are you aware of any community concerns regarding the site or its operation and administration (Details)
No
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
No
Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
No
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Not at this time
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Popile Inc Superfund Site El Dorado Arkansas Five-Year Review
Interview - Nearest neighbor(s)
Name Mr Bob Stephenson Company Agent for Mr Jerry Blackman 1300 Crestwood Drive El Dorado AR 71730
Date Completed 051811
Interviewer George Baeuta
What is your overall impression of this project
The problem was tended to but at great (excessive) cost
What effects have site operations had on the surrounding community
None
Are you aware of any community concerns regarding the site or its operation and administration (Details)
None that I know of
Are you aware of any events incidents or activities at the site such as vandalism trespassing or emergency responses from the local authorities (Details)
None Are you aware of any land usedeed restrictions in the area associated with the site and protection of public health
Non-use of certain areas Limited use of other areas per Jerry Blackman Institutional control documents
Do you feel well informed about the sites activities and progress
Yes
Do you have any comments suggestions or recommendations regarding the sites management or operation
Good Advance notice of activities Community does not seem to be concerned at this time Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
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Approximate extent of contaminant plume from 1998-2000 study
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Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
El Dorado Arkansas Five-Year Review
Interview - Arkansas Department of Environmental Quality
Name Clay McDaniel Title Engineer
Date Completed April 18 2011
Interviewer USACE MVN
1) What is your overall impression of this project
While the groundwater contaminant plume has not migrated offsite contaminant concentrations within the source zone have increased over time where the modeling indicated a relatively constant level ADEQ is not prepared to transition from the OampF phase (EPA acting as the lead agency) to the OampM phase (ADEQ acting as the lead agency) until the engineering controls are repaired and a more consistent data set is made
2) Is the remedy functioning as expected
Yes the plume boundaries are relatively stable But breaches in the engineering controls (erosion to the capped areas exposure of geotextile liner and puncturing of the clay caps from pine tree roots) could lead to expansion of the plume boundaries
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The engineering controls are not being maintained Pine trees upwards of 20 tall are growing on top of the surface impoundments These trees have likely punctured through the clay caps and allowed rainwater to leach through the impoundments Other areas on the site have clay caps andor vegetative covers that are potentially compromised from erosion andor tree growth Part of a vegetative cover has been eroded where the dirt road going to the railroad tracks has exposed parts of the geoshytextile fabric Also the entire fence line extending from S Field Road to the southwest corner of the site has been taken down
The institutional controls are still maintained
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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J V f
V
a L 1 1
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
Yes up until about 5 years ago MMG would maintain the vegetative covers of the surface impoundment cells and other areas on-site Since then pine trees have grown on both the larger soil disposal cell and the smaller debris disposal cell The pine trees have matured enough to speculate that they have punctured the clay caps which act as hydraulic barriers to water movement into the cells This could eventually lead to further groundwater contamination
Groundwater sampling should have been conducted annually for the 5 years leading up to this Five Year Review Report However only (1) one groundwater sampling event was conducted during this timeframe The recent sampling event was conducted during a very dry period which precluded collection of the desired data set because some wells were dry
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
The site is not yet in the OampM phase and maintenance at the site has been ignored for the past 5-6 years The cost to repair the site from lack of maintenance has not been anticipated
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
The most recent sampling event was optimized for this site
7) Are you aware of any community concerns regarding the site or its operation and administration
No
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
8) Do you have any comments suggestions or recommendations regarding the project
