Five-Year Review Report
Ace Services Site Colby, Thomas County, Kansas
September 2008
United States Environmental Protection Agency Region 7 Kansas City, Kansas
With assistance from
United States Army Corps of Engineers Kansas City District
Approved by: Date:
i(a, Direct Superfund Division 30021044 U.S. EPA Region 7
Superfund ACO SERVICES SITE FIVE-YEAR REVIEW REPORT Executive Summary
A Five-Year Review has been completed at the Ace Services Site (Site) in Colby, Kansas. This is the first Five-Year Review at the Site.
The Site is located near the edge of Colby, Kansas, at 500 East Fourth Street in Thomas County. The surrounding area is primarily light industrial and commercial, although there are a few residences within two blocks. The hexavalent-chromium (Cr(VI)) groundwater plume originates in the general area of the former Ace Services business and originally extended approximately 1.5 miles east-southeast. The width of the plume varied from 500 to 1000 feet. There are also residential areas overlying the plume.
Northwest Manufacturing Company operated a plating facility at the Site from 1954 to 1969. Ace Services was formed in 1969 and operated a chromium electroplating operation at the Site through 1989. The Kansas Department of Health and Environment (KDHE) first began an investigation into improper plating waste management practices by Ace Services in 1971. In 1975 a Wastewater Treatment facility (WWT) was erected on the east side of the plating building. Plating waste was subsequently treated in the WWT and discharged to an unlined evaporation lagoon to the east of the plating building.
In 1980 elevated chromium levels were detected in Colby, Kansas Public Water Supply (PWS) well PWS-8 located about one-fourth mile east of the Ace Site and in other nearby private wells. PWS-8 was removed from service. During a follow up investigation KDHE again observed improper waste handling practices. Additionally, lead and chromium contamination was found in the lagoon soil. Ace Services contracted with Zerr Engineering of Colby, Kansas, for the excavation of 500 to 1,000 cubic yards of contaminated soil from the lagoon area.
The Ace Site was added to the National Priority List (NPL) in September 1995. The Record of Decision (ROD) was signed in May 1999 and amended in September 2001. The remedy in the ROD requires remediation of the chromium grouiidwater plume to the maximum contaminant level (40 CFR 141 62) of 100 ug/1 total chromium. Although the 1999 ROD and 2001
ES-2 ACIE SERVICES SITE HVE-YEAR REVIEW REPORT Amended ROD are silent with respect to Operable Units (OU), Site work was divided into two OUs: OU 1, Buildings/Soil, and OU2, Groundwater.
OU1. consisted of the first phase of cleanup at the Site and included cleaning and scarification of the floor surfaces in the plating and machine shop buildings as well as debris removal from inside and outside the buildings. Testing of the building interior surfaces showed that decontamination met the standards specified in the ROD. These buildings were later demolished during OU2 to make room for the larger groundwater treatment equipment necessitated by the larger contamination plume.
OU2 consisted of two phases of cleanup at the Site. The first phase for OU2 included demolition and removal of the existing plating and machine shop buildings and removal of contaminated soils. During the demolition, much more contamination,, than was originally anticipated, was discovered in the concrete foundations of the building and in the soil beneath the plating shop. This soil was removed as deep as could be excavated (about 15 feet below present grade), and the excavation backfilled with clean soil. One area of the excavation did not meet the cleanup standards set in the ROD, but the U.S. Environmental Protection Agency (EPA) determined that the depth of the remaining contamination prevented exposure. The building slab over this area was considered to act as a cap to prevent precipitation or infiltration from causing further migration of the contamination due to leaching through the soils to the groundwater. The second phase of OU2 included construction of a new groundwater extraction and treatment system utilizing ion exchange to remove chromium from the extracted groundwater with discharge limits of 17 ug/1 hexavalent and 100 ug/1 total chromium and a groundwater cleanup level of 100 ug/L total chromium. In addition, KDHE offered hook up to the City water system to private wells within or near the plume during OU2 Site work.
The treatment facility was built and began operating on August 12, 2003. It has operated nearly continuously since that time except for a one week period in October 2003 when KDHE discovered that 1,2-DCA contamination from the High Plains cooperative association (COOP) plume was found in extraction wells EX-1I, EX-2I, and PWS-8. Extraction wells EX-1, EX-2,
ES-3 ACE SERVICES SITE FIVE-YEAR REVIEW REPORT and PWS-8 remained offline until the High Plains COOP installed a granular activated carbon (GAC) system to remove the volatile organic compounds prior to entering the Ace Service treatment system. All wells were brought back into operation on August 24, 2004. The addition of the GAC system has had little impact on the operation of the Site treatment system except for the more frequent need to change out the bag filters which become clogged with carbon fines shortly after, a carbon change out occurs and the additional pumping pressure needed to move water through the entire treatment system including the GAC.
The Site groundwater extraction and treatment system is operated by the City of Colby, Kansas, through an agreement with EPA Region 7. The City staff has done an excellent job operating and maintaining the system. The treatment system has provided approximately 50 percent of the demand for potable water to the City of Colby, Kansas (the City). Black and Veatch Special Projects Corporation performs operational oversight and periodic evaluation of both the extraction and treatment system performance. Adjustments to the system are made as needed to maximize capture of the plume. Since August 2003, the extraction system has reduced the size of the total chromium plume exceeding 100 ug/L by over 90 percent. The treatment system has effectively removed chromium from the extracted groundwater, with no chromium exceedances in effluent discharge to the Prairie Dog Creek or to the City drinking water system. A total of approximately 1.488 billion gallons of groundwater water have been treated by the Site groundwater treatment system since inception. A total of 1,231.56 kilograms of chromium have been removed during treatment. The City has beneficially reused approximately 0.994 billion gallons of the treated groundwater in their potable water supply system.
Exposure pathways have been effectively eliminated through hook up of private wells to the City water system and a City enforced permit requirement for installation of any future wells. The Site property is zoned light industrial. The ROD called for a deed restriction on the Site property which has not yet been implemented due to historical ownership concerns related to multiple trusts. This does not present a protectiveness issue while the treatment facility is operation. Due to fluctuating monitoring results near the Site building, there is an investigation being planned to
ES-4 ACE SERVICES SITE FIVE-YEAR REVIEW REPORT determine if source material remains that may contribute to groundwater contamination in the future.
The remedy at the Site currently protects human health and the environment because exposure pathways to groundwater have been removed through hook up of private wells to the City water system, an institutional control in the form of a permit requirement for installation of new wells, and the Site property zoned as light industrial. The groundwater contaminant plume has been reduced by greater than 90 percent of its original extent within a period of live years.
ES-5 ACE SERVICES SITE nVE-YEAR REVIEW REPORT Table of Contents
Section
Executive Summary ES-2 List of Abbreviations iv Five-Years Review Summary Form ; vi
1.0 Introduction 1 2.0 Site Chronology 3 3.0 Background 4 3.1 Physical Characteristics 4 3.2 Land and Resource Use 4 3.3 History of Contamination and Enforcement Activities 5 3.4 Basis for Response Action , 7 4.0 Remedial Actions : 8 4.1 Remedy Objectives 8 4.2 Remedy Selection 9 4.3 Remedy Implementation 10 4.4 Operational and Functional Activities 16 5.0 Progress Since Last Review 19 6.0 Five-Year Review Process 20 6.1 Administrative Components 20 6.2 Community Involvement 20 6.3 Document Review 20 6.4 Data Review 21 6.5 Site Inspection 23 6.6 Interviews 25 7.0 Technical Assessment : 26 7.1 Question A 26 7.2 Question B 31 7.3 Question C 35 7.4 Technical Assessment Summary 36 8.0 Issues 37 9.0 Recommendations and Follow-up Actions 38 10.0 Protectiveness Statement : 39 11.0 Next Review : 41 ACE SERVICES SITE I-'IVL-YEAR REVIEW REPORT Figures Figure 1: Site Location Figure 2: Total Chromium Isoconcentration Contour Map - Shallow Zone Figure 3: Total Chromium Isoconcentration Contour Map- Intermediate Zone Figure 4: Total Chromium Isoconcentration Contour Map - Deep Zone Figure .5: Vertical Groundwater Flow Lines
Attachments Attachment A: Monitoring Data Summary Tables and Trend Plots Attachment B: Site Inspection Checklist Attachment C: Site Inspection Photographs
in AC!.: SERVICES SITE FIVE-YEAR REVIEW REPORT List of Abbreviations
ARARs Applicable or Relevant and Appropriate Requirements ARW Ace Recovery Well AWQC Ambient Water Quality Criteria BRA Baseline Risk Assessment BVSPC Black & Veatch Special Projects Corp. CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COOP Cooperative Association Cr chromium Cr(lII) trivalent chromium Cr(VI) hexavalent chromium E&E Ecology and Environment EPA U.S. Environmental Protection Agency EX extraction well Fe(II) ferrous iron Fe(lll) ferric iron GAC granular activated carbon gpm gallons per minute GWTP Groundwater Treatment Plant GWTS Groundwater Treatment System HOPE High Density Polyethylene HI Hazard Index KDHE Kansas Department of Health and Environment KS Kansas MCL maximum contaminant level MCLG maximum contaminant level goal mg/kg milligram per kilogram mg/L milligrams per liter msl mean sea level MW monitoring well NAWQC National Ambient Water Quality NCP National Contingency Plan NPL National Priority List O&M operation and maintenance PLC programmable logic controller POTW Publicly Owned Treatment Works PRO Preliminary Remediation Goal PWS public water supply RA Remedial Action RCRA Resource Conservation and Recovery Act RI Remedial Investigation RID Reference Doses RPM Remedial Project Manager
IV ACE SERVICES SITE I:IVE-YEAR REVIEW REPORT ROD Record of Decision RSE Remedial System Evaluation RTU Remote Terminal Unit SARA Superfund Amendments and Reauthorization Act TCLP Toxicity Characteristics Leaching Procedure (jg/L micrograms per liter USAGE U.S. Army Corps of Engineers VOCs Volatile Organic Compounds WWT Wastewater Treatment XRF X-ray Fluorescence ACBSI-RVICI.-SSIT1: l:lVi;-YEAR REVIEW REI'OKT Five-Year Review Summary Form
SITE\\LDEtiTlFlCATION\ \ Site name (from WasteLAN): Ace Services Site EPA ID (from WasteLAN}'. KSD046746731 Region: 7 State: KS City/County: Colby/Thomas }SITE\\S\TA\TUS i^^HMMUUK^Mac^BBW^^ft^H^^^^MH^BMMaMBiH^^HH^^^^^^^^^^^^^^^^^BBa NPL status: V Final —D Delete__ __ d D— Othe_ r \(specify r — j /) Remediation status (choose all that apply): D Under Construction V Operating D Complete Construction completion date: _09 / 22 / 2003 Site Wide FYR V YES D NO Has Site been put into reuse? D YES V NO \REVIE\WSTkTm Lead agency: V EPA D State D Tribe D Other Federal Agency Author name: Rob Weber Author title: Remedial Project Manager | Author affiliation: U.S. EPA Region 7 Review period: 09 / 22 / 2003 to 09 / 227 2008 Date(s) of Site inspection: JJ./29_/_2007 and 04/22-23/2008 Type of review: ~v Statutory D Policy V Post-SARA D Pre-SARA D NPL-Removal only D Non-NPL Remedial Action Site D NPL State/Tribe-lead D Regional Discretion _ Review number: vl (first) D 2 (second) D 3 (third) D Other (specify) Triggering action: D Actual RA On-site Construction at OU #_ D Actual RA Start "V Construction Completion D Previous Five-Year Review Report D Other (specify) Triggering action date (from WasteLAN): 09 / 22 / 2003 (PCOR) Due date (fiveyears after triggering action date): _J)9 / _22 / _2008 Issues:
1. Trcntmcni plant Audil Reports do not address results of effluent discharge to the tributary to Prairie Dog Creek and City Drinking Water System
2. Source area soils may have a potential to continue contributing to the grounclwalcr contaminant plume.
3. The ROD calls for placement of deed restrictions to prevent future use of contaminated groundwatcr, lo prevent residential use of the Site and buildings, and lo prevent removal of floors and soils beneath the building. These deed restrictions have not been .implemented to date due lo historical ownership concerns related lo multiple trusts.
VI ACE SERVICES SITE FIVE-YEAR REVIEW REPORT
Recommendations and l-'ullow-un Actions: 1. Add section lo Aiulil Report addressing results of discharges to irihulary Prairie Dog Creek and City Drinking Waicr System. 2. Based on recoinmendiitions from a Remediation Systems Evaluation, a source area investigation will he conducted lo determine the nature of contamination in source area soils and if the potential exists I'or the contaminants in these soils to leach lo groundwalcr. Remediation system enhancements may he considered hascd on the results oflhc soil investigation. 3. The ahscnce of a deed restriction docs not present a current protectivcness issue due lo the operation of the groundwaler treatment plant on-sile. Institutional controls have hccn implemented for the Site through public education and warnings about use ol the groundwaler in (he plume area. The City also has implemented a permit system which limils new wells in the City. The City has y.oncd the Site as light industrial Future use of ihe
Site is expected lo remain commercial or industrial, and future use oflhc Sile facility will he lo house Ihe treatment plant at Icasl for the duration of Ihc remedial action. An investigation is planned lo determine if there are still residual source materials on the Site property contributing lo the groundwater contamination. A future determination during the next Five-Year Review will be made to assess whether or nol a deed restriction can be implemented without disruption of the treatment system.
Protectivcness Slalcmciil(s):
Operable Unil I The remedy at OLJ1 is protective of human health and the environment The metal and plating shop buildings and associated foundations remedy included scarificalion of Ihe floor surfaces in Ihc plating and machine shop buildings as well as debris removal from inside and outside the buildings. OUI actions were conducted in accordance with Sile decision documents. The exposure pathways, the Site buildings, for this OU no longer exist and were removed as part of the OU2 activilics.
Operable Unit 2 The remedy at OU2 currently protects human health and Ihc environment. The metal and plating shop buildings and foundations were removed. Soils beneath these structures were excavated lo a dcplh of 15 feel below grade. A new groundwater treatment building was constructed above the residual soils, will serve as a cap. and will remain for at Icasl Ihc duration of the remedial action. The lagoon area surface soils were excavated and clean fill was placed on the surface of the Sile. The groundwalcr contaminant plume has been reduced lo greater than 90 percent of its original extent. Downgradicnt private well receptors have been provided an alternate water supply and Ihc remaining private wells arc periodically monitored.
However, in order for the remedy lo be protective in the long-term, the following actions will need to he taken lo ensure long-term proteclivcncss. An investigation is planned lo determine if there are residual source materials on Ihc Site properly lhal arc contributing to Ihc groundwater contamination. The results of the investigation may lead to additional investigations and/or Site remediation system enhancements. An evaluation during Ihe next Five-Year Review period will be made to assess whether or not a deed restriction can be implemented without disruption of the treatmenl system. The absence of a deed restriction docs nol present a current prolcclivcncss issue due to the operation of (he groundwalcr treatment plant on-site. Institutional controls have been implemented for Ihe Sile through public education and warnings aboul use of Ihe groundwater in the plume area. The City also has implemented a permil system which limils new wells in Ihc Cily. The Cily has zoned Ihc Sile as lighl industrial. Future use of (he Sile is expected lo remain commercial or industrial, and future use of the Sile facility will be lo house Ihe treatment plant at Icasl for Ihc duration of Ihc remedial action.
Because the remedial actions at all OUs arc protective, the Site is protective ofhuman health and the environment.
Other Comments:
Nol applicable
Vll ACE SERVICES SITE r-TVE-YEAR REVIEW REPORT 1.0 Introduction
The purpose of Five-Year Review is to determine whether the remedy at a Site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identity issues found during the review, if any, and recommendations to address them.
The United States Environmental Protection Agency (EPA) is preparing this Five-Year Review pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) section 121(c) and the National Contingency Plan (NCP). CERCLA § 121(c) 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 5 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.
EPA interpreted this requirement further in the NCP; 40 CFR § 300.430(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.
