Response Action Completion Report (RACR) Good Neighbor …Secure Site · 2012. 11. 16. · The...

Response Action Completion Report (RACR)Good Neighbor Cleaners (DCRP 0060)

6410 Cavalcade Street, Houston,Harris County, Texas

Prepared by:

ECOLOGY AND ENVIRONMENT, INC.1412 Main Street, Suite 1500

Dallas, Texas 75202

November 2, 2011

Submitted to:

TEXAS COMMISSION ON ENVIRONMENTAL QUALITYDry Cleaner Remediation Program

State-Lead Section, Remediation DivisionP.O. Box 13087

Austin, Texas 78711-3057

ecology and environment, inc.Global Environmental Specialists

1412 Main St., Suite 1500Dallas, Texas 75202Tel: (214) 245-1000, Fax: (214) 245-1001

Executive SummaryPage _1_ of _4_

ID No.DC0060

Report Date:November 2, 2011

TEXAS COMMISSION ON ENVIRONMENTAL QUALITYResponse Action Completion Report

Cover Page

Regulatory ID number (Solid waste registration number, VCP ID number, etc) DC0060check one: X Initial RACR submittal for this on-site property Subsequent RACR submittal

Report date: November 2, 2011 TCEQ Region No.: 12

TCEQ Program (check one)

Corrective Action (Mail Code 127) Superfund PRP Lead (Mail Code 143)

Voluntary Cleanup Program (Mail Code 221) Municipal Solid Waste Permits (Mail Code 124)

Petroleum Storage Tank Program (Mail Code 137) X Dry Cleaner Remediation Program (Mail Code 136)

On-Site Property Information

On-Site Property Name: Good Neighbor Cleaners

Street no. 6410 Pre dir: Street name: Cavalcade Street type: Street Post dir:

City: Houston County: Harris County Code: 101 Zip: 77026

Nearest street intersection or location description: Cavalcade Street and Blaffer, southwest corner

Latitude: Degrees, Minutes, Seconds OR Decimal Degrees (circle one) North 29.799809

Longitude: Degrees, Minutes, Seconds OR Decimal Degrees (circle one) West -95.30542

Off-Site Affected Property Information

Off-Site Affected Property Name:Numerous single-family residential houses within plume management zoneshown in Attachment 1A-1.

Street no. Pre dir: Street name: Street type: Post dir:

City: County: County Code: Zip:

Check if there are no off-site properties affected

Contact Person Information and Acknowledgement

Person (or company) Name: Texas Commission on Environmental Quality

Contact Person: Dan Switek Title: Project Manager

Mailing Address: 12100 Park 35 Circle, Building D

City: Austin State: TX Zip: 78753 E-mail address [email protected]

Phone: 512-239-4132 Fax:

By my signature below, I acknowledge the requirement of §350.2(a) that no person shall submitinformation to the executive director or to parties who are required to be provided information under thischapter which they know or reasonably should have known to be false or intentionally misleading, or failto submit available information which is critical to the understanding of the matter at hand or to the basisof critical decisions which reasonably would have been influenced by that information. Violation of thisrule may subject a person to the imposition of civil, criminal, or administrative penalties.

Signature of Person Name, print: Dan Switek Date:


ID No.DC0060


Check the reports/forms submitted:

Remedy Standard A

Self-Implementation Notice Submittal date:

Response Action Plan - Approval date:

Remedy Standard B

X Response Action Plan - Approval date:Submitted to TCEQ DCRP on July 25, 2011 and updatedwith revised figures on September 8, 2011.

List all media (surface soil, subsurface soil, groundwater, sediment, surface water, air) that contained orcontains a PCLE zone and specify the response action taken for each media. Indicate the type of removal,decontamination, physical control, or institutional control action that was used in the response action. If amedia with a PCLE zone was not addressed in the response action, provide an explanation below.

Media COCs1

Removal Decontamination PhysicalControl

InstitutionalControl

Modified ResponseObjective

2

PMZ WCU TI

Surface Soil PCE, TCE,cDCE, tDCE,1,1-DCE, VC,

benzene

X X X NA NA

Saturated Soil PCE, TCE,cDCE, tDCE,1,1-DCE, VC,

benzene

X X NA NA

Groundwater PCE, TCE,cDCE, tDCE,1,1-DCE, VC,

1,1,2-TCA,benzene

X X X NA NA

Is there a media that contains a PCLE zone that was not addressed in the responseaction?

X yes no

If yes, provide justification for not addressing the PCLE zone in the response action.The Dry Cleaner Remediation Program (DCRP)-funded response action was limited to surface andsubsurface soil in the primary source area. The groundwater protection concentration level (PCL)exceedance (PCLE) zone is addressed using a plume management zone (PMZ), and the TCEQ intends toauthorize annual sampling of the attenuation monitoring points (AMPs) based on budgetary priorities of theDCRP. Contingent groundwater response actions are dependent on annual groundwater monitoring andwill be deferred to subsequent fiscal years based on the budgetary priorities of the TCEQ.

Current land use of the on-site affected property: Residential X Commercial/industrialProjected future land use of the on-site property (if known): Residential X Commercial/industrial

Explain why you believe the response action to be complete.The soil response action addressed the primary soil source area. The response action included theremoval and capping of sewer sources in the excavation area. Soil and saturated soil were excavated to18 feet below ground surface (ft BGS) and treated ex-situ while the excavation area was continuouslydewatered. Although confirmation samples were not collected, the excavation boundary was extended

1Specify either a specific COC or, if the response action is the same for all COCs in one type, specify the type of COC

(for example, VOCs, SVOCs, metals).2

If a modified groundwater response objective was used, check the type(s) of modifications.