EPA should repair damages to the engineering controls This includes but is not limited to (1) repairing any punctures caused by tree roots into vegetative covers andor clay liners (2) repairing areas where erosion has impacted the vegetative covers esp the dirt road going to the railroad tracks and (3) re-erecting the fence line that was taken down
After the engineering controls are repaired EPA should ensure that regular maintenance is conducted and that institutional controls are being followed
The 2001 ROD Amendment called for sampling to be conducted annually leading up to the Five Year Review Report ADEQ would like annual sampling to be conducted for the next 5 years before the next Five Year Review Report is submitted These upcoming sampling events should be included in a schedule as part of this Five Year Review Report
The PCP bio-plume model should be re-evaluated to incorporate sampling data collected since the model was first run to determine if the PCP plume is behaving as anticipated
This Five Year Review Report should discuss the requirements that should be implemented to address sampling results that reveal contamination above the Alternate Concentration Limits (ACLs) of 2080 ppb for PCP amp 110 ppm for PAHs (expressed as benzo(a)pyrenes)
Popile Inc Superfund Site
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
El Dorado Arkansas Five-Year Review
Interview - USEPA Region 6
Name Shawn Ghose MS PE ASME Title RPM Popile
Date Completed April 21 2011
Interviewer USACE MVN
1) What is your overall impression of this project
A This was a very interesting project The original ROD was to pump amp treat the ground water so the contaminant plume with PCP does not travel to Bayou de Laturre in the downgradient direction The Rl in 1992 had not sufficiently characterized the subsurface hydrology A SCAP boring sampling and modeling study in 97-99 showed that the PCP amp PAH plume stayed in the impoundments where wood treating fluids were disposed in the past 30+ years Based on the results the remedy should have been a No further action ROD But at ADEQs insistence a ROD Amendment in 2001 adopted a Technical impractibilty waiver with monitoring Monitoring of the contaminant plume for past ten years has established the plume is static and confined to the impoundments where the treatment fluids were disposed The results of the last sampling in 2010 confirmed the model prediction in 2000 that the plume will be static for next fifty years Also there is no threat to Bayou Latourre from the plume reaching the river in downgradient direction
2) Is the remedy functioning as expected
There was no active remedy except monitoring the contaminant plume of 150 feet confined to the past impoundments In 1991 EPA excavated sludge and contaminated soils and stabilized the materials with rice hulls and fly ash in clay lined holding cells in southern portion of the Site
3) Monitoring data shows the plume is stable and not migrating offsite and the engineering controls to limit site access and prevent release (fencing signs erosion control etc) are being maintained What is the status of the institutional controls Have land use restrictions been put in place If not is there a plan to implement them
The individual tracts owners signed Institutional Controls in 2008 not to drill into or use the shallow Cockfield aquifer There is no further need for fencing etc except the small engineered cap in the north part of Popile
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
bull-raquovAraquo3g|Ev-v^r^
Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
lt bull bull
5 I
1 bull
f
- t
Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
rV -W^ I Jmii-Vi5poundV W I ^^^laquo
gt-i^
J V f
V
a L 1 1
bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
4) Have there been any significant changes in the OampM requirements maintenance schedules or sampling routines since start up or in the last five years If so do they affect the protectiveness or effectiveness of the remedy
A NO The only OampM for protectiveness (ie cut off exposure pathway ) is the Institutional Control which has been in place since 2008 The access to monitor wells may be nice to have but it is unlikely that the plume which has not moved for 40 years will move in the next 10 or 20 years
5) Have there been any unexpected OampM difficulties or costs at the site since start up or in the last five years
A No Monitoring or sampling wells within narrow intervals may be waste of resources The plume is static and the soil cell in the south must have become like a porous rock with no leaching expected This has been shown by analysis of soil monitoring wells
6) Have there been opportunities to optimize OampM or sampling events Any resultant or desired cost savings or improved efficiency
