# Second Five-Year Review Report Rogers Road Municipal Landfill Pulaski County, Arkansas

September 2005

Region 6 United States Environmental Protection Agency Dallas, TexasR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# SECOND FIVE-YEAR REVIEW Rogers Road Municipal Landfill Superfund Site EPA ID# ARD981055809 Pulaski County, Arkansas This memorandum documents United States Environmental Protection Agency (EPA) approval of the Rogers Road Municipal Landfill Superfund Site Five-Year Review Report. Summary of Five-Year Review Findings
The second five-year review of the Rogers Road Municipal Landfill site (“site” or “Rogers Road site”) located near Jacksonville, in Pulaski County, Arkansas, was completed in September 2005. The results of the second five-year review indicate that the remedy is protective of human health and the environment. Overall, the remedial actions performed appear to be functioning as designed, and the site has been maintained appropriately. No deficiencies were noted that impact the protectiveness of the remedy. The remedy was chosen to remove the principal health threats that presented excess lifetime cancer risk, prevent further actual or threatened releases of hazardous substances from the site, and establish a method of long term monitoring to ensure protectiveness. Materials containing above10 parts per billion (ppb) dioxin concentrationswere removed and incinerated at the nearby Vertac Superfund site, and the affected areas were backfilled and re-graded. Soil cover was placed on materials that were between 1 and 10 ppb dioxin level, greater than 37 ppb dieldrin, and dieldrin and herbicide contamination associated with a hazard index above 0.7. Operations and maintenance (O&M) at the site consists of site inspections to confirm fence integrity, and maintenance of the soil cover. Site inspections show that the fencing is effectively preventing access to the site and site groundwater. Because no contaminants of concern defined by the Record of Decision were detected in the four years of annual groundwater monitoring, the Arkansas Department of Environmental Quality (ADEQ) recommended discontinuing groundwater monitoring. EPA concurred that this recommendation was appropriate to implement, and ground water monitoring was stopped after 1997. The site was to be deleted from the National Priorities List (NPL), but has been held up over the issue of institutional controls. Counsel for EPA and the City of Jacksonville had correspondence and discussions over the issue during the period of 1999 through 2002. The issue was complicated by the fact that the site property was reported to be in private hands with no clear record of title among numerous potential heirs, and lengthy delay ensued. In September 2003, an action to quiet title to the site property, which the City Attorney had facilitated and assisted, was successfully concluded in state court. In August 2005, in consultation with the EPA Office of General Counsel, the EPA Region 6 attorney and the Jacksonville City Attorney renewed efforts to resolve the issue of enactingR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Table of Contents

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# Section Page Summary of Five-Year Review Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-1 

# Determinations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-2 

# Concurrence Signatures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-3 

# List of Acronyms

............................................................. iii 

# Five-Year Review Summary Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
1. Introduction ...........................................................1 2. Site Chronology ........................................................3 3. Background ...........................................................3 4. Remedial Actions .......................................................6 4.1 Remedy Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 4.2 Remedy Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 4.3 Operations and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 4.4 Progress Since Initiation of Remedial Action ............................9 5. Five-Year Review Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 6. Five-Year Review Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 6.1 Interviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 6.2 Site Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 6.3 Standards Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 6. 4 D ata Revi ew
..................................................... 1 5 7. Assessment

........................................................... 1 7 8. Deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 9. Recommendations and Follow-up Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 10. Protectiveness Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 11. Next Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Figures Figure 1: Site Map

Tables Table 1: Chronology of Site EventsR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT 

# Table of Contents

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# Attachments Attachment 1: References Attachment 2: Interview Record Forms Attachment 3: Site Inspection Record with PhotographsR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# List of Acronyms ADEQ Arkansas Department of Environmental Quality ADPC&E Arkansas Department of Pollution Control and Ecology ARARs Applicable or Relevant and Appropriate Requirements CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CD Consent Decree CDC Center for Disease Control CFR Code of Federal Regulations E&E Ecology and Environment ERCS Emergency Response Clean-up Service EPA United States Environmental Protection Agency FR Federal Register HI Hazard Index LDR Land Disposal Restrictions NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List MCLs Maximum Contaminant Limits O&M Operation and Maintenance OSWER Office of Solid Waste and Emergency Response OUs Operable Units ppb part per billion RCRA Resource Conservation and Recovery Act RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision TAT Technical Assistance Team TBC To Be Considered TCDD Tetrachlorodibenzo-p-dioxinR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Five-Year Review Summary Form SITE IDENTIFICATION Site name (from WasteLAN): Rogers Road Municipal Landfill EPA ID (from WasteLAN): ARD980809941 Region: EPA Region 6 State: AR City/County: Jacksonville/Pulaski SITE STATUS NPL Status: : Final 9 Deleted 9 Other (specify): Remediation status (choose all that apply): 9 Under Construction 9 Operating : Complete Multiple OUs? 9 Yes : No Construction completion date: September 1995 Has site been put into reuse? : Yes 9 No [Tree farming; municipal beautification] REVIEW STATUS Reviewing agency: : EPA 9 State 9 Tribe 9 Other Federal Agency: Author: Shawn Ghose M.S., P.E., RPM EPA Region 6, 6SF-AP Review period: September 2000 to September 2005 Date(s) of site inspection: September 9, 2005 Type of review: : Statutory 9 Policy 9 Post-SARA 9 Pre-SARA 9 NPL-Removal only 9 Non-NPL Remedial Action Site 9 NPL State/Tribe-lead 9 Regional Discretion 

# Review number: 9 1 (first) : 2 (second) 9 3 (third) 9 Other (specify): Triggering action: 9 Actual RA Onsite Construction 9 Actual RA Start at OU# _____ 9 Construction Completion : Recommendation of Previous Five-Year Review Report 9 Other (specify): 

# Triggering action date (from WasteLAN): September 27, 2000 ( 1 st

# Five Yr Review) Due date (five years after triggering action date): September 27, 2005R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Second Five Year Review Summary Form

Deficiencies:
No deficiencies noted.
Recommendations and Follow-up Actions: • An appropriate instrument granting restrictive covenants that prohibit use of groundwater for human, livestock, and agricultural consumption or contact should be finalized and properly executed and recorded in the site deed records. • An explanation of significant differences (ESD) should be issued to reflect the early attainment of groundwater cleanup goals and the consequent cessation of annual groundwater monitoring. • Upon proper recording of appropriate restrictive covenants and issuance of an ESD, the process of deleting the site from the NPL should be initiated and completed.