EPA Region 7 has conducted a Five-Year Review of the remedial actions implemented at the Site in Thomas County, Kansas. This review was conducted from December 2007 through September 2008. This report documents the results of the review. ACI-SERVICES SITE HVE-YEAR REVIEW REPORT This is the first Five-Year Review for the Site. The triggering action for this review is the date of the preliminary closeout report for the groundwater extraction and treatment system in September 2003. The Five-Year Review is required due to the fact that chromium contamination remains on-site above levels that allow for unlimited use and unrestricted exposure. ACE SERVICES SITE I-IVE-YEAR REVIEW REPORT 2.Q Site Chronology
A chronology of significant Site events and dates are included in Table Table 1: Chronology of Site Events COMPLETION EVENT DATE Discovery 08/01/1980 Preliminary Assessment .10/01/1982 Site Inspection 11/06/1982 Preliminary Assessment 09/28/1989 Site Inspection 09/28/1989 Aerial Survey 04/18/1990 Expanded Site Inspection 11/27/1991 NonNational Priorities List Potentially Responsible Party Search 09/08/1992 Removal Assessment 10/15/1993 Hazard Ranking System Package 05/06/1994 Information Repository Established 07/08/1994 Removal Action - Soil Building Surface Decontamination 07/14/1994 Listing on National Priorities List 09/29/1995 Remedial Investigation/Feasibility Study 05/05/1999 Record of Decision 05/05/1999 Remedial .Design 08/1999 Remedial Action - Building Decontamination 02/04/2000 Record of Decision Amendment 09/13/2001 Remedial Design - Groundwater Pump and Treat 01/09/2002 Remedial Action - Building Demolition 4/30/2002 Remedial Action - Groundwater Treatment Plant Operational 08/12/2003 and Functional Interim Remedial Action Report 09/19/2003 Preliminary Close-Out Report 09/22/2003 Long-Term Response Action Ongoing
3 - ACE SERVICES SITE I:IVI:-Y'EAI< REVIEW REPORT 3.0 Background
3.1 Physical Characteristics
The Site is located near the edge of Colby, Kansas, at 500 East Fourth Street in Thomas County (Figure 1). The geographic coordinates for the Site are approximately 100°02'10" West Longitude and 39°23'47" North Latitude. The Site lies in the southwest quarter of section 31, Township 7 South, Range 33-West. The facility is next to a small church and a hardware store. The Thomas County courthouse is approximately two and one-half blocks west of the Site. The surrounding area is primarily light industrial and commercial, although there are a few residences within two blocks.
Prior to the start of the remedy, a hexavalent-chromium (Cr(VI) groundwater plume originated in the general area of the former Ace Services business and extended approximately one and one- half miles east-southeast. The width of the plume varied from 500 to 1,000 feet. The northern plume boundary was approximated by U.S. Highway 24, and the leading edge is just east of the City boundary along Highway 24. These Site boundaries are based on the maximum extent of the 100 micrograms per liter (ug/L) total-chromium isoconcentration line. Remedial activities have significantly reduced the extent of the chromium plume to isolated areas that continue to exceed the action-level of 100 ug/L total chromium (Cr(IlI)).
3.2 Land and Resource Use
At the time of the ROD, the Site was used as a storage facility and was surrounded by residential and commercial areas. Future use of the Site is to continue to be industrial or commercial. Comments presented by the community did not include concern for use of the Site as anything other than these uses. The remedy proposes institutional controls to prevent future use of the Site as residential.
The Ogallala aquifer below the Site is used as a primary potable water resource for the region, and specifically is a municipal source for Colby, Kansas, and for individual residences in the Site area that are not connected to the municipal water system of Colby, Kansas. A Colby, Kansas ACIF. SERVICES SITE irivi:-:-YEAR REVIEW REPORT municipal water supply well (PWS-8) has been contaminated and was taken out of service because of the contamination. The community has expressed a strong interest in being able to return the well to service in the near future.
3.3 History of Contamination and Enforcement Activities
Northwest Manufacturing Company operated a plating facility at the Site from 1954 to 1969. Ace Services was formed in 1969 and operated a chrome electroplating operation at the Site through 1989. The Site included two buildings, the plating shop building and an office/machine shop building. The plating building featured three concrete/cinder block troughs where vats of plating solution were located during operations. The Kansas Department of Health and Environment (KDHE) first began an 'investigation into improper plating waste management practices by Ace Services in 1971. In 1975 a wastewater treatment facility (WWT) was erected on the east side of the plating building. Plating waste was subsequently treated in the WWT and discharged to an unlined evaporation lagoon to the east of the plating building.
In 1980, elevated chromium levels were detected in Colby, Kansas Public Water Supply (PWS) well PWS-8 located about one-fourth mile east of the Site and in other nearby private wells. PWS-8 was removed from service. During a follow up investigation KDHE again observed improper waste handling practices. Additionally, lead and chromium contamination was found in the lagoon soil. In 1981, Ace Services contracted with Zerr Engineering of Colby, Kansas, for the excavation of 500 to 1,000 cubic yards of contaminated soil from the lagoon area.
In 1988 KDHE issued an Administrative Order requiring Ace Services to clean up the Site. Ace Services did not comply with that order. Ace Services terminated operations at the Site in 1989 after losing corporate status due to failure to pay taxes and fees.
In 1992, KDHE coordinated the removal of plating wastes from the plating shop building. Investigations undertaken as part of this removal determined that the floors and walls of the troughs were contaminated with lead and chromium. It was further determined that the ACE SERVICES SITE FIVE-YEAR REVIEW REPORT contamination may have migrated into the underlying soils. This assessment also found that elevated levels of lead and chromium were still present in the lagoon soils east of the WWT.
In 1994 EPA conducted a removal action to clean up the contaminated soils, concrete and structures at the Site. This action established clean up goals for soils of 1,500 mg/kg total chrome and 500 mg/kg total lead. The WWT was demolished and removed in this action. The walls and floors of the three plating troughs were removed and the underlying soils were excavated. Not all of the contaminated soils could be removed at that time due to concerns for undermining the building structure. Once the contaminated soils that could be accessed were removed, the trough excavations were backfilled with clean soil and topped with concrete level with the remaining floor slab in the building.
As part of the 1994 removal, an attempt was made to reduce the Cr(VI) in the surface layer of the concrete floor slab to less toxic Cr(III) by applying a sulfuric acid solution followed by sodium metabisulfite. The 1994 cleanup also included an assessment of the lagoon area which determined that there were soils contaminated in excess of the cleanup goals. Approximately 500 tons of soil were excavated from the lagoon and disposed of.
The Ace Site was added to the National Priority List (NPL) in September 1995. Sampling conducted in 1996 and 1999 indicated that areas of the plating shop floor slab surface were still contaminated. These areas were scarified (progressively ground down) removing approximately 1 -inch from the top of the concrete surface.
The Ogallala Aquifer underlies the area in and around Colby, Kansas. A portion of this aquifer has been contaminated with hexavalent chrome from releases at the Site. Extensive groundwater sampling was performed from 1980 through 2000 with much of the sampling being done between 1996 and 2000. The sampling efforts indicated that the chromium plume was approximately a mile long, one-fourth mile wide and 130 feet thick with the western edge of the plume beginning in the proximity of the Site. Concentrations of Cr(VI) in the plume ranged up to about 4.000 ug/L. The ROD required remediation of the groundwater chrome plume to the ACI- SI.-KVICES SITE RVli-YLAR REVIEW REPORT maximum contaminant level (40 CFR 141 62) of 100 |ig/L total chromium. The prescribed method of remediation was a pump and treat system utilizing ion exchange to remove chromium from the exlracted groundwater wii.li discharge limits of 17 ug/L hexavalent and 100 ug/L total chromium and a groundwater cleanup level of 100 ug/L.
3.4 Basis for Response Action
The baseline risk assessment estimates what risks the Site poses if no action were taken. It provides the basis for taking action and identifies the contaminants and exposure pathways that need to be addressed by the remedial action. Actual or threatened releases of hexavalent chromium from this Site, if not addressed by implementing the response action selected in this ROD, may present an imminent and substantial endangerment to public health, welfare, or the environment.
The evaluation of noncarciriogenic risks for current downgradient residents and future on-site and off-site residents through the groundwater exposure pathway resulted in hazard indices of 0.42 and 20.0, respectively. A hazard index calculated for a Site in excess of 1.0 indicates that potential adverse health effects may occur from exposure to the Site contaminants. For the Site, the hazard index exceeded 1.0 for future residents drinking and bathing in groundwater contaminated with hexavalent chromium. ACE SERVICES SITE HVE-YEAR REVIEW RI-I'OKT 4.0 Remedial Actions
4.1 Remedy Objectives
The primary focus of the remedial actions is to remediate the contaminated groundwater and on- Site building interiors, which are the major risks posed from the Site, and limit future use of the facility to industrial or commercial purposes.
Remedial action objectives developed for contaminated groundwater are to prevent ingestion, inhalation, or direct contact with groundwater having chromium concentrations in excess of current regulatory drinking water standards and to prevent further migration of chromium to prevent further degradation of natural resources.
Remedial action objectives developed for contaminated soil are to maintain prevention of exposure to soils having total chromium or lead concentrations in excess of current action levels and to prevent migration of chromium and lead that would result in groundwater contamination.
Remedial action objectives developed for the contaminated buildings are to prevent exposure to indoor air or interior dusts/concrete having total chromium, hexavalent chromium lead, arsenic, cadmium, manganese, or nickel concentrations in excess of industrial health-based screening levels and to prevent migration of chromium and lead that could result in groundwater contamination.
EPA has assumed that this facility will continue to be used for industrial or commercial purposes. The cleanup levels have been determined to allow future use of the facility as an industrial or commercial facility. The levels of contamination remaining on-site render the property unsuitable for other land uses, such as residential. Access restrictions would be implemented during remediation efforts to minimize exposure to humans. ACE SERVICES SITE riVE-YEAR REVIEW REPORT 4.2 Remedy Selection
The 1999 ROD concluded that the presence of lead in dust in on-site buildings and contamination on interior surfaces posed potential health concerns for industrial or commercial uses. The major components of the selected remedy for on-site buildings included the following:
• Institutional controls, as permitted by law, to prevent residential use of the Site and buildings and to prevent: removal of floors and soils beneath the building. • Removal of contaminated interior concrete surfaces by grit blasting. • Decontamination of building interiors by dusting, vacuuming, and wiping. • Disposal of decontamination debris as appropriate, if necessary at a Resource Conservation and Recovery Act (RCRA) facility.
The 1999 ROD also concluded that the presence of hexavalent chromium in the groundwater at the Site presents a threat to any future on-site or off-site resident users of groundwater. The major components of the selected remedy for groundwater include the following:
• Institutional controls including deed restrictions, as permitted by law, to prevent use of contaminated groundwaler. • Active restoration of the aquifer by pumping and treating the contaminated groundwaler. • Treatment of contaminated groundwater by electrochemical reduction and precipitation techniques. • Discharge of treated groundwater to the on-site tributary to Prairie Dog Creek. Alternatively and as appropriate, treated and untreated groundwater will be discharged to the local Colby, Kansas, publicly owned treatment works (POTW) and, at: the option of state and local authorities, the treated groundwater may be beneficially reused rather than discharged. • In situ bioremediation of contaminated groundwater is possible, as indicated by the results of treatability studies during design. • Groundwater monitoring and periodic review of results.
The 2001 Amended ROD addresses groundwater hexavalent chromium Cr(VI) contamination in the groundwater. Evaluation of soil data determined that removal actions performed at the Site have eliminated health concerns from exposure to contaminated surface soils at the Site. In addition, the buildings that had metals contamination on the interior surfaces have been demolished and removed from the Site. ACE SERVICES .SITE RVE-YEAR REVIEW REI'ORT The presence of Cr(VI) in the groundwater at the Site presented a threat to any future on-site or off-site residential users of groundwater. The major components of the selected remedy lor groundwater as outlined in the September 2001 Amended ROD (amendment to the May 1999 ROD) included the following:
• Institutional controls including deed restrictions, to the degree possible, to prevent use of contaminated groundwater. • Active restoration of the aquifer by pumping and treating the contaminated groundwater. • Treatment of contaminated groundwater by ion exchange. • Discharge of treated groundwater to the on-site tributary to Prairie Dog Creek. Alternatively and as appropriate, treated and untreated groundwater will be discharged to the local Colby, Kansas POTW and, at the option of state and local authorities, the treated groundwater may be beneficially reused rather than discharged. • Groundwater monitoring and periodic review of results. • Provision of City water supply hookups to owners of affected residential wells by a water main and installation of meters and house connections.
4.3 Remedy Implementation
Although the 1999 ROD and 200f Amended ROD are silent with respect to operable units (OU), the remedy was implemented in two OUs: OU1, Buildings/Soil, and OU2, Groundwater.
OU1 consisted of the first phase of cleanup at the Site and included cleaning and scarification of the floor surfaces in the plating and machine shop buildings as well as debris removal from inside and outside the buildings. Testing of the building interior surfaces showed that decontamination met the standards specified in the ROD. These buildings were later demolished during OU2 to make room for the larger groundwater treatment equipment necessitated by the larger contamination plume.
OU2 consisted of two phases of cleanup at the Site. The first phase for OU2 included demolition and removal of the existing plating and machine shop buildings and removal of contaminated soils. During the demolition, much more contamination was discovered in the concrete foundations of the building, and in the soil beneath the plating shop, than was originally anticipated. This soil was removed as deep as could be excavated (about 15 feet below present grade) and the excavation backfilled with clean soil. One area of the excavation did not meet the ACE SERVICES SITE riVE-YI-AK REVIEW KEI'QRT cleanup standards set in the ROD, but EPA determined that the depth of the remaining contamination prevented exposure. The building slab over this area was considered to act as a cap lo prevent precipitation or infiltration from causing further migration of the contamination due to leaching through the soils to the groundwater. The second phase of O.U2 included construction of a new groundwater extraction and treatment system utilizing ion exchange to remove chromium from the extracted groundwater with discharge limits of 17 u.g/L hexavalent and 100 ug/L total chromium and a groundwater cleanup level of 100 ug/L total chromium. In addition. KDHE offered hook up to the City water system to private wells within or near the plume during OU2 Site work.
A summary of how each of the components of the selected remedy was implemented at the Site based on the ROD and its amendment is provided below following each set of bulleted items:
• Removal of contaminated interior concrete surfaces by grit blasting. • Decontamination of building interiors by dusting, vacuuming, and wiping. • Disposal of decontamination debris as appropriate, if necessary at a Resource Conservation and Recovery Act (RCRA) facility.
On-site construction activities began on November 30, 1999, and the final inspection for the remedial action for building decontamination was completed on February 24, 2000. Hazardous debris were collected from the machine shop and plating shop buildings and from outside the building areas. The machine shop and plating shop surfaces were dusted, wiped, vacuumed, and/or scarified. Waste materials were recycled or disposed of in RCRA solid and hazardous waste facilities. These activities were documented in the Final Remedial Action Report:
Buildings (BVSPC, 2000). The metal shop and plating shop were demolished as part of the groundwater treatment system installation presented below:
Institutional controls, as permitted by law, to prevent residential use of the Site and buildings and to prevent removal of floors and soils beneath the building. Institutional controls including deed restrictions, to the degree possible, to prevent use of contaminated groundwater. ACI- SERVICES SITE FIVE-YEAR REVIEW REPORT
Institutional controls have been implemented for the Site through public education and warnings about use of the groundwater in the plume area. The City also has implemented a permit system which limits new wells in the City. The City has zoned the Site as light industrial. Future use of the Site is expected to remain commercial or industrial, and future use of the Site facility will be to house the treatment plant at least for the duration of the remedial action.
The 1999 ROD called for placement of deed restrictions to prevent .future use of contaminated groundwater, to prevent residential use of the Site and buildings, and to prevent removal of floors and soils beneath the building. These deed restrictions have not been implemented to date due to historical ownership concenis related to multiple trusts. This does not present a current protectiveness issue due to the operation of the groundwater treatment plant on-site. An investigation is planned to determine if there are still source areas on the Site property contributing to the groundwater contamination.
• Active restoration of the aquifer by pumping and treating the contaminated groundwater. • Treatment of contaminated groundwater by electrochemical reduction and precipitation techniques. • In situ bioremediation of contaminated groundwater is possible, as indicated by the results of treatability studies during design. • Treatment of contaminated groundwater by ion exchange.
