Rogers Road Municipal Landfill

Five-Year Review Report

September 2000

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002134
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Rogers Road Municipal Landfill

Pulasld County, Arkansas

Five-Year Review Report

September 2000

CH2MHILL

002135
FIVE-YEAR REVIEW

Rogers Road Municipal Landfill Supcrfund Site

EPA ID #ARD981055809

Pulaski County, Arkansas

This memorandum documents EPA's approval of the Rogers Road Municipal Landfill

Superfund Site Five-Year Review Report prepared by CH2MHU1 on behalf of EPA.

Summary of Five-Year Review Findings

This is the first five-year review of the Rogers Road Municipal Landfill Site (the "Site")

located near Jacksonville, in Pulaski County, Arkansas. The results of the five-year

review indicate that the remedy is protective of human health and the environment.

Based on this five-year review. Site documentation confirms the remedial action at the

Site as originally set forth in the Record of Decision (ROD) has been implemented as

planned (except as noted in the following section) and is protective of human health and

the environment.

Actions Needed

Overall, the remedial action performed is functioning as designed, and the Site has been

maintained appropriately. No deficiencies were noted that impact the protectiveness of

the remedy, and the remedy should remain protective if Site Operations and Maintenance

is continued. Ground water monitoring must also continue until the City of Jacksonville

puts restrictive covenants in place, and me Site is deleted from the National Priorities

List. The restrictive covenants described in the ROD have been developed, but have not

been put in place by the city because of legal controversy over title to the property. In

addition to the placement of restrictive covenants, the Arkansas Department of

Environmental Quality has requested that the appropriate solid waste regulating

authority be notified of the low detects ofnon-Site-related metals in the monitoring wells

that may be caused by leaching from the municipal landfill.

Determinations

I have determined that the remedy for the Rogers Road Municipal Landfill Superfund

Site is protective of human health and the environment.

y^ieiAATYLU, /^w^-

Myron 0/Knudson, P.E.

Director, Superfund Division

U.S. Environmental Protection Agency

Region 6

Date

901266

002136
CONCURRENCES

FIRST FIVE-YEAR REVIEW REPORT

for

Rogers Road Municipal Landfill Superfund Site

Pulaski County, Arkansas

EPA ID#ARD981055809

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KatnIeeiTA'Aisling, U.S-E^A Date ' •

Remedial Project Manager-Technical Support Team

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^L^/22—a ^

Gustavo T. Chavama, U.S. EPA

Chief, AR/OK/TX Project Management Section

^^tss^^o

Date

^/'Z^S./OP

Date

i-n^—_____ Wf^

WilHam ^•^ T T C VD A r»-»+<» I K. Honker, U.S. EPA Date

Chief, AR/QKZIX Branch ^

Mark A. Peycke, U.S. (EPA Date

Chief, Superfund Branch, Office of Regional Counsel

Pamela Phillips, U.S. EPA

Deputy Director, Superfund Division

Date

^M/W^K/^

Junei Buzzell'U.S Buzzell^US. EPA

Writer Editor, Superfund Division

Date

002137
Five-Year Review Report

First Five-Year Review Report

for

Rogers Road Municipal Landfill

Pulaski County, Arkansas

September 27,2000

PREPARED BY:

CH2M HILL

Contract Number 68-W6-0036

Work Assignment Number 048-FRFE-06ZZ

PREPARED FOR:

Region 6

United States Environmental Protection Agency

Dallas, Texas

901265

002138
ROGERS ROAD MUNICIPAL LANDFILL

FIRST FIVE-YEAB REVIEW REPORT

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ROGERS ROAD MUNICIPAL LANDFILL

FIRST FIVE-YEAR REVIEW REPORT

Executive Summary

The first five-year review of the Rogers Road Municipal Landfill site located near Jacksonville,

in Pulaski County, Arkansas, was completed in September 2000. The results of the five-year

review indicate that the remedy is expected to be 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

abovelO parts per billion (ppb) dioxin concentrations were 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. Annual groundwater monitoring was also

performed. 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 has recommended discontinuing groundwater monitoring. EPA concurs

that this recommendation will be appropriate to implement once restrictive covenants are in place

prohibiting groundwater use on the property, and the site is deleted from the National Priorities

list (NPL). (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.) Some

metals were detected in low concentrations in groundwater during monitoring, but they are not

contaminants of concern associated with the hazardous materials disposed ofonsite. These

metals may be associated with the solid waste portions of the landfill, and should be referred to

the appropriate solid waste regulatory authority.

Based on this five-year review, site documentation confirms the remedial action at the site as

originally set forth in the Record of Decision (ROD) has been implemented as planned (except

for the implementation of restrictive covenants) and continues to be protective of human health

and the environment.

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ROGERS ROW MUNICIPAL LANDFILL

FIRST FIVE-YEAR REVIEW REPORT

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Table of Contents

ROGERS Row MUNICIPAL LANDFIU.

FIRST FIVE-YEAB REVIEW REPORT

Section Page

Executive Summary ......................................'................... ES-1

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 ......................................... 8

4.4 Progress Since Initiation of Remedial Action ............................ 9

5. Five-Year Review Process .............................................. . 10

6. Five-Year Review Findings ............................................. . 10

6.1 Interviews....................................................... 11

6.2 Site Inspection ................................................... 11

6.3 Standards Review ................................................. 13

6.4 Data Review ..................................................... 15

7. Assessment ........................................................... 16

8. Deficiencies .......................................................... . 17

9. Recommendations and Follow-up Actions ................................ . 17

10. Protectiveness Statements) ............................................. . 17

11. Next Review ......................................................... . 18

Figures

Figure 1:

Tables

Table 1:

Table 2:

Table 3:

Site Map

Chronology of Site Events

Annual Operations and Maintenance Estimated Costs

Recommendations and Follow-Up Actions

PAGE I SEPTEMBER 2000

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TJ*I*|J* /»< ^J*M«MM«<* ROGERS ROW MUNICIPAL LANDFILL

Table of Contents FIRSTFM-YEARREVIEWRPPORT

Attachments

Attachment 1: List of Documents Reviewed

Attachment 2: Interview Record Forms

Attachment 3: Site Inspection Checklist/Inspection Roster/O&M Costs

Attachment 4: Site Inspection Photographs

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ROGERS ROAD MUNICIPAL LANDFILL

FIRST FIVE-YEAR REVIEW REPORT

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

PR 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-dioxin

PAGE Hi SEPTEMBER 2000

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ROGERS ROAD MUNICIPAL LANDFILL

FIRST FIVE-YEAR REVIEW REPORT

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Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN): Rogers Road Municipal Landfill

EPA ID (from WasteLAN): ARD981055809

Region: EPA Region 6

SITE STATUS

NPL Status: B Final D Deleted n Other (specify):

Remediation status (choose all that apply): n Under Construction a Operating sComplete

Multiple OUs? o Yes a No

Has site been put Into reuse? 5 Yes B No

State; AR

Construction completion date: September 1995

City/County: NA/Pulaski

REVIEW STATUS

Reviewing agency: a EPA o State aTribe a Other Federal Agency:

Author: EPA Region 6, with support from RAC6 contractor CH2M HILL

Review period: August 1994 through September 2000

Date(s) of site inspection: June 27,2000

Type of review: E Statutory

a Policy

D Post-SARA a Pre-SARA D NPL-Removal only

o Non-NPL Remedial Action Site a NPLState/Tribe-lead

o Regional Discretion

Review number: B 1 (first) o 2 (second) o 3 (third) n Other (specify):

Triggering action:

JB Actual RAOnsite Construction a Actual RA Start at OU#

n Construction Completion a Recommendation of Previous Five-Year Rew'ew Report

n Other (specify):

Triggering action date (from WasteLAN): August 4,1994

Due date (five years after triggering action date); August 4.1999

PAfiEV SEPTEMBER 2000

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ROGERS ROAD MUNICIPAL LANDFILL _.

FIRST FIVE-YEAB REVIEW REPORT

Five-Year Review Summary Form

Deficiencies:

No deficiencies noted.

Recommendations and Follow-up Actions;

• Maintain records of annual O&M costs and site security logs; submittal of such

records/logs is not required.

• After four annual groundwater monitoring events conducted from 1994 through 1997, no

Contaminants of Concern as defined by the ROD were detected and the ADEQ

recommended cessation of sampling. Based on a review of ADEQ data, EPA concurs with

this recommendation pending finalization of restrictive covenants prohibiting groundwater

use on the property, and the deletion of the site from the NPL. Requirements for

groundwater monitoring under solid waste regulations for the municipal landfill portions

of the site may also apply, and the current monitoring well network could potentially be

used for that purpose, as well as the data collected by ADEQ from 1994 through 1997.

The appropriate agencies should be notified of the availability of the groundwater wells to

be used for monitoring under that program, and of the detection of metals in groundwater

samples that may be associated with the solid waste portion of Rogers Road Municipal

Landfill and neighboring Jacksonville Municipal Landfill.

Protectiveness Statement(s):

The remedy completed for the Rogers Road Municipal Landfill site is protective of human

health and the environment.

Other Comments:

None.