Protectiveness Statement(s): The remedy completed for the Rogers Road Municipal Landfill site is protective of human health and the environment.

Other Comments:

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# Second Five-Year Review Report

Rogers Road Municipal Landfill
The United States Environmental Protection Agency (EPA) Region 6 has conducted the second five-year review of the remedial actions implemented at the Rogers Road Municipal Landfill site (“site” or “Rogers Road site”) located near Jacksonville, Pulaski County, Arkansas for the period September 2000 through September 2005. The purpose of a five-year review is to determine whether the remedy at a site is protective of human health and the environment. This report documents the results of the review for this site, conducted in accordance with EPA guidance on five-year reviews.

Existing EPA guidance on five-year reviews includes the following: • Office of Solid Waste and Emergency Response (OSWER) Directive 9355.7-02 (May 23, 1991), Structure and Components of Five-Year Reviews (introduced five-year review requirements). • OSWER Directive 9355.7-02FS1 (August 1991), Fact Sheet: Structure and Components of Five-Year Reviews

. • OSWER Directive 9355.7-02A (July 26, 1994), Supplemental Five-Year Review Guidance (introduced level of review considerations for sites where response is ongoing). • OSWER Directive 9355.7-03A (December 21, 1995), Second Supplemental Five-Year Review Guidance(identified three purposes of five-year review and emphasized that reviews must include a signed protectiveness determination, along with recommendations to correct deficiencies.

Guidance provided in these documents has been incorporated into the five-year review performed for this site, as have the concepts outlined in the Draft Comprehensive Five-Year Review Guidance , October 1999, OSWER Directive 9355.7-03B-P.



# 1.0 Introduction The second five-year review for the Rogers Road Municipal Landfill site is required by statute.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Statutory reviews are required for sites where, after remedial actions are complete, hazardous substances, pollutants, or contaminants will remain onsite at levels that will not allow for unrestricted use or unrestricted exposure. This requirement is set forth by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). Statutory reviews are required only if the ROD was signed on or after the effective date of the Superfund Amendments and Reauthorization Act of 1986 (SARA). CERCLA §121(c), as amended by SARA, states:

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

The NCP §300.430(f)(4)(ii) of the Code of Federal Regulations (CFR) 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.

This is the second five-year review for the Rogers Road Municipal Landfill site. The triggering action for this statutory review is the date of the first five-year review September 27,2000. This review is required because hazardous substances, pollutants, or contaminants were left onsite above levels that allow for unlimited use and unrestricted exposure, and the Record of Decision (ROD) called for institutional controls limiting groundwater use on and immediately down gradient of the site (EPA, 1990).R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# 2.0 Site Chronology A chronology of significant site events and dates are included in Table 1, provided at the end of the report text. A reference list is provided in Attachment 1.


# 3.0 Background The Rogers Road Municipal Landfill site is about one acre of the ten-acre landfill located outside the city limits of Jacksonville in Pulaski County, Arkansas. The site is approximately 12 milesnortheast of Little Rock, Arkansas. The landfill is situated immediately east of Rogers Road, onetenth mile south of Graham Road. The southern portion of Rogers Road which adjoins the landfill is unpaved. Land records at the Pulaski County Courthouse describe the plot of land as the east half of the northeast quarter of Secti on 28, Township 3 North and Range 10 West (EPA, 1990). Less than one-half mile east of the Rogers Road Municipal Landfill Superfund site the Jacksonville Municipal Landfill Superfund site (see Figure 1). Because of the proximity of the sites and the similarities in their features and characteristics, the site characterization and remedial action activities for these sites were carried out concurrently.

The Rogers Road Municipal Landfill site is located within a residential and agricultural area. The area to the north, south, and east is wooded. Rogers Road adjoins the site to the immediate west (see Figure 1); the property beyond Rogers Road to the west is agricultural. There is a fairly high population density within one-half mile radius of the site (approximately 51 single-family homes); areas further out are more sparsely populated. At the time of the ROD it was assumed that approximately 153 to 204 people lived within a one-half mile radius (EPA, 1990). The ROD also stated that the landfill was located in a predominantly agricultural area, the area did not lend itself to commercial types of development, that there were no businesses or commercial areas located within one and one-half miles of the site, and that the types of receptors were not expected to change in the foreseeable future. Observations during the June 2000 site inspection (see Section 6) indicate this continues to be the case.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# A residential well inventory was conducted as part of the Remedial Investigation (RI) and information was collected from residences near the landfill. The City of Jacksonville installed a municipal water system which has served the residents in the area of Rogers Road since sometime prior to 1974 (EPA, 1990). Reportedly only one residence near the Rogers Road Landfill ever used groundwater, and this household stopped using the well when municipal water was made available. The other residences were reported to have used only the City water system.

The City of Jacksonville acquired the property on September 16, 1953. Approximately half of the site was used intermittently as a municipal waste disposal facility, in conjunction with the Jacksonville Landfill (see Figure 1), until October 1974. The landfill was closed when the Arkansas Department of Pollution Control and Ecology (ADPC&E, now Arkansas Department of Environmental Quality [ADEQ]) refused to grant a landfill permit because of the high water table and poor drainage in the area.

Records indicate that open burning and trenching with bucket and dragline were the waste handling methods used until 1974, along with open dumping and landfilling. During the years that the facility was operated, the site was run as a typical sanitary landfill and not a permitted RCRA disposal facility. As a result, companies which hauled waste to the landfill were not required to provide the site operator with detailed information regarding generators, waste types, or quantities. No detailed records indicating specific waste types or quantities are known to have been kept by the site owner/operator, making identification of generators and operators difficult.