Both the 1999 ROD and the 2001 Amended ROD envisioned active aquifer restoration through pump-and-treal. In the 2001 Amended ROD, an ion exchange treatment process was chosen in lieu of the electrochemical process described in the 1999 ROD. This option was selected because of the increased amounts of extracted groundwater to be treated, the reduction in expected average concentrations in that water, and the associated change in cost-effectiveness in favor of ion exchange. A component of the 1999 ROD was an option to consider in situ bioremediation to enhance remediation efforts in the groundwater. This was eliminated given that it was determined to interfere with the ion exchange treatment system by creating an anaerobic environment in the groundwater affecting the performance of the system and requiring an additional ion-exchange resin bed at significant additional cost. The benefits from the additional treatment did not justify the additional costs and performance reductions.
12 ACE SERVICES SITE I:IVI:;-YEAK REVIEW REPORT
Design of the pump and treat system as outlined in the 2001 Amended ROD was completed by BVSPC in January 2002. Prior to beginning construction, the existing machine shop, plating .shop, and underlying concrete slabs were demolished and removed. The demolition work also included removal of 1,000 cubic yards of soil contaminated with Cr(Vl) from around the former troughs and foundation piers in the plating shop. This portion of the remedy eliminated the concern for exposure to contaminants within the existing buildings. The demolition effort is documented in the Demolition Summary Report (BVSPC 2003a).
The groundwater treatment system (GWTS) consists of a groundwater extraction system and a treatment plant. The groundwater extraction system is comprised of a total of 13 extraction wells screened in shallow, intermediate, and deep zones of the aquifer. Twelve of the wells are new and one (PWS-8) is a former PWS well that was taken out of service due to chromium contamination. This well was retrofitted as an extraction well for the remediation system. The locations of the extraction wells were determined via computer flow modeling during the design phase to optimize control and capture of the chromium plume. Each well head is enclosed in a small heated and ventilated well house building. The well house also contains the motor control center, program logic control (PLC) remote terminal unit (RTU) cabinet, flow meter, modulating flow control valve, and all other piping, electrical, and control appurtenances for the well. Each well pumps into a buried HOPE pipeline system, which conveys the water to the influent storage tank at the groundwater treatment plant (GWTP). Each well is controlled from the PLC system in the main office at the GWTP via a fiber optic link.
The treatment plant is provided with two 250,000 gallon above-ground storage tanks. One tank stores raw groundwater from the extraction wells and the other stores treated water from the GWTP. The tanks provide about 4 hours of storage capacity to allow for flow balancing in the treatment system.
13 ACI- SERVICES S1TI- FIVE-YEAR REVIEW REPORT The GWTP uses an ion exchange system to remove hexavalent chrome from the extracted groundwater. The ion exchange system consists of two parallel process trains, each consisting of three ion exchange beds. Each bed is loaded with 560 cubic feet of Type II strong base anion exchange resin in chloride form. As water passes through the bed, the hexavalent chrome (as chromic acid) is exchanged for a chloride ion in the resin. Each three-bed train can be operated independently at any flow rate selected by the operator. The ion exchange system operates in a lead-lag configuration to provide full redundancy to assure that effluent quality is always met. In each train, contaminated groundwater flows through the lead bed where the chrome is removed. The water then flows through a lag bed, which serves as redundant backstop in case there is some chrome breakthrough from the lead bed. The third bed in each train is in standby. Water does not flow through the standby bed. When the resin in the lead bed becomes fully saturated with chrome, the beds are advanced so the lag bed goes into lead service and the formerly standby bed goes into lag service. The spent resin in the former lead bed is then removed and replaced with new virgin resin and that bed is placed in standby. Each process train is designed for a nominal flow of 250 gallons per minute (gpm) giving the plant a nominal capacity of 250 gpm if only one treatment train were to be operated. Final testing of the treatment system demonstrated that the actual capacity of the completed system is in excess of 1,100 gpm (BVSF'C 2003b).
A pair of raw water pumps (one per train) draws contaminated groundwater from the influent storage tank and pumps the water through a 5 micron filter then through the treatment train and out to the effluent storage tank. Back wash, air piimp, rinse, recycle, sluicing and transfer vessel systems are provided to facilitate resin management and transfer.
The treatment plant has large overhead doors at opposite sides which allow a full-sized 18 wheel tanker (ruck to park inside the building for resin transfers. This allows for the transfer of spent resin to a waste tanker and transfer of fresh resin from a tanker directly to the process vessels during any kind of weather and at any time of day.
14 ACT: SERVICES SITE FIVE-YEAR REVIEW REI'ORT The treated water effluent storage tank is provided with a dual out-fall. The initial planned primary means of discharge from the effluent tank was via a gravity discharge to the adjacent tributary to Prairie Dog Creek. Alternatively, a pair of treated water pumps are provided to pump the effluent tank directly into the City drinking water system as approved by KDHE. A chlorination system is provided to chlorinate water pumped to the City system.
The groundwater pump and treat system has been operating since August 2003.
• Discharge of treated groundwater to the on-site tributary to Prairie Dog Creek. Alternatively and as appropriate, treated and untreated groundwater will be discharged to the local Colby, Kansas POTW and, at the option of state and local authorities, the treated groundwater may be beneficially reused rather than discharged.
The groundwater pump and treat system started operation in August 2003. Treated water was discharged exclusively to the unnamed tributary to Prairie Dog Creek until June of 2005. In June 2005, after the system had proved effective at removing chromium to safe levels for human ingestion, discharge began to the City drinking water system. Since June 2005, the majority of discharges have been beneficially reused through discharge to the City drinking water system. A total of approximately 1.488 billion gallons of groundwater have been treated by the Site groundwater treatment system since; inception. A total of 1,231.56'kilograms of chromium have been removed during treatment. The City has beneficially reused approximately 0.994 billion gallons of the treated groundwater in their potable water supply system.
• Groundwater monitoring and periodic review of results.
A semi-annual groundwater monitoring program that includes sampling till wells has been established for the Site. This consists of sampling 48 monitoring wells, six observation wells, nine residential wells, the Ace Recovery Well (at three depth intervals), 12 extraction wells, and PWS-8 (the former PWS well). .The samples are analyzed for total chromium and field parameters including temperature, specific conductivity, pH, turbidity, dissolved oxygen, and oxidation-reduction potential. Monitoring wells are sampled using a conventional purge (three volumes or more) and sample method and extraction wells are sampled through a sample port. Laboratory analysis is provided by the Region 7 Laboratory.
15 ACT- SI-KVICIIS SITE FIVE-YEAK REVIEW REI'OKT
The results of the sampling events, and an evaluation of the performance of the extraction system in achieving cleanup of the groundwater, is provided in the Long-Term Response Action, Cleanup Status Reports submitted on a semi-annual basis as part of a contract with BVSPC.
• Provision of City water supply hookups to owners of affected residential wells by a water main and installation of meters and house connections
KDHE made public water available to residents with private wells located within or in proximity to the chromium plume. A majority of the residents with private wells chose to switch to public water thereby eliminating this potential exposure pathway. Although the residential wells have been discontinued for potable use, monitoring of these wells continues. Monitoring data indicates that all of the monitored wells have been below detectable levels of chromium since October 2006. Monitoring also showed there were no exceedances of the action level for chromium in the residential wells for the period covered by this Five-Year Review report.
4.4 Operational and Functional Activities
The treatment facility was built and began operating on August 12, 2003. It has operated nearly continuously since that time except for an occasional power outage or equipment breakdown. The longest shutdown occurred during a one week period in October 2003 when KDHE discovered that 1,2-DCA contamination from the High Plains COOP plume was found in wells EX-1I. EX-21, and PWS-8. After one week, the majority of the extraction system resumed operations. Extraction wells EX-1, EX-2, and PWS-8 remained off-line until the High Plains COOP installed a granular activated carbon (GAC) system to remove the volatile organic compounds (VOCs) prior to entering the Ace. Service treatment system. All extraction wells were brought back into operation on August 24, 2004. The addition of the GAC system has had little impact on the operation of the Ace treatment system except for the more frequent need to change out the bag filters which become clogged with carbon fines shortly after a carbon change out occurs.
Process monitoring is conducted twice daily (morning and afternoon) at three locations: plant influent, plant effluent, and the effluent to the City. In the morning, an additional seven ACI- SERVICES SITE riVI'-YCAR REVIEW REPORT samplings are collected: downstream of the influent tank, downstream of the bag filter BF-1, downstream of bag filter BF-2, downstream of ion exchange train A lead vessel, downstream of ion exchange train A lag vessel, downstream of ion exchange train B lead vessel, downstream of ion exchange train B lag vessel. All samples are analyzed for hexavalent chromium and pH. In addition, influent and effluent samples are analyzed for total chromium. The daily analysis of the samples is performed at the GWTP with a Hach kit. Once a week, the morning samples are split and sent to the independent laboratory contracted through an EPA cooperative agreement with the City.
As part of the EPA contract with BVSPC a Long-Term Response Action Audit is performed to monitor key plant operations and evaluate the plant operator's conformance to specified requirements for system operation. The audit addresses equipment and operations associated with both the extraction and treatment systems. The audits include a Site visit to observe the City operators and obtain key plant operating data. Any record-keeping deficiencies or needed repair and maintenance items are rioted along with recommended corrective actions. Findings and recommendations are summarized in reports on a. semi-annual basis (reduced from quarterly).
In addition to the audit reports, a Cleanup Status Report is also developed on a semi-annual basis (formerly quarterly). The purpose of this report is to evaluate the effectiveness of the extraction system in remediating the chromium plume. Based on findings from the evaluation, pumping rates are modified as necessary to capture the target plume as the target plume extent varies, as well as to avoid over pumping which increases the cost of treatment plant operation.
Table 2 below shows the annual operation and maintenance (O&M) costs for system operation over this Five-Year Review period:
17 ACE SERVICES SITE FIVE-YEAR REVIEW UEI'ORT Table 2: Annual System Operations/O&M Costs
Federal Fiscal Year(FY) Total Cost Estimate FY2003 $83,923.25 FY2004 $628,571.83 FY2005 $1,083, 197.08 FY2006 $1,295,435.76 FY2007 $995,993.70 FY2008 $746,079.40 (ongoing at the time of this (ongoing at the time of this report) report) AC1£ SERVICES SITE riV|--Y£AR REVIEW REPORT 5.0 Progress Since Last Review
This is the first Five-Year Review for the Site. During this Five-Year Review period, significant progress has been made at reducing the size of the chromium plume that exceeds the action level (100 ug/L total chromium). In all three aquifer zones, shallow, intermediate, and deep, the estimated area of the chromium plume exceeding the action level has been reduced by greater than 90 percent. See Figures 2, 3, and 4 comparing the limits of the chromium plume prior to the start of the remedy in April 2003 versus the limits as of the October 2007 monitoring event.
As pumping rates have been varied or select wells shut off due to reduced chromium concentrations or low regional groundwater level conditions, some rebound in concentrations has been experienced. When this occurs, adjustments are made to select extraction wells to ensure capture of the target plume.
Wells showing persistent concentrations above the action level are located nearest the source area. However, these wells are also showing a consistent downward trend over time.
An investigation is planned on the Ace Service property to determine if potential soil source materials remain that may still be contributing to groundwater contamination. This investigation will help determine if any additional actions are necessary to expedite and optimize the completion of the remedy.
19 ACE SERVICES SITE HVE-YEAR REVIEW REPORT 6.0 Five-Year Review Process
6.1 Administrative Components
The five-year review process was conducted by Rob Weber, EPA Region 7 remedial project manager (RPM) for the Site and supported by Jeremy Johnson. EPA Region 7 Toxicologist and Human Health Risk Assessor; Venessa Madden, EPA Region 7 Ecological Risk Assessor; Paul Speckin, U.S. Army Corps of Engineers (USAGE) Civil Engineer; and Chuck Williams, USAGE Hydrogeologist. The Five-Year Review began on September 11, 2007, with a review of the Site file.
6.2 Community Involvement
A tact sheet announcing the start of the first five-year review for the Ace Services Superfund Site in Colby, Kansas, was (1) faxed on November 30. 2007, to Senator Sam Brownback, Senator Pat Roberts, and Representative Jerry Moran. (2) placed on the Region 7 Website on November 30, 2007, and (3) mailed to the updated mailing list of 105 addresses on November 30, 2007.
A newspaper display advertisement announcing the start of the Five-Year Review was published in the Colby. Kansas Free Press on December 3, 2007.
6.3 Document Review
Documents reviewed as part of the Five-Year Review included the following:
• Baseline Risk Assessment, Groundwater, Soil, Dust, and Air (BVSPC, October 1998) • Remedial Investigation Report (BVSPC, October 1998) « Feasibility Study, (BVSPC, November 1998) « Record of Decision (USEPA. Region 7, May 1999) « Pump Test Results Memorandum (BVSPC, November 2000) • Final Remedial Action Report: Buildings (BVSPC, November 2000) • Groundwater Model Technical Memorandum (BVSPC, December 2000) • Groundwater Model Technical Memorandum Amendment (BVSPC, July 2001) « Amended Record of Decision (USEPA Region 7, September 2001) • Long-Term Response Action, Field Sampling Plan (BVSPC, August 2003) « Long-Term Response Action, Quality Assurance Project Plan (BVSPC, August 2003) • Remedial Action Report, Demolition Summary (BVSPC, September 2003)
20 ACI-snuvici-ssnt; FIVL-YEAR REVIEW REPORT
• Interim Remedial Action Report (BVSPC, September 2003) • Preliminary Close Out Report (USEPA Region 7, September 2003) • Remedial Action Report, (BVSPC, October 2003) • Long-Term Response Action, Semi-Annual Cleanup Status Report (BVSPC. January 2004) • Long-Term Response Action, Annual Cleanup Status Report (BVSPC. June 2004) • Final Construction Report - As Installed, Metzler Private Well Site (BE&K/TerraNext, June 2004) • Long-Term Response Action, Audit Reports No. 1 (BVSPC, November 2003) through No. 1 5 (BVSPC, November 2007) • Long-Term Response Action, Cleanup Status Report No. 3 (December 2004) through No. 9 (November 2007) • Quarterly Operation/Maintenance and Monitoring Report, Hi-Plains Coop and Granular Activated Carbon System (MILCO Environmental Services, Inc., March 2007) • Quarterly Operation/Maintenance and Monitoring Report, Hi-Plains Coop and Granular Activated Carbon System (MILCO Environmental Services, Inc., December 2007) • April 2008 Data Evaluation, (BVSPC, June 4, 2008) • Long-Term Response Action, Audit Report No. 16 (BVSPC, June 3, 2008)
6.4 Data Review
Treatment Plant Effluent
All daily effluent data sampling results were reviewed as part of the Five-Year Review. Effluent discharge, whether to the tributary to Prairie Dog Creek or to the City drinking water system, is sampled on a daily basis and tested using Hach test kits and a Hanna monitoring probe. These tests are accurate enough to provide an early indication of a possible problem with the system, but cannot be relied on to give the true concentration of effluent discharge. Samples collected on Wednesday of each week are split with one split sent to an off-site laboratory for analysis. Laboratory effluent sample results have all been nondetect for Cr(VI) with detection levels at 10 u,g/L. Total chromium is not sampled in the discharge since most, if not all, of the chromium at the Site is in the Cr(VI) form. The discharge limits for the Site are 17 u,g/L Cr(VI) and 100 u,g/L total chromium.
Grounchvatcr Monitoring Data
All groundwater monitoring data, from the beginning of the project in the 1980s through April 2008, was reviewed. However, the groundwater monitoring system did not reach its current configuration until 2003.
21 ACI-SERVICES SITE FIVE-YEAR REVIEW REPORT
Data summary tables and trend plots for monitoring data, collected from April 2003 through April 2008 are included in Attachment A.
Since the start up of the extraction system in August 2003, there has been a significant reduction in the a real extent of the plume exceeding the 100 ug/L total chromium action level. In each of the three aquifer zones, the area of the plume exceeding 100 ug/L has been reduced by over 90 percent. There have been occasional concentration fluctuations and spikes experienced in some monitoring and extraction wells, but in general, the chromium concentrations at all of the monitoring points has shown a significant downward trend. The results from the sampling events in April 2007, October 2007, and April 2008 show that the vast majority of monitoring results are at nondetect.
Performance of the system is periodically evaluated and adjustments to pumping rates are made to optimize capture of the plume. Below are three examples of how adjustments have been made to the system based on periodic evaluation of the sampling results.