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First Five-Year Review Report

Rogers Road Municipal Landfill

The United States Environmental Protection Agency Region 6 has conducted a five-year review

of the remedial actions implemented at the Rogers Road Municipal Landfill site located near

Jacksonville, Pulaski County, Arkansas for the period August 1994 through September 2000.

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. EPA RAC6 contractor

CH2M HTLL provided support for preparation of this Five-Year Review Report.

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 five-year review for the Rogers Road Municipal Landfill site is required by statute.

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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 first five-year review for the Rogers Road Municipal Landfill site. The triggering

action for this statutory review is the date of initiation of the remedial action on August 4,1994.

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

downgradient of the site (EPA, 1990).

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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. Sources of this information are listed in Attachment 1, Documents Reviewed.

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 miles

northeast of Little Rock, Arkansas. The landfill is situated immediately east of Rogers Road,

one-tenth 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 Section 28, Township 3 North and Range 10 West (EPA,

1990). Less than one-half mile east of the Rogers Road Municipal Landfill Superfund Site is 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.

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FIBST FIVE-YEAR REVIEW REPORT

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 me 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, which

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FIRST FNE-YEMt REVIEW REPORT

produced numerous chemical products including dioxins, are believed to have been disposed of

at the Rogers Road site. An estimated 15 to 50 drums ofdioxin 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, l990b). Onsite soil and decaying drums were found to be contaminated

with dioxin (2,3,7,8-tetrachlorodibenzo-p-dioxin [TCDD] 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.

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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 abovelO 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 debris containing 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.

• Steam-cleaning and disposal of large items of refuse removed from contaminated areas at the

Rogers Road Site.

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• 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 ffl >.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 downgradient 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 Federal 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, Riedel-Peterson,

mobilized to begin remedial operations at the Site. After preliminary road work was completed,

excavation of contaminated soil was initiated.

During the action, Riedel-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

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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.

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

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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.

See Section 6.2 for a summary 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 site Record 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).

Control of groundwater use immediately downgradient of the site is not strictly enforceable, but

residents are on municipal water supply. ADEQ has requested that the appropriate solid waste

regulating authority be notified of the low detects of non-Site-related metals in the monitoring

wells that may be caused by leaching from the municipal landfill. ADEQ recommends that the

appropriate solid waste regulating authority be notified and that the 1994-1997 groundwater

monitoring data be considered under such authority.

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O&M procedures appear to be adequate although documentation of O&M frequency and annual

costs have not always been consistently maintained in the period following construction

completion (reporting to EPA is not required). As discussed previously, groundwater monitoring

at the site was discontinued due to the lack of detection of COC's defined in the ROD, but it is

EPA's position that groundwater monitoring should continue until institutional controls in the

form of restrictive covenants are in place and the site is deleted from the NPL.

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 made information available to the

public regarding its intent to perform the five-year review through the Rogers Road site status

summary on EPA's Region 6 website, at http://www.epa.gov/earthlr6/6sf/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 information repositories. The five-year review consisted of interviews with

relevant parties, a site inspection conducted at the site, 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, the standards review, and the

data review are described in the following subsections.

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FIRST FIVE-YEAR REVIEW REPORT

6.1 Interviews

Interviews were conducted with representatives from the City of Jacksonville, and with

representatives of state and federal regulatory agencies at the City of Jacksonville offices and at

the Jacksonville and Rogers Road Municipal Landfill sites on June 27,2000. Interview Record

Forms which document the issues discussed during these interviews are provided in

Attachment 2.

Interviews were conducted with Murice Green of the City of Jacksonville, Brian Wakelyn of the

ADEQ, and Kathleen Aisling and Kenneth dark of the EPA. The overall 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, the entire site was overgrown. No community concerns have been

expressed regarding this site since prior to the initiation of the remedial action in 1994.

O&M costs associated with the site have not been individually tracked; submission of

documentation was not specified in the O&M plans. Based on the interviews, however, the City

indicated no significant changes had occurred in the ongoing O&M activities, and therefore the

costs have most likely remained consistent since the completion of the remedy (see Section 6.2).

6.2 Site Inspection

A site inspection was conducted at the site on June 27,2000. The completed site inspection

checklist is provided in Attachment 3. Photographs taken during the site visit are provided in

Attachment 4.

The area around the site along Rogers Road is densely wooded (Photo 1, Attachment 4). The

fencing around the site appeared intact and secure, although no signs were posted on the fence or

the gate (Photos 2 -5, Attachment 4). No vandalism was evident, and the roads were adequate

RR-5YRJ000927.WPD PAOE 110F 18 SEPTEMBER 2000

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ROGERS ROAD MUNICIPAL LANDFILL

FIRST FIVE-YEAR REVIEW REPORT

(Photos 1 and 9, Attachment 4). Unauthorized dumping reportedly took place prior to the

remedial action, and debris was noted outside the perimeter of the site. The soil cover appeared

to be in good condition; no settlement, cracks, or erosion was evident (Photos 2-4, and 6,

Attachment 4). 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.

However, the site is situated in a natural low area, and standing water in the area surrounding

Rogers Road Landfill has been noted by the City of Jacksonville staff following rain events.

Monitor wells MWR-01 and MWR-02 were located and photographed (Photo 8, Attachment 4;

locations noted on Figure 1). 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.

As part of the review, actual O&M costs are compared to the projected costs to determine if there

have been any unanticipated or unusually high O&M costs during the review period. The ROD

estimated an annual O&M cost of $5,000 for fence maintenance and site inspection, and $16,900

for groundwater monitoring (EPA, 1990). The O&M costs presented in the ROD as well as the

FS Table referenced in the ROD estimate are provided in Attachment 3. Although detailed

O&M cost documentation has not been maintained, a current annual O&M estimate was

provided by the City of Jacksonville and ADEQ (also provided in Attachment 3). Table 2

provides a summary of these costs for Rogers Road. The annual total for site inspection and

cover maintenance for both the Rogers Road and Jacksonville sites was $13,440, the annual

groundwater monitoring cost for both sites was estimated at $7,000 for a total of $20,440. It was

assumed for the purposes of this review that half of the amount, or $ 10,220, is the approximate

annual cost of O&M for Rogers Road. Although the site inspection and maintenance costs are

slightly more than what was projected in the ROD, the groundwater monitoring costs are

significantly lower. Therefore the O&M costs are not an issue of concern for this site.

RR_5YR_000927.WPO PAGE 12 OF 18 SEPTEMBER 2000

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FIRST FIVE-YEAR REVIEW REPORT

6.3 Standards Review

Applicable or Relevant and Appropriate Requirements (ARARs) for this site were identified in

the ROD dated September 27,1990. This 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 regulated 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 0.

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)(l).

6. Requirements to evaluate the potential impacts to floodplains as regulated under the

Executive Order on Floodplain Management, Executive Order No. 11988.

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

the remedial action:

RR_5YR_000927.WPO PAGE130F18 SEPTEMBER 2000

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FIRST FIVE-YEAR REVIEW REPORT

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 CPR 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.

Hazardous waste incineration is no longer occurring as part of the site remedy, and the 40 CFR

Part 264 Subpart 0 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 CPR Parts 107 and 171-177 are no longer applicable.

Since the ROD was signed, there have been no changes to the regulations under 40 CFR 256.23

(guidance for closure of open dumps), and there have been no changes to Executive Order No.

11988 (floodplains). m addition, there have been no changes to CERCLA section 104(d)(4)

(noncontiguous facilities) since the ROD was signed. No promulgated changes could be found in

the CDC's concentration recommendations for 2,3,7,8-TCDD.

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FIRST FIVE-YEAR REVIEW REPORT

In addition, there have been no changes to the regulatory requirements described under 40 CFR

264.117(a)(l). This regulation requires 30 years of post-closure care and monitoring or for

another period determined by the Regional Administrator. The EPA has determined, based on

groundwater sampling results, that the groundwater is not impacted by the COCs and that

continued monitoring is not 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). However, the Rogers Road Landfill met the requirements for closure as a hazardous

waste landfill under 40 CFR 264.117(a)(l), and the regulations of 40 CFR 258 would not apply.

The EPA has 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.

In summary, it appears 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.

6.4 Data Review

During the remedial action, the confirmatory sampling involved a 14 x 14 grid around all the

areas that were visibly contaminated or shown to be contaminated 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 resampled. 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-TCDD 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

RRJ5YR_000927.WPO PAGE150F18 SEPTEMBER2000

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ROGERS ROAD MUNICIPAL LMOFU.

FIRST FIVE-YEAR REVIEW REPORT

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 last sampling event, aluminum and iron were detected at concentrations above

secondary drinking water standards (established for taste and aesthetics) at wells MWR-08,

MWR-09, and MWR-10. Many wells exhibited metals concentrations above background well

concentrations in this and previous events (ADEQ, 1999). 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.

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 City of Jacksonville through control of site access

through fencing. The establishment of permanent restrictive covenants prohibiting groundwater

use is pending. In addition, no COCs have been detected in groundwater to-date.

RR-5YR.000927.WPD PAGE160F18 SEPTEMBER2000

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FIRST FiVE-YEAfl REVIEW REPORT

8.0 Deficiencies

No deficiencies were noted.