Wastes appear to have been disposed of in one long trench and in several surface piles, accompanied by open dumping in numerous areas around the site, which appear to have been covered with a layer of soil. After the landfill was closed, local residents continued to use the site as an open dump until the site was fenced. To prevent unauthorized access, the City of Jacksonville fenced the portion of the facility used for burning and land disposal (a 300 by 237 foot area) in 1986. Wastes from the Vertac Superfund site in Jacksonville, Arkansas, whichR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# produced numerous chemical products including dioxins, are believed to have been disposed of atthe Rogers Road site. An estimated 15 to 50 drums of dioxin contaminated herbicidemanufacturing waste were disposed at the landfill.

The Rogers Road Municipal Landfill was identified to EPA on May 10, 1983, through a citizen’s complaint. At that time, EPA was conducting a site inspection of the Jacksonville Landfill. After a field investigation, the Rogers Road Municipal Landfill was proposed for inclusion on the National Priorities List (NPL) of uncontrolled hazardous waste sites on January 22, 1987. The site was added to the NPL on July 22, 1987.

A Remedial Investigation (RI) was conducted between November 1988 and March 1990, and a risk assessment was performed based on the analytical findings of the RI. The results of the RI and risk assessment and prior investigations are summarized in the RI Report (Peer and Resource Applications, Inc., 1990a). The Feasibility Study (FS) was also released at this time (Peer and Resource Applications, 1990b). Onsite soil and decaying drums were found to be contaminated with dioxin (2,3,7,8-tetrachlorodibenzo-p-dioxin [T CDD] equivalents), the herbicides 2,4-D and 2,4,5-T, and the pesticide dieldrin (EPA, 1996).

The investigations undertaken at the Rogers Road landfill revealed that contaminates in the soil comprised the principal threat posed by the site. A remedy was chosen based on the following criteria:

• Remedy the contaminated soil using thermal treatment and soil cover to ensure it no longer presents a threat to human health or the environment.

• Eliminate the health risks due to ponded water onsite by filling in the existing site trenches with clean fill.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# • Establish a method of long term monitoring to ensure that the soil cover is properly maintained and the groundwater quality is adequately monitored. (EPA, 1990)

The remedial actions undertaken to meet these criteria are described in the following paragraphs.



# 4.0 Remedial Actions The remedial action completed at the Rogers Road Municipal Landfill Superfund site included removal and incineration at the nearby Vertac Superfund site of materials containing concentrations of dioxin above10 ppb, and backfilling and regrading of the affected areas. The remedy also included placement of soil cover over materials demonstrating concentrations between 1 and 10 ppb dioxin, greater than 37 ppb dieldrin, and dieldrin and herbicide contamination associated with a hazard index (HI) above 0.7. A total of 200 cubic yards and 76 drums of material were removed, treated, and disposed at Vertac.

Included in the following subsections is a description of the remedy selection process employed at the Rogers Road Municipal Landfill Superfund site, the implementation of the remedy, the Operations and Maintenance (O&M), and the progress made at the site since initiation of remedial action and construction completion.

4.1 Remedy Selection The ROD for this site was signed on September 27, 1990. The selected remedy included: • Excavation of contaminated soil and debriscontaining greater than 10 ppb equivalent 2,3,7,8- TCDD and backfilling the excavated area. • Transportation of the excavated material to the Vertac Superfund site in Jacksonville, Arkansas. • Incineration of the excavated contaminated material and disposal of residuals at Vertac.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# • Steam-cleaning and disposal of large items of refuse removed from contaminated areas at the Rogers Road site. • Covering soil, debris and water meeting the criteria stated below with twelve inches of soil: - 2,3,7,8-TCDD concentrations >1.0 and # 10 ppb - Cumulative HI >.7 for 2,4,5-T; 2,4,5 TP; and dieldrin, or - Dieldrin >37 ppb. • Backfilling the site trench; • Institutional controls such as fence maintenance and land-use restrictions limiting ground water use on and immediately down gradient of the site; and • Ground water monitoring.

On June 20, 1994, a Consent Decree (CD) between EPA and the City of Jacksonville regarding the site was entered in United States District Court. This CD and the CD for the nearby Jacksonville Landfill site were the first in the country between a municipality and EPA that utilized this type of mixed work settlement. Under the agreement, EPA performed the work that involved handling the hazardous substances, including excavation of the hot spots of contamination, transporting the material to Vertac, incineration, and decontamination. The City performed the non-hazardous work, including fencing, backfilling, grading, re-vegetating, inspection and maintenance, installation of additional groundwater wells, groundwater sampling and analysis, and land-use controls.

4.2 Remedy Implementation On August 22, 1995, Ecology and Environment (E&E), the EPA Technical Assistance Team (TAT) and the Emergency Response Clean-up Service (ERCS) contractor, Reidel-Peterson, mobilized to begin remedial operations at the site. After preliminary road work was completed, excavation of contaminated soil was initiated.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# During the action, Reidel-Peterson re-containerized contaminated material that was in decaying drums and excavated soil. This material, along with investigation-derived waste such as contaminated personal protective equipment, was transported to the Vertac Superfund site for treatment at the incinerator. Confirmation soil samples were collected after this initial excavation to verify the degree of contaminant removal and to determine the areas of moderate contamination (2,3,7,8-TCDD concentrations >1.0 and # 10 ppb and dieldrin >37 ppb) which would later be covered with clean soil.

A total of 200 cubic yards of contaminated soil and 76 drums of hazardous materials (including 19 drums of investigation-derived wastes) were transported to Vertac and incinerated. This is a higher volume than the 130 cubic yards estimated in the ROD. Despite this increase in volume, remedial activities went smoothly. Incineration at Vertac began on October 20, 1994, and ended on December 4, 1994. The January 20, 1995, Technical Assistance Report for the Rogers Road Municipal Landfill written by E&E (E&E, 1995), details the remedial action activities performed by EPA and its contractors.

The total cost for the action was $129,070.00 for the excavation, preliminary sampling, and transportation of the waste and $1.07 million for the confirmatory sampling and incineration at Vertac.