ID No.DC0060


laterally to the maximum extent allowable by the dewatering system and the maximum achievable depth.Subsurface soils are saturated, and by conducting dewatering operations, accessible contaminatedsaturated soils were removed and treated ex-situ. Soil samples BS-1 and BS-2 were collected from thebottom of the excavation at approximately 18 ft BGS. The concentrations of tetrachloroethylene (PCE)were 2,000 to 2,600 milligrams per kilogram (mg/kg), which are above the critical 1,584 mg/kg soil-to-ambient air (AirSoilInh-V) PCL. The concentrations of trichloroethylene (TCE), cis-1,2-dichloroethylene(cDCE), and vinyl chloride (VC) were below the critical

AirSoilInh-V and

AirGW-SoilInh-V PCLs. Permanganate

solution was applied to the bottom of the excavation and mixed with soil from an estimated 18 to 22 ft BGSin accessible areas using a backhoe. Soil from the sidewalls of the excavation was mixed withpermanganate-treated soils to reduce their moisture content and to facilitate their compaction. Additionalpotassium permanganate was applied beneath the static water level, and graded into the blended soilusing a backhoe bucket. Ex-situ treatment consisted of soil handling, tilling, and permanganate treatment.Five-point composite samples TCA-1 and TCA-2 were collected from the two treatment batches to assesstreatment effectiveness. The concentrations of PCE were 6.3 to 17 mg/kg in TCA-1 and TCA-2, whichexceed the 0.05 mg/kg soil-to-groundwater (GWSoilIng) leaching PCL, and the concentrations of TCE,cDCE, and VC were below the

GWSoilIng PCLs. Treated soils were placed back into the excavation and

compacted, and the excavation area was capped with a concrete cover. AlthoughGW

SoilIng PCLs areapplicable from 0 to 5 ft BGS, no in-place soil samples were collected.

The soil response action did not extend to the uppermost groundwater bearing unit (GWBU), which is asandy interval that exists from 23 to 35 ft BGS beneath the excavation area. However, excesspermanganate was mixed into the accessible saturated soils at the bottom of the excavation from 18 to22 ft BGS. Leaching and dispersion from the saturated soils may have limited impact on groundwatercontamination for several months. Although the soil response action was not intended to treatgroundwater, the dewatering operations removed approximately 50,000 gallons of contaminatedgroundwater, which was treated with a tray-aeration stripper and granular activated carbon and dischargedto the sanitary sewer.

The response action substantially reduced PCE contamination in the surface and saturated soils in theprimary source area above the uppermost GWBU, which should mitigate additional loading of PCE into theuppermost GWBU. Although a second soil source area has been identified beneath the building, theconcentrations of PCE are significantly lower than in the primary source area. The concentrations of PCEin the uppermost GWBU beneath the primary source area appear to be controlled by PCE solubility. Forexample, the concentration of PCE was 110 milligrams per liter (mg/L) in nearby well MW-7 in July 2011,which approaches the 200 mg/L solubility limit for PCE. The continued dissolution of PCE from densenon-aqueous phase liquids (DNAPL) in the uppermost GWBU will provide a continued source ofgroundwater contamination.

The response action did not address the second GWBU, which is a thin Class 3 GWBU that is present atan approximate depth of 50 ft BGS. DNAPL source contamination appears to exist in the uppermostGWBU and in the clayey soils between the uppermost and second GWBU. MW-16 is the closest well tothe source area in the second GWBU and is located 23 ft west of the southwest corner of the excavationarea. The concentration of PCE steadily increased in MW-16 from 2007 to 2011, where the concentrationof PCE was 0.42 mg/L in August 2007, 3.8 mg/L in May 2009, 9.4 mg/L in February 2010, and 17 mg/L inJuly 2011. No response actions are planned to reverse this trend.

A third GWBU potentially exists between 80 and 160 ft BGS. The Drinking Water Survey Report (March2006) identified an industrial well located at 3838 Majestic Street (Well No. 65-14-517), which is south andup/cross-gradient from the PCE plume, and another industrial well (Well No. 65-14-506) located near theintersection of Highway 610 and Homestead Road, which is northeast and up/cross-gradient of the PCEplume. The industrial water wells are screened from 284 to 299 ft BGS and from 316 to 336 ft BGS, andthe boring logs for these wells identify sand from 82 to 164 ft BGS and from 96 to 161 ft BGS. Themaximum depth of the assessment at this site by cone penetrometer testing (CPT) was 72 ft BGS inMC-3, which is located within Building 1 and identifies silty clay. The maximum depth of contamination


ID No.DC0060


was identified by membrane interface probe (MIP) in MC-2, which is located approximately 6 ft west of theexcavation area, where PCE contamination was observed at the maximum MIP depth of 67 ft BGS. TheAffected Property Assessment Report (APAR) does not evaluate potential PCE contamination in thepotential third GWBU. The APAR was originally submitted to the TCEQ on November 12, 2010, and wasrevised with new figures and re-submitted on September 8, 2011.

Checklist for Report CompletenessPage _1_ of _2_

ID No.

DC0060

Report Date:

November 2, 2011

Checklist for Report CompletenessUse this checklist to determine the portions of the form that must be submitted for this report. Answer all questions by checkingYes or No. If the answer is Yes include that portion of the report. If the answer is No, do not complete or submit that portion ofthe report. All form contents that are marked "Required" must be submitted. Form contents marked with an asterisk (*) are notincluded in the blank form and are to be provided by the person.

Report Contents

Required Cover Page

Required Executive Summary

Required Checklist for ReportCompleteness

Required Worksheet 1.0Confirmation of Response

Action Objectives

Required Attachment 1A*Maps and Cross Sections

Required Attachment 1B*

Graphs

Required Attachment 1C*Response Action Diagrams

No Was a plume management zone used as part of theresponse action?

Yes Worksheet 2.0

Plume Management Zone

Attachment 2A*

Map of Plume ManagementZone

No Was an area of technical impracticability approved for useas part of the response action?

Yes Worksheet 3.0

Technical Impracticability

Attachment 3A*Map of Technical

Impracticability Area

No Were institutional controls used or required as part of theresponse action?

Yes Worksheet 4.0Institutional Controls

Required Worksheet 5.0

Performance Measures andProblems

No Did the response action require any operation andmaintenance activities?