9.0 Recommendations and Follow-up Actions

It is suggested that individual O&M cost records for this site be maintained by the City, to

facilitate review of the appropriateness of O&M costs in future 5-year reviews. Although

groundwater appears to be free of COC contamination, some metals were detected that may be

associated with the solid waste portion of the landfill, and the appropriate solid waste regulatory

authority should be notified. In addition, groundwater monitoring should continue for the

Superfund portion of the landfill until the restrictive covenants are in-place which prohibit

groundwater use on the site, and until the site is deleted from the NPL.

10.0 Protectiveness Statement

Once the restrictive covenants are finalized, 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 s 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.

RR_5YR_000927.WPO PAGE170F18 SEPTEMBER 2000

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FIRST FIVE-YEAR REVIEW REPORT

11.0 Next Review

Since the first five year review was due on or before August 4,1999, the next five year review

should be completed on or before August 2004. The subsequent review should include a site

inspection and review ofO&M procedures, costs, and surrounding groundwater use.

RR-5YRL.000927.WPO PAGE 18 OF 18 SEPTEMBER 2000

002165
J-——L -L_

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Figure 1: Site Map and Monitoring Well Network

Rogers Road and Jacksonville Municipal Landfills

002166
ROGERS ROAD MUNICIPAL LANDFILL

FRST FIVE-YEAR REVIEW REPORT

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FIRST FIVE-YEAR REVIEW REPORT

Table 1

Chronology of Site Events

Date

May 10,1983

July 22,1987

November 1988-March 1990

June 30,1990

September 27,1990

August 1994 • September 1995

November 1994

November 1995

November 1996

November 1997

August 2000

Event

Site was identified to EPA by citizen complaint

Site added to the NPL list with a score of 29.64

Remedial Investigation and Risk Assessment conducted

Remedial Investigation/Feasibility Study report completed

Record of Decision signed

Remedial Action activities conducted, start of review period

First annual groundwater monitoring event conducted.

Second annual groundwater monitoring event conducted.

Third annual groundwater monitoring event conducted.

Fourth annual groundwater monitoring event conducted; cessation of groundwater

monitoring recommended due to lack of detections of site-related constituents.

First Five Year Review Report Completed

Table 2

Annual O&M Estimated Costs

Kern

Site clearing equipment rental

Site Inspector monthly cost

Groundwater Monitoring annual

cost

TOTAL

Estimated cost

$1080

$20

$3,500

Frequency

6/year

1/month

1/year

Cost

$6,480

$240

$3,500

$10,220

RR_5YB_000927_TABLES.WO PAGE 1 OF 2 SEPTEMBER 2000

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FIRST FIVE-YEAR REVIEW REPORT

Tables

Recommendations and Follow-up Actions

Recommendations/

Follow-up Actions

Maintain annual O&M cost records and site

access togs to facilitate future 5-year reviews

Continue groundwater monitoring until

restrictive covenants are in place and site is

deleted from the NPL

Refer site to appropriate solid waste regulatory

authority, and refer monitor well network details

and monitoring results for consideration as

needed/appropriate.

Party Responsible

City of Jacksonville

ADEQ

EPA

Oversight

Agency

EPA

EPA

NA

Milestone

Date

ongoing

2001

2001

Follow-up

Actions: Affects

Protectiveness

(Y/N)

N

N

N

PAGE 2 OP 2 SEPTEMBER 2000

002169
ROGERS ROAD MUNICIPAL LANDFILL

FIRST FIVE-YEAR REVIEW REPORT

Attachment 1

Documents Reviewed

RR_5YR_000927.WPO SEPTEMBER 2000

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FIRST FIVE-YEAR REVIEW REPORT

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FIRST FIVE-YEAR REVIEW REPORT

Attachment 1

Documents Reviewed

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 4th 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 Superfund 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.

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FIRST FIVE-YEAR REVIEW REPORT

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 Hamburg, 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 Hamburg, Attorney, City of Jacksonville, regarding "Rogers

Road Landfill Superfund NPL Site". Summarizes telephone conversation 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 Hamburg, 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.

Peer Consultants, P. C., and Resource Applications, me., 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.

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Attachment 2

Interview Record Forms

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RR_5YR_000927.WPD SEPTEMBER 2000

002175
Five-Year Review Interview Record

Rogers Road/Jacksonville

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 June 27,2000 In person

Jacksonville Municipal Landfill EPA ID# ARD980809941 June 27,2000 In person

Interview

Conducted by

Organization Phone Email Address

Margaret O'Hare CH2MHILL,as

rep ofEPA

972-980-

2170

mohare@ch2m.com 5339 Alpha Road Suite 300

Dallas, Texas 75240

Katie Swanson CH2MHILL,as

rep ofEPA

972-980-

2170

kswanso2 @ch2m.com 5339 Alpha Road Suite 300

Dallas, Texas 75240

Interview Questions and Responses

1. What is your overall impression of the work conducted at each site? (general sentiment)

Response: No additional response (beyond that provided by other interviewees).

2. From your perspective, what effect have remedial operations at the site had on the surrounding

community?

Response: No additional response.

3. Are you aware of any ongoing community concerns regarding the site or its operation and

administration? Please provide details.

Response: No additional response.

4. Are you aware of any events, incidents, .or activities that have occurred at either site, such as

dumping, vandalism, trespassing, or emergency response from local authorities, since the

startup of remedial action? If so, please give details.

Response: hi the mid-90's, raw sewage was being discharged to the Jacksonville site near

MWJ-07 by a neighboring resident; the discharge was halted when it was

identified.

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ROGERS ROAD/JACKSONVILLE MUNICIPAL LANDFILLS, FIVE-YEAR REVIEW INTERVIEW RECORD

RESPONSE PROVIDED BY BRIAN WAKELYN/ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

5. Have there been routine communications or activities (site visits, inspections, reporting

activities, etc.) conducted by your office regarding either site since the startup of remedial

action other than the annual site inspection? If so, please describe purpose and results.

Response: Groundwater monitoring was conducted annually by the state through 1997;

during those visits it has been observed that the area around the Rogers Road

landfill is underwater for extended periods due to poor drainage unrelated to the

remedial activities. Portions of the Jacksonville landfill arc also very wet.

Because no detections of site-related contaminants were reported in the monitoring

wells during any annual sampling event, annual groundwater monitoring has not been

conducted since 1997.

6. Have there been any complaints, violations, or other incidents related to the site that required a

response by your office? If so, please give summarize the events and results of the responses.

Response: No.

7. Were any problems or difficulties encountered after the initiation of remedial action which

impacted construction progress and implementability?

Response: No additional response.

8. Were or have any problems been encountered at either site which required or will require

changes in the Record of Decision or remedial action performed?

Response: No additional response.

9. Have there been any significant changes in the site status or maintenance requirements since

completion of remedial action? If so, do they affect the protect! veness or effectiveness of the

remedy? Please describe changes and impacts.

Response: Annual groundwater monitoring conducted by ADEQ was discontinued after the 1997

monitoring event, because no site-related constituents had been detected in any

groundwater samples during 4 annual monitoring events. A recommendation to

permanently discontinue groundwater monitoring has been sent to EPA.

10. Have there been unexpected O&M difficulties or costs at either site since the start of O&M?

If so, please give details

Response: No.

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ROGERS ROAD/JACKSONVIllE MUNICIPAL LANDFILLS, FIVE-YEAR REVIEW INTERVIEW RECORD

RESPONSE PROVIDED BY BRIAN WAKELYN/ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

11. What are the approximate annual O&M costs for each site?

Response: Groundwater monitoring was generally $6,000 - $7,000 per event.

12. Is groundwater use restricted beyond the perimeter fenced area of either site? Is the

groundwater use restriction by institutional control verified as part of each site's annual

inspection?

Response: The only restrictions are within the perimeter fence. Although nearby

residential wells are not used for drinking water, ADEQ recommends that

letters be sent to residents communicating the results of groundwater samples

and that institutional controls be established to prevent future use.

13. Have there been opportunities to optimize the operation, maintenance, or sampling efforts at

the site since the start of the remedial action? Please describe changes and the resultant or

desired cost savings or improved efficiency.

Response: As indicated in the response to Question 9, groundwater monitoring was

discontinued after the 1997 event, pending EPA concurrence. During the years

the groundwater monitoring was being done, the government contracting

process meant the low bidder had to be selected, which resulted in 3 different

contractors being used for the 4 events. The process would have been easier,

more consistent, if the same contractor could have been used for all events.

14. Do you have any comments, suggestions, or recommendations regarding either site?

Response: Impose institutional controls for groundwater use from neighboring properties,

permanently discontinue groundwater monitoring related to the Superfund site

portion of the landfills, and notify solid waste regulating authority of the

potential need to monitor groundwater for constituents related to the municipal

landfill portion of the sites.