During the fall of 1994, the City of Jacksonville continued regrading activities and installed three additional groundwater monitoring wells between the Jacksonville Landfill and the Rogers Road Landfill as required by the ROD and CD. The City demobilized in late October when heavy rains in the area made passage through the site difficult. City activities recommenced in July 1995 when the site was sufficiently dry for vehicles to pass. The City regrading activities were completed in September 1995.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# 4.3 Operations and Maintenance The City of Jacksonville, as agreed upon in the CD and accompanying Statement of Work and as detailed in the Remedial Action Work Plan (City of Jacksonville, 1994), has assumed all responsibility for O&M at the Rogers Road site. O&M activities include routine site inspections to ensure that positive drainage is occurring, and maintenance of perimeter fencing. These activities maintain the protectiveness of the remedy.

The ROD specified annual groundwater monitoring for up to thirty years to ensure that the remedy was effective and operating properly (with review every five years to determine continued necessity). ADEQ assumed responsibility for groundwater monitoring, and performed the monitoring for four annual events, from 1994 to 1997. Because no COCs as defined by the ROD were detected during these four events, ADEQ recommended cessation of the groundwater monitoring after the 1997 event. EPA agreed and groundwater monitoring was suspended, however, an explanation of significant differences should be issued to reflect this determination.

See Section 6.2 for a discussion of projected versus actual annual O&M costs.

4.4 Progress Since Initiation of Remedial Action All remedial action construction requirements have been completed. The site is fenced and the City of Jacksonville is controlling access to the site and site groundwater. ADEQ has provided official concurrence for deleting the site from the NPL once restrictive covenants are in place restricting groundwater use (ADEQ, 1999a). These restrictive covenants are the type of institutional controls contemplated in the siteRecord of Decision (EPA, 1999a). The City of Jacksonville is in the process of putting the restrictive covenants in place, pending resolution of legal issues associated with title to the remediated area (EPA, 2000; EPA, 2000a; City of Jacksonville, 2000, EPA, 2002, EPA, 2005). The process has not been fully resolved since the September 2000 review. However, with the City Attorney’s facilitation and assistance, an action to quiet title to the site property was successfullypursued in the Circuit Court of Pulaski County,R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Arkansas. The decree that resulted in the fall 2003 from that action has cleared up considerable confusion over the ownership of the site property, and put the City in a position to work with the site property owners to execute and record proper restrictions on land use. In August 2005, the EPA Region 6 attorney and the Jacksonville City Attorney initiated serious discussions, assisted by support from the EPA Office of General Counsel, over the proper form of an instrument granting an easement and restrictive covenants to the City, but providing a right of enforcement in the EPA as a third party beneficiary to the grant. This process is expected to come to fruition very soon with the execution and proper recording of that instrument. Once this process has been completed and an explanation of significant differences has been issued for the site, the process of site deletion from the NPL should be initiated and followed through to completion.

Control of groundwater use immediately down gradient of the site is not strictly enforceable, but residents are on municipal water supply. ADEQ had requested that the solid waste regulatory authority be notified of the detection of low levels of non-site-related metals in the monitoring wells that may be caused by leaching from the municipal landfill. This notification has been accomplished.

O&M procedures appear to be adequate with O&M frequency being maintained as per the O&M plan instituted following construction completion (reporting to EPA is not required). As discussed previously, groundwater monitoring at the site was discontinued due to the repeated lack of detection of COC’s as defined in the ROD, thus indicating the achievement of cleanup goals for groundwater; and the EPA has agreed with this approach, subject to the caveat that it should be adopted in an explanation of significant differences for the site remedy. The imminent recording of restrictive covenants for the site property that control groundwater use should ensure that there are no pathways available for human or livestock contact with, or consumption of, groundwater from the site.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# 5.0 Five-Year Review Process This five-year review has been conducted using the concepts found in EPA’s Draft Comprehensive Five-Year Review Guidance , dated October 1999 (EPA, 1999), and in accordance with the guidance contained in the existing final five-year review guidance documents that are listed on page 1 of this report. The EPA will make information available to the public regarding the five-year review through the Rogers Road site status summary on EPA’s Region 6 website, at http://www.epa.gov/earth1r6/6sf/pdffiles/rogersrd.pdf . It is EPA’s intention to advertise the availability of the five-year review report in a newspaper local to the site and on the site status summary website referenced above, and to provide a copy of the report to the site information repositories. The five-year review consisted of interviews with relevant parties, a site inspection, and a review of applicable data and documentation covering the period of the review. The findings of the review are described in the following section.


# 6.0 Five-Year Review Findings The information collected during the interviews, the site inspection, and the data review are described in the following subsections.

6.1 Interviews Interviews were conducted with the Mayor of the City of Jacksonville, and with a representative of ADEQ at the City of Jacksonville offices and at the Jacksonville and Rogers Road Municipal Landfill sites on September 9, 2005. Interview Record Forms which document the issues discussed during these interviews are provided in Attachment 2.

An interviews was conducted with Mayor Tommy Swaim of the City of Jacksonville by the EPA site RPM Shawn Ghose, as well with Brian Wakelyn of the ADEQ. In addition, during the conduct of the site inspection, RPM Shawn Ghose had an opportunity to discuss site O&M with Mr. Jay Whisker the city engineer who is in charge of maintaining the O&M. The overallR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# impression from all respondents was that the remedy implementation went smoothly and had a positive effect on the surrounding community. The health risks were removed, the grading done at the site as part of the remedy resulted in drainage improvements, and the site is now maintained, whereas prior to remedy implementation, and the entire site was overgrown. No community concerns have been expressed regarding this site since the last five-year review in September 2000.

6.2 Site Inspection A site inspection was conducted at the site on September 9, 2005. The completed site inspection record is provided in Attachment 3, along with an inspection report provided by the City of Jacksonville and associated photographs.

The area around the site along Rogers Road is densely wooded. The fencing around the site appeared intact and secure, although no signs were posted on the fence or the gate. No vandalism was evident, and the roads were adequate. The soil cover appeared to be in good condition; no settlement, cracks, or erosion was evident. The site was dry on the day of the site inspection and appeared well-graded. The presence of poison oak, poison ivy, and numerous ticks were observed.