Yes Worksheet 6.0Operation and Maintenance

No Has there been any change to the plans for post-responseaction care from that submitted in the RAP?

Yes Worksheet 7.0Post-Response Action Care

No Was any information for this report obtained from outsidesources?

Yes Appendix 1*

References

No Was an ESA and/or Compensatory Restoration used aspart of the response action?

Yes Appendix 2*ESA and Compensatory

Restoration

No Were institutional controls or landowner concurrencerequired in the response action?

Yes Appendix 3*Institutional Controls andLandowner Concurrence

Checklist for Report CompletenessPage _2_ of _2_

ID No.

DC0060

Report Date:

November 2, 2011

Report Contents

No Is there data or boring/monitor well information notpreviously submitted?

Yes Appendix 4*Data Tables, Boring Logs, and

Well Completions

No Did sampling procedures differ from those described in theRAP?

Yes Appendix 5*Sampling Procedures

No Has any sampling been conducted for which the analyticalresults were not previously submitted?

Yes Appendix 6*Laboratory Data Packages

No Were statistics or geostatistics used in the responseaction?

Yes Appendix 7*Statistical Methodology

No Were any wastes generated that were not reported throughSTEERS?

Yes Appendix 8*Waste Disposition

Confirmation of Response ActionObjectives

RACR Worksheet 1.0 Page _1_ of _12_

ID No.

DC0060

Report Date:

November 2, 2011

Use this worksheet to describe the attainment of the response action objectives in each media.

Response Action Objectives

What was the selected remedy standard for this affected property? A X B

List the environmental media to which this applies Surface soil and saturated soilRepeat this section for each medium that had a different response action objective.

Provide a detailed description of the response action. Describe the removal actions, decontaminationactions, treatment system(s), physical or institutional control actions, and any actions for ecologicalconsiderations (ecological services analysis and compensatory restoration plans) that were conducted ineach media and indicate if there were any differences between the actions taken and the actionsproposed in the SIN or RAP.Project BackgroundThis response action addressed the primary source area (Contamination Source Area No. 2), which islocated southeast of Building 1 and appears to be primarily associated with overflow of an undergroundwastewater sampling station and leakage from an underground wastewater pipe. As shown in Attachment1C-1, the unused wastewater line extends south from the former wastewater underground storage tanks(USTs) and intersects a wastewater sampling station. The wastewater sampling station had anapproximate 2-foot diameter manhole cover, which was previously covered with sediment and stagedequipment. The sampling station consisted of an open top pipe that was approximately 6 ft BGS. Anadditional wastewater line flowed into the sampling station from the west-southwest direction. Effluentfrom the wastewater sampling station flowed east through a wastewater flow station to the City of Houstonsanitary sewer along Blaffer Street. The wastewater sampling station included a weir and a sonic waterlevel indicator.

Soil and groundwater contamination in the response area were initially identified by MIP boring MG-12 inAugust 2009 and subsequently in soil vapor extraction (SVE) pilot test wells VE-1 to VE-4 and monitoringwell MW-24 in August 2009. The concentrations of PCE ranged from 43.7 to 1,900 mg/kg in theinvestigation-derived waste (IDW) samples collected from SVE pilot test wells VE-1 to VE-4 andmonitoring well MW-24. After the removal of staged pipe and salvaged cars from the former tenant’swarehouse operations, MIP borings MG-13 to MG-25 were sampled in May 2010 to refine the source area.The highest MIP responses at the site were observed in MG-12, MG-22, and MG-24. MIP borings MC-2,MG-21, and MG-25 were used to define the extent of the source area. Additionally, bottom samples BS-1and BS-2 were collected from approximately 18 ft BGS with a backhoe during the response action; this soilwas subsequently treated during the response action. The concentrations of PCE in BS-1 and BS-2 were2,000 and 2,600 mg/kg. Although the concentrations of PCE in these samples exceed the 0.05 mg/kgsoil-to-groundwater leaching (

GWSoilIng) PCL, the

GWSoilIng PCL does not apply for saturated soil, which

exists below the static water table that has been encountered at approximately 5 ft BGS. Attachment 1C-2provides a summary of the sample data in Contamination Source Area No. 2.

Project ScopeThe response action included dewatering operations, excavation, in-situ and ex-situ permanganatetreatment, and the backfill of the excavation area with the treated soil. Attachment 1C-3 shows the depthsof excavation and the locations of the dewatering well-points, while Attachment 1C-4 shows the excavationsections and soil profiles. The estimated excavation volume is 800 bank (in-place) cubic yards (BCY);however, no survey was performed to confirm the volume. Attachment 1C-5 shows the excavation,staging, and treatment areas. The response action was performed by E & E as the prime subcontractorand by Effective Environmental, who was the response action contractor subcontracted by E & E. Theresponse action was initiated on July 25, 2011 and concluded on August 31, 2011. Appendix 4 provideslaboratory data tables, a photographic log, plugging reports, and field activity notes.



ID No.

DC0060

Report Date:

November 2, 2011

Plugging and Abandonment of Wells and Sewer LineMonitoring well MW-24 and SVE pilot test wells VE-1 to VE-4 were plugged and abandoned by a licenseddriller prior to the excavation. Best Drilling removed VE-1 to VE-4 and MW-24 on July 26, 2011, andplugged the borings with bentonite pellets to minimize the infiltration of pressurized groundwater into theexcavation. The well plugging reports are provided in Appendix 4.

The manhole for the wastewater flow station was removed on July 27, 2011, and the 6-inch diameterconcrete sewer pipe was exposed. The sewer line was approximately 6 ft BGS. A licensed-plumberinstalled a Fernco-fitting and end cap to the severed sewer line that connects to the City of Houstonsanitary sewer. A City of Houston inspector arrived to inspect the plugged sewer connection on Friday,July 29, 2011, and later approved the plugged line on Tuesday, August 2, 2011. The approval letter isprovided in Appendix 4.