After the start of the groundwater extraction system in August 2003, analytical data for the ACE Recovery Well (ARW) ARW-S and ARW-I wells showed a steady increase in chromium concentrations through the April 2005, sampling event. This well is located immediately downgradient of the former plating facility. The concentration increase was attributed to possible leaching from residual source material that remains in the subsurface of the former plating facility. To ensure capture of this plume, in April 2005 pumping rates were increased in extraction well EX-1I and EX-ID. Since that time there has been a significant decrease in the chromium concentrations in ARW-S and ARW-I, with the October 2007 results at nondetect. Increases in the ARW wells have been observed in the April 2008 sampling results, but none of the results were above the maximum contaminant level (MCL). Other downgradient wells in close proximity to the former plating facility, extraction well EX-1I and monitoring well MW-2I, have consistently been above the action level but have shown a consistent downward trend over time. In April 2007, there was a significant spike (553 ug/L) in concentration at monitoring well
22 ACE SERVICES SITE NVE-YEAK REVIEW REI'QKT MW-2S which is located near extraction well EX-1; however, this concentration was significantly reduced in the October 2007 sampling results (30 ug/L), and was nondetect in the April 2008 results.
Chromium concentrations in extraction wells EX-4S and EX-5S displayed a rebound in the October 2007 sampling event, after these extraction wells had been shut off for over two years. The pumping rate in extraction well EX-5I/D was increased from 100 gpm to 125 gpm to effect capture of the plume.
Based on the results of the April 2008 Data Evaluation (BVSPC, 2008) and the overall reduced chromium concentrations throughout the Site groundwater, extraction wells EX-2-I, EX-3-I, EX- 4-l/D have been taken offline and the pumping rate for extraction wells EX-5-I/D was decreased to the original planned pumping rate of 100 gpm. Total system flow of 295 gpin is being alternated every two weeks between treatment trains and will be reevaluated based on the sample results from the next semi-annual sampling event.
6.5 Site Inspection
A Site inspection was performed on November 29, 2007. The Site inspection checklist is included in Attachment B and photos taken during the Site inspection are included in Attachment C. The purpose of the Site inspection is to make an assessment of Site conditions and determine if the remedy is functioning as intended by the design documents.
The following individuals participated in the Site inspection: Rob Weber, EPA Region 7 RPM for the Site; Ashley Allen, KDHE project manager; Paul Speckin, USAGE; Chuck Williams, USAGE; and Jim Helus, treatment plant operator for the City.
The inspection consisted of a general question/answer session with the Five-Year Review team and Mr. Helus. Mr. Helus then provided a comprehensive tour of the treatment plant, including an overview of treatment system operations, procedures for resin change out, the daily and weekly sampling protocol, and personal computer based system controls. The O&M manual, as-
23 ACE SERVICES SITE RVE-YEAR REVIEW RETORT built drawings, sampling records, and maintenance records were all readily available at the Site. Access to the treatment plant is restricted by a door that remains locked when the facility is not occupied as well as an intrusion alarm system. The facility has not experienced any significant vandalism problems.
The plant, office, storage, and lab areas were clean and very well organized. Overall, the treatment plant was in very good condition, with no significant issues noted during the inspection. There was some minor rust on the treatment plant piping, apparently the result of persistent condensation during the hot summer months. This was identified in audit report No. 15 dated November 30, 2007, with a recommendation to prep and paint the piping during the winter when condensation was not an issue.
After the plant inspection, the team inspected each of the extraction well locations and nearby monitoring wells. Each extraction well, along with associated electrical components and valving. is housed within a locked shed. Each well and components was inspected and all appear to be in good condition. No signs of vandalism were apparent at any of the well locations. Access to extraction wells EX-3, EX-4, and EX-5 is via an unimproved road. There was significant rutting at a few locations along the road and it appeared it could become difficult to traverse during bad weather conditions. Project personnel indicated they had never experienced problems during their maintenance or monitoring activities. If conditions worsen, it may be necessary to fill the ruts with gravel or have a road grader even out the road.
In addition to the above Site inspection, Rob Weber, the EPA Region 7 RPM for the Site, conducted a Site visit on April 22 and 23, 2008, during semi-annual sampling activities to confirm that Site waste documentation was in place with respect to spent resin transportation and disposal. A general review of the Site and vicinity was conducted and no significant changes were observed as compared to the November 29, 2007, Site inspection.
24 ACE SERVICES SITE I:1VI:-VEAR REVIEW REPORT 6.6 Interviews
Interviews were conducted on November 29, 2007, during the Site inspection. City personnel interviewed included the City manager, the groundwater treatment plant operator, the public utilities director, and the Site information technology manager. A general consensus from those interviewed at the City indicated that the system was operating well and no major concerns were expressed by the public or others. The reuse of the treated water as a potable water supply was mentioned by City personnel as beneficial to the City and its citizens. The water provided by the Site treatment system supplied approximately 50 percent of the demand for the City's potable water supply. Day-to-day operational issues were addressed with EPA and EPA's contractor, BVSPC.
25 ACT: SERVICES SITE RVE-YEAR REVIEW REI'ORT 7.0 Technical Assessment
The Five-Year Review must determine whether the remedy at a Site is protective of human health and the environment. EPA guidance describes three questions used to provide a framework for organizing and evaluating data and information and to ensure all relevant issues are considered when determining the protectiveness of a remedy. These questions are assessed for the Site in the following paragraphs. At the end of the section is a summary of the technical assessment.
7.1 Question A: Is the remedy functioning as intended by the decision documents?
Yes.
7.1.1 Remedial Action Performance
The groundwater extraction system is effectively capturing the chromium plume and has significantly reduced the size of the plume exceeding the 100 ug/L total chromium cleanup level. In comparison to the initial baseline total chromium isoconcentration in April 2003. the estimated limits of the plume exceeding 100 ug/L in April 2008 for each of the aquifer zones is as follows:
Zone April 2003 Approximate Plume Area April 2008 Approximate Plume Area Surface 60.4 acres 3.7 acres Intermediate 70.5 acres 4.2 acres Deep 88.9 acres 0 acres
There has been a greater than 90 percent reduction in the plume size for each of the aquifer zones. A graphical representation of the change in plume size is shown on Figures 2, 3., and 4 for the shallow, intermediate, and deep aquifer zones respectively. The solid isoconcentra.tions lines represent the extent of the plume as of April 2008. The dashed isoconcentration lines represent the extent of the plume in April 2003. Figure 5 presents the vertical groundwater flow lines at the Site. .
Groundwater monitoring is performed on a semi-annual basis and the data is evaluated for system performance and effectiveness. The sampling and evaluation is performed by BVSPC
26 ACE SERVICES SITE FIVE-YEAR REVIEW RI-I'ORT under contract to EPA Region 7. Based on the results of the monitoring, pumping rates for the extraction wells are adjusted as necessary in response to observed plume concentrations aquifer conditions and available well yield to capture the target plume.
A total of approximately 1.488 billion gallons of groimdwater have been treated by the Site groundwater treatment system since inception. A total of 1,231.56 kilograms of chromium have been removed during treatment. The City has beneficially reused approximately 0.994 billion gallons of the treated groundwater in its potable water supply system.
Continuing with the current operational procedures should maintain the effectiveness of the remedy, with the only question being when to shut down the system. The system is quickly approaching the point when influent concentrations will be below the total chromium action level. When the decision is made to discontinue operation of the system, ongoing confirmatory periodic sampling of the monitoring/extraction wells should continue to ensure no rebound of concentration that would necessitate re-starting the system.
7.1.2 System Operations and Maintenance
The groundwater extraction and treatment systems are operated and maintained by the City. BVSPC provides periodic oversight of both systems to evaluate and optimize the effectiveness of the groundwater extraction and to monitor key plant operations to ensure operator's contbrmance to specified requirements for system operation. Findings from this oversight are documented in a Long-Term Response Action Audit Report. These reports were generated on a quarterly basis up to the fourteenth Audit Report dated May 10, 2007. After the fourteenth report, frequency was reduced to semi-annual. The latest report reviewed as part of this Five-Year Review was dated June 3, 2008.
The audit reports provide a thorough evaluation of O&M of both the extraction well system and i groundwater treatment system. These reports vary from the Cleanup Status Reports that evaluate the effectiveness in remediating the groundwaler plume. The audits review system operation, maintenance records, monitoring records, and evaluate ways to optimize operations. Problems
27 ACE SERVICES SITE FIVE-YEAR REVIEW REPORT and anomalies regarding operation of the well Held and treatment system arc identified in each audit report along with recommendations to correct the problems. Plant personal have a good track record of following up and correcting problems in a timely manner.
The overall impression of the Five-Year Review team was that the system was well run and well maintained. Housekeeping was excellent and all required documents-O&M manual, as-built drawings, plant operation records, historical monitoring results, and maintenance logs-were all readily available at the Site.
One item noted was that effluent discharge results for water discharged to the Prairie Dog Creek and the City drinking water system, were not addressed in the audit reports. All effluent results between August 2003 (the startup of the treatment plant) through June 2008 were reviewed as part of this Five-Year Review. The results demonstrate the treatment plant has been effectively removing chromium to below the discharge standards. There have been no detected discharges to Prairie Dog Creek or the City drinking water system that have exceeded the discharge standards (17 ug/L hexavalent chromium and 100 ug/L total chromium). However, the primary purpose of the treatment plant is to remove the chromium contamination to levels that can be safely discharged. Therefore, it seems reasonable that achievement of this goal should be one of the items documented in the audit reports. It is recommended that discharge results be addressed in future audit reports.
7.1.3 Opportunities for Optimization
System optimization has been an ongoing process, with continual adjustment of pumping locations and rates to most efficiently reach remedial goals. Optimization of the treatment process has also been a continual fine-tuning exercise. Sampling frequency has been decreased where appropriate. A Remedial System Evaluation (RSE) was performed in April 2007 with a final report completed in September 2007. The RSE report made several recommendations to optimize operations and reduce costs. These recommendations were evaluated and implemented as appropriate. There were no additional opportunities for optimization identified as part of this Five-Year Review.
28 ACC:SERVICES SITE FIVE-YEAR REVIEW REPORT
7.1.4 Early Indicators of Potential Issues
Although equipment breakdowns have occasionally occurred, the problems are repaired in a timely manner. There have been no repair or maintenance issues that appear to have had a significant negative impact on the performance of the remedy.
During the RSE. the RSE team noted that there was an initial increase then a decrease in chromium concentrations at the ARW sampling locations. It was determined that this was the results of one of two causes: it either (1) represents the redistribution of existing groundwater contamination under a new pumping regime or (2) represents contaminant mass that leached from the soil to the groundwater and then migrated to the ARW location. There was no specific event that could be directly tied to this slug of contamination; however, demolition of the building and removal of source material below the building occurred approximately two years prior to this increase in concentrations. If a heavy rain event occurred during that time, it could have mobilized contaminants remaining in the soil below the building. The RSE report noted the estimated travel time from the source to the ARW sample location is two years, which may correlate with the time frame between demolition/soil removal and the increase in concentration.
It should also be noted that Ecology and Environment, Inc. (E&E) developed a report for a 1994 removal action consisting of general cleanup of Site plating shop and associated debris, cleanup of the former wastewater treatment building, stabilization and cleanup of the trough area in plating shop, and cleanup of lagoon area soils. During excavation of trough C, a thin layer with elevated Cr(Vl) concentrations was discovered. The thin layer had Cr(VI) concentrations of 19.000 mg/kg and total chromium concentrations of 27,000 mg/kg. 'Excavation in trough C extended to a depth of 20 feet. The report also identified the need to pump rainwater that had accumulated in trough C. The water was sampled and had chromium concentrations up to 6.0 mg/L.
29 ACE SERVICES SITE l:IVl-:-YEAR REVIEW REPORT In 2003. a Remedial Action Report - Demolition Summary (generated by Black & Veatch Special Projects Corporation for EPA) documented the demolition of the plating shop building, machine shop, and former gas station and excavation of Site soils in preparation for the installation of the new groundwater treatment plant building. The excavation activities occurred beneath the former Site plating shop building and in a former wastewater lagoon area near the plating shop building. Upon completion of the excavation in the area of the new planned groundwater treatment building, soils with up to 7.000 ± 940 parts per million of chromium based on x-ray fluorescence (XRF) readings were allowed to remain in place at a depth of 12 feet below original ground surface or 15 feet below current ground surface. Chromium at the base of the excavation exceeded its action level for toxicity characteristics leaching procedure (TCLP). The decision was made by EPA to allow the contamination to remain in place given that the depth of contamination was not accessible to excavation equipment and that the new treatment building and attending paved areas would effectively serve as a cap to the contamination. In the lagoon area, excavation occurred to a depth of approximately two feet below ground surface. Results indicate that chromium exceeded the action level in two locations and lead exceeded the action level in one location. Both chromium and lead samples from this area did not exceed their respective action levels for TCLP. Excavation of the lagoon area was stopped by EPA to allow for more excavation and disposal in the new treatment plant building area.
Based on these reports, it is likely that contamination remains in soil below the location of the former facilities. Whether or not it is acting as an ongoing source of groundwater contamination is unknown. EPA Region 7 is currently in the process of procuring a contract to perform additional investigation in these areas to determine if significant source material remains that may be contributing to groundwater contamination.
30 ACE SERVICES SITE FIVE-YEAR REVIEW REPORT 7.1.5 Implementation of Institutional Controls and Other Measures
Institutional controls have been implemented for the Site through public education and warnings about use of the groundwater in the plume area. The City also has in place a permit system which limits new wells in the City. The Site property is zoned as light industrial. Future use of the Site is expected to remain commercial or industrial, and future use of the Site facility will be to house the treatment plant at least for the duration of the remedial action.
The ROD calls for placement of deed restrictions to prevent future use of the Site for anything other than commercial or industrial. This deed restriction had not been implemented 1o date due to historical ownership concerns related to multiple trusts. This does not present a current protect! veness issue due to the operation of the groundwater treatment plant on-site.
7.2 Question B: Arc the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of the remedy selection still valid?
Yes.
7.2.1 Changes in Exposure Pathways
• Has land use or expected land use on or near the Site changed (e.g., industrial to residential, commercial to residential)?
Land use has not changed at or near the Site and any potential future land use changes have not been observed.
• Have any human health or ecological routes of exposure or receptors changed or been newly identified (e.g., dermal contact where none previously existed, new populations or species identified ori-site or near the Site) that could affect the protectiveness of the remedy?
No new exposure pathways have been identified that would affect the protectiveness of the remedy. Also, as noted previously, exposure scenarios involving contact with residual contamination in the plating buildings are no longer valid as the buildings have been removed. KDHE made public water available to residents with private wells located within or in proximity to the chromium plume. A majority of the resjdents with private wells chose to switch to public water thereby eliminating this potential exposure pathway. Although the residential wells have
31 ACE SERVICES SITE FIVE-YEAR REVIEW REPORT been discontinued for potable use, monitoring of these wells continues. Monitoring data indicates that all of the monitored residential wells have been below detectable levels of chromium since October 2006. There have been no exceedances of the MCLs in the residential wells in the last five years. No other changes to previously identified receptors and routes of exposure have been identified that would affect the protectiveness of the remedy.
• Are there newly identified contaminants or contaminant sources?
The available data do not demonstrate new contaminants or contaminant sources. The EPA is conducting a source area investigation to determine if residual source materials remain that may contribute to groundwater contamination.
« Are there unanticipated toxic byproducts of the remedy not previously addressed by the decision documents (e.g., byproducts not evaluated at the time of remedy selection)?
No unanticipated toxic byproducts of the remedy have been identified.
« Have physical Site conditions (e.g., changes in anticipated direction or rate of groundwater flow) or the understanding of these conditions (e.g.. changes in anticipated direction or rate of groundwater How) changed in a way that could affect the protectiveness of the remedy?
In October 2003, it was discovered that extraction wells EX-1I, EX-2I, and PWS-8 were contaminated with VOCs from a petroleum plume originating at the High Plains COOP, located upgradient of the Site. It was necessary to shut down extraction wells EX-1, EX-2, and PWS-8 until a GAC system was put in place to pre-treat the VOC contaminated groundwater prior to entering the Site treatment plant. Extraction wells EX-1, EX-2, and PWS-8 returned to service in August 2004. This delayed full implementation of the remedy but has not had a long-term impact affecting the protectiveness of the remedy. No other physical site conditions have changed affecting the protectiveness of the remedy.