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RR.5YR.000927.WO SEPTEMBER 2000

002179
Five-Year Review Interview Record

Rogers Road/Jacksonville

Pulaski/Lonoke Counties, Arkansas

Interviewee: Murice Green

City of Jacksonville

Phone: 501-982-6071

Site Name EPA ID No. Date of

Interview

Interview

Method

Rogers Road Municipal Landfill EPA ID# ARD981055809 June 27.2000 In person

Jacksonville Municipal Landfill EPA ID# ARD980809941 June 27,2000 In person

Interview

Conducted by

Organization Phone Email Address

Margaret O'Hare CH2M HILL, as

rep ofEPA

972-980-

2170

mohare@ch2in.com 5339 Alpha Road Suite 300

Dallas, Texas 75240

Katie Swanson CH2M HILL, as

rep ofEPA

972-980-

2170

kswanso2 @ch2m.com 5339 Alpha Road Suite 300

Dallas, Texas 75240

Interview Questions and Responses

1. What is your overall impression of the work conducted at each site? (general sentiment)

Response: The work done at the sites [Rogers Road Landfill and neighboring Jacksonville

Landfill] took care of the problem, in fact, the regrading necessary as part of the

remedy took care of a lot of the drainage problems at the sites. Both sites are

now in a condition that they could be applied to recreational use; there is good

ground cover, trees, and grass.

2. From your perspective, what effect have remedial operations at the site had on the surrounding

community?

Response: The remediation had a positive effect on the surrounding area, both sites are

now more attractive than some of the surrounding areas. At Jacksonville

Landfill, mulch from the city mulching operation was used to dress up the site.

About 3 to 4 years ago the National Tree Foundation sent the city some saplings

and a tree farm was started onsite (although a drought recently killed many of

the trees). The trees are used for city beautification projects. The ditches at the

site are maintained by the county. At Rogers Road, there were drainage

improvements due to the remedy, although no mulch was applied to this site.

There is a low area at the back of the site where drainage is not as good.

PAGE 1 OF4 INTERVIEW CONDUCTED JUNE 27,2000

002180
ROGERS ROAD/JACKSONVILLE MUNICIPAL LANDFILLS, FIVE-YEAR REVIEW INTERVIEW RECORD

RESPONSE PROVIDED BY MURICE GREEN/CITY OF JACKSONVILLE

3. Are you aware of any ongoing community concerns regarding the site or its operation and

administration? Please provide details.

Response: A homeowner that lives near the Southeast comer of the Jacksonville site

complained about water draining from the site onto his property. This was not

a result of the remedial action, however, the City responded to his complaint by

dredging out the drainage ditch in the area; there have been no further

complaints.

4. Are you aware of any events, incidents, or activities that have occurred at either site, such as

dumping, vandalism, trespassing, or emergency response from local authorities, since the

startup of remedial action? If so, please give details.

Response: There haven't been any problems since the completion of the remedial action

(during the remedial activities there was a problem with theft of the barb wire

fencing and gates). There is a gas line that runs down the middle of the

Jacksonville site that requires periodic access by the operators of the gas line,

but there have been no signs of tampering.

5. Have there been routine communications or activities (site visits, inspections, reporting

activities, etc.) conducted by your office regarding either site since the startup of remedial

action other than the annual site inspection? If so, please describe purpose and results.

Response: The city does not keep a log or submit O&M reports, but the sites are inspected

on a monthly basis (or as needed) to check the area, ensure the fence and gates

are intact, check the condition of the wells, and check the need for

mowing/bush-hogging/regrading. The city plans to keep a log of these

activities in the future.

6. Have there been any complaints, violations, or other incidents related to the site that required a

response by your office? If so, please give summarize the events and results of the responses.

Response: Not since completion of the remedial action (see response to questions 3 and 4).

RR_5YfL000927_ATT2_lNTERVIEW_Cmf.WPO PAGE 2 OF 4 INTERVIEW CONDUCTED JUNE 27,2000

002181
ROGERS ROAD/JACKSONVILLE MUNICIPAL LANDFILLS, FIVE-YEAR REVIEW INTERVIEW RECORD

RESPONSE PROVIDED BY MURICE GREEN/CITY OF JACKSONVILLE

7. Were any problems or difficulties encountered after the initiation of remedial action which

impacted construction progress and implementability?

Response: Nothing out of the ordinary. The remedial action was delayed for

approximately a month or so due to wet weather, there is standing water in the

area of the landfills since it is a natural low area. Roads had to be built to

facilitate access.

8. Were or have any problems been encountered at either site which required or will require

changes in the Record of Decision or remedial action performed?

Response: No.

9. Have there been any significant changes in the site status or maintenance requirements since

completion of remedial action? If so, do they affect the protect! veness or effectiveness of the

remedy? Please describe changes and impacts.

Response: Not in terms of activities managed by the City.

10. Have there been unexpected O&M difficulties or costs at either site since the start of O&M?

If so, please give details

Response: Costs for O&M activities conducted by the city have not been historically

tracked by the city (not part of the O&M responsibilities as understood by the

city). There have been no significant changes in the activities involved,

however, and therefore the costs have most likely remained consistent since the

completion of the remedy.

11. What are the approximate annual O&M costs for each site?

Response: See response to Question 10; the city can provide an estimated annual cost

upon request.

12. Is groundwater use restricted beyond the perimeter fenced area of either site? Is the

groundwater use restriction by institutional control verified as part of each site's annual

inspection?

Response: The restrictions only apply within the fenced area of each site. Although the

existing residential wells have been sampled, these wells are not known to be

used (the area is on city water).

RR_5YB_000927_ATl2_lMTERVIEW_CrrY.WPD PAGE 3 OF 4 INTERVIEW CONDUCTED JUNE 27,2000

002182
ROGERS ROAD/JACKSONVILLE MUNICIPAL LANDFILLS, FIVE-YEAR REVIEW INTERVIEW RECORD

RESPONSE PROVIDED BY MURICE GREEN/CrTY OF JACKSONVILLE

13. Have there been opportunities to optimize the operation, maintenance, or sampling efforts at

the site since the start of the remedial action? Please describe changes and the resultant or

desired cost savings or improved efficiency.

Response: As indicated in the response to Question 10, there have been no significant

changes in the O&M activities under the city's responsibility since the

completion of remedial action.

14. Do you have any comments, suggestions, or recommendations regarding either site?

Response: No.

RR_5YR_000927_ATT2_lNTERVlEW_Crry.WPO PAGE 4 OF 4 INTERVIEW CONDUCTED JUNE 27,2000

002183
Five-Year Review Interview Record

Rogers Road/Jacksonville

Pulaski/Lonoke Counties, Arkansas

Site Name

Rogers Road Municipal Landfill

Jacksonville Municipal Landfill

Interview

Conducted by

Margaret O'Hare

Katie Swanson

Interview Questions and Responses

1. What is your overall impression of the work conducted at each site? (general sentiment)

Response: The construction at both sites went very well, it was a very thorough job.

2. From your perspective, what effect have remedial operations at the site had on the surrounding

community?

Response: The action took away some of the stigma attached to the sites as Superfund

sites and landfills, had a positive effect on the community, and returned the land to

some amount of reuse. The sites were very overgrown prior to the action, now

they both have access roads and arc routinely mowed. Also, odors noticeable

prior to the action arc gone.

3. Are you aware of any ongoing community concerns regarding the site or its operation and

administration? Please provide details.

Response: No ongoing community concerns.

Organization

CH2MHILL,as

repofEPA

CH2M HILL. as

repofEPA

EPA ID No.

EPA ID# ARD981055809

EPA BD# ARD980809941

Phone

972-980-

2170

972-980-

2170

Interviewee: Kathleen Aisling

EPA Region 6, RPM

Phone: (214) 665-8509

Email

mohare@ch2m.com

kswanso2@ch2m.com

Date of

Interview

June 27,2000

June 27,2000

Address

5339 Alpha Road Suite 300

Dallas, Texas 75240

5339 Alpha Road Suite 300

Dallas, Texas 75240

Interview

Method

In person

In person

PAGE 10F3 INTERVIEW CONDUCTED JUNE 27,2000

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ROGERS ROAD/JACKSONVILLE MUNICIPAL LANDFILLS, FIVE-YEAR REVIEW INTERVIEW RECORD

RESPONSE PROVIDED BY KATHLEEN AlSUNG/U.S. EPA REGION 6

4. Are you aware of any events, incidents, or activities that have occurred at either site, such as

dumping, vandalism, trespassing, or emergency response from local authorities, since the

startup of remedial action? If so, please give details.

Response: At the beginning of the remedial action, there were two incidents of note, one

involving the theft of some fencing from the sites, and the other involving the

discharge onsite of raw sewage from a neighboring property onto the

Jacksonville landfill property. No incidents since 1995.

5. Have there been routine communications or activities (site visits, inspections, reporting

activities, etc.) conducted by your office regarding either site since the startup of remedial

action other than the annual site inspection? If so, please describe purpose and results.

Response: Since the completion of remedial action, EPA representatives were present at

the first two annual groundwater monitoring events, and have performed two

additional site visits (generally at least one visit per year).

6. Have there been any complaints, violations, or other incidents related to the site that

required a response by your office? If so, please give summarize the events and results

of the responses.

Response: No.

7. Were any problems or difficulties encountered after the initiation of remedial action which

impacted construction progress and implementability?

Response: No.

8. Were or have any problems been encountered at either site which required or will require

changes in the Record of Decision or remedial action performed?

Response: No.

9. Have there been any significant changes in the site status or maintenance requirements since

completion of remedial action? If so, do they affect the protectiveness or effectiveness of the

remedy? Please describe changes and impacts.

Response: None, except for the discontinuation of groundwater monitoring by ADEQ. EPA

concurs with ADEQ that it is appropriate to discontinue groundwater monitoring.