Dewatering and Groundwater TreatmentThe uppermost GWBU is a productive sandy interval that exists between 23 and 35 ft BGS beneath theexcavation area. The uppermost GWBU is under confining pressures, and the static water level isgenerally encountered approximately 5 ft BGS. After the pore pressure logs for the CPT-deployed MIPborings indicated that the overlying soils were dry, SVE pilot test wells VE-1 to VE-4 were installed to20 ft BGS. The wells flooded and recharged fairly quickly when dewatered, which indicates hydraulicconnection between soils at 20 ft BGS and the uppermost GWBU. Dewatering operations were performedduring the response action to dewater the soils, which improves side-slope stability, improves soil handlingand treatment effectiveness, and allows adequate compaction of the fill material.

On July 26, 2011, Effective Environmental excavated a 2-ft deep continuous trench along the west, north,and south boundaries of the excavation area to facilitate the installation of dewatering well points.Subsequently on July 27, 2011, Griffin Dewatering installed 17 dewatering well points in trench on thewest, north, and east side of the excavation. The well points were installed to 30 ft BGS using hydraulicjetting, and approximately 5,000 gallons of water were collected in the trench, and then pumped to20,000 gallon frac tank. The well points consist of 1.5-inch diameter PVC wells with screens from 25 to30 ft BGS. On July 28, 2011, Griffin Dewatering connected the 17 dewatering well points to a 6-inchdiameter manifold line, and connected the manifold line to a diesel-powered vacuum pump. The skid-mounted pump station was hard-piped to the first of two 20,000 gallon frac tanks, which were connected inseries. On July 28 and 29, 2011, ProAct Services installed a 50-gallon per minute (gpm) groundwatertreatment system, which included a trailer-mounted oil-water separator, a tray-aeration air stripper, andactivated carbon vessels for water and air effluent streams. The treated groundwater was discharged tothe City of Houston sanitary sewer through a clean-out approximately 100 ft north of the excavation areaunder a One Time Discharge Authorization. The air emissions from the tray-aeration stripper were treatedby two 2,000-lb vapor phase carbon vessels in series and discharged to the atmosphere under Air Permit-by-Rule (PBR) 106.533. The One Time Discharge Authorization and the Air PBR Notification andChecklist are provided in Appendix 8.

Dewatering operations were initiated on Friday, July 29, 2011; however, the vacuum pump overheatedwhen it became dry, and the pump stopped working over the weekend. On Monday, August 1, 2011,Griffin Dewatering replaced the belts on the dewatering pump, and installed a backflow line from the fractank so that the pump could continuously pump water from the well-points and re-circulate water in the fractank without overheating. Continuous dewatering operations were initiated in the morning, and continuousdewatering was performed through the morning of August 8, 2011. The contents of eight IDW drums ofwastewater were also pumped into the frac tank on August 2, 2011. The IDW was generated inAugust 2010 by the development and purging of monitoring wells MW-33 to MW-37. A total of55,500 gallons of water were pumped through the treatment system during the response action, whichincluded approximately 50,000 gallons of extracted groundwater, 5,000 gallons of hydraulic jetting water,250 gallons of IDW wastewater, and 250 gallons of decontamination water. This equates to approximately5 gpm of groundwater during the 7 days of dewatering, which was sufficient to dewater beneath the



ID No.

DC0060

Report Date:

November 2, 2011

excavation.

Wastewater samples were collected before treatment in the mobile groundwater treatment system, butafter the wastewater had been vacuum extracted from the uppermost GWBU and discharged, staged, andrecirculated for several days in the frac tanks. The wastewater samples were collected on August 1, 3, 4,and 8, 2011, and submitted to ALS Environmental Laboratory for analysis of volatile organic compounds(VOCs) by Method 8260B. Because of the initial 5,000 gallons of drilling water, the concentration of PCEwas only 0.74 milligrams per liter (mg/L) in WWB-1-080111; whereas the concentrations of PCE were 2.7,3.3, and 3.1 mg/L in subsequent pretreatment wastewater samples. The average concentration of PCE inthe last three samples was 3.0 mg/L, which is significantly less than the 110 mg/L of PCE detected innearby MW-7 on July 27, 2011. The lower concentration is due to capture and blending of less-contaminated water surrounding the source area and due to volatilization during vacuum extraction,discharge, and staging and recirculation in the two frac tanks. The dewatering operations are estimated tohave removed a minimum of 1.25 lbs of PCE from the uppermost GWBU, which is the product of 3.0 mg/Lof PCE and 50,000 gallons of groundwater.

ExcavationThe excavation was initiated by breaking-up the concrete on July 25, 2011 and removing and staging theconcrete in the southeast corner of the site on July 26, 2011. Three loads of concrete debris wereremoved from the site on July 28, 2011 by MTZ Truck and disposed at Coastal Crushed Concrete inHouston, TX.

The locations of the soil staging pile and soil treatment cell were marked-out on July 27, 2011, andconstructed and initially loaded on July 28 and 29, 2011. The 30-ft by 100-ft soil staging pile and 90-ft by100-ft soil treatment cell were underlain with a 20-mil high-density polyethylene (HDPE) liner. The lesscontaminated shallow soils were placed as a bottom liner in the treatment cell in an approximate 1-ft lift.The soil volume of the bottom liner was approximately 270 BCY, which is approximately 1/3 of the totalexcavated soil volume of 800 BCY. The soil staging pile and treatment cell were covered with a liner onThursday and Friday afternoon because of light precipitation.

Effective Environmental initiated excavation on July 28, 2011 and completed the excavation of surfacesoils to 5 ft BGS on Friday, July 29, 2011. The wastewater sampling station and sewer lines wereexposed during the excavation. Soils were placed in the soil staging area and treatment cell and coveredover the weekend due to light precipitation. Dewatering operations were initiated on Friday, and deeperexcavation was postponed until Monday, August 1, 2011. By August 1, 2011, the weather was hot and dryand remained so for duration of the response action. The excavation was completed to a total depth ofapproximately 18 ft BGS on August 1, 2011. The excavation was not surveyed, but the depths wereestimated and the surface dimensions were measured using a measuring wheel. The depths ofexcavation are shown on Attachment 1C-3. The total excavation volume is approximately 800 bank(in-place) cubic yards (BCY).