A No Wells have been sampled many times showing the plume to be static The next sampling should be in 10 years This should result in significant cost savings and not sampling just to satisfysome customary procedure Moreover at the next sampling event the natural attenuation parameters in well PZ-02 MW-37 MW-27MW-39 and MW-40 need not be measured as last 10 years of monitoring has shown that biodegradation is taking place But the rate of natural attenuation is very slow and would not be measureable in 10 years
7) Are you aware of any community concerns regarding the site or its operation and administration
A No No concerns expressed by local community
8) Do you have any comments suggestions or recommendatioTis regarding the project
A Since the analysis of data from last ten years and more show the contaminant plume to be stable and no leachate is exiting the soil cell on the southside of the Site the sampling should be reduced to once every ten years The fences are not required as the tract owners will maintain the Institutional Control (which is underground) Preferably the Site should be Deleted from the NPL
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
--ri-i
1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
bull-raquovAraquo3g|Ev-v^r^
Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
lt bull bull
5 I
1 bull
f
- t
Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
rV -W^ I Jmii-Vi5poundV W I ^^^laquo
gt-i^
J V f
V
a L 1 1
bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Frcm 1993 Popile Inc ROD
UCtlD
mdash snout IWt mdash o n m x t oncH mdash m t UME -- DoiMo m m
SHuuiM uoMioma laquoaJLs OCpoundP M0M10RHC WCUJ CltClttrade m W M CRtAIDl W M 7laquo f a r Bto) PKzaami
tsiwAtn) laquolaquolaquo txroir or mt t -wusi emrAMHun nuu t OH cnouNtmAiDt
BTWTtD ATOM tXTlMT OT DSSOIVIS coNiMUHin punre M ciKXMmuien
cnouMMMCR n o w ontcnoM
Approximate extent of contaminant plume from 1998-2000 study
SatlX I S FEET
Esnt lATED AREAL EXTENT OF GROUHDWATER CONTAMINATION
POPILE INC E t DORADO ARKANSAS
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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J V f
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bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Appendix D Site Inspection Checklist
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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J V f
V
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bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Site Inspection Checklist
Site Inspection Checklist
Popile Inc Superfund Site El Dorado Arkansas
Purpose This Site Inspection Checklist outlines the inspection areas and items required under the Engineering Maintenance (EM) Plan (dated December 2003) for the Popile Inc Superfund Site The EM Plan has been implemented as part of the groundwater monitoring program at the site under the September 2001 Amended Record of Decision The site inspections should include four main areas monitoring wellspiezometers erosion controls site accesssecurity controls and general site observations
Site Information Date of Inspection 051911 Inspector(s) George Baeuta Shawn Ghose Clay McDaniel Ann Wiley Weather ConditionsTemperature Cloudy 70-80
I Monitoring WellsPiezometers
El Properly securedlocked | ^ Functioning | ^ Good condition
bull Needs MaintenanceRepair ^ Vault Box Inspected
E All required wells located Q Repair indicated on map
Comments (specify monitoring wells requiring repair)
Wells listed for monitoring in good condition and replaced with new locks per 2010 Popile Groundwater Monitoring Report Condition of wells verified during 19 May 2011 site visitinspection
II Erosion Controls
3 Channelstrenches (Check clear of debris Adequate drainage)
El Culverts (Check clear of debris)
El Vegetation (Check signs of stress Eroded areas)
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
PWW
bull 0
j - i i ^ i I mdash
Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
L - ^ i- ^ bull4-
Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
bull-raquovAraquo3g|Ev-v^r^
Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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5 I
1 bull
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- t
Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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gt-i^
J V f
V
a L 1 1
bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Comments
Some eroded area near small soil cell located northeast of site (see Photo ) but currently not significant to impact protectiveness of soil cell
II Erosion Controls continued
El LandfillHolding Cells (Check for each of the following conditions)
bull Settlement (Low Spots) El Settlement not evident bull Settlement indicated on map
Measurements (if applicable)
Comments
bull Cracks
E Cracking not evident Q
Measurements (if applicable)
Comments
Cracking indicated on map
bull Erosion
E Erosion not evident Q Eroded areas indicated on map
Measurements (if applicable)
Comments
Refer to Photo
bull Holes
E Holes not evident bull Locations of holes indicated on map
Measurements (if applicable)
Comments
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
bull Bulges