RR_5YR_000927_ATT2_lNTERVIEW_EPA_Aia.lNG.WPO PAGE 2 OF 3 INTERVIEW CONDUCTED JUNE 27,2000

002185
ROGERS ROAD/JACKSONVILLE MUNICIPAL LANDFILLS, FIVE-YEAR REVIEW INTERVIEW RECORD

RESPONSE PROVIDED BY KATHLEEN AISUNG/U.S. EPA REGION 6

10. Have there been unexpected O&M difficulties or costs at either site since the start of O&M?

If so, please give details

Response: No.

11. What are the approximate annual O&M costs for each site?

Response: The city and ADEQ are responsible for O&M costs; the ROD provides

projected O&M costs.

12. Is groundwater use restricted beyond the perimeter fenced area of either site? Is the

groundwater use restriction by institutional control verified as part of each site's annual

inspection?

Response: Groundwater use is restricted for the entire landfill even though the area where

contamination was left in place and capped makes up only a portion of the

property, less than an acre. No institutional controls are in place for

neighboring properties.

13. Have there been opportunities to optimize the operation, maintenance, or sampling efforts at

the site since the start of the remedial action? Please describe changes and the resultant or

desired cost savings or improved efficiency.

Response: Yes, with the discontinuation of groundwater monitoring. EPA concurs with

the appropriateness of this action.

14. Do you have any comments, suggestions, or recommendations regarding either site?

Response: Officially discontinue annual groundwater as part of the annual O&M for these

sites. Pass the sites and control of the groundwater monitoring wells over to the

appropriate regulatory authority for use in solid waste post-closure monitoring

as appropriate.

RR_5YR_000927J^TT2JNTERVlEW_EPA_AlSLlNG.WPD PAGE 3 OF 3 INTERVIEW CONDUCTED JUNE 27,2000

002186
ROGERS ROAD MUNICIPAL LANOFU

FIRST FIVE-YEAR REVIEW REPORT

[This page intentionally left blank.]

RR_5YR_000927.WPO SEPTEMBER 2000

002187
Five-Year Review Interview Record

Rogers Road/Jacksonville

Pulaski/Lonoke Counties, Arkansas

Interviewee: Ken dark

EPA Region 6, OSC

Phone:

Site Name EPA ID No. Date of

Interview

Interview

Method

Rogers Road Municipal Landfill EPA ID# ARD981055809 June 27,2000 In person

Jacksonville Municipal Landfill EPA ID# ARD980809941 June 27,2000 In person

Interview

Conducted by

Organization Phone Email Address

Margaret O'Hare CH2MHILL,as

rep ofEPA

972-980-

2170

mohare @ch2m.com 5339 Alpha Road Suite 300

Dallas, Texas 75240

Katie Swanson CH2M HILL, as

rep ofEPA

972-980-

2170

kswanso2@ch2m.com 5339 Alpha Road Suite 300

Dallas, Texas 75240

Interview Questions and Responses

1. What is your overall impression of the work conducted at each site? (general sentiment)

Response: Concur with the city's assessment of the work (The work done at the sites

[Rogers Road Landfill and neighboring Jacksonville Landfill] took care of the

problem, in fact, the regrading necessary as part of the remedy took care of a lot

of the drainage problems at the sites. Both sites are now in a condition that they

could be applied to recreational use; there is good ground cover, trees, and

grass.)

2. From your perspective, what effect have remedial operations at the site had on the surrounding

community?

Response: Positive impact, noting in particular the tree farms, which involve the National Tree

Foundation and local scouts.

3. Are you aware of any ongoing community concerns regarding the site or its operation and

administration? Please provide details.

Response: No additional response provided (beyond that provided by other respondents).

4. Are you aware of any events, incidents, or activities that have occurred at either site, such as

dumping, vandalism, trespassing, or emergency response from local authorities, since the

startup of remedial action? If so, please give details.

Response: No additional response provided.

PAGE 1 OF3 INTERVIEW CONDUCTED JUNE 27,2000

002188
ROGERS ROAD/JACKSONVILLE MUNICIPAL LANDFILLS, FIVE-YEAR REVIEW INTERVIEW RECORD

RESPONSE PROVIDED BY KEN CLARK/U.S. EPA REGION 6

5. Have there been routine communications or activities (site visits, inspections, reporting

activities, etc.) conducted by your office regarding either site since the startup of remedial

action other than the annual site inspection? If so, please describe purpose and results.

Response: No additional response provided.

6. Have there been any complaints, violations, or other incidents related to the site that

required a response by your office? If so, please give summarize the events and results

of the responses.

Response: No.

7. Were any problems or difficulties encountered after the initiation of remedial action which

impacted construction progress and implementability?

Response: No.

8. Were or have any problems been encountered at either site which required or will require

changes in the Record of Decision or remedial action performed?

Response: No.

9. Have there been any significant changes in the site status or maintenance requirements since

completion of remedial action? If so, do they affect the protectiveness or effectiveness of the

remedy? Please describe changes and impacts.

Response: No additional response provided.

10. Have there been unexpected O&M difficulties or costs at either site since the start of O&M?

If so, please give details

Response: No additional response provided.

11. What are the approximate annual O&M costs for each site?

Response: No additional response provided.

RR_5YR_000927_ATT2_lNTERVlEW_EPA_ClARK.WPO PAGE 2 OF 3 INTERVIEW CONDUCTED JUNE 27,2000

002189
ROGERS ROAD/JACKSONVILLE MUNICIPAL LANDFILLS, FIVE-YEAR REVIEW INTERVIEW RECORD

RESPONSE PROVIDED BY KEN CLARK/U.S. EPA REGION 6

12. Is groundwater use restricted beyond the perimeter fenced area of either site? Is the

groundwater use restriction by institutional control verified as part of each site's annual

inspection?

Response: No additional response provided.

13. Have there been opportunities to optimize the operation, maintenance, or sampling efforts at

the site since the start of the remedial action? Please describe changes and the resultant or

desired cost savings or improved efficiency.

Response: No additional response provided.

14. Do you have any comments, suggestions, or recommendations regarding either site?

Response: No additional response provided.

RR_5YR_000927_ATT2_lNTERVIEW_EPA_CLARK.WPO PAGE 3 OF 3 INTERVIEW CONDUCTED JUNE 27,2000

002190
ROGERS ROAD MUNICIPAL LANDFILL

FRST FIVE-YEAR REVIEW REPORT

[This page intentionally left blank.]

RR-5YR.000927.wo SEPTEMBER 2000

002191
ROGERS ROAD MUNICIPAL LANOFIU.

FIRST FIVE-YEAR REVIEW REPORT

Attachment 3

Site Inspection Checklist

RR_5YR_000927.WPO SEPTEMBER 2000

002192
ROGERS ROAD MUNICIPAL LANDFILL

FIRST FIVE-YEAR REVIEW REPORT

[This page intentionally left blank.]

RR-5YR.000927.WPO SEPTEMBER 2000

002193
Rogers Road Municipal Landfill

Five-Year Review Site Inspection Checklist

<

Please note that "O&M" is referred to throughout this checklist. At sites where Long-Term

Response Actions are in progress, O&M activities may be referred to as "system operations"

since these sites are not considered to be in the O&M phase while being remediated under the

Superfund program. N/A means "not applicable."

SITE INFORMATION

Site Name: Rogers Road Municipal Landfill EPAID: ARD981055809

City/State: Pulaski County, Arkansas Date of Inspection: June 27,2000

Agency Completing 5 Year Review: US EPA Weather/temperature: 80 F, overcast, calm

Remedy Includes: (Check all that apply)

B Landfill cover/containment

a Access controls

a Institutional controls

a Groundwater pump and treatment

a Surface water collection and treatment

D Other:

Attachments: a Inspection team roster attached D Site map attached

II. INTERVIEWS (Check all that apply)

1. O&M site manager:

Name: Murice Green

Title: Chief of Public Works, City of Jacksonville

Date: June 27,2000

Interviewed: a at site s at office a by phone Phone Number (501)982-6071

Problems, suggestions: n Additional report attached (if additional space required).

2. O&M staff:

Name: James Whisker

Title: City Engineer

Date: June27,2000

Interviewed: B at site

Problems, suggestions:

B at office a by phone Phone Number: (501 )982-6071

a Additional report attached (if additional space required).

PAGE 1 OF 14 JUNE 27,2000

002194
ROGERS ROAD MUNICIPAL LANDFILL

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response office, police

department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county

offices, etc.) Fill in all that apply.

Agency: Arkansas Department of Environmental Quality

Contact: Brian Wakelyn

Name:

Title: Project Manager

Date: June 27,2000

Phone Number: (501) 682-0845

Problems, suqgestions: o Additional report attached (if additional space required).

Agency: U.S. Environmental Protection Agency

Contact: Ken dark

Name:

Title: OSC

Date: June 27,2000

Phone Number: (214)665-6774

Problems, suggestions: o Additional report attached (if additional space required).

Agency:

Contact:

Name:

Title:

Date:

Phone Number

Problems, suggestions: n Additional report attached (it additional space required).

Agency:

Contact:

Name:

Title:

Date:

Phone Number:

Problems, suggestions: o Additional report attached (if additional space reguired).