The concentrations of VOCs in the excavated soil ranged from 50 to 2,300 parts per million by volume(ppmV) using a photo-ionization detector (PID), and PCE contaminated soil remained in the sidewalls andat the bottom of the excavation. The sidewalls could not be extended because of the dewatering system,and the excavation was extended to the maximum depth achievable by the backhoe. The scope of workdid not include the collection of confirmation samples. However, the backhoe was used to collect soilsamples BS-1 and BS-2 from the bottom of the excavation at approximately 18 ft BGS. The samples weresent to ALS Environmental Laboratory and analyzed for VOCs by Method 8260B with a 14 day turnaroundtime. The concentrations of PCE were 2,000 and 2,600 mg/kg in BS-1 and BS-2, and the correspondingmaximum PID readings were 440 and 350 ppmV. The bottom samples collected from 18 ft BGS wererecorded as brown, plastic, sandy clay, and the top of the uppermost GWBU was approximately 23 ft BGS.

With consent of the TCEQ project manager, the scope was modified in the field to include in-situ mixing



ID No.

DC0060

Report Date:

November 2, 2011

and additional potassium permanganate was purchased from available local inventory.

Ex-Situ Soil TreatmentSoil was treated in the treatment cell by chemical oxidation. Soil handling operations, including placement,spreading, and multiple passes with a tracker-tiller, were use to dry, break-up, and aerate the PCE-contamination soil in the 90-ft by 100-ft treatment cell during dry weather, where the daily hightemperatures were approximately 101ºF. The treatment cell had an approximate 1-ft thick bottom linerthat consisted of approximately 270 BCY of shallow soil from the excavation, which was used to protectthe underlying 20-mil HDPE liner. Two batches of soil were treated in the treatment cell. Both batchesconsisted of approximately 270 BCY of excavated soil (each were 1/3 of the total excavation volume), andboth were placed in an approximate 1-ft lift on top of the bottom liner.

Chemical oxidation was performed by mixing and spray-applying a saturated solution of potassiumpermanganate on to the soils followed by tilling. A total of 6,600 lbs of RemOx S® powder was purchasedfor the ex-situ soil treatment, which was provided in 120 55-lb buckets. With consent from the TCEQproject manager, the response action was amended in the field to include in-situ soil treatment, and anadditional 1,320 lbs (24 buckets) of RemOx S® were purchased from available local inventory. Noadditional RemOx S® supplies were available locally.

Approximately 1/3 of the treatment cell was treated with permanganate at a time. Approximately 1/3 of theRemOx S® powder was poured into a 300-gallon tote. Water was then continuously pumped through thetote, which mixed with permanganate creating a near-saturated solution of potassium permanganate. Thesolution was then spray-applied onto the soils in the treatment cell

Approximately 267 BCY of soil was placed in the first treatment batch on August 1, 2011. The soil wasspread into an approximate 1.0-ft lift and the soil was tilled several times to break up, dry, and aerate thesoil. The first treatment batch was treated twice with potassium permanganate, on the mornings ofAugust 2 and August 3, with 1,925 lbs of potassium permanganate (35 buckets of RemOx S®) pertreatment. This equates to 7.2 lbs of permanganate per BCY (lbs/BCY) of soil per treatment for the top12-inches of soil, or 3.6 lbs/BCY per treatment when the 12-inch base layer is included. After eachapplication, the potassium permanganate solution ponded on top of the treatment cell, and was allowed inseep into the soil for a few hours before tilling operations were performed. Assuming a 2.5% saturatedsolution, approximately 9,240 gallons of water were applied per application to 14,400 cubic feet of soil(including the base layer), which equates to approximately 30% of the pore volume assuming a 30%porosity. The underlying 12-inch base layer was partially treated by the two treatments. The top12 inches of soil were scraped from the top of treatment cell on August 4, 2011, and the soils were loadedinto the bottom of the excavation. Five-point composite samples were collected from the treatment cellbefore (TCB-1-080111) and after (TCA-1-080111) treatment to assess the effectiveness of treatment.Samples were sent to an ALS Environmental Laboratory and analyzed for VOCs by Method 8260B with a14 day turnaround time. The concentration of PCE was reduced from 150 mg/kg before treatment to 6.3mg/kg after treatment.

Approximately 267 BCY of soil was placed in the second treatment batch on August 4, 2011. The soil wasspread into an approximate 1.0-ft lift and the soil was tilled several times to break up, dry, and aerate thesoil. The second treatment batch was treated once with potassium permanganate, on the morning ofFriday, August 5, 2011, with 2,145 lbs of potassium permanganate (39 buckets of RemOx S®). Thisequates to 8.0 lbs/BCY of permanganate for the top 12-inches of soil. After the potassium permanganatesolution was allowed to seep into the soil, the treatment cell was tilled with multiple passes. The top12 inches of soil were scraped from the top of treatment cell on Monday, August 8, 2011, and the soilswere loaded into the excavation. Five-point composite samples were collected from the treatment cellbefore (TCB-2-080411) and after (TCA-2-080811) treatment to assess the effectiveness of treatment.Samples were sent to an ALS Environmental Laboratory and analyzed for VOCs by Method 8260B with a14 day turnaround time. The concentration of PCE was reduced from 210 mg/kg before treatment to 17



ID No.

DC0060

Report Date:

November 2, 2011

mg/kg after treatment.