The site is situated in a natural low area, however, and standing water in the area surrounding Rogers Road Landfill has been noted previously by the City of Jacksonville staff following rain events. Monitor well surface completions appeared to be in good condition. Not all wells were located during the site inspection due to the presence of dense vegetation, including poison oak and ivy, and the abundance of ticks observed in the area. The wells are visited by City personnel during the periodic inspections several times per year.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# 6.3 Standards Review Applicable or Relevant and Appropriate Requirements (ARARs) for this site were identified in the ROD dated September 27, 1990. The First Five-Year Review included identification of and evaluation of changes in these ARARs to determine whether such changes may affect the protectiveness of the selected remedy.

The ROD identified the following ARARs as having an impact on the proposed remedy:

1. RCRA Land Disposal Restrictions (LDRs), as regulated under 40 CFR Part 268.

2. Transportation of hazardous wastes, as re gulated under 40 CFR Part 263 and 49 CFR Parts 107 and 171-177.

3. The operational standards and monitoring requirements for hazardous waste incinerators, as regulated under 40 CFR Part 264 Subpart O.

4. Guidance for the closure of open dumps as regulated under 40 CFR 256.23.

5. The post-closure care and monitoring requirements for hazardous waste disposal facilities as regulated under 40 CFR 264.117(a)(1).

6. Requirements to evaluate the potential impacts to flood plains as regulated under the Executive Order on Floodplain Management, Executive Order No. 11988.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# The Rogers Road Landfill ROD identified the following criteria as to be considered (TBCs) for the remedial action:

1. The Center For Disease Control’s (CDC’s) 2,3,7,8-TCDD concentration recommendations for residential settings of 1.0 ppb in surface soil and 10.0 ppb when covered by at least 12 inches of clean fill.

2. CERCLA section 104(d)(4), which allows EPA to treat noncontiguous facilities as one where those facilities are reasonably related on the basis of geography or threat.

3. 40 CFR Part 258 (Proposed), which contains the operating, design, closure, and post-closure criteria for municipal solid waste landfills.

4. 40 CFR Parts 260, 261, 264, and 270, which contain proposed standards for owners and operators of hazardous waste incinerators.

No state ARARs were identified in the ROD.

As noted in the First Five-Year Review, Hazardous waste incineration is no longer occurring as part of the site remedy, and the 40 CFR Part 264 Subpart O regulations no longer apply to the site. This also would apply to the regulations relating to hazardous waste incineration under 40 CFR Parts 260, 261, 264, and 270. In addition, since hazardous waste is no longer being transported at the site, the regulations at 40 CFR Part 263 and 49 CFR Parts 107 and 171-177 are no longer applicable.

Also noted in the First Five-Year Review, at that time there have been no changes to the regulations under 40 CFR 256.23 (guidance for closure of open dumps), and there had been no changes to Executive Order No. 11988 (flood plains). In addition, there had been no changes toR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# CERCLA section 104(d)(4) (noncontiguous facilities) . No promulgated changes could be found in the CDC’s concentration recommendations for 2,3,7,8-TCDD in the First Five-Year Review.

In addition, the First Five-Year Review noted there had been no changes to the regulatoryrequirements described under 40 CFR 264.117(a)(1). This regulation requires 30 years of postclosure care and monitoring or for another period determined by the Regional Administrator. The EPA had determined previously, based on groundwater sampling results, that the groundwater is not impacted by the COCs and that continued monitoring would not be necessary once restrictive covenants are in place at this site. The proposed regulations under 40 CFR Part 258 were promulgated on October 9, 1991 (56 FR 51016). The Rogers Road Landfill met the requirements for closure as a hazardous waste landfill under 40 CFR 264.117(a)(1), however, and the regulations of 40 CFR 258 would not apply.

The First Five-Year Review noted the EPA had promulgated changes in the LDRs with regards to the classification of contaminated soil (40 CFR 268.49, 63 FR 28602-28622). The remedy satisfies these ARAR requirements.

Based on the standards review conducted during the First Five-Year Review, it appeared that no new laws or regulations have been promulgated or enacted that would call into question the effectiveness of the remedy at Rogers Road to protect human health and the environment. No additional standards review has been conducted for this second five-year review.

6.4 Data Review Since the first five-year review (September 2000) there has been no change in the O&M procedures at the site, thus the only data to be reviewed are the proper maintenance of the cap, maintenance of proper drainage and the maintenance of the site fence which have all been adequately performed by the City of Jacksonville. For details of the data review for the first five year review the reader is directed to examine the September 2000 Five-Year Review.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# During the remedial action, the confirmatory sampling involved a 14 x 14 grid around all the areas that were visibly contaminated or shown to becontaminated during the remedial investigation. Sample locations that did not meet remedial action goals and all the adjacent grid locations were then re-excavated, and the entire re-excavated area was re-sampled. This process was continued until all grid locations met remedial action goals.

As per the ROD and the CD, areas where 2,3,7,8-TC DD equivalent concentrations were greater than or equal to 10 ppb were excavated and the material was transported to Vertac for incineration. In several areas, this involved excavation deeper than the one foot projected from previous investigations. A total of 200 cubic yards of waste material was removed. Final confirmatory sampling showed that removal of this quantity of material was sufficient to meet remedial action goals. The complete results of the confirmatory sampling are given in the Technical Assistance Report for the Rogers Road Municipal Landfill (E&E, 1995). The data contained in this report demonstrate that cleanup levels specified in the ROD were achieved.

Groundwater monitoring at the site was conducted concurrently with the groundwater monitoring of the Jacksonville Municipal Landfill Superfund site between 1994 and 1997. Five wells were sampled annually (MWR-01, MWR-05, MWR-08, MWR-09, and MWR-10 - see Figure 1) and submitted for analysis for dioxins, metals, volatiles, semivolatiles, and pesticides. None of the compounds of concern listed in the ROD (Equivalents of 2,3,7,8-TCDD, chlorophenols, herbicides, and pesticides) were observed during the four sampling events (ADEQ, 1999).