4. Other interviews (optional) aN/A a Additional report attached (if additional space required).

Kathleen Aisling/EPA Remedial Project Manager

RR_5YR_000927_A7T3A_SlTElNSPECTIONCHKlST.WPO PAGE 2 OF 14 JUNE 27,2000

002195
ROGERS ROAD MUNICIPAL LANDFILL

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

III. ONSITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1. O&M Documents

D O&M Manual

s As-Built Drawings

a Maintenance Logs

Remarks:

o Readily available

a Readily available

o Readily available

a Up to date

a Up to date

o Up to date

BN/A

gN/A

BN/A

2. Health and Safety Plan Documents

D Site-Specific Health and Safety Plan g Readily available a Up to date

g Contingency plan/emergency response plan a Readily available g Up to date

Remarks: There are no site conditions that would restrict normal emergency response

BN/A

BIN/A

3. O&M and OSHA Training Records

Remarks:

o Readily available D Up to date BN/A

4. Permits and Service Agreements

a Air discharge permit

o Effluent discharge

a Waste disposal, POTW

a Other permits

Remarks:

o Readily available

a Readily available

a Readily available

n Readily available

D Up to date

o Up to date

a Up to date

a Up to date

BN/A

BN/A

BN/A

BN/A

5. Gas Generation Records

Remarks:

o Readily available o Up to date BN/A

6. Settlement Monument Records

Remarks:

n Readily available g Up to date IN/A

7. Groundwater Monitoring Records B Readily available a Up to date gN/A

Remarks:

8. Leachate Extraction Records

Remarks:

a Readily available g Up to date BN/A

9. Discharge Compliance Records

Remarks:

o Readily available g Up to date BN/A

10. Dally Access/Security Logs

Remarks:

g Readily available g Up to date BN/A

PAGE 3 OF 14 JUNE 27,2000

002196
ROGERS ROAD MUNICIPAL LANDFILL

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

IV. O&M Costs a Applicable HN/A

1. O&M Organization

a State in-house n Contractor for State

BpRpjn-house a Contractor for PRP

o Other

2. O&M Cost Records

a Readily available a Up to date a Funding mechanism/agreement in place

Oriainal O&M cost estimate: $5.000 for site inspection and cover maintenance a Breakdown attached

$16,900 for groundwater monitoring (see attached ROD and FS cost information)

Total annual cost bv year for review oeriod if available • not available, estimated annual cost for site inspection and cover

maintenance provided by City of Jacksonville (see attached estimate) is $6,720/year. Estimated groundwater cost is $3,000 -

$3,500/year.

From (Date): To (Date): Total cost: o Breakdown attached

From (Date): To (Date): Total cost a Breakdown attached

From (Date): To (Date): Total cost a Breakdown attached

From (Date): To (Date): Total cost o Breakdown attached

From (Date): To (Date): Total cost o Breakdown attached

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

Describe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS a Applicable

A. Fencing

1. Fencing damaged o Location shown on site map a Gates secured aN/A

Remarks: No damage evident, the City of Jacksonville reported that the former dty engineer had done thorough

inspection of fence perimeter

B. Other Access Restrictions

1. Signs and other security measures o Location shown on site map

Remarks: No signs posted on gate or fencing

ON/A

PAGE 4 OF 14 JUNE 27,2000

002197
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FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

C. Institutional Controls

1. Implementation and enforcement

Site conditions imply ICs not properly implemented: a Yes s No oN/A

Site conditions imply ICs not being fully enforced: a Yes o No oN/A

Type of monitoring (e.g, self-reporting, drive by): Site inspections of fencing used to restrict access

Frequency: monthly

Responsible party/agency: City of Jacksonville

Contact Murice Green

Name:

Title: Chief of Public Works

Date: June 27,2000

Phone Number. (501 )982-6071

Reporting is up-to-date: oYes oNo HN/A

Reports are verified by the lead agency: o Yes 5 No HN/A

Specific requirements in deed or decision documents have been met: a Yes oNo nN/A

Violations have been reported: s Yes oNo nN/A

Other problems or suggestions: n Additional report attached (if additional space required).

2. Adequacy a ICs are adequate a ICs are inadequate nN/A

Remarks: ICs are adequate at restricting access to the site and site groundwater. Although groundwater immediately

downgradient is not under control of City, residents are on municipal supply and groundwater use is not expected.

D. General

1. Vandalism/trespassing o Location shown on site map ja No vandalism evident

Remarks:

2. Land use changes onsKe

Remarks:

IN/A

3. Land use changes offstte

Remarks:

IN/A

VI. GENERAL SITE CONDITIONS

A. Roads B Applicable aN/A

1. Roads damaged s Location shown on site map B Roads adequate oN/A

Remarks:

RR_5YR_000927_ATl3A_SlTElNSPECT10NCHKIST.WPO PAGE50F14 JUNE27.2000

002198
ROGERS ROAD MUNICIPAL LANDFILL

FIVE-YEAR REVIEW StTE INSPECTION CHECKLIST

B. Other Site Conditions

Remarks: Some offsite dumping is evident, tires, trash and wood debris are present near the site. The City of

Jacksonville reported that unauthorized dumping took place prior to initiation of the remedy.

VII. LANDFILL COVERS a Applicable

A. Landfill Surface

1. Settlement (Low spots)

Areal extent

Remarks:

n Location shown on site map

Depth:

a Settlement not evident

2. Cracks

Lengths:

Remarks:

D Location shown on site map

Widths: Depths:

a Cracking not evident

3. Erosion

Areal extent

Remarks:

g Location shown on site map

Depth:

a Erosion not evident

4. Holes

Areal extent

Remarks:

o Location shown on site map

Depth:

B Holes not evident

5. Vegetative Cover

a Cover property established

Remarks:

ja No signs of stress B Grass a Trees/Shrubs

6. Alternative Cover (armored rock, concrete, etc.)

Remarks:

HN/A

7. Bulges

Areal extent:

Remarks:

o Location shown on site map

Height

a Bulges not evident

PAGE 6 OF 14 JUNE 27.2000

002199
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FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

Wet Areas/Water Damage a Wet areas/water damage not evident

a Wet areas a Location shown on site map Areal extent

a Ponding o Location shown on site map Areal extent

g_Seeps a Location shown on site map Areal extent:

g.Soft subgrade o Location shown on site map Areal extent

Remarks: Tnere is poor drainage in the surrounding areas, site has been graded to prevent the occurrence of standing

water.

9. Slope Instability jo.SIides o Location shown on site map ^ No evidence of slope instability

Areal extent

Remarks:

B. Benches 5 Applicable BN/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow

down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench n Location shown on site map nN/Aorokay

Remarks:

2. Bench Breached a Location shown on site map gN/Aorokay

Remarks:

3. Bench Overtopped g Location shown on site map aN/Aorokay

Remarks:

C. Letdown Channels a Applicable aN/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope of the

cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion

gullies.)

1. Settlement D Location shown on site map n No evidence of settlement

Areal extent Depth:

Remarks:

2. Material Degradation o Location shown on site map

Material type: Area) extent:

Remarks:

o No evidence of degradation

3. Erosion o Location shown on site map

Areal extent: Depth:

Remarks:

o No evidence of erosion

RR-5YR_000927_ATT3A_SlTElNSPECT10NCHKIST.WPD PAGE 7 OF 14 JUNE 27.2000

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FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

4. Undercutting

Areal extent:

Remarks:

S Location shown on site map

Depth:

a No evidence of undercutting

5. Obstructions

Type:

Area! extent

Remarks:

D Location shown on site map

Height:

nN/A

6. Excessive Vegetative Growth

a Evidence of excessive growth

a Location shown on site map

Remarks:

a No evidence of excessive growth

a Vegetation in channels but does not obstruct flow

Areal extent:

D. Cover Penetrations o Applicable aN/A

1. Gas Vents

a Active o Passive

o Property secured/locked

o Evidence of leakage at penetration

Remarks:

DN/A

[] Routinely sampled

o Functioning

o Needs O&M

o Good condition

2. Gas Monitoring Probes

o Routinely sampled

o Properly secured/locked a Functioning

a Evidence of leakage at penetration o Needs O&M

Remarks:

aN/A

o Good condition

3. Monitoring Wells (within surface area of landfill)

o Routinely sampled

a Property secured/locked a Functioning

o Evidence of leakage at penetration o Needs O&M

Remarks:

oN/A

o Good condition

4. Leachate Extraction Wells

a Routinely sampled

a Properly secured/locked a Functioning

o Evidence of leakage at penetration o Needs O&M

Remarks:

ON/A

a Good condition

5. Settlement Monuments o Located

Remarks:

D Routinely surveyed ON/A

PAGE80F14 JUNE 27,2000

002201
ROGERS ROAD MUNICIPAL LANDFILL

FIVE-YEAH REVIEW SITE INSPECTION CHECKLIST

E. Gas Collection and Treatment g Applicable EN/A

1. Gas Treatment Facilities gN/A

n Raring g Thermal destruction g Collection for reuse

o Good condition n Needs O&M

Remarks:

2. Gas Collection Wells, Manifolds and Piping gN/A

g Good condition g Needs O&M

Remarks:

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) n N/A

D Good condition g Needs O&M

Remarks:

F. Cover Drainage Layer a Applicable BN/A

1. Outlet Pipes Inspected g Functioning gN/A

Remarks:

2. Outlet Rock Inspected g Functioning gN/A

Remarks:

G. Detention/Sedimentation Ponds g Applicable ^N/A

1. SiKation g Siltafon evident gN/A

Area! extent: Depth:

Remarks:

2. Erosion g Erosion evident gN/A

Area! extent Depth:

Remarks:

3. Outlet Works g Functioning gN/A

Remarks:

4. Dam g Functioning gN/A

Remarks:

H. Retaining Walls g Applicable BN/A

PAGE 9 OF 14 JUNE 27,2000

002202
ROGERS ROAD MUNICIPAL LANDFILL

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

1. Deformations o Location shown on site map

Horizontal displacement: Vertical displacement:

Remarks:

o Deformation not evident

Rotational displacement:

2. Degradation

Remarks:

a Location shown on site map a Degradation not evident

Perimeter Ditohes/Off-site discharge B Applicable oN/A

1. Siltation

Areal extent

Remarks:

D Location shown on site map

Depth:

B Siltation not evident

2. Vegetative Growth

Areal extent

Remarks:

n Location shown on site map

Type:

H Vegetation does not impede flow

3. Erosion

Areal extent

Remarks:

g Location shown on site map

Depth:

B Erosion not evident

4. Discharge Structure o Location shown on site map

a Functioning a Good Condition

Remarks: No discharge structure, drainage managed by site grading.

BN/A

VIII. VERTICAL BARRIER WALLS a. Applicable

1. Settlement

Area) extent:

Remarks:

o Location shown on site map

Depth:

o Settlement not evident

2. Performance Monitoring

a Performance not monitored

a Performance monitored

a Evidence of breaching

Remarks:

Frequency:

Head differential:

aN/A

IX. GROUNDWATER/SURFACE WATER REMEDIES a. Applicable

PAGE100F14 JUNE 27.2000

002203
ROGERS ROAD MUNICIPAL LANDFILL

FIVE-YEAR REVIEW SfTE INSPECTION CHECKLIST

1. Pumps, Wellhead Plumbing, and Electrical

o All required wells located n Good condition g Needs 0& M

Remarks:

DN/A

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances

a System located g Good condition g Needs 0& M

Remarks:

ON/A

3. Spare Parts and Equipment

g Readily available

o Requires Upgrade

Remarks:

ON/A

a Good condition

D Needs to be provided

B. Surface Water Collection Structures, Pumps, and Pipelines n Applicable BN/A

1. Collection Structures, Pumps, and Electrical

g Good condition a Needs 0& M

Remarks:

oN/A

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances g N/A

o Good condition g Needs 0& M

Remarks:

3. Spare Parts and Equipment

o Readily available

g Requires Upgrade

Remarks:

nN/A

o Good condition

g Needs to be provided

C. Treatment System g Applicable a N/A

1. Treatment Train (Check components that apply)

g Metals removal g Oil/water separation

g Air stripping g Carbon adsorbers

g Additive (list type, e.g., chelation agent, flocculent)

g Others (list):

g Good condition g Needs O&M

g Sampling ports property marked and functional

g Sampling/maintenance log displayed and up to date

g Equipment property identified

g Quantity of groundwater treated annually (list volume):

g Quantity of surface water treated annually (list volume):

Remarks:

gBioremediation

g Filters (list type):

PAGE 11 OF 14 JUNE 27,2000

002204
ROGERS ROAD MUNICIPAL LANDFILL

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

2. Electrical Enclosures and Panels (properly rated and functional)

a Good condition a Needs O&M

Remarks:

aN/A

3. Tanks, Vaults, Storage Vessels

o Good condition a Proper secondary containment a Needs O&M

Remarks:

DN/A

4. Discharge Structure and Appurtenances

a Good condition o Needs 0& M

Remarks:

aN/A

5. Treatment Building(s)

o Good condition (esp. roof and doorways)

o Chemicals and equipment properly stored

Remarks:

aN/A

o Needs Repair

6. Monitoring Wells (pump and treatment remedy)

o All required wells located a Properly secured/locked o Functioning

g Good condition a Needs O&M

Remarks:

aN/A

a Routinely sampled

D. Monitored Natural Attenuation a Applicable aN/A

1. Monitoring Wells (natural attenuation remedy) g N/A

D All required wells located a Property secured/locked ^Functioning g Routinely sampled

g Good condition g Needs O&M

Remarks: All wells were not located during the site visit due to dense vegetation including poison oakflvy and ticks. The

background wells are difficult to access due to land owner and animals present in the area. These wells are inspected

routinely during the periodic inspections by the city.

X. OTHER REMEDIES g Applicable

If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical

nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

PAGE 12 OF 14 JUNE 27,2000

002205
ROGERS ROAD MUNICIPAL LANDFILL

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a

brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas

emission, etc.)

The remedy is effective and functioning as designed. The remedy was chosen to remove the principal health threats that

presented excess lifetime cancer risk, and prevent further actual or threatened releases of hazardous substances from the

site. Materials containing abovelO ppb dioxin concentrations were removed and treated, 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 diekjrin, and/or dieldrin and herbicide contamination associated with a hazard index above 0.7. Institutional controls

include site inspections to confirm fence integrity and land use restrictions. Site inspections show that the fencing is

effectively preventing access to the site. Annual groundwater monitoring was also conducted, but was halted in 1997 since no

contaminants of concern were detected.

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 protectiveness of the remedy.

O&M procedures appear to be adequate. Written records of O&M frequency and annual costs have not been individually

maintained, and the City indicated an effort will be made to keep these records up-to-date and readily accessible in the future.

Groundwater monitoring at the site was discontinued due to lack of detected site-related contaminants. The existing

monitoring well network could potentially be used for monitoring under the appropriate solid waste regulatory authority, so

abandonment is not recommended at this time.

C. Early Indicators of Potential Remedy Failure

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of

unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the future.

None observed.

RR_5YR_000927_ATT3A_SrTElNSPECT10NCHKIST.WPD PAGE 13 OF 14 JUNE 27,2000

002206
ROGERS ROAD MUNICIPAL LANDFILL

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

Groundwater monitoring was determined to no longer be necessary, once the restrictive covenants are in place. However,

solid waste regulations may still apply. The current monitoring well network could possibly be used for solid waste monitoring

purposes, and groundwater data and information about the wells should be conveyed to the appropriate solid waste regulatory

authority.

RR_5YR_000927_ATT3A_SlTElNSPECT10NCHKIST.WPO PAGE140F14 JUNE27.2000

002207
Inspection Team Roster

Rogers Road Municipal Landfill Site, 5 Year Review

June 27.2000

Name

Margaret O'Hare

Katie Swanson

Kin Siew

Brian Wakelyn

Jay Whisker

Murice Green

Kathleen Aisling

Kenneth dark

Agency

CH2M HILL

CH2MHILL

ADEQ

ADEQ

City of Jacksonville

City of Jacksonville

USEPA

USEPA/ERCS

Phone Number

(972)980-2170

(972) 980-2170

(501)682-0855

(501)682-0845

(501) 982-6071

(501)982-3146

(214)665-8509

(214) 665-6774

PAGE I OF 1 SEPTEMBER 2000

002208
ROGERS ROAD MUNICIPAL LANDFILL

FIRST FIVE-YEAR REVIEW REPORT

[This page intentionally left blank.]

RR_5YR_000927.WD SEPTEMBER 2000

002209
TABLE 6 (COfit*d)

COST ESTIMATE

ALTERNATIVE 5

Rogers Road Landfill site

Jacksonville, Arkansas

Activity

Estimated Unit Cost($)

Quantity price (1990)

Administrative & Legal

6 51 of Direct cost 30,190

Engineering 6 Services

6 101 of Direct Cost 60.lfi0

TOTAL INDIRECT COST: 240,710

TOTAL CAPITAL COST (DIRECT + INDIRECT)t 842,460

II. 0 & H Cost

• Annual Data Review 6 Hrs $60/Hr 480

• 5-Year Evaluation 160 Hrs $60/Hr 9,600

• Maintenance of Existing

Fence L.S . 2,000

• Annual Inspection and

Maintenance of Soil Cover L.S . 3,000

A . Periodic Inspection of

Containers Stored Onsite

for One Year L.S . 3,000

B. Present Worth of LongTerm Groundwater Monitoring

(Annual and 5-Year) (See

Rogers Road FS Report,

Table 6-1 for Details). 259,800

C. Present Worth of Annual

Data Review

($480 X 15.3725) 7,380

D. Present Worth of 5-Year

Evaluation ($9,600 X 2.782) 26,700

1-89

002210
TABLB « (Cont'd)

COST ESTIMATE

ALTBRKATIVB 5

Rogers Road Landfill Site

Jacksonville, Arkansas

Activity

Estimated Unit Cost($)

Quantity Price (1990)

E. Present Worth of Existing

Fence Maintenance Based

on 51 Discount Rate for

30 Years ($2,000 X 15.3725)

F. Present Worth of Inspection

and Maintenance of Soil Cover

Based on 5) Discount Rate

for 30 Years ($3.000 X

15.3725)

G. Land Use Control Contingencies

tor 30 Years

TOTAL 0 6 M COST

(MET PRESENT WORTH)*

30.750

4 6., 120

10.000

383,750

III. TOTAL COST OF ALTERNATIVE 5

(CAPITAL + 0 & M)

(K-T PRESENT WORTH): $ 1,226,210

1-90

002211
T2BLX 6-1

COST KSXIIOTX

KISXSfOXSVt Is HO XCTIOH

Rogers Road Landfill Site

Ptilxcki Count y, Arlcanim«

Cost ($) References/

<1»90» Remarks

estlnated

Quantity

Unit

Activity Price .