In-Situ Soil Treatment, Backfill, and RestorationThe scope of the response action was limited to removal of accessible contaminated soil above theuppermost GWBU, within the limits of the budget, equipment, and side-slope stability. The top of theuppermost GWBU is approximately 23 ft BGS. Soils were excavated to a total depth of approximately18 ft BGS, which was generally the limit of excavation for the backhoe. The backhoe was used to collectbottom samples BS-1-080111 and BS-2-080111, and the samples were screened with a PID andsubmitted to ALS Environmental Laboratory for analysis of VOCs by Method 8260B. The concentrationsof PCE were 2,000 and 2,600 mg/kg in BS-1 and BS-2, and the corresponding maximum PID readingswere 440 and 350 ppmV. The bottom samples were recorded as brown, plastic, sandy clay.

The objective of in-situ mixing was to place as much potassium permanganate into the clayey source areabeneath the static water table as was possible, given existing inventories of RemOx S® in the Houstonarea. An additional 1,320 lbs of potassium permanganate (24 buckets of RemOx S®) were purchased tofacilitate in-situ treatment of the soils. Although the dewatering system successfully lowered the watertable, some seepage was observed in the bottom of the excavation. On August 2, 2011, 1,375 lbs ofpotassium permanganate powder (25 buckets of RemOx S®) were placed into the backhoe bucket, andthen placed into bottom of the excavation. Approximately 500 gallons of water were added to dilute thesolution. The backhoe angled into the excavation, and the bucket was extended into the accessible soiland retracted to mix in the permanganate solution. The backhoe is estimated to have treated soils from18 to 20 ft BGS beneath the 23-ft by 33-ft base of the excavation, which equates to 24.5 lbs/BCY ofpotassium permanganate. Purple-stained water, remaining in the bottom of the excavation, was allowedto seep into the underlying clayey soils during dewatering operations from August 2 to August 4, 2011.

The first batch of soils was removed from the treatment cell on August 4, 2011. The treated soil was firstapplied to the south side of the excavation in order to allow the backhoe to get closer to the bottom of theexcavation. Approximately 500 gallons of water was added to the purple-stained water that was ponded atthe bottom of the excavation. The backhoe moved closer to the excavation and was able to pick up soilsto estimated depths of 22 ft BGS and mix with the purple-stained water. The backhoe then pulled PCEcontaminated soil from the sidewalls to the extent practical and mixed them with permanganate in thebottom of the excavation. Because the liquefied soils at the bottom of the excavation were too wet tocompact, they were picked up and placed on the side of the excavation, and treated soil from the firsttreatment batch was placed in the bottom of the excavation and compacted with the backhoe bucket. Wetsoils were added back into the excavation during the loading and compacting operations. After theexcavation was loaded and compacted to 10 ft BGS, an additional 550 lbs of potassium permanganate(10 buckets of RemOx S®) were poured into the backhoe bucket and then spread across the bottom of theexcavation at 10 ft BGS. The permanganate powder was hydrated with enough water to turn it purple.The sidewalls were then caved in and mixed with the permanganate to approximately 8 to 9 ft BGS in the33-ft by 33-ft base on the excavation, which equates to approximately 9.1 lbs/BCY of potassiumpermanganate. In-situ mixing operations were concluded on August 4, 2011.

The contents of 11 soil IDW drums were placed into the excavation on August 5, 2011. The IDW drumsincluded drilling wastes from the installation of boundary wells MW-33 to MW-37, which were installed inAugust 2010. Monitoring wells MW-33 to MW-35 and MW-37 were located outside of the groundwatertravel distance from the source since its origin, and no VOCs were detected in the monitoring wellsamples. In monitoring well MW-36, which is located cross-gradient and north of the property, no PCEwas detected in the August 2010 sample, but the sample contained 0.19 mg/L of TCE, 0.016 mg/L ofcDCE, and 0.0029 mg/L of vinyl chloride.

On Monday, August 8, 2011, the treated soil from the second treatment batch was removed and placedinto the excavation. Dewatering operations were also stopped on the morning of August 8, and thedewatering wells were removed on August 8 and 9, 2011. The backhoe was used to place the treated soil



ID No.

DC0060

Report Date:

November 2, 2011

in the excavation and to compact the subsurface soil with dynamic blows from the bucket. The shallowsoil was also compacted by multiple passes of a sheep’s foot roller. After saw cutting the edges of theconcrete, approximately 30 cubic yards of #1 bank sand was brought the site and spread in anapproximate 4-inch layer on top of the compacted fill. Forms and rebar were placed above the 4-inchsand layer beginning on August 10, 2011, and the concrete was poured on August 12, 2011.

Air SamplingA PID was used to monitor the concentrations of VOCs in soil gas and in the breathing zone on theperiphery of the excavation, soil staging pile, soil treatment cell, and on the property boundary duringmajor soil handling activities. The soil gas monitoring was used to confirm the objectives of the responseaction, and to increase the scope of the response action by performing in-situ treatment withpermanganate for the bottom and sidewalls of the excavation. The maximum PID readings for excavatedsoil ranged from 50 to 2,300 ppmV. The PID readings in the breathing zone on the periphery of theexcavation ranged from 0 to 12 ppmV; however, the readings only exceeded 1 ppmV for short durations.The PID readings in the breathing zone on the periphery of the soil staging pile ranged from 0 to2.5 ppmV. The normal PID readings in the breathing zone on the periphery of the soil treatment area were0.0 ppmV. During one pass on August 1, 2011, the PID readings on the west boundary averaged 0.2 to0.3 ppmV, with a maximum reading of 2.7 ppmV. However, during a second pass less than 5 minuteslater, the PID readings were 0.0 ppmV on the periphery of the treatment cell. The western propertyboundary was monitored on several occasions during the more disrupted soil handling activities, and noPID readings were measured above 0.0 ppmV.

The concentration of vinyl chloride was measured twice using Draeger tubes. On August 2, 2011, thehighest concentration of VOCs in disturbed soils from the soil staging pile was 125 ppmV, and thecorresponding concentration of vinyl chloride was 0.0 ppmV. On August 3, 2011, the highestconcentration of VOCs in disturbed soils from the soil staging pile was 50 ppmV, and the correspondingconcentration of vinyl chloride was 0.0 ppmV.