7.2.2 Changes in Standards, Newly Promulgated Standards, To Be Considereds
« Have there been changes to risk-based cleanup levels or standards identified as Applicable or Relevant and Appropriate Requirements (ARARs) in the ROD that call into question the protectiveness of the remedy?
32 ACI- SERVICES SITE RVE-YIJAK REVIEW KEI'ORT No, the cleanup levels are still valid or are no longer relevant because of the removal and remedial actions taken. The Cr VI groundwater cleanup level of 100 |ag/L, which was based on the federal MCL, is still valid. Also, the exterior soil cleanup level of 1,500 mg/kg for total chromium is below a hazard index of 1 and within EPA's target cancer risk range of 10"6 to 10"4. The lead cleanup standard is less than the industrial worker screening level of 750 milligrams per kilogram (mg/kg). The cleanup levels for indoor air and interior dust/concrete are no longer valid as the plating buildings containing residual contamination (for which the standards were developed) have been removed. Therefore, there is no need to evaluate indoor air or interior dust/concrete cleanup levels.
Despite the above findings, it is worth noting that a chromium VI groundwater preliminary remediation goal (PRO) based on current risk assessment practices (see table 3) would be approximately 40 f-ig/L at a U\ of 1. This value represents the upper end of the range (i.e., more conservative) of potential chromium VI PRGs. Oilier potential sources of PRGs, such as the Region 6 Medium-Specific Screening Levels, provide a tap water PRO of 110 |ag/L. Note that the differences between these PRGs are a result of the exposure duration and the receptor being evaluated.
7.2.3 Changes in Toxicity and Other Contaminant Characteristics
• Have toxicity factors for contaminants of concern at the Site changed in a way that could affect the protectiveness of the remedy?
Chromium VI was the only contaminant evaluated quantitatively in the 1998 Baseline Risk Assessment (BRA). All other compounds (lead, arsenic, etc.) were evaluated qualitatively. The chromium VI oral and dermal reference doses (RIDs) used in the 1998 BRA are no longer valid. For a comparison, see the Table 3. Also, the recommended gastrointestinal, absorption factor used to derive the dermal RID has changed per Risk Assessment Guidance for Superfund Volume 1: Human Health Evaluation Manual (Part E, Supplemental Guidance for Dermal Risk Assessment) (USEPA. 2004). Despite these changes in toxicity values, they are not expected to affect the protectiveness of the remedy as the cleanup level for groundwater is based on the MCL.
33 ACE SERVICES SITE FIVE-YEAR REVIEW REI'ORT
Table 3. Evaluation of Toxicity Values Toxicity Values 1998 Baseline Risk Assessment Current Guidance and Policy
Chromium VI Oral RfD: 5E-03 mg/kg-day 3E-03 mg/kg-day Gastrointestinal Absorbtion 0.5 0.025 Efficiency: Chromium VI Dermal RfD: 2.5E mg/kg-day 7.5E-05 mg/kg-day
• Have other contaminant characteristics changed in a way that could affect the protect! veness of the remedy?
There have been no changes in contaminant characteristics that could affect the protectiveness of the remedy.
7.2.4 Changes in Risk Assessment Methods
• Have standardized risk assessment methodologies changed in a way thai could affect the protectiveness of the remedy?
Standardized risk assessment methodologies have changed since the 1998 BRA and ROD, but they have not changed in a way that could affect the protectiveness of the remedy. Table 4 illustrates the changes in risk assessment methodologies with the most significant change involving the exposure receptor and exposure duration. As a result of these changes in exposure factors, as well as toxicity values, the hazard indices in the 1998 BRA were underestimated approximately four-fold. However, previously estimated hazard indices (i.e., future groundwater pathway) already exceeded acceptable levels requiring remedial action.
Table 4. Evaluation of Exposure Factors and impacts on Risk Estimates Exposure Factors 1998 Baseline Risk Assessment Current Guidance and Policy
Surface Area Adult 18,200cm- 18,000 cm' Surface Area Child 7,200 cm2 6,600 err/ Exposure Time Adult 0.2 hour/day 0.58 hour/day Exposure Time Child 0.2 hour/day 1 hour/day 30 years, time-weighted average Exposure Duration/Receptor (6 years as child and 24 years as an 6 years, child adult)
34 ACE SERVICES SITE FIVE-YEAR REVIEW REPORT
7.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy?
No.
7.3.1 Ecological Risks
An ecological risk assessment was completed. No complete exposure pathways were determined to exist and therefore ecological risk was not considered in developing clean-up levels for the Site. Results of sediment sampling conducted by KDHE in 1989 in the unnamed tributary to Prairie Dog Creek do not exceed the current chromium ecological screening level for toxicity to macroinvertebrates (43.4 mg/kg) as taken from the "Development and Analysis of Sediment Quality Guidelines for Freshwater Ecosystems" by D. MacDonald, C. G. Ingersoll, and T.A. Berger and published in 2000.
The ecological risk assessment did not consider the pathway associated with treated groundwater discharged to Prairie Dog Creek. If How from this discharge created a continuous flow, then chronic criteria would be appropriate. If discharge created an intermittent flow, then acute criteria would be appropriate. The current discharge standards for hexavalent chromium (17 l-ig/L) do meet the chronic or acute levels of the National Ambient Water Quality (NAWQC) for protection of aquatic life. The chronic NAWQC standard for hexavalent chromium is 1 1 jag/L and the acute standard is 16 ug/L.
After reviewing discharge records it was found that the flow to the tributary is not continuous and discharge levels have all been below detectable levels with a detection limit below both the chronic and acute NAWQC standards for hexavalent chromium. Therefore, as currently operated, the remedy is ecologically protective.
7.3.2 Natural Disaster Impacts
No known natural disasters have occurred that would affect the protectiveness of the remedy. 7.3.3 Any Other Information That Could Call Into Question the Protectivencss of the Remedy
There is no other information found in this Five-Year Review that would call into question the protectiveness of the remedy.
7.4 Technical Assessment Summary
There has been significant progress made at attaining the remediation goals at the Site. All parties involved with the Site are actively engaged in the remedial action to maximize effectiveness and efficiency. Site conditions are evaluated on a regular basis and adjustments are made to the extraction and treatment systems when necessary. This active approach to the remediation has resulted in reduction in the plume size by over 90 percent. The equipment and facilities associated with the extraction and treatment systems are well maintained to ensure near continuous operations. There have been no significant shutdowns that have had a negative impact on the protectiveness of the remedy. A total of approximately 1.488 billion gallons of groundwater have been treated by the Site groundwater treatment system since inception. A total of 1,231.56 kilograms of chromium have been removed during treatment. The City has beneficially reused approximately 0.994 billion gallons of the treated groundwater in their potable water supply system.
The remedy at the Site currently protects human health and the environment because exposure pathways to groundwater have been cut off through hook up of private wells to the City water system, the plume has been reduced to greater than 90 percent of its original extent, an institutional control exists in the form of a permit requirement for installation of new wells, and the site property is zoned as light industrial.
36 ACESIIKVICI-S SITE nVE-YL-AK REVIEW KEI'ORT 8.0 Issues
TABLE 5: Issues Affects Protectiveness Issue No. Issue (Y/1N) Current Future Treatment plant Audit Reports do not address results of effluent discharge to the No No tributary to Prairie Dog Creek and City Drinking Water System Source area soils may have a potential to
continue contributing to the groundwater No No contaminant plurne. The ROD calls for placement of deed restrictions to prevent future use of contaminated groundwater. to prevent residential use of the Site and buildings, and to prevent removal of floors and soils No No beneath the building. These deed restrictions have not been implemented to date due to historical ownership concerns related to multiple trusts.
37 ACI-.SERVICES SITI- I-'IVI:-Y1£AR REVIEW KEI'QRT 9.0 Recommendations and Follow-Up Actions
Below is a list of recommended actions to address the issues identified in section 8.0.
TABLE 6; Recommendations and Follow-Up Actions Issue Recommendations/ Follow-up Party Oversight Milestone No.* Actions Responsible Agency Date Add section to Audit Report addressing Oftnhpi* results of discharges to tributary Prairie Vy L' 1 U Ut I 1 EPA EPA 2008 Audit Dog Creek and City Drinking Water Report System. Based on recommendations from an Remediation Systems Evaluation, a source area investigation will be conducted to determine the nature of contamination in source area soils and September 2 EPA/KDHE EPA if the potential exists for the 30, 20 1 0 contaminants in these soils to leach to groundwater. Remediation system enhancements may be considered based on the results of the soil investigation. The absence of a deed restriction does not present a current protectiveness issue due to the operation of the groundwater treatment plant on-site. Institutional controls have been implemented for the Site through public education and warnings about use of the groundwater in the plume area. The City also has implemented a permit system which limits new wells in the City. The City has zoned the Site as light industrial. Future use of the Site is expected to remain commercial or September 3 EPA EPA/KDHE industrial, and future use of .the Site 1 9, 20 1 3 . facility will be to house the treatment plant at least for the duration of the remedial action. An investigation is planned to determine if there are still residual source materials on the Site property contributing to the groundwater contamination. A future determination during the next Five- Year Review will be made to assess whether or not a deed restriction can be implemented without disruption of the treatment system.
38 ACE SERVICES SITE RVE-VEAR REVIEW REPORT 10.0 Protectiveness Statements
Operable Unit 1
The remedy at OU1 is protective of human health and the environment. The metal and plating shop buildings and associated foundations remedy included scarification of the floor surfaces in the plaling and machine shop buildings as well as debris removal from inside and outside the buildings. OU1 actions were conducted in accordance with Site decision documents. The exposure pathways and the Site buildings for this OU no longer exist and were removed as part of the OU2 activities.
Operable Unit 2
The remedy at OU2 currently protects human health and the environment. The metal and plating shop buildings and foundations were removed. Soils beneath these structures were excavated to a depth of 15 feet below grade. A new groundwaler treatment building constructed above the residual soils will serve as a cap and will remain for at least the duration of the remedial action. The lagoon area surface soils were excavated and clean fill was placed on the surface of the Site. The groundwaler contaminant plume has been reduced to greater than 90 percent of its original extent. Downgradient private well receptors have been provided an alternate water supply and the remaining private wells are periodically monitored.
However, in order for the remedy.to be protective in the long-term, the following actions will need to be taken to ensure long-term protectiveness. An investigation is planned to determine if there are residual source materials on the Site property that are contributing to the groundwater contamination. The results of the investigation may lead to additional investigations and/or Site remediation system enhancements. An evaluation during the next Five-Year Review period will be made to assess whether or not a deed restriction can be implemented without disruption of the treatment system. The' absence of a deed restriction does not present a current protectiveness issue due to the operation of the groundwater treatment plant on-site. Institutional controls have been implemented for the Site through public education and warnings about use of the
39 ACI2 SERVICES SITE FIVE-YEAR REVIEW REPORT groundvvater in the plume area. The City also has implemented a permit system which limits new wells in the City. The City has zoned the Site as light industrial. Future use of the Site is expected to remain commercial or industrial, and future use of the Site facility will be to house the treatment plant at least for the duration of the remedial action.
Site Wide
Because the remedial actions at all OUs are protective, the Site is protective of human health and the environment.
40 ACE SERVICES SITU FIVE-YEAR REVIEW REPORT 11. Next Review
The next Five-Year Review for the Ace Service Site is required five-years from the signature date of this review.