During the ground water monitoring period of 1994 to 1997 many wells exhibited metal concentrations. These metals are not contaminants of concern associated with the Superfund portion of the site, and are possibly associated with the municipal waste portions of the landfill.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# 7.0 Assessment Based on the site interviews, the site inspection, and the data review, it appears the remedy is functioning as intended by the ROD. The assumptions used at the time of the remedy selection are still valid, and no additional information has been identified that would call into question the protectiveness of the remedy. No erosion or standing water is evident at the site, onsite groundwater use is currently restricted by the Cityof Jacksonville through control of site access by fencing.

No COCs had been detected in groundwater during groundwater monitoring events conducted previously. Accordingly, there has been no groundwater monitoring since 1997, based upon the recommendation of the ADEQ and EPA concurrence with this recommendation. Although, as noted above in section 4.4, there was a delay in implementing the restrictive covenants primarily due to the substantial legal questions concerning title to the property, those were cleared up in a successful action to quiet title facilitated and assi sted by the Jacksonville City Attorney’s office, resulting in a court decree in the fall of 2003. This action provides the foundation for successful implementation of restrictive covenants that will strictly control the use of groundwater and prevent its use in connection with livestock, agriculture, gardens, and human consumption or contact. A recent effort by the EPA attorney and the Jacksonville City Attorney is anticipated to produce an appropriate grant of an easement and restrictive covenants that will meet the site’s requirements. This instrument should be properly executed and recorded. Additionally, an explanation of significant differences (ESD) shoul d be published to reflect the cessation of long term site groundwater monitoring. Once these actions have been accomplished, the EPA should initiate the site NPL Deletion process. The O&M process should continue and maintain the site to be protective of the human health and the environment.



# 8.0 Deficiencies No deficiencies were noted.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# 9.0 Recommendations and Follow-up Actions An appropriate instrument granting restrictive covenants that prohibit use of groundwater for human, livestock, and agricultural consumption or contact should be finalized and properly executed and recorded in the site deed records. An ESD should be issued to reflect the early attainment of groundwater cleanup goals and the consequent cessation of annual groundwater monitoring. Upon proper recording of appropriate restrictive covenants and issuance of an ESD, the process of deleting the site from the NPL should be initiated and completed.



# 10.0 Protectiveness Statement Once the restrictive covenants are properly recorded and an ESD has been issued, this site meets all the site completion requirements as specified in OSWER Directive 9320.2-3C, Procedures for Completion and Deletion of National Priorities List Sites and Update. Specifically, confirmatory sampling verified that the site has achieved the ROD cleanup standards: all contaminated soil and debris containing greater than 10 ppb equivalent 2,3,7,8-TCDD were excavated and all soil and debris with 2,3,7,8-TCDD concentrations >1.0 and # 10 ppb, or with a Cumulative HI >.7 for 2,4,5-T; 2,4,5 TP and dieldrin were either excavated or covered with one foot of clean soil. In addition, no soil was left onsite with a dieldrin concentration above 37 ppb, and the site was backfilled with clean soil. Ground water monitoring conducted after the remedial action was completed provides further assurance that implementation of the remedy eliminated the source of contamination at the site. The soil cover has been maintained since completion of the remedial action.

Because the remedial actions at the Rogers Road Municipal Landfill site are protective, the remedy for the site is protective of human health and the environment.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# 11.0 Next Review Since the second five year review was completed during September 2005, the next five-year review should be completed in or before September 2010. This review should include a site inspection and review of O&M procedures.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Table 1 Chronology of Site Events
Date Event May 10, 1983 Site was identified to EPA by citizen complaint July 22, 1987 Site added to the NPL list with a score of 29.64 November 1988- March 1990 Remedial Investigation and Risk Assessment conducted June 30, 1990 Remedial Investigation/ Feasibility Study report completed September 27, 1990 Record of Decision signed August 1994 - September 1995 Remedial Action acti vities conducted, start of review period November 1994 First annual groundwater monitoring event conducted. November 1995 Second annual groundwater monitoring event conducted. November 1996 Third annual groundwater monitoring event conducted. November 1997 Fourth annual groundwater monitoring event conducted; cessation of groundwater monitoring recommended due to lack of detections of site-related constituents. September 2000 First Five Year Review Report Completed.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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## Attachment 1 

# ReferencesR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Attachment 1 

# References Arkansas Department of Environmental Quality (ADEQ), 1999. Letter Report from Mr. Mike Bates/ADEQ to Mr. Bill Honker/U.S. EPA Region 6 regarding Jacksonville Landfill and Rogers Road Landfill Superfund Sites, Jacksonville, Arkansas . Summary of 4 th