E Bulging not evident bull Bulging indicated on map
Measurements (if applicable)
Commente
bull Vegetative Cover
E Grass ^ Cover properly established IE
E Trees or shrubs - indicate size and location on site map
No signs of stress
Comments Trees are about 3 to 20 feet with 2 to 6 inches tree trunk diameters Trees are mostly pine trees and are concentrated on top of the major soil cell area
bull Water DamageWet Areas
E Water damagewet areas not evident
If water damage evident specify below
bull Wet areas O Location(s) indicated on map
Measurements
bull Ponding bull Location(s) indicated on map
Measurements
bull Seeps bull Location(s) indicated on map
Measurements
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
bull-raquovAraquo3g|Ev-v^r^
Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
n Soft subgrade D Location(s) indicated on map
Measurements
Comments
bull Slope Instability
bull Slides bull Location(s) indicated on map bull Slides not evident
Measurements
Comments
III Site AccessSecurity Controls
Fencing
E Damaged IE Location(s) indicated on map CI Damage not evident
E Gates secured
Comments
Fence Fence and gates along the southern eastern and northen perimeter boundaries of the site are all intact However the original fence on the west side of the Popile site adjacent to the currently active timber operating neighbor do not have the wire nets (chicken wire) and were probably taken down by the site owner El Ark Industries Inc The aluminum poles are standing while the wire nets are neatly stacked on the ground at the original fence line Bob Stephenson Agent for Jerry Blackman (one of the three owners of El Ark Industries Inc) currently operates the adjacent active timberlogging facility Mr Stephenson indicated that Mr Blackman provided him institutional control documents he agreed and signed on with USEPA and that he and his employees are aware of deed restrictions at the site as well as areas indicated by Mr Blackman for non-use OR limited use See photos and map for current condition and location of the fence on the western perimeter of the site
Gates Gate towards the railroad track located on the eastern boundary of the site are secured However the main gate from the road (state road county road) is wide open when USEPAADEQUSACE personnel visited the site on 19 May 2011 Signs and notices are in-placed and visible See photos and map for current condition of gates
Signs
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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1 bull 1
1
Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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bull
Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
IE In place bull Vandalism Q Location(s) indicated on map
Comments
IV General Site Conditions and Observations
Roads O Damaged bull Location(s) indicated on map IE Good condition
Comments
Except for current use of the main gate by the site owners as well as the taking down of the western perimeter fence by the site owners
Other Site Features
Comments
Vandalism E Not evident D Indicated on map
Comments
Except for activities of site owners See Institutional Control (EPA ID ARD008052508) agreements signed by the site owners and photos of current utilization of the site by the site owners
Land Use Changes Offsite n Yes IE No n NA bull Evidence of deed restriction violation
Comments Note Currently active timber logging operation at the western perimeter of the site outside the fenceline
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Land Use Changes Offsite D Yes ^ No D NA
Comments
Adequacy of Engineering Maintenance The implementation and scope of maintenance procedures for the current and long-term protectiveness of the remedy are effective and functioning as designed ^ Yes n No
Comments
Soil cells are intact Security fence and gates are intact except where site owners open the main gate as well as taken down the wire nets at the western perimeter fence due to their current operations on and adjacent to the site Trees (mainly pine trees) on top and surrounding the main soil cell are growing
Early Indicators of Potential Remedy Problems Indicate issues andor observations such as unexpected changes in the cost or scope of maintenance or a high frequency of unscheduled repairs suggesting that the protectiveness of the remedy may be compromised in the future E Applicable D Not applicable
Comments
Continued growth of roots of maturing trees may continue to penetrate the soil cells and depending upon their root growths may create pathways to wastes contained in the soil cells Vegetation helps prevent erosion and maintain integrity of the soil cells and former impoundment areas
Opportunities for Improvement List alternatives for improvement in monitoring tasks or the operation of the remedy E Applicable D Not applicable
Comments
Previous Inspection Have all issues and problems frorh the previous inspection been resolved
E Yes IE No
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Comments