41 ACIZSI:KVIC1-S SITU I-'IVIE-YEAR KEV1EW KIZI'OKT
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GROUNDWATER FLOW LINE ACE SERVICES FIVE YEAR REVIEVV SAND PORTION OF AQUIFER BELOW WATER TABLE FIGURE 5 CROSS SECTION LOCATION Reproduced from Long Term Response ActIon Cleanup VeI1Ica1 Groundwater Flow Lines Status Report Number 9, Black &veatch, Nov" 2007 ACE SERVICES SITE KIVE-YEAR REVIEW Rl-l'ORT
Attachment A
Monitoring Data Summary Tables
and
Trend Plots ACE SERVICES.FIVE YEAR REVIEW REPORT
Table A1: Ace Services Site - Total Chromium Analytical Results Summary, Shallow Wells
Total Cr Well (ug/L) Apr- Sep- Oct- Nov- Dec- Jan- Feb- Mar- Apr- Jun- Aug- Oct- Dec- Apr- Oct- Apr- Oct- Apr- Oct- Apr- Number 2003 2003 2003 2003 2003 2004 2004 2004 2004 2004 2004 2004 2004 2005 2005 2006 2006 2007 2007 2008 Shallow Wells MW 1 S 1.1 U - 15 U - - 15 U - 15 UJ - 15 U 10 U 15 U 10 U 15 U - - MW 2 S 60.1 39 23 49.9 47.1 41.9 34.6 26.5 19.1 29 16.7 15 U 15 U 15 U 10 U 15 U 10 U 553 30 15 U MW 4 S 3.8 - 15 U - - - - 15 U 15 U 15 U 10 U 15 U 10 U 15 U - 15 U MW 5 S 26 - 15 U - 15 U 15 U - 15 U 10 U 15 U 10 U 15 U - 15 U MW 6 S 1.9 15 U - - - - - 15 U - - 15 U - 15 U 10 U 15 U 10 U 15 U - 15 U MW 7 S 48.1 15 U - - - 45 - 314 - 45.7 109 15.1 10 U 15 U - 15 U MW 8 S 1850 15 U 15 U 15.2 17.6 16.6 17.7 15 U 15 U 26.3 21.6 23.1 15 U 15 U 37.6 43.3 11.2 15 U 15 U 15 U MW 9 S 285 71.4 19 79.4 100 111 - 99.6 116 116 195 211 193 15 U 15 U 59 37.1 36.6 29 17 MW 11 S 182 - 60 - - - - - 19.1 - - 26.5 - 15 U 14.2 15 U 42 15 U - 15 U MW 12 S 36.4 - 15 U - - - - 15 .U - 15 U 15 U 10.6 15 U 10 U '15 U 15 U MW 13 S 173 162 152 165 151 148 163 117 928 95.6 50.8 43.5 34 15 U 10 U 15 U 10 U 15 U 15 U MW 14 S 133 57.8 51 70.5 57.1 52.1 49.8 42.7 23.5 40.5 27 22.5 15 U 15 U 10.6 28 22.3 16 - 29 MW 15 S 204 202 200 204 162 159 159 185 232 137 108. 199 162 103 111 186 122 86 74 34 MW 16 S 1.7 15 U - - • - 15 U - 15 U - 15 U 10 U 15 U 10 U 15 U - - MW 17 S 25.1 - 15 U - - ' - - 15 U - - 15 15 U 11.4 15 . U 27.4 15 U MW 18 S 64.6 - 42 - - - 15 U - 15 U - 15 U 10 U 15 U 23.1 27 25 25 ARW - S 17.1 552 - - - 1640 2370 2610 2560 3810 1600 1250 162 15 U 23 81 OB 1 S 279 15 U - - - - - 25.8 - - 50.1 15 U 10 U 45.8 77.4 15 U - 15 U OB 2 S 360 - 61 - - 45.8 - 56.5 - 15 UJ 30.3 38.2 26.7 16 - 15 U HPMW 3 S - 15 U ------15 U - - HPMW 6 S 1.4 - .- - - - - . - 15 U - 15 U 10 U 15 U 10 U 15 U - 15 U HPMW 9 S 0.91 - - - 780 - - - - 17.2 64 10' U 15 U - 15 U EX 2 S - - 41 495 609 379 321 279 203 239 299 106 ------EX 3 S - 210 134 480 529 200 ' 160 150 113 J 141 109 934 70.9 15 U 33.8 17.7 122 33 15 U 31 EX 4 S. - 127 81 77.7 70.2 66.5 • 62.9 - 15 U 54.5 36.6 15 U 35.1 15 U 17.9 15 U 10 U 15 U 59 ' 15 U EX 5 S - 77.2 ' 62 59.9 56.1 54.2 50.9 44.2 20.4 . 42.7 32 25.9 16.4 15 U 21.6 15 U 10 U 15 U 125 15 U
Duplicate results in parentheses MW = monitoring well Cr = chromium HPMW = Hi-Plains Co-op monitoring well ug/L = microgram per liter OB = Observation Well U = qualified as nondetect ARW = Ace Recovery well J = qualified as nondetect PWS = public water supply S = shallow RW = residential well I = intermediate EX = extraction well D = deep SC = sample connection - = no sample collected
Adapted from summary tables in April 2008 Data Evaluation Technical Memorandum, Black & Veatch, June 4, 2008 ACE SERVICES FIVE YEAR REVIEW REPORT
Table A2: Ace Services Site - Total Chromium Analytical Results Summary, Intermediate Wells Total Cr Well (ug/L) Apr- Sep- Oct- Nov- Dec- Jan- Feb- Mar- Apr- Jun- Aug- Oct- Dec- Apr- Oct- Apr- Oct- Apr- Oct- Apr- Number 2003 2003 2003 2003 2003 2004 2004 2004 2004 2004 2004 2004 2004 2005 2005 2006 2006 2007 2007 2008 Intermediate Wells MW 1 0.7 U - 15 U - - - - - 15 U - - 15 U - 15 U 10 U 15 U 10 U 15 U - - MW 2 949 939 955 988 1200 972 1340 1280 1580 1350 1140 1160 1570 686 406 253 143 124 117 99 MW 4 24.7 - 15 U - - - - - 15 U - - 15 U - 15 U 10 U 15 U 10 U 15 U - - MW 5 10.9 - 15 U - - - - - 15 U - - 15 U - 15 U 10 U 15 U 10 U 15 U - MW .6 14.5 - .15 U - - - - - 15 U - - 15 U •- 15 U 10 U 15 U 10 U 15 U 15 U MW 7 132 - 15 U - - 15 U - 292 - 15 U 10 U 15 U 10 U 15 U MW 8 1960 80.4 56 20.9 25 38.5 69.3 90.8 89.2 134 294 52.5 15 U 15 U 10.7 15 -U 10 U 15 U 15 U .15 U MW 9 1920 646 416 471 225 948 2760 2000 1680 1570 2810 258 149 15.7 17 15 U 10 U 15 U 15 U MW 11 267 ' - 103 - - - - - 19.1 - - 15 U - 15 U 10 U 15 U 10 U 15 U - 15 U MW 12 132 113 - - - - - 18.3 - - 15 U 15 U 10 U 15 U 10 U 15 U - 15 U
MW 13 .283 138 110 90.9 77.6 111 L104 74 58.6 52.3 35.2 35.6 15 U 15 U 10 15 U 10 U 15 U 15 U MW 14 107 99.7 143 150 130 108 97.8 73 44.9 59.7 36.9 303 18.2 15 U 13 16.3 37.1 60 15 U MW 15 56.4 96.5 171 179 336 236 228 158 121 57.2 24.2 20.5 15 .U 15 U 10 U 15 U 10 U 15 U - 15 U MW 16 3.8 15 U - 15 U 15 U - 15 U 10 U 15 U 10 U 15 U - MW 17 3.9 15 U - 15 U 15 U - 15 U 10 U 15 U 10 U 15 U . MW 18 17.9 - 15 U - - - - 15 U - - 15 U - 15 U 10 U 15 U 10 U 15 U - - ARW - 4.9 - 265 - - - - - 1110 957 1230 756 1690 794 804 65 15 U - 39 OB 1 155 - 85 - - - - - 77.2 -' 79.8 - 15 U 10 U 15 U 26.3 19 - 15 U OB 2 4Q8 - 15 U - - - - in - -. 207 - 170 132 111 77 46 - 19 EX 1 - 1410 1390 1360 1010 1030 1150 1140 1060 3220 1190 1360 1150 953 926 667 500 379 . 349 315 EX 2 - 770 527 1190 1580 1910 1520 1220 997 1250 1420 553 346 205 181 114 80 53 43 29 EX 3 - - - 884 706 431 382 366 311 818 315 296 222 145 135 100 72 59 55 43 EX 4 I/O - 170 156 158 166 173 161 151 145 130 110 106 856 43.1 61 46.1 36.5 30 15 U 19 EX 5 I/D - 128 116 120 129 137 127 118 93.2 107 93.2 88.2 72.2 27 51 64.8 67.5 105 15 U 31 PWS 8 - 1040 940 1990 2050 2350 2310 2260 2290 2710 3100 1190 797 443 350 224 190 139 15 U 91
Duplicate results in parentheses MW = monitoring well Cr = chromium HPMW = Hi-Plains Co-op monitoring well ug/L = microgram per liter OB = Observation Well U = qualified as nondelect ARW = Ace Recovery well J = qualified as nondeteci PWS = public water supply S = shallow RW = residential well I = intermediate EX = extraction well D = deep SC = sample connection - = no sample collected
Adapted from summary tables in April 2008 Data Evaluation Technical Memorandum, Biack & Veatch, June 4, 2008 ACE SERVICES FIVE YEAR REVIEW REPORT
Table A3: Ace Services Site - Total Chromium Analytical Results Summary, Deep Wells
Total Cr Well (ug/L) Apr- Sep- Oct- Nov- Dec- Jan- Feb- Mar- Apr- Jun- Aug- Oct- Dec- Apr- Oct- Apr- Oct- Apr- Oct- Apr- Number 2003 2003 2003 2003 2003 2004 2004 2004 2004 2004 2004 2004 2004 2005 2005 2006 2006 2007 2007 2008 Deep Wells MW 1 D 5.6 - 15 U - - - - - 15 U - - 15 U - 15 U 10 U 15 U 10 U 15 U - 15 U MW 2 D 184 75.4 35 286 107 729 145 125 168 712 630 85.4 158 55.2 10 U 38.3 U 10 U 15 U 15 U 15 U MW 3 D 6.7 - 15 U - - 335 - 15 U 15 U 10 U 15 U 10 U 15 U - • 15 U MW 4 D 1.6 15.9 - - - - ' 15 U - 46.4 15 U 10 U 15 U 169 15 U ' - 15 U MW 5 D 1.8 - 15 U - - - 15 U - - 15 U - 15 U 21.1 15 U 10 U 15 U - - MW 6 D 108 71 - - - - 33.7 20.8 15 U 10 U 15 U .10 U 15 U - 15 U MW 7 D 26.1 15 U - 33.8 - - 35.4 - 15 U 10 U 15 U 10 U 15 U - 15 U MW 8 D 478 15 U 15 U 15 74 139 169 137 93.4 149 319 15 U 15 U 15 U 10 U 15 U 10 U 15 U 15 U 15 U MW 9 D 3340 464 15 U 1350 1900 1820 1820 1600 1620 1680 1730 121 1470 15 U 10.1 15 U 10 U 15 U - 22 MW 11 D 682 - 15 U 15 U - - 15 U - .15 UJ 10 U 20.1 13.8 15 U 15 U MW 12 D 3.7 - 15 U - - - - 15 U - - 15 U - 15 U 10 U 15 U 10 U 15 U - MW 13 D 221 106 70 44 15 U 15 U 15 U 15 U 15 U 15 U 10 U 15 U 15 U 15 UJ 10 U 15 U 10 U 15 U 15 U MW 15 D 1240 1330 999 868 487 384 360 305 273 202 125 134 120 41.7 372 22.0 11.1 15 U 15 U MW 16 D 2 - 15 U - - - 15 U - 15 U - 15 U 10 U 15 10 U 15 U - - MW 17 D 22.1 - 15 U - - - - - 15 U 15. U 15 U 10 U 15 U 10 U 15 U - - MW 18 D 132 - 15 U - - - - - 15 U 15 U 15 U 10 U 15 U 10 U 15 U - 15 U ARW - D 6.4 - 68 - - - - 194 160 188 202 291 277 287 156 15 U 70 OB 1 D 1290 - • 99 - - 513 - - 60.6 - I 15 U 10 U 15 U 10 U 15 U - 15 U OB 2 D 2770 - 228 - - - - 604 - 257 51.9 11.6 15 U 10 U 15 U 15 U EX 1 D 58.4 34 28.1 22 35.5 54.6 56.5 537 312 617 53.7 51.3 15 U 17.4 15 U 10 U 15 . U 15 U 15 U EX 2 D 654 485 634 966 948 838 662 485 593 1010 331 416 119 53.8 34.7 21.6 15 U 15 U 26 EX 3 D 478 409 371 349 324 268 262 177 198 106 78 59.7 15.4 36.9 31 6 12.3 15 U 31 15 U
Duplicate results in parentheses MW= monitoring well Cr = chromium HPMW= Hi-Plains Co-op monitoring well ug/L = microgram per liter OB = Observation Well U = qualified as nondetect ARW = Ace Recovery well J = qualified as nondetect PWS = public water supply S = shallow RW = residential well I = intermediate EX = extraction well D = deep SC = sample connection - = no sample collected
Adapted from summary tables in April 2008 Data Evaluation Technical Memorandum, Black & Veatch, June 4, 2008 ACE SERVICES FIVE YEAR REVIEW REPORT
Table A4: Ace Services Site - Total Chromium Analytical Results Summary, Residential Wells
Total Cr Well (ug/L) Apr- Sep- Oct- Nov- Dec- Jan- Feb- Mar- Apr- Jun- Aug- Oct- Dec- Apr- Oct- Apr- Oct- Apr- Oct- Apr- Number 2003 2003 2003 2003 2003 2004 2004 2004 2004 2004 2004 2004 2004 2005 2005 2006 2006 2007 2007 2008 Residential Wells RW. 1 27.1 ------RW 2 1.9 15 U 15 U 61 - 22.1 11.2 15 U 10 U 15 U 15 U 15 U RW 3 3.2 - 15 U - - - - 15 U - 15 U - 15 U 10 U 15 U 10 U 15 U 15 U 15 U RW 4 3.6 - 15 U 15 U 15 U 15 U 10 'U 15 10 U 15 U 15 U 15 U RW 5 6.2 15 U - - - - 15 U - - 15 U - 15 U 362 22.8 10 U 15 U 15 U 15 U RW 6 94.1 55 - - - 15 U - • 15 U - 15 U 10 U 15 U 10 U 15 U 15 U 15 U RW 7 475 - 17 15 U - 15 U 15 U 10 U 15 U 10 U 15 U 15 U 15 U RW 8 75.7 63 - - - - 743 - - 50.1 - 15 U 29.9 17.2 13.1 15 U 15 U 15 U RW 9 2.4 15 U - - 15 U - 15 U 15 U 10 U 15 U 10 U 15 U 15 U 15 U
Duplicate results in parentheses MW = monitoring well Cr = chromium HPMW= Hi-Plains Co-op monitoring well ug/L. = microgram per liter OB = Observation Well U = qualified as nondetect ARW = Ace Recovery well J = qualified as nondetect PWS = public water supply S = shallow RW = residential well I = intermediate EX = extraction well D = deep SC = sample connection - = no sample collected
Adapted from summary tables in April 2008 Data Evaluation i echnicai Memorandum, Black & Veatch, June 4, 2008 Ace Services: Shallow Well MW-2S
600
553
500
400
300
200 Total Chromium Concentration (ug/L) Concentration Chromium Total
100 60.1 49.9 47.1 39 34.6 29 15U 41.9 16.7 15U 15U 15U 10U 15U 30 23 26.5 19.1 10U 0
3 3 3 3 4 4 4 4 5 5 5 5 6 6 6 6 7 7 7 7 8 -03 -0 -0 -04 -04 -0 -0 -05 -05 -0 -0 -06 -06 -0 -0 -07 -07 -0 -0 -08 n t-0 c b n t-0 c b n t-0 c b n t-0 c b n g t-0 c b u c e u c e u c e u c e u c e Apr-0 J Aug O D Fe Apr-0 J Aug O D Fe Apr-0 J Aug O D Fe Apr-0 J Aug O D Fe Apr-0 J Au O D Fe Apr-0 Date of Sample Ace Services: Shallow Wells MW-8S, MW-9S
400
1850 350
300 285
250
211 MW-8S 200 193 195 MW-9S
150
116 111 116 100
Total Chromium Concentration (ug/L) Total Chromium Concentration 100 99.6 79.4 71.4 59 43.3 50 36.6 29 26.3 23.1 1917.6 17.7 15U 37.6 37.1 17 15U 15U 21.6 15.2 16.6 15U 15U 15U 15U 15U 15U 0 15U 15U 11.2 Apr-08 Apr-07 Oct-07 Apr-06 Oct-06 Apr-05 Oct-05 Apr-04 Oct-04 Apr-03 Oct-03 Jun-07 Jun-06 Jun-05 Jun-04 Jun-03 Feb-08 Feb-07 Feb-06 Feb-05 Feb-04 Aug-07 Aug-06 Aug-05 Aug-04 Aug-03 Dec-07 Dec-06 Dec-05 Dec-04 Dec-03 Date of Sample Ace Services: Shallow Wells MW-7S, MW-11S, MW-12S
350
314
300
250
200 182 MW-7S MW-11S MW-12S 150
100 Tottal Chromium Concentration (ug/L) Tottal Chromium Concentration
60 48.1 42 50 45 45.7 26.5 36.4 19.1 15U 15U 10.9 14.2 15.1 15U15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 0 10.6 10U 10U Apr-08 Apr-07 Oct-07 Apr-06 Oct-06 Apr-05 Oct-05 Apr-04 Oct-04 Apr-03 Oct-03 Jun-07 Jun-06 Jun-05 Jun-04 Jun-03 Feb-08 Feb-07 Feb-06 Feb-05 Feb-04 Aug-07 Aug-06 Aug-05 Aug-04 Aug-03 Dec-07 Dec-06 Dec-05 Dec-04 Dec-03 Date of Sample Ace Services: Shallow Wells MW-13S, MW-14S, MW-15S
250
232
204 202 204 200 199 200 186 185 173
162 165 163 162 162 159 159 150 152 151 148 133 137 MW-13S 122 MW-14S 117 111 MW-15S 108 100 103 95.6 92.8 86 74 70.5