# annual groundwater sampling event, November 17-19, 1997, and statistical evaluation of Events 1 through 4. April 12, 1999. Arkansas Department of Environmental Quality (ADEQ), 1999a. Letter from Randall Mathis, Director, to Myron Knudson, Director Superf und Division, EPA, regarding “Jacksonville and Rogers Road Landfills”. Provides ADEQ concurrence of deletion of the referenced sites from the NPL. June 21, 1999. Arkansas Department of Pollution Control and Ecology (ADPC&E), 1995. Letter Report from Mr. Devon Hobby/ADPC&E to Ms. Kathleen Aisling/U.S. EPA Region 6 regarding Jacksonville Landfill and Rogers Road Landfill Superfund Sites, Jacksonville, Arkansas. Summary of first annual groundwater sampling event, November-December 1994. March 28, 1995. City of Jacksonville, 2000. Letter from Robert Bamburg, City Attorney, City of Jacksonville, to James L. Turner, Senior Attorney, EPA, regarding “United States v. City of Jacksonville, United States Federal Court No. LR-C-94-196.” Response to EPA’s April 25, 2000, request for update regarding City of Jacksonville’s progress toward establishing restrictive covenants at the Rogers Road property in support of the site’s deletion from the NPL. May 3, 2000. City of Jacksonville, 1994. Remedial Action Work Plan for the Rogers Road Municipal Landfill Superfund Site. September 1994. Ecology and Environment (E&E), 1995. Technical Assistance Report (includes Remedial Action Sampling and Analysis Plan, Quality Assurance Project Plan, Health and Safety Plan, and Remedial Action Closeout Report). January 1995. U. S. Environmental Protection Agency (EPA), 1990. Record of Decision: Rogers Road Municipal Landfill, AR. ROD/R06-90/063. Final, September 1990. U.S. Environmental Protection Agency (EPA), 1991. Structure and Components of Five-Year Reviews . Office of Solid Waste and Emergency Response (OSWER) Directive 9355.7-02. May 23, 1991.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# U.S. Environmental Protection Agency (EPA), 1991. Factsheet: Structure and Components of Five-Year Reviews . OSWER Directive 9355.7-02FS1. August 1991. U.S. Environmental Protection Agency (EPA), 1994. Supplemental Five-Year Review Guidance . OSWER Directive 9355.7-02A. July 26, 1994. U.S. Environmental Protection Agency (EPA), 1995. Second Supplemental Five-Year Review Guidance . OSWER Directive 9355.7-03A. December 21, 1995. U.S. Environmental Protection Agency (EPA), 1996. Rogers Road Municipal Landfill Superfund Site Closeout Report . April 30, 1996. U. S. Environmental Protection Agency (EPA), 1999. Comprehensive Five-Year Review Guidance. EPA540R-98-050. OSWER Directive 9355.7-03B-P. Draft, October 1999. U. S. Environmental Protection Agency (EPA), 1999a. Letter from James L. Turner, Assistant Regional Counsel, EPA, to Robert Bamburg, City of Jacksonville Attorney, regarding “Jacksonville Municipal Landfill and Rogers Road Landfill Superfund Sites”. Requests the City of Jacksonville establish deed restrictions as a component of the sites’ deletion from the NPL. August 18, 1999. U. S. Environmental Protection Agency (EPA), 2000. Letter from James L. Turner, Senior Attorney, EPA, to Robert Bamburg, Attorney, City of Jacksonville, regarding “Rogers Road Landfill Superfund NPL Site”. Summarizes telephoneconversation regarding status of City’s efforts toward establishing restrictive covenants at Rogers Road property in support of the site’s deletion from the NPL. February 15, 2000. U. S. Environmental Protection Agency (EPA), 2000a. Letter from James L. Turner, Senior Attorney, EPA, to Robert Bamburg, Attorney, City of Jacksonville, regarding “Rogers Road Landfill Superfund NPL Site”. Requests update regarding City of Jacksonville’s progress toward establishing restrictive covenants at the Rogers Road property in support of the site’s deletion from the NPL. April 25, 2000. U. S. Environmental Protection Agency (EPA), 2002. Letter from James L. Turner, Senior Attorney, EPA, to Robert Bamburg, Attorney, City of Jacksonville, regarding “Rogers Road Landfill Superfund NPL Site”. Follow-up correspondence concerning the actions of the City of Jacksonville to quiet title on the Rogers Road property in pursuit of establishing restrictive covenants at the site in support of EPA efforts to delete it from the NPL. July 29, 2002.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# U. S. Environmental Protection Agency (EPA), 2005. Letter from James L. Turner, Senior Attorney, EPA, to Robert Bamburg, Attorney, City of Jacksonville, regarding “Rogers Road Landfill Superfund NPL Site”. Confirms telephoneand electronic mail discussions of a draft document that would grant an easement and restrictive covenants to the City of Jacksonville, enforceable by the EPA as a third party beneficiary. September 26, 2005. Peer Consultants, P. C., and Resource Applications, Inc., 1990a. Remedial Investigation Report for Rogers Road Landfill Site, Jacksonville, Arkansas. June 1990. Peer Consultants, P. C., and Resource Applications, Inc., 1990b. Feasibility Study Report for Rogers Road Landfill Site, Jacksonville, Arkansas. June 1990.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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## Attachment 2 

# Interview Record FormsR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Five-Year Review Interview Record Rogers Road/Jacksonville Landfill Pulaski/Lonoke Counties, Arkansas Interviewee: Brian Wakelyn Arkansas Department of Environmental Quality Phone: (501) 682-0845
Site Name EPA ID No. Date of Interview Interview Method Rogers Road Municipal Landfill EPA ID# ARD981055809 9/9/2005 In person Jacksonville Municipal Landfill EPA ID# ARD980809941 9/9/2005 In person 

## Interview Conducted by Organization Phone Email Address

Shawn Ghose EPA Region 6 (214) 665-6782 ghose.shawn@epa.gov 1445 Ross Avenue, Suite 1200 MailCode: 6SF-AP Dallas, Texas 75202-2733 

## Interview Questions and Responses 

## 5. What is your overall impression of the work conduc ted at each site since the first five-year review was completed in September 2000? Response: The two sites look well maintained. Fences are in place

6. From your perspective, what effect have the ongoing presence of the sites had on the surrounding community? Are you aware of any ongoing community concerns or positive experiences? Response: The City has not mentioned any community concerns

7. Are you aware of any events, incidents, or activities that have occurred at either site, such as dumping, vandalism, trespassing, or anything that required emergency response from local authorities or a response from your office, since the completion of the first five-year review in September 2000? If so, please give details. Response: No
8. Have there been routine communications or activities (site visits, inspections, reporting activities, etc.) conducted by your office regarding either site since the completion of the first five-year review in September 2000 (including annual site inspections )? If so, please describe purpose and results. Response: NoR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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## 9. Have there been any significant changes in the site status or maintenance requirements since completion of the first five-year review in September 2000? If so, do they affect the protectiveness or effectiveness of the remedy? Please describe changes and impacts. Response: No
10. What are the approximate annual O&M costs for each site incurred by ADEQ? Have there been unexpected O&M difficulties or costs at either s ite since the start of O&M, or opportunities to optimize the O&M activities at the site since completion of the first five-year review in 2000?
Response: 

## Only indirect costs, meeting and discussions with EPA ( This question is not relevant to the 2 nd 

## Five Year Review) 11. Has ground water use beyond the perimeter-fenced area of either site changed since completion of the first five-year review? Is the groundwater use restriction (onsite) by institutional control verified as part of each site’s annual inspection?
Response: 