Four summa canisters were placed in one location along the western boundary of the property on differentdates. The location is shown in Attachment 1C-5. Samples were collected as 8-hour time-weightedaverage (TWA) samples (sample IDs AWB-#-Date), and the samples were submitted to ALSEnvironmental Laboratory for analysis of VOCs by Method TO-15. The samples were collected during themore significant soil handling activities:

Sample AWB-1-080111 was collected during the excavation of subsurface soils, the loading of thesoils to the soil staging pile and soil treatment cell, and the tilling of the soil treatment cell.

Sample AWB-2-080211 was collected during the permanganate treatment of the soil treatmentcell and four passes of the tiller.

Sample AWB-3-080411 was collected during the removal and loading of the first batch of treatedsoil into the excavation, the in-situ mixing operations, and the loading of the second batch into thesoil treatment area.

Sample AWB-4-080811 was collected during the loading of the second treatment batch into theexcavation.

Sample results were compared with the National Institute for Occupational Safety and Health (NIOSH)recommended exposure limits for time-weighted average (TWA) concentrations for up to a 10-hourworkday during a 40-hour workweek. Appendix 4.5 provides the concentrations of VOCs and the TWAconcentrations. Sample AWB-1-080111 had the highest detection concentrations of VOCs, including0.02 ppmV of PCE, 0.0014 ppmV of TCE, 0.0041 ppmV of cDCE, an estimated 0.00044 ppmV of vinylchloride, 0.0017 ppmV of benzene, 0.16 ppmV of toluene, 0.004 ppmV of ethylbenzene, and 0.009 ppmVof total xylenes. The concentrations of VOCs in AWB-1-080111 were generally more than an order ofmagnitude higher than the concentrations of VOCs in the remaining samples. The concentrations ofVOCs were significantly below the NIOSH recommended exposure limits. The closest exceedance was



ID No.

DC0060

Report Date:

November 2, 2011

the concentration of benzene in AWB-1-080111, which was approximately 600 times below the 1 ppmVTWA concentration. Sample results are provided in Appendices 4 and 6.

Describe how the response action achieved the property-specific response objectives for the PCLE zonein each media in the context of the response objectives set forth in §350.32 or §350.33, as applicable.Explain how the response action was appropriate based on the hydrogeologic and COC characteristics.Describe any unprotective conditions that continued or resulted from the remedial actions and the actionstaken to mitigate unprotective conditions.Response action objectives were identified in the Response Action Plan (RAP, July 27, 2011), and arerepeated as follows:

Groundwater contamination within the PMZ should be managed such that:

Attenuation monitoring points (AMPs) and attenuation action levels (AALs) should be definedwithin the PMZ that are protective of the alternate point of exposure (POE). When theconcentrations of COCs exceed the AALs at an AMP or the alternate POE, an active responseaction may be necessary to protect the alternate POE (30 TAC 350.33(f)(4)(D)(iii)).

Readily recoverable non-aqueous phase liquids (NAPLs) should be removed to the extentpracticable (30 TAC 350.33(f)(4)(E)(ii)). Although DNAPL was not specifically observed, thegroundwater concentrations are indicative of NAPL, and DNAPL is likely present within soil andgroundwater beneath the Soil PCLE Zone No. 2.

Ensure that leachate from surface and subsurface soil PCLE zones does not increase theconcentration of COCs in Class 2 groundwater above the concentrations measured at the time ofRAP submittal (30 TAC 350.33(a)(2)). This requirement is imposed on all Remedy Standard Bresponse actions and is not specific for PMZs. For the Good Neighbor Cleaners site,groundwater concentrations are not allowed to increase in the uppermost GWBU because ofleachate, but this requirement is not pertinent for the second GWBU, which is a Class 3 GWBU.

The specific response action objectives (RAOs) and response actions include:

1. No response action was proposed for Soil PCLE Zone No. 1. The concentrations of chemicals ofconcern (COCs) are significantly lower in Soil PCLE Zone No. 1, and leachate from Soil PCLEZone No. 1 is not anticipated to increase the concentrations of COCs above their maximumconcentration in the uppermost GWBU. Soil PCLE Zone No. 1 is predominantly located underthe concrete foundation of the warehouse building.

No response action was performed.

2. Remove and treat source area contamination from Soil PCLE Zone No. 2 through excavation andex-situ soil treatment using permanganate to reduce the likelihood that the concentration of PCEin MW-7 will increase above its present concentration and to mitigate the leaching ofcontamination to the second GWBU and potentially to lower GWBUs.

The response action removed soils to 18 ft BGS and treated them ex-situ to reduce theconcentrations of PCE from up to 2,600 mg/kg to less than 20 mg/kg. Additional in-situtreatment was performed by mixing potassium permanganate into sidewall soils and inthe underlying saturated soils to approximate depths of up to 22 ft BGS, which isapproximately 1 ft above the top of the uppermost GWBU. The 0.050 mg/kg soil-to-groundwater PCL does not apply to saturated soils beneath 5 ft BGS. The concentrationof PCE was 110 mg/L in MW-7 on July 27, 2011, which was sampled before excavationand dewatering activities were initiated.

3. Remove or treat groundwater contamination. Although groundwater contamination may be



ID No.

DC0060

Report Date:

November 2, 2011

partially addressed through the application of permanganate into the excavation, subsequentgroundwater response actions are deferred to FY2012 and beyond, depending on DCRPprioritization and funding allocation.

Dewatering operations were performed to facilitate the soil response. Approximately50,000 gallons of groundwater were removed from beneath the excavation area. Theresponse action removed between 1.25 and 45 lbs of PCE from the uppermost GWBU.

4. No response actions were proposed in FY2011 to address groundwater contamination migratingfrom the site. AALs are set to trigger when an additional groundwater response action isnecessary.

The AMPs were sampled on July 25 to 27, 2011.