COPitgl Cogt

A. Direct Cost

• Nell Drilling

(3 Hew Nells) 120 L.F.

• Hell Casing

installation

(Stainless Steel) (0 L.F.

• Mobilization and

Decontamlnafcion L.S.

B. Indirect. Coat

• Health ( Safety

€ 5« of Direct Cost

• Bid & Scope Contingency

C 10» of Direct Cost

(30/L.r. 3,600 Reference 20

$50/L.r. 3,000 Reference 20

5.000

BUBTOTtI.; 11,600

600

1,200

002924

002212
TXBLX 6-J. (ooatelwd)

COST XSTIMAXX

USViWKCIVS 2: 80 JCTZOH

Rogers Road Landfill Sit«

Pulaski County, Arkansas

Activity

Eatlnated Unit Cost($> Raferencaa/

Quantity Prica . (1990) Remarks

• Adainlatrative and Legal

8 10 % of Direct. Cod 1.200

• Engineering 6 Services

During Drilling

I 51 of Direct Cost 600

SUBTOTAL: 3,603

TOTAL CXPITXI. COST: IS,200

II. 0 t M Coat

A. Monitoring

(1) Annual Monitoring;

• Groundwater Sampling 30 Bra 930/Hr 900

• Groundwater.Lab

Analysis

002925

002213
CXBUC 6-1. (continued}

CO&I X9TUOXK

mxmarxvx i: no ACTION

Rogers Road Landfill Site

Pulisici County, kxk&nsas

Estimated

Quantity

Onit

Price

Coat($>

(1990)

References/

Remarks

Five Hall Sactples,

One Field Blank. One

Spike Sample and One

QC Saaple 8 Samples

Contingency Analysl* 6 Samples

• Maintenance Contingency

xozu. uanaL uoaisoaxss COST:

(2) Report Preparation:

A. 5-year Review

Report 160 Hrs $60/Br

TOTM. 5-TIAH. KtSOKt tVOCSUaXlW COST:

12,000

2.000

14,SCO

2.080

16,900

9.600

9,600

Reference 30

002926

002214
TRBU 6-1 (continnod)

COST XSIIHX.TX

uzBuann l: no ACTIOS

Rogers Road Landtlll Site

Pul*«kt Ccnmty, XrkAnsxi*

Activity

£«tloatod Unit Coat($) References/

Quantity Price . (1990) Remarks

B. Present Worth of

Annual Monitoring

f Maintenance Cost

Based on 51 Discount

for 30 year* -

( (1C,900 X IS.3725 t 250. •00

C. Present (forth of

5-year Review Reports

( $9.600 X 2.182) 2fi.70Q

Tonu. fsxsxax WORTH or o « H COST: 286,500

XXZ. VVSXt, COB* (»» PRXSKM* MORTR)

or Ksassaaatvs c-i 302.000

002927

002215
Sent By: CITY OF JACKSONVILLE,- 501 085 0168: Jul-7-00 8:40AM;

CITY OF JACKSONVILLE

E N G I N E E Rl N G D S.P A RT M E NT

FACSIMILE TEANSMITTAL SHEET

TOi

Maigaret P. CYHacc

COMPANY:

CH2MHUJ.

DATEi

Jply 7^2000

• IZITALWO. Otr fAGES Wa.VDQSC mWS..

2

ccB-t;:

SuptsSsaS SaSes

P.O. BOX 12<

JACtSONVILtE. A.R T2t7«

<fl)«12-««7t |<AX«,{fl)««2««l««

002216
By: CITY OF JACKSONVILLE; S01 985 0108; Jul-7-00 8:40AU; Page 2/2

CITY OF JACKSONVILLE

ENGINEERING DEPARTMENT

JttMf S. Whiakcr, City En^neer

Cost of Operating and Maintaining

Superftmd Sites

Jacksonville LandflU and Rogers Road Landfill

Bush Hog $45.00Yhr.

Sidecutter___$45.00/hr.

Inspection S20.00Af.

Two (2) bush hogs and one (1) sidecuttcr require sixteen (16) hours to clear both sites.

The city clears sites six (6) times per year. Inspection once a month by two (2) people

per year. Therefore:

3 machines @$45.00/hour = $ 135.00/hour

x t6 hours

$ 2,160.00

S2,160.00 x 6 rimes per year = $ 12.960.00

2iiispectjQts@S20.00perlKx.ir~ $ 40.00/hour

__x 12 hours

$480.00

$ 12,960.00 -(• $ 480.00 - $ 13,440.00

Total cost is S 13,440.00 per year. This cost estimate does 50$ include the

$6,000.00 - $7.000.00 per year of ground water sampling from 1994 -1998.

002217
ROGERS ROAD MUNICIPAL LANDFILL

FIRST FIVE-YEAR REVIEW REPOBT

Attachment 4

Site Inspection Photographs

RR_5YB_000927.WPO SEPTEMBER 2000

002218
ROGERS ROAD MUNICIPAL LANDFILL

FIRST FIVE-YEAR REVIEW REPORT

(This page intentionally left blank.]

RR-5YR_000927.WPD SEPTEMBER 2000

002219
First Rw Year Review Site Inspection Photographs

Rogers Road Municipal Landfill Supertund Site

Photograph 1.

Facing south along Rogers Road. Photo

taken from south of Rogers Road

residences/north of site.

PHOTOGRAPHS TAKEN JUNE 27,2000 PAQE10F9

002220
First Flw Year Review Sfte Inspection Photographs

Rogers Road Municipal Landfill Supenund She

Photograph 2.

Facing east-northeast from outside

perimeter fence just north of main access

gate. View is of north end of

excavated/covered area of site.

Perimeter fence visible in foreground.

Photo overlaps to right with Photograph 3.

PHOTOGRAPHS TAKEN JUNE 27.2000 PAQE20F9

002221
FIret FIVB Year Review Site Inspection Photographs

Rogera Road Municipal Landfill Supertund Site

Photograph 3.

Facing east, from outside perimeter fence,

on Rogers Road just north of main access

gate.

Perimeter fence visible in foreground.

Overlaps to left with Photograph 2, and to

right with Photograph 4.

PHOTOGRAPHS TAKEN JUNE 27,2000 PAQE30F9

002222
First Flw Year Review Site Inspection Photographs

Rogers Road Municipal Landfill Supertund Site

Photograph 4.

Facing east-southeast, from outside

perimeter fence, on Rogers Road just

north of main access gate.

Perimeter fence visible in foreground.

Excavated/backfilled area is the vegetated

area without trees.

Photograph overlaps to left with

Photograph 3.

PHOTOGRAPHS TAKEN JUNE 27,2000 PAQE40F9

002223
First Five Year Review Site Inspection Photographs

Rogere Road Municipal Landfill Superfund Site

Photograph 5.

Facing east-southeast into site through

main access gate, from Rogers Road.

PHOTOGRAPHS TAKEN JUNE 27,2000 PAGE 5 OF 9

002224
(—• r" r~ r" r" r" r' r-" r

First Rw Year Revfew Site Inspection Photographs

Rogera Read Municipal landffllSupeftundSlte

Photograph 6.

Facing east, from outside perimeter fence,

on Rogers Road just south of main access

gate.

Perimeter fence visible in near foreground.

Excavated/backfilled area is the vegetated

area without trees.

PHOTOQfWHS TAKEN JUNE 27,2000 PA0660F9

002225
First Fm Year Rwtew Site Inspection Photographs

RoflersRofld MurocipftI Landfili Superiunu Sn9

Photograph 7.

Facing northeast, from just north of southwest corner of perimeter

fence. Clearing in background is (he excavated/covered area of the

landfill.

PHOTOOnXPHSTAKEN JUNE 27,2000 PAQE70F9

002226
r" r~" r r~ r" r r"

FIret Fh« Year Revfw Site Inspecfton Photographs

Rogef» Road Municipal Landfill SuperfuntI Sits

Photograph 8.

.js^i'- Pacing south at south end of Rogers Road.

^"^ Monitor wells MWR-01 (foreground) and

MWR-02 (background). Surface

completions appear in good condition.

PHOTOGRAPHS TAKEN JUNE 27,2000 PAGE80F9

002227
i- - ^— (- - i r" c " (— r r f - r r" c"— r~ ( r~ r~ r" [

First Fhft Year Revtew Site Impedlon Photographs

Rogera Road Munldpat LandflN Supertund Site

Photograph 9.

Facing east along southern perimeter road

along south side of site.

Perimeter fence runs along north side of

road, at left.

Monitor well MWR-05 is at end of this

road, at the southeast corner of the

perimeter fence.

Rft.6YR.000927J^n4PHOTO(»WH8.WPO PHOTOOBAPHS TAKEN JUNE 27,2000 PAQE90F9

002228