## No. The ICS are being worked by EPA and City for a deed of Easement and Restrictive Covenants to prohibit using ground water near the site. Ground water is not being sampled 12. The first five-year review recommended that ground water monitoring continue for the Rogers Road site until the restrictive covenants could be put inplace. Please describe the status of ground water monitoring conducted since completion of the first five-year review. Response: Has not been done, but recent communication between EPA and City of Jacksonville may facilitate Deletion.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Five-Year Review Interview with Mayor Tommy Swaim Rogers Road/Jacksonville Landfill Pulaski/Lonoke Counties, Arkansas
Site Name EPA ID No. Date of Site Inspection Rogers Road Municipal Landfill EPA ID# ARD981055809 September 9, 2005 Jacksonville Municipal Landfill EPA ID# ARD980809941 September 9, 2005 

# Interview Conductor Organization Phone Email Address

Shawn Ghose EPA Region 6 (214) 665-6782 ghose.shawn@epa.gov 1445 Ross Avenue, Suite 1200 MailCode: 6SF-AP Dallas, Texas 75202-2733



# Meeting with the Mayor of Jacksonville
The EPA RPM for the two sites Shawn Ghose M.S., P.E. inspected the Jacksonville Municipal Landfill and Rogers Road Landfill Superfund sites accompanied by John Hepola the Branch Chief and Gus Chavarria the Section Chief of EPA’s Arkansas Program Branch. EPA personnel were shown around the two sites by Jay Whisker P.E. the City Engineer of Jacksonville and his staff who provide the regular maintenance of the site. After the site inspection, the RPM and the EPA Section Chief for the Arkansas Program Branch attended a meeting with Mayor Tommy Swaim at the Mayor’s office in Jacksonville. The Mayor indicated his general satisfaction with the progress of O&M at the two landfill sites and his desire to be of assistance to the EPA. The RPM conveyed to the Mayor, the EPA’s general satisfaction with the way the O&M for the two sites are being carried out by the City of Jacksonville. However, the RPM impressed upon the Mayor the need to hasten the imposition of the restrictive covenants that would control groundwater use at the Rogers Road site. The RPM also expressed satisfaction that in late August 2005, the Mayor had urged the City Attorney to work with the EPA in completing th e legal instruments that would grant restrictive covenants to the City to prohibit ground water use on the Rogers road property. Mayor Swaim promised to continue to work with the City Attorney consistent with their respective elective positions to accomplish the finalization and implementation of the restrictive covenants.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Attachment 3 

# Site Inspection Record with PhotographsR OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Five-Year Review Site Inspection Record Rogers Road/Jacksonville Landfill Pulaski/Lonoke Counties, Arkansas
Site Name EPA ID No. Date of Site Inspection Rogers Road Municipal Landfill EPA ID# ARD981055809 September 9, 2005 Jacksonville Municipal Landfill EPA ID# ARD980809941 September 9, 2005 

## Site Inspection Team Organization Phone Email Address

Shawn Ghose EPA Region 6 (214) 665-6782 ghose.shawn@epa.gov 1445 Ross Avenue, Suite 1200 MailCode: 6SF-AP Dallas, Texas 75202-2733



## Site Inspection Description


## The EPA RPM for the two sites Shawn Ghose M.S., P.E. inspected the Jacksonville Municipal Landfill and Rogers Road Landfill Superfund sites accompanied by John Hepola the Branch Chief and Gus Chavarria the Section Chief of EPA’s ArkansasProgram Branch. EPA personnel were shown around the two sites by Jay Whisker P.E. the City Engineer of Jacksonville and his staff who provide the regular maintenance of the site. Both the sites looked well maintained. The caps seem to be in good order without any major cracks. The vegetation on the cap seem to have been mowed recently with about 4-6 inch growth. No noticeable erosion was seen on the caps. The fences around the cap looked secure with entry into the cap controlled through locked gates. A 20 foot section of the fence reported by Jay Whisker to be broken, was fixed on the day of the inspection. A tree farm at the Jacksonville Landfill site showed good growth of planted trees. No trees have been transplanted since the last five year review in September 2000. The monitor wells made of stainless steel cover seemed in good condition and they were locked. In short the requirements of the O&M of 1] Maintenance of the cap and the fence 2] Control of the growth of vegetation on the cap 3] Maintenance of the monitor wells were satisfied. Records of th e maintenance are noted in the City of Jacksonville report to EPA.R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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## September 20, 2005
Mr. Shawn Ghose Environmental Protection Agency

Re: Jacksonville and Rogers Rd. Landfill Dear Mr. Ghose, The purpose of this letter is to convey the actions of the City of Jacksonville’s actions at Rogers Rd landfill and Jacksonville landfill. The la st logged inspection was April 14, 2003. Myself and Murice Green inspected the site for fencing and maintenance of the area. As I recall there were not any problems that we could find. I logged my next visits on August 31, 2005 and on September 1, 2005. The cable across the access to Rogers Rd landfill was down. The gates leading into the landfill itself were still in tact. The monitoring wells that were visited were all still locked. The vegetation around the perimeter was still thick. The fencing was missing in one small area (approximately 20’). Steps are currently under way to mend the gap in the fence. At the Jacksonville landfill the gates and fencing were still in tact. The vegetation around the site was thick. All monitoring wells were in tact with locks attached. The grass in the area was being mowed at the site. No problems were seen in the area. In conclusion, although I have only logged a visit every other year, employees from Jacksonville monitor the sites by driving by on a consist basis, and mowing and maintenance are handled every year. The attached pictures show the site in good shape with locked monitoring wells. The only noted problem (the 20’ gap in the fence) had vegetation growing so thick that a person could not enter the area. If you should have any further questions please contact me at (501)-982-6071. Sincerely,

James Whisker City Engineer City of Jacksonville 

# City of Jacksonville 1 Municipal Dr Jacksonville, AR 72076R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Photograph taken by the City of Jacksonville: “Rogers Road Landfill from entrance gate looking South.”R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Photograph taken by the City of Jacksonville: “Rogers Road Landfill from center of the South end looking South.”R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Photograph taken by the City of Jacksonville: “Rogers Road Landfill from South side looking East.”R OGERS R OAD M UNICIPAL LANDFILL S ECOND F IVE -Y EAR R EVIEW R EPORT

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# Photograph taken by the City of Jacksonville: “Rogers Road Landfill from South side looking West.”