Yes on the monitoring wells since 1 ^ 5 Year Review Report and 2010 Groundwater Monitoring activity During the 19May 2011 site inspection the USEPA-ADEQ-USACE inspection team discovered the main gate open as well as some security issues on the western perimeter of the Popile site Security fences and gates are controlled by the site owners One site owner have the main gate open as well as another site owner have the wire nets at the western perimeter of the site taken down These site owners have signed deedrestrictions or Institutional Control documents with the US EPA
Appendix E Site Photos Gates and Security Perimeter Fence
bdquo 4gt^ i^gt^ -
Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Appendix E Site Photos Gates and Security Perimeter Fence
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Photo 1 Main gate to Popile site from S Fields Rd Main gate open when inspection team arrived at site 19 May 2011 facing south
Photo 2 Popile Superfund Site placard left (east) of main gate 19 May 2011 far inn sniith facing south
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 3 Popile Superfund Site placard right (west) of main gate 19 May 2011 facing south ^
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Photo 4 Popile Superfund Site western perimeter security fence 19 May 2011 facing northeast taken from timberlogging facility (El Ark Industries Inc)
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 5 Popile Superfund Site western perimeter security fence 19 May 2011 facing east taken from timberlogging facility (El Ark Industries Inc)
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Photo 6 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
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Photo 7 Popile Superfund Site western perimeter security fence 19 May 2011 facing southeast taken from timberlogging facility (El Ark Industries Inc)
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Photo 8 Popile Superfund Site eastern perimeter security fence 19 May 2011 facing northeast taken from inside Popile site
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
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Photo 9 Popile Superfund Site southern perimeter security fence 19 May 2011 facing south taken from inside Popile site Note active timber logging activity (and equipment) across the fence
Photo 10 Popile Superfund Site southern-western corner of penmeter security fence 19 May 2011 facing southeast taken from inside Popile site Note active timber logging activity (and equipment) across the fence and start absence of wire net
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 11 Popile Superfund Site southwestern perimeter security fence 19 May 2011 facing north and west taken from inside Popile site Note active timber logging activity (and employees pick-up trucks) and absence of wire net across the fence
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
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Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
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Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 12 Popile Superfund Site western perimeter security fence 19 May 2011 facing north-and west taken from inside Popile site Note active timber logging activity (and equipment) and absence of wire net across the fence
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Erosion Condition and Vegetation
Photo 14 Close-up of eroded area near small soil cell located northeast of Popile site 19 May 2011
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 15 Former impoundment area looking south at main soil cell 19 May 2011 note grass vegetation on former impoundment areas (foreground) as well as trees on top of main soil cell (background)
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 16 Looking north at main soil cell (left half of photo) and monitoring wells (right half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (right half of photo) as well as trees on top of main soil cell (left portion of photo)
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
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Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
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Photo 17 Looking south at main soil cell (right half of photo) and monitoring area (left half of photo) near the eastern perimeter fence 19 May 2011 Note grass vegetation on monitoring area (left half of photo) as well as trees on top of main soil cell (right portion of photo)
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Monitoring Wells
Photo 18 Looking north at upgradient monitoring wells (MW 24 and MW-25) near the western perimeter fence 19 May 2011 Note locks on side and labels on top of vault box
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 19 Looking south at upgradient monitoring wells (MW-8 and MW-9) near the western perimeter fence 19 May 2011