57.1 Total Chromium Concentration (ug/L) Total Chromium Concentration 57.8 52.1 50.8 50 49.8 51 42.7 40.5 43.5 34 27 28 22.3 22.5 34 16 15U 29 23.5 10.6 15U 15U 15U 15U 15U 10U 10U 0 Apr-08 Apr-07 Oct-07 Apr-06 Oct-06 Apr-05 Oct-05 Apr-04 Oct-04 Apr-03 Oct-03 Jun-07 Jun-06 Jun-05 Jun-04 Jun-03 Feb-08 Feb-07 Feb-06 Feb-05 Feb-04 Aug-07 Aug-06 Aug-05 Aug-04 Aug-03 Dec-07 Dec-06 Dec-05 Dec-04 Dec-03 Date of Sample Ace Services: Shallow Wells MW-16S, MW-17S, MW-18S
70
64.6
60
50
42 40 MW-16S MW-17S MW-18S 30 27.4 27 25.1 25 25
23.1 20
Total Chromium Concentration (ug/L) Total Chromium Concentration 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 11.4 15U 15U 10 10U 10U 10U
1.7 0 Apr-08 Apr-07 Oct-07 Apr-06 Oct-06 Apr-05 Oct-05 Apr-04 Oct-04 Apr-03 Oct-03 Jun-07 Jun-06 Jun-05 Jun-04 Jun-03 Feb-08 Feb-07 Feb-06 Feb-05 Feb-04 Aug-07 Aug-06 Aug-05 Aug-04 Aug-03 Dec-07 Dec-06 Dec-05 Dec-04 Dec-03 Date of Sample Ace Services: Shallow Well ARW-S
4500
4000 3810
3500
3000
2610 2500 2370
2000
1640 1600 1500
1250
Total Chromium Concentration (ug/L) Total Chromium Concentration 1000
500 552
162 15U 23 81 0 17.1
4 5 6 7 8 -0 -0 -0 -0 -0 Apr-03Jun-03Aug-03Oct-03Dec-03Feb Apr-04Jun-04Aug-04Oct-04Dec-04Feb Apr-05Jun-05Aug-05Oct-05Dec-05Feb Apr-06Jun-06Aug-06Oct-06Dec-06Feb Apr-07Jun-07Aug-07Oct-07Dec-07Feb Apr-08 Date of Sample Ace Services: Shallow Wells OB-1S, OB-2S
400
360 350
300 279
250
OB-1S 200 OB-2S
150
Total Chromium Concentration (ug/L) Concentration Chromium Total 100 77.4
61 56.5 45.8 50 45.8 50.1 30.3 26.7 25.8 38.2 15UJ 16 15U 15U 10U 15U 15U 15U 0
3 3 3 3 4 4 4 4 5 5 5 5 6 6 6 6 7 7 7 7 8 -03 -0 -0 -04 -04 -0 -0 -05 -05 -0 -0 -06 -06 -0 -0 -07 -07 -0 -0 -08 n t-0 c b n t-0 c b n t-0 c b n t-0 c b n g t-0 c b u c e u c e u c e u c e u c e Apr-0J Aug O D Fe Apr-0J Aug O D Fe Apr-0J Aug O D Fe Apr-0J Aug O D Fe Apr-0J Au O D Fe Apr-0 Date of Sample Ace Services: Shallow Extraction Wells EX-2S, EX-3S, EX-4S, EX-5S
700
609 600
529
500 495 480
400 379 EX-2S EX-3S 321 EX-4S 299 300 EX-5S 279
239
203 200 210 200 184
Total Chromium Concentration (ug/L) Total Chromium Concentration 160 150 141 127 125 106 113 109 100 81 77.7 77.2 70.266.5 93. 70.9 62.9 54.5 59 62 59.9 50.9 36.6 33.8 56.154.2 44.2 25.9 35.1 33 31 41 42.7 15U 17.7 12.2 15U 20.4 32 15U 0 15U 15U 16.4 15U 15U 17.9 21.6 15U 15U 10U 10U 15U 15U 15U
4 5 6 7 8 -0 -0 -0 -0 -0 Apr-03Jun-03Aug-03Oct-03Dec-03Feb Apr-04Jun-04Aug-04Oct-04Dec-04Feb Apr-05Jun-05Aug-05Oct-05Dec-05Feb Apr-06Jun-06Aug-06Oct-06Dec-06Feb Apr-07Jun-07Aug-07Oct-07Dec-07Feb Apr-08 Date of Sample Ace Services: Intermediate Wells MW-2I, MW-8I, MW-9I
3000
2810 2760
2500
2000 2000 1960 1920
1680 1580 1570 MW-2I 1570 1500 MW-8I 1340 1350 MW-9I 1200 1280 1160 1140 1000 955 972 988 948 949 939
686 Total Chromium Concentration (ug/L) Total Chromium Concentration 646
471 500 406 416 294 253 258 225 149 143 124 117 56 25 90.8 89.2 99 80.4 38.5 134 52.5 15U 20.9 15U 15.7 17 10.7 15U 15U 10U 10U 15U 15U 15U 15U 0 69.3 15U
4 5 6 7 8 -0 -0 -0 -0 -0 Apr-03Jun-03Aug-03Oct-03Dec-03Feb Apr-04Jun-04Aug-04Oct-04Dec-04Feb Apr-05Jun-05Aug-05Oct-05Dec-05Feb Apr-06Jun-06Aug-06Oct-06Dec-06Feb Apr-07Jun-07Aug-07Oct-07Dec-07Feb Apr-08 Date of Sample Ace Services: Intermediate Wells MW-11I, MW-12I
300
267
250
200
MW-11I 150 132 MW-12I
113 103 100 Total Chromium Concentration (ug/L) Total Chromium Concentration
50
19.1 15U 15U 15U 15U 15U 18.3 10U 10U 15U 15U 10U 15U 15U 15U 0 10U Apr-08 Apr-07 Oct-07 Apr-06 Oct-06 Apr-05 Oct-05 Apr-04 Oct-04 Apr-03 Oct-03 Jun-07 Jun-06 Jun-05 Jun-04 Jun-03 Feb-08 Feb-07 Feb-06 Feb-05 Feb-04 Aug-07 Aug-06 Aug-05 Aug-04 Aug-03 Dec-07 Dec-06 Dec-05 Dec-04 Dec-03 Date of Sample Ace Services: Intermediate Wells MW-13I, MW-14I, MW-15I
400
350 336
300 283
250 236 228 MW-13I 200 MW-14I 179 171 MW-15I
150 158 150 138 143 130 121 107 110 111 99.7 108 104
Total Chromium Concentration (ug/L) Total Chromium Concentration 100 97.8 96.5 90.9 74 77.6 73 58.6 59.7 57.2 60 50 56.4 52.3 36.9 35.6 37.1 44.9 35.2 30.3 18.2 15U 16.3 15U 24.2 13 15U 20.5 10U 10U 15U 15U 15U 15U 15U 15U 15U 15U 15U 0 10U 10U Apr-08 Apr-07 Oct-07 Apr-06 Oct-06 Apr-05 Oct-05 Apr-04 Oct-04 Apr-03 Oct-03 Jun-07 Jun-06 Jun-05 Jun-04 Jun-03 Feb-08 Feb-07 Feb-06 Feb-05 Feb-04 Aug-07 Aug-06 Aug-05 Aug-04 Aug-03 Dec-07 Dec-06 Dec-05 Dec-04 Dec-03 Date of Sample Ace Services: Intermediate Well ARW-I
1800 1690
1600
1400
1230 1200 1110
1000 957 ARW-I 804 800 794 756
600
Total Chromium Concentration (ug/L) Total Chromium Concentration 400
265 200
39 4.9 65 15U 0
4 5 6 7 8 -0 -0 -0 -0 -0 Apr-03Jun-03Aug-03Oct-03Dec-03Feb Apr-04Jun-04Aug-04Oct-04Dec-04Feb Apr-05Jun-05Aug-05Oct-05Dec-05Feb Apr-06Jun-06Aug-06Oct-06Dec-06Feb Apr-07Jun-07Aug-07Oct-07Dec-07Feb Apr-08 Date of Sample Ace Services: Intermediate Wells OB-1I, OB-2I
450
408 400
350
300
250 OB-1I 207 OB-2I 200 170 155 150 132 111
Total Chromium Concentration (ug/L) Total Chromium Concentration 111 100 85 79.8 77 77.2 46 50 26.3 19 15U 15U 19 15U 10U 0 15U
4 5 6 7 8 -0 -0 -0 -0 -0 Apr-03Jun-03Aug-03Oct-03Dec-03Feb Apr-04Jun-04Aug-04Oct-04Dec-04Feb Apr-05Jun-05Aug-05Oct-05Dec-05Feb Apr-06Jun-06Aug-06Oct-06Dec-06Feb Apr-07Jun-07Aug-07Oct-07Dec-07Feb Apr-08 Date of Sample Ace Services: Intermediate Extraction Welss EX-1I, EX-2I, EX-3I
3500
3220
3000
2500
2000 1910 EX-1I EX-2I 1580 1520 EX-3I 1500 1390 1420 1410 1360 1360 1250 1220 1190 1140 1150 1150 1190 1060 953 1000 1030 926 1010 997 884 818 Total Chromium Concentration (ug/L) Total Chromium Concentration 770 706 667 553 500 500 527 379 431 366 349 346 315 382 311 205 315 296 181 222 114 72 80 59 145 135 53 55 43 43 0 100 29
4 5 6 7 8 -0 -0 -0 -0 -0 Apr-03Jun-03Aug-03Oct-03Dec-03Feb Apr-04Jun-04Aug-04Oct-04Dec-04Feb Apr-05Jun-05Aug-05Oct-05Dec-05Feb Apr-06Jun-06Aug-06Oct-06Dec-06Feb Apr-07Jun-07Aug-07Oct-07Dec-07Feb Apr-08 Date of Sample Ace Services: Intermediate Extraction Wells EX-4I/D, EX-5I/D
200
180 173 170 166 161 160 156 158 151 145 140 137 128 129 127 130 120 120 118 116 110 107 105 106 EX-4I/D 100 EX-5I/D 88.2 93.2 93.2 85.6 80
72.2 64.8 61 67.5 60 46.1 Total Chromium Concentration (ug/L) Total Chromium Concentration 51 40 43.1 30 31 36.5 27 20 15U 19 15U 0 Apr-08 Apr-07 Oct-07 Apr-06 Oct-06 Apr-05 Oct-05 Apr-04 Oct-04 Apr-03 Oct-03 Jun-07 Jun-06 Jun-05 Jun-04 Jun-03 Feb-08 Feb-07 Feb-06 Feb-05 Feb-04 Aug-07 Aug-06 Aug-05 Aug-04 Aug-03 Dec-07 Dec-06 Dec-05 Dec-04 Dec-03 Date of Sample Ace Services: Deep Wells MW-2D, MW-8D
800
712 700
630
600
500 478
MW-2D 400 MW-8D
319 300
Total Chromium Concentration (ug/L) Total Chromium Concentration 200 184 169 158 145 168 139 137 149 107 100 125 75.4 74.3 93.4 85.4 55.2 72.9 38.3 35 28.6 15U 15U 10U 10U 15U 15U 15U 15U 15U 15U 15U 15U 10U 10U 15U 0 15U 15 Apr-08 Apr-07 Oct-07 Apr-06 Oct-06 Apr-05 Oct-05 Apr-04 Oct-04 Apr-03 Oct-03 Jun-07 Jun-06 Jun-05 Jun-04 Jun-03 Feb-08 Feb-07 Feb-06 Feb-05 Feb-04 Aug-07 Aug-06 Aug-05 Aug-04 Aug-03 Dec-07 Dec-06 Dec-05 Dec-04 Dec-03 Date of Sample Ace Services: Deep Wells MW-3D, MW-4D, MW-5D, MW-6D, MW-7D
400
350 335
300
250 MW-3D MW-4D 200 MW-5D MW-6D 169 MW-7D 150
108
Total Chromium Concentration (ug/L) Total Chromium Concentration 100
71
50 46.4 33.7 33.8 26.1 35.4 15U 20.8 21.1 15U 15U 15U 15.9 15U 15U 15U 15U 15U 15U 15U 15U 6.7 10U 10U 10U 10U 15U 1.6 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 0 1.8 10U 10U 10U 10U Apr-08 Apr-07 Oct-07 Apr-06 Oct-06 Apr-05 Oct-05 Apr-04 Oct-04 Apr-03 Oct-03 Jun-07 Jun-06 Jun-05 Jun-04 Jun-03 Feb-08 Feb-07 Feb-06 Feb-05 Feb-04 Aug-07 Aug-06 Aug-05 Aug-04 Aug-03 Dec-07 Dec-06 Dec-05 Dec-04 Dec-03 Date of Sample Ace Services: Deep Wells MW-9D, MW-15D
2000 1900
3340 1820 1800 1820 1730 1680
1600 1620 1600 1470 1400 1330 1350 1240 1200
MW-9D 1000 999 MW-15D 868 800
600 487
Total Chromium Concentration (ug/L) Total Chromium Concentration 464 400 384 360 305
273 202 200 125 134 120 121 41.7 37.2 11.1 10.1 22 15U 10U 15U 15U 15U 22 0 15U 15U Apr-08 Apr-07 Oct-07 Apr-06 Oct-06 Apr-05 Oct-05 Apr-04 Oct-04 Apr-03 Oct-03 Jun-07 Jun-06 Jun-05 Jun-04 Jun-03 Feb-08 Feb-07 Feb-06 Feb-05 Feb-04 Aug-07 Aug-06 Aug-05 Aug-04 Aug-03 Dec-07 Dec-06 Dec-05 Dec-04 Dec-03 Date of Sample Ace Services: Deep Well ARW-D
350
300 291 277 287
250
200 202 194 188 ARW-D 156 160 150
100
Total Chromium Concentration (ug/L) Total Chromium Concentration 70 68 50
6.4 15U 0 Apr-08 Apr-07 Oct-07 Apr-06 Oct-06 Apr-05 Oct-05 Apr-04 Oct-04 Apr-03 Oct-03 Jun-07 Jun-06 Jun-05 Jun-04 Jun-03 Feb-08 Feb-07 Feb-06 Feb-05 Feb-04 Aug-07 Aug-06 Aug-05 Aug-04 Aug-03 Dec-07 Dec-06 Dec-05 Dec-04 Dec-03 Date of Sample Ace Services: Deep Wells OB-1D, OB-2D
2000
2770 1800
1600
1400 1290
1200
OB-1D 1000 OB-2D
800
604 600 513 Total Chromium Concentration (ug/L) Total Chromium Concentration 400
257 228 200
60.6 51.9 99 15U 10U 11.6 15U 15U 10U 10U 15U 15U 15U 0 15U
4 5 6 7 8 -0 -0 -0 -0 -0 Apr-03Jun-03Aug-03Oct-03Dec-03Feb Apr-04Jun-04Aug-04Oct-04Dec-04Feb Apr-05Jun-05Aug-05Oct-05Dec-05Feb Apr-06Jun-06Aug-06Oct-06Dec-06Feb Apr-07Jun-07Aug-07Oct-07Dec-07Feb Apr-08 Date of Sample Ace Services: Deep Extraction Wells EX-1D, EX-2D, EX-3D
1200
1010 1000 966 948
838 800
654 662 EX-1D 634 617 600 593 EX-2D EX-3D
478 485 485 416
400 409 371
349 324 312 331 Total Chromium Concentration (ug/L) Total Chromium Concentration 268 262
200 198 177 119 106 78 54.6 56.5 59.7 53.8 58.4 53.7 31.6 34.7 31 26 28.1 53.7 15.4 36.9 21.6 12.3 15U15U 15U 15U 34 35.5 51.3 17.4 10U 15U 0 22 15U 15U 15U 15U
4 5 6 7 8 -0 -0 -0 -0 -0 Apr-03Jun-03Aug-03Oct-03Dec-03Feb Apr-04Jun-04Aug-04Oct-04Dec-04Feb Apr-05Jun-05Aug-05Oct-05Dec-05Feb Apr-06Jun-06Aug-06Oct-06Dec-06Feb Apr-07Jun-07Aug-07Oct-07Dec-07Feb Apr-08 Date of Sample Ace Services: Well PWS-8
3500
3100 3000
2710
2500 2350 2310 2260 2290 2050 2000 1990
PWS-8
1500
1040 1190 1000 940 Total Chromium Concentration (ug/L) Total Chromium Concentration 797
500 350 443 224 190 139 91 15U 0
4 5 6 7 8 -0 -0 -0 -0 -0 Apr-03Jun-03Aug-03Oct-03Dec-03Feb Apr-04Jun-04Aug-04Oct-04Dec-04Feb Apr-05Jun-05Aug-05Oct-05Dec-05Feb Apr-06Jun-06Aug-06Oct-06Dec-06Feb Apr-07Jun-07Aug-07Oct-07Dec-07Feb Apr-08 Date of Sample Ace Services: Residential Well RW-2, RW-3, RW-4, RW-5
70
61 60
50
40 RW-2 36.2 RW-3 RW-4 30 RW-5
22.8 22.1 20 Total Chromium Concentration (ug/L) Concentration Chromium Total 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 11.2 15U 15U 15U 15U 10U 10 10U 6.2 10U 10U 10U 10U
3.6 3.2 0 1.9 Apr-03 Aug-03 Jan-04 Jun-04 Nov-04 Apr-05 Sep-05 Feb-06 Jul-06 Dec-06 May-07 Oct-07 Mar-08 Date of Sample Ace Services: Residential Wells RW-6, RW-7, RW-8, RW-9
100
94.1 90
80 75.7 74.3
70
63 60
55 RW-6 50.1 RW-7 50 47.5 RW-8 RW-9 40
29.9 30 Total Chromium Concentration (ug/L) Total Chromium Concentration
20 17 17.2 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 15U 13.1 15U 15U 15U 15U 15U 15U 10U 10U 15U 15U 10U 15U 15U 15U 15U 15U 10 10U 10U 10U
2.4 0 Apr-03 Aug-03 Jan-04 Jun-04 Nov-04 Apr-05 Sep-05 Feb-06 Jul-06 Dec-06 May-07 Oct-07 Mar-08 Date of Sample ACE SERVICES SITE l-'IVl'-YEAR REVIEW REPORT
Attachment B
Site Inspection Checklist ACE SERVICES SITE I-TVE-YEAR REVIEW REPORT
Site Inspection Checklist
I. SITE INFORMATION Site name: Ace Services Site Date of inspection: 11/29/07 Locution and Region: C:olby, KS EKAII): KSDCI46746731 Agency, office, or company leading the five-year Weather/temperature: Sunny/ 20 - 30°F review: EPA Region 7 Remedy Includes (Chedc all that apply) l~l Landfill cover/conlainmcnt f~l Monitored natural attenuation E3 Access controls l~l Groundwater containment E»3 Institutional controls l~l Vertical barrier waUs 13 Groundwatur pump and treatment D Surface water collection and treatment D Other: Attachments: |3 Inspection team roster attached C] Site map attached II. INTERVIEWS (Check all that apply) 1. O&M site manager Jim Helus Citv of Colbv Public Works 11/29/07 Name Title Date Interviewed H at site n at office D hy phone Phone no. Problems, suggestions. P^ Report attached
2. O&M staff Nnme Title Date Interviewed n at site Q at offico D by phone Phone no. Problems, suggestions: f~I Report attached
Five-year Review Report - 1 ACI7. SERVIC1-SSITI- FIVb-YtAK KHVIEW KIII'OKT
Local regulatory authorities and response agencies (i.e., State imd Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.