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 20 Looking north at monitoring wells (MW 29 MW-30 and MW-31) near the eastern perimeter fence 19 May 2011 Wells located southeast of former impoundment areas
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
i
Photo 21 Looking north at monitoring well MW-27 near former impoundment area (source) and the eastern perimeter fence 19 May 2011 Well located northeast of former impoundment areas
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 22 Monitoring well PZ-02 (downgradient) near the eastern perimeter fence across railroad track 19 May 2011 Well located northeast of former impoundment areas
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Additional Site Photographs
yengtbull V- CiS^f^^ -f^f e-ltj-_- laquo
Photo 23 Former impoundment area looking north Eastern perimeter fence and railroad track towards the right of photo 19 May 2011 Note heavy equipment stored near and along eastern perimeter of fence at Popile Site
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 24 Former impoundment area looking south Eastern perimeter fence and railroad track towards the left of photo 19 May 2011 Note heavy equipment
Photo 25 Close-up on one heavy equipment in Photo 23 amp 24 looking southeast
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 26 Close-up of Photo 25 Note deteriorating batteries
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
- ^ - ^ pound ^ bull ^ 5 ^ - ^ ^
Photo 27 Looking west at the Popile site (towards former impoundment areas background) from across the railroad track 19 May 2011 Access thru locked gate at eastern perimeter fence (background)
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
f r
Photo 28 Looking south at railroad tracks Right side of photo is the main soil cell inside the eastern security perimeter fence On the left side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Photo 29 Looking north at railroad tracks Left side of photo is the former impoundment area inside the eastern security perimeter fence On the right side of photo are downgradient monitoring wells and Bayou De Loutre 19 May 2011 Access thru locked gate at eastern perimeter fence ( on left of photo)
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Appendix F List of Documents Reviewed
Amended Record of Decision September 2001 - EPA Region 6
Technical Impractibility Waiver September 2001 - EPA Region 6
Phase II Groundwater Study and Modeling Investigation 1998 - Morrison Knudsen
Groundwater Model Study of Natural Attenuation 1999 - Morrison Knudsen
Sampling and Analysis Plan for Post-Groundwater Modeling Parameter Confirmation Popile Inc Superfund Site El Dorado Arkansas September 1999 - Morrison Knudsen
Final Work Plans Addenda and EM Plan December 2003 - MMG
Interim Groundwater Report Groundwater Monitoring Program February 2004 - MMG
bull Final Groundwater Summary Report - Year One Groundwater Monitoring Program January 2005 - MMG
Final Groundwater Summary Report - Year Two Groundwater Monitoring Program July 2005-MMG
Final Groundwater Summary Report - Year 3 Groundwater Monitoring Program July 2006 - MMG
Site Inspection Report February 2004 - MMG
Final Site Repair Activities Report November 2004 - MMG
Site Inspection Report- Year 2 May 2005 - MMG
Site Inspection Repairs Report- Year June 2006 - MMG
First Five-Year Review for Popile Inc Site Union County El Dorado Arkansas US EPA Region 6 Dallas Texas September 2006
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 2936 acres - El Ark Industries Inc April 142008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 Tract 3 - Great Lakes Chemical Corporation June 2 2008
Institutional Control Documents EPA ID008052508 110^ Congressional District 4 73 acres - El Dorado Timber Co Inc March 18 2008
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-
Institutional Control Documents EPA IE008052508 100^ Congressional District 4 City of El Dorado Tract 1 and City of El Dorado Tract 2 - City of El Dorado June 13 2008
Final Reports - GW Summary and Site Inspection Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas January 2011 - SPA-MMG
Final Groundwater Summary Report Addendum Groundwater Monitoring - 2010 Popile Inc Superfund Site El Dorado Arkansas February 2011 - SPA-MMG
Compound Specific Isotope Analysis Revealing Natures Evidence httpwwwmicroseepscomhtmlcsiahtml accessed June 3 2011 ~ Microseeps Inc 220 William Pitt Way Pittsburgh PA 15238
A Guide for Assessing Biodegradation and Source Identification of Organic Ground Water Contaminants using Compound Specific Isotope Analysis (CSIA) EPA 600R-08148 December 2008 httpwwwepagovnrmrlpubs600r08148600r08148pdf accessed June 3 2011-USEPAADA
- Appendix A Site Maps (Location Secondary Cap GW Model Plumes) and Institutional Control Agreements
- Appendix B El Dorado Times Public Announcement (4202011)
- Appendix C Interview Documentation
- Appendix D Site Inspection Checklist
- Appendix E Site Photos
- Appendix F List of Documents Reviewed
-