Agency Contact Nnmc Title Date Phone no. Problems, suggestions; d Report attached
Agency Contact Name Title Dale Phone no. Problems; suggestions; l~l Report attached
Agency Contact Name Title Date Phone no. Problems, suggestions, l~l Report attached
Agency Contact Name Title Date Phone no. Problems; suggestions; l~l Report attached
4. Other Interviews (optional) l~l Report attached.
Five-year Review Report - 2 ACE SEKVICI:-:S srrr: riVl--YEAK REVIEW REI'OKT
111. ON-SITE DOCUMENTS* RECORDS VERIFIED (Check all that apply) 1. O&M Documents 12 O&M manual 13 Readily available 13 Up to date D N/A El As-built drawings El Readily available El Up to date D N/A 13 Maintenance logs 13 Readily available E] Up to dale CD N/A Remarks
2. Site-Specific Hrulth and Safety Plan El Readily available 13 Up to date CD N/A 13 Contingency plan/emergency response plan 13 Readily available El Up to dale DN/A Remarks
3. O&M nnd OSHA Training Records [H Readily available CD Up to date DN/A Remarks
4. Permits nnd Service Agreement* l~l Air discharge1 permit D Readily available CJ Up to date • DM/A El Effluent discharge CD Readily available CD Up to date DN/A D Waste disposal, POTW CD Readily available CD Up to date DNVA CD Other pemi its CD Readily available CD Up to date ON/A Remarks Effluent discharces to public water supply or drainage surface water. Discharge standards are 100 ue/L total chromium for drinkinc water discharge and 17 uc/L hexavalent chrome and 100 ua/L total chrome for surface water discharge. However, there are no discharge permit? fpr ifojs, sj(e, 5. Gas Generation Records D Readily available Q Up to date El N/A . Remarks
6. Settlement Monument Records CD Readily available CD Up to date El N/A Remarks
7. Groundwater Monitoring Records El Readily available El Up to date CD N/A Remarks
X. Lciichute Extraction Records CD Readily available l~l Up to date El N/A Remarks
9. Dischnrge Coni|pliance Records DAir D Readily available D Up to date QN/A El Water (effluent) El Readily available El Up to date ID N/A Remarks
10. Daily Access/Security Logs CD Readily available CD Up to date El N/A Remarks No daily access .c;ecuritv loss
Five-year Review Report - 3 ACE SERVICES SITH I-'IVE-YEAR REVIEW KEI'OKT
IV. O&M COSTS O&M Organization Slate in-house [~l Contractor for State PRP in-houso Q Contractor for PRP Federal Facility' in-house [3 Contractor for Federal Facility Other City of Colby is the plant operator. Black and Veatch provide technical support_
O&M Cost Records El Readily available [3 Up to date l~l Funding mechanism/agreement in place Original O&M cost estimate F~l Breakdown attached
Total annual cost by year for review period if available
From To d Breakdown attached Date Date Total cost From To l~l Breakdown attached Date Dale Total cost From To CD Breakdown attached Date Date Total cost From To C] Breakdown attached Date Date Total cost From To d Breakdown attached Date Date Total cost
Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: No
V. ACCESS AND INSTITUTIONAL CONTROLS Q Applicable
A. Fencing
1. Fencing damaged C] Location shown on site map d Gates secured RlN/A Remarks
I). Other Access Restrictions 1. Signs and other security measures 13 Location shown on sitemap DN/A Remarks There is a sign on the front door of the treatment building
Five-year Review Report - 4 ACE SERVICES SITE FIVE-YEAR REVIEW REPORT
C. Institutional Controls (ICs) 1. Implementation and enforcement Site conditions imply ICs not properly implemented d Yes d No d N/A Site conditions imply ICs not being fully enforced d Yes d No d N/A
Type of monitoring (e.^., self-reporting, drive by) Frequency Responsible parly/agency Contact Name Title Date Phone no.
Reporting is up-io-datc d Yes d No d N/A Reports arc verified by the lead agency d Yes dNo [~1N/A
Specific requirements in deed or decision documents have been met d Yes dNo d N/A Violations have been reported d Yes d No d N/A Other problems or suggestions: d Report attached Residents in downgradient area of plume are monitored There is a city ordnance in place preventing installation of residential supply wells.
2. Adequacy d ICs are adequate d ICs are inadequate l~l N/A Remarks
I). General Vandalism/trespassing d Location shown on site map £3 No vandalism evident Remarks Minimal in past. No signs of vandalism currently present.
Land use changes on site d N/A Remarks None
3. Land use changes off sited N/A Remarks None
VI. GENERAL SITE CONDITIONS A. Roads d Applicable DM/A 1. Roads damaged d Location shown on site map [3 Roads adequate l~lN/A Remarks Unimproved road to some of the downgradient extraction wells. May require four-wheel- drive during wet conditions 'out no problems navigating with standard passenger vehicle during site inspection.
Five-year Review Report - 5 riVH-YEAK Kl-VIEW KEI'OKT
B. Other Site Conditions Remarks
vn. LANDFILL COVERS D Applicable QN/A A. landfill Surface [. Settlement (Lov/ spots) l~l Location shown on site map CD Settlement not evident Area! extent Depth Remarks
~- Crncks l~l Location shown on site map CD Cracking not evident Lengths Widths Depths Remarks
3. Erosion l~l Location shown on site map l~l Erosion not evident Areal extent Depth Remarks
-I. Holes l~l Location shown on site map CD Holes not evident Areal extent Depth Remarks
5. Vegetative Cover CD Grass CD Cover properly established l~l No signs of stress • Trees/Shrubs (indicate size and locations on a diagram) Remarks fj. Alternative Cover (armorc d rock, concrete, etc.) f~l N/A Remarks
7. Bulges l~l Location shown on site map CD Bulges not evident Areal extent Height' Remarks
Five-year Review Report - 6 ACIISliKVlCI;SSITE Kivi.;-YEAk REVIEW REPORT
Wet Areas/Water Damage CI Wet areas/water damage not evident d Wet areas l~l Location shown on site map Arcal extenl_ Q Ponding l~l Location shown on site map Areal extcnt_ D Seeps l~1 Location shown on site map Areal extent_ d Soft subgradu: l~l Location shown on site map Areal cxtcnt_ Remarks
9. Slope Instability CH Slides d Location shown on site map D No evidence of slope instability Areal extent Remarks
B. Benches D Applicable (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
I. Mows Bypass Bench I I Location shown on site map l~l N/A or okay Remarks
Bench BrencheiJ [~l Location shown on site map D N/A or okay Remarks
3. Bench Overtopped ocation shown on site map N/A or okay Remarks
C. Letdown Channels D Applicable [UN/A (Channel lined with erosion control mats, riprap, grout bags, or gsibions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)
I. Settlement [U Location shown on site map l~l No evidence of settlement Arcal extent_ Depth Remarks
Material Degradation Location shown on site map [3 No evidence of degradation Material type Arcal extent _ Remarks
Erosion [3 Location shown on site map l~l No evidence of erosion Areal extent_ Depth Remarks
P'ivc-year Rev iew Report - 7 ACI! SERVICES SITU rivL-:-Yr-/\K REVIEW REPORT
4. Undercutting CD Location shown on site map CD No evidence of undercutting Areal extent Depth Remarks
5. Obstructions Type CD No obstructions • Location shown on site map Areal extent Size Remarks
6. Excessive Vegel at Kre Growth Type 1 1 No evidence of excessive growth l~l Vegetation in channels does not obstruct flow l~l Location shown on site map Areal extent Remarks
D. Cover Penetrations CD Applicable CD N/A 1. Gas Vents [D Active CD Passive CD Properly secured/locked CD Functioning l~l Routinely sampled CD Good condition CD Evidence of leakage at penetration l~l Needs Maintenance DM/A Remarks
2. Gas Monitoring Probes CD Properly secured/locked l~l Functioning l~l Routinely sampled CD Good condition CD Evidence of leakage at penetratjon CD Needs Maintenance CD N/A Remarks
3. Monitoring Wells (within surface area of landfill) CD Properly secured/locked CD Functioning CD Routinely sampled CD Good condition CD Evidence of leakage at penetration CD Needs Maintenance CD N/A Remarks
•1. Leachate Extraction Wells CD Properly secured/locked CD Functioning CD Routinely sampled CD Good condition CD Evidence of leakage at penetration CD Needs Maintenance C3N/A Remarks
5. Settlement Monuments CD Located CD Routinely surveyed DN/A Remarks
Five-year Review Report - 8 ACE SERVICES SITE FIVE-YEAR REVIEW REI'ORT
E. Gas Collection and Treatment D Applicable D N/A I. Gas Treatment Facilities [~l Flaring f~1 Thermal destruction l~l Collection for reuse CD G ood condition CD Needs Maintenance Remarks
Gas Collection Wells, Manifolds and Piping l~1 G ood condition Q Needs Maintenance Remarks
.3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) CD Good condition [D Needs Maintenance l\ N/A Remarks
F. Cover Drainage Layer l~l Applicable DN/A I. Outlet Pipes Impeded l~l Functioning DN/A Remarks
Outlet Rock Inspected l~l Functioning DN/A Remarks
G. Detention/Sedimentation Ponds d Applicable DN/A Siltaf ion Areal extent Dcpth_ DN/A C] Siltation not evident Remarks
Erosion Areal extent_ Depth d Erosion not evident Remarks
Outlet Works Functioning l~1 N/A Remarks
Dam CD Functioning l~l N/A Remarks
Five-year Review Report - 9 ACT-SEKVIU-.S.SITI: l:IVl:-YEAR REVIEW REPORT
R Retaining Walls D Applicable D N/A 1. Deformations [3 Location shown on site map [~1 Deformation not evident Horizontal displnccment Vertical displacement Rotational displacement Remarks
*1 Degradation [] Location shown on site map d Degradation not evident Remarks
I. Perimeter Ditches/Off-Site Discharge D Applicable D N/A 1. Siltntion d Location shown on site map O Siltation not evident Areal extent Depth Remarks
2 Vegetative Growth [^ Location shown on site map DN/A O Vegetation dues not impede flow Areal extent Type Remarks
3. Erosion CD Location shown on site map l~l Erosion not evident Areal extent Depth Remarks
-1. Discharge Structure [] Functioning CD N/A Remarks
VIU. VERTICAL BARRIER WALLS D Applicable QN/A 1. Settlement C] Location shown on site map [~l Settlement not evident Areal extent Depth Remarks
2 Performance Monitoring Type of monitoring fl Performance not monitored Frequency D Evidence of breaching Head differential Remarks
Five-year Review Report -10 ACI7 SHRVICIHSSITI.- I:IVL:-YEAR REVIEW REPORT
LX. GROUKDWATER/SURFACE WATER REMEDIES H Applicable CD N/A A. Groundwaler Extraction Wells, Pumps, and Pipelines H Applicable [~lN/A 1. Pumps, Wellhead Plumbing, and Electrical 13 Good condition 13 All required wells properly operating CD Needs Maintenance^ N/A Remarks
*•• Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances 13 Good condition CD Needs Maintenance Remarks
3. Spare Parts and Equipment S Readily available |3 Good condition CD Requires upgrade !~l Needs to be provided Remarks
a Surface Water Collection Structures, Pumps, and llpelines 13 Applicable CD N/A i. Collection Structures, Pumps, and Electrical 13 G ood condition CD Needs Maintenance Remarks
2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances E3 G ood condition [D Needs Maintenance Remarks
\ Snare Parts and Equipment C>3 Readily available CD Good condition CD Requires upgrade CD Needs to be provided Remarks
Five-year Review Report - 11 AC1: SlikVICI-SSITIi i:ivi.:-YE/\i< REVIEW RETORT
C. Treatment System Kl Applicable DN/A I. Treatment Train (Check components that apply) H Metals removal ED Oil/water separation l~l Bioremediation ED Air stripping 13 Carbon adsorbers Rl Filters Bng, Resin Trap Filter, Resin, Carbon Adsorbers associated with High Plains_ ED Additive (e.g., chelation agent, flocculent) ED Others E3 Good condition ED Needs Maintenance 13 Sampling polls properly marked and functional 13 Sampling/maintenance log displayed and up to date 13 Equipment properly identified 13 Quantity of groundwater treated annually 365.000.QQO gallons ED Quantity of surface water treated annually Remarks
Electrical Enclosures and Panels (properly rated and functional) f~l N/A H Good condition l~l Needs Maintenance Remarks
Tanks, Vaults, Storage Vessels D N/A 13 Good condition [~l Proper secondary containment l~l Needs Maintenance Remarks
Discharge Structure and Appurtenances ED N/A |3 Good condition l~l Needs Maintenance Remarks
Treatment Ouilding(s) l~l N/A IxiGood condition (esp. roof and doorways) [~l Needs repair n Chemicals and equipment properly stored Remarks
6. Monitoring Wells (pump and treatment remedy) ED Properly secured/locked ED Functioning ED Routinely sampled 13 Good condition [D All required wells located d Needs Maintenance CD N/A Remarks Not ell wells inspected but ones inspected during site visit were in good condition
D. Monitoring Data 1. Monitoring Data E3 Is routinely submitted on lime 13 Is of acceptable quality Monitoring data suggests: roundwater plume is effectively contained 13 Contaminant concentrations are declining
Five-year Review Report - 12 ACE SEKVICIZS SITE I;IVI--YI:AR Review KL-POKT
D. Monitored Natural Attenuation
1. Monitoring Wells (natural attenuation remedy) 18 Properly secured/locked [3 Functioning IS Routinely sampled ISI Good condition CH All required wells located D Needs Maintenance l~l N/A Remarks
X. OTHER REMEDIES If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition ofany facility associated with the remedy. An example would be soil vapor extraction.
XI. OVERALL OBSERVATIONS Implementation of the Remedy
Describe issues ;ind observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.).
B. Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectivencss of the remedy.
Five-year Review Report 113 AC1I SERVICES SITU AR REVIEW REPORT
c. Early Indicators of Potential Remedy Problems Describe issues und observations such as unexpected chnnges in the cost or scope of O&M or n high frequency of unscheduled repairs, that suggest that the protcctivcncss of the remedy may be compromised in the future.
D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Five-year Review Report - 14 ACI- SERVICES SITU JilVLj-YEAK REVIEW REPORT
Attachment C
Site Inspection Photographs
North Side of Treatment Building
Influent and Effluent Tanks – South Side of Treatment Building
Truck Access Door – South Side of Treatment Building
Effluent Discharge Pipe to Tributary to Prairie Dog Creek
Treatment Plant Control Panel
O&M Manuals and As-built Drawings
Resin Tanks - Treatment Train B
Ion Exchange Lead Vessel – Treatment Train B
Ion Exchange Lag Vessel – Treatment Train B
Ion Exchange Offline Vessel – Treatment Train B
Influent Sample Port – Note Minor Rust on Piping
Sample Port SC-7: Train B Effluent Sample Location
View Between Treatment Trains
Overview of Treatment Facility – Looking West
Building Housing GAC High Plain COOP GAC Unit
Monitoring Wells Associated with High Plains COOP VOC Plume
Protective Building - Former City Production Well PWS-8
Inside PWS-8 Building
EX-3D Protective Building – Typical for All Extraction Wells
Interior of Building Housing EX-4S – Typical for All Extraction Wells
Ace Recovery Well