If different from the information provided in the RAP, explain how the COCs were handled, treated,disposed, or transferred to another media and document that the response action did not result in anyadditional exposure conditions due to response action activities.The response action was performed pursuant to the RAP. However, the scope was increased to includein-situ mixing of permanganate into inaccessible soils. Groundwater was treated by aeration and carbonsorption and then discharged to the sanitary sewer under a One Time Discharge Authorization, and airemissions from water treatment were treated with activated carbon under Air PBR 106.533. Excess soil,spent carbon, sediment, and empty containers were disposed at appropriately licensed landfills. Becauseof soil handling activities, the response action included incidental emissions of VOCs to the atmosphere.Air samples were collected from the property boundary during major soil handling activities.

Explain how the response action achieved the objectives within the reasonable time frame.The response action substantially remediated the primary soil source that contributes to contaminationand migration in the groundwater. The response action should prevent the concentrations of PCE fromincreasing in the uppermost GWBU beneath to source area due to additional infiltration from the soil.Although excess permanganate was mixed into the soil between approximately 18 and 22 ft BGS, theequipment was not capable of reaching the top of the uppermost GWBU, which is approximately 23 ftBGS. The response action did not address contamination in the uppermost or second GWBU, or thePCE-contaminated saturated soil beneath the uppermost GWBU.

Were physical controls used as part of the response action? Yes X NoIf yes, describe the type and purpose of the physical control and discuss how the physical control hasproved effective.Not applicable.

Soil Response Action Objectives

When using removal and/or decontamination with controls or controls only, demonstrate that the physicalcontrol or combination of measures reliably contained COCs within and/or derived from the surface soiland subsurface soil PCLE zone materials over time.Not applicable.

Explain how the removal or decontamination action reduced the concentration of COCs to the criticalsurface soil and subsurface soil PCL throughout the soil PCLE zone and prevented COC concentrationsabove the critical soil PCLs from migrating beyond the original boundary of the soil PCLE zone.Approximately 800 BCY of soil were excavated from the primary source area, treated ex-situ withpermanganate, and returned to its place of origin. Approximately 112 BCY of soil was also treatedbetween 18 and 22 ft BGS by in-situ permanganate mixing. The objective was not to treat soils to belowthe applicable PCLs; rather, the objective of the response action was to prevent soil contamination fromincreasing the concentration of PCE to above 110 mg/L in MW-7, which was the concentration on July 27,



ID No.

DC0060

Report Date:

November 2, 2011

2011 that coincides with the time of the RAP submittal on July 25, 2011. The concentrations of PCE inseven grab samples (VE-1 IDW, VE-2 IDW, VE-3 IDW, VE-4 IDW, MW-24 IDW, BS-1, and BS-2) from theexcavation area ranged from 44.7 to 2,600 mg/kg, and averaged 1,063 mg/kg. Five-point composite soilsamples TCA-1 and TCA-2 were collected after treatment from the first and second treatment batch, andthe concentrations of PCE were 6.3 and 17 mg/kg, respectively. Although these concentrations exceedthe 0.050 mg/kg

GWSoilIng PCL, the PCL is only applicable to surface soil and not to saturated soils that

exist beneath the static water level at approximately 5 ft BGS.

Soil PCLE Zone No. 1, which is under the building, was not addressed during this response action. Theconcentrations of PCE in Soil PCLE Zone No. 1 are significantly less than in Soil PCLE Zone No. 2, andthey are not anticipated to increase the concentration of PCE in the uppermost GWBU to above theconcentrations at the time of RAP submittal.

Groundwater Response Action Objectives

Name of groundwater-bearing unit to which this informationapplies

Uppermost GWBU

Repeat this section for each groundwater-bearing unit for which a different response action wasconducted.Groundwaterclassification

1 X 2 3

Was a modified groundwater response action used for any part of the groundwaterPCLE zone (§350.33(f)(2), (3), or (4))? X Yes NoIf yes, complete the appropriate portions of this report.

Explain how the removal or decontamination actions reduced the concentration of COCs to the criticalgroundwater PCL throughout the groundwater PCLE zone and prevented COC concentrations above thecritical groundwater PCL from migrating beyond the original boundary of the groundwater PCLE zone. IfCOC concentrations above the critical groundwater PCL ever migrated beyond the original boundary ofthe groundwater PCLE zone, explain the actions taken to address the increase in the PCLE zone.The soil response action removed a significant mass of PCE from the primary source area, and additionalPCE contamination was incidentally removed from the uppermost GWBU during dewatering operations.The response action did not specifically address the uppermost GWBU. The uppermost GWBUpresumptively contains DNAPL, which means that source area contamination is controlled by thesolubility limit of PCE. The concentration of PCE was 110 mg/L in MW-7 and the solubility limit for PCE isapproximately 200 mg/L. This is significantly more than the 0.005 mg/L GWGWIng PCL. PCEcontaminated groundwater has migrated downgradient in the uppermost GWBU since as early as 1969,and downgradient sources of contamination will likely lead to AAL exceedances in future years.

Explain how the response action prevented COCs from migrating to air at concentrations above the PCLsfor air if the groundwater-to-air PCLs (

AirGWInh-V) were exceeded.

The solubility limit of PCE is approximately 200 mg/L, which is less than the 498 mg/LAir

GWInh-V PCL.Thus, PCE does not and cannot exceed the

AirGWInh-V PCL. PCE contaminated soil within the uppermost

GWBU potentially exceeds the 1,584 mg/kgAir

SoilInh-V PCL. Although the 1,584 mg/kgAir

SoilInh-V PCL wasexceeded in soil samples from VE-4 IDW, BS-1, and BS-2, where the respective concentrations of PCEwere 1,900, 2,000, and 2,600 mg/kg, the soil samples were collected in sandy clay soils. The soilcontamination in the uppermost GWBU is associated for sand, which has a lower surface-to-volume ratioand which is subject to more desorption because of the higher groundwater exchange rate. Because ofthese factors, soils within the uppermost GWBU would not be anticipated to exceed the

AirSoilInh-V PCL.

However, the concentration of PCE may exceed the AirSoilInh-V PCL in the underlying saturated clay soils,where the concentrations of VOCs increased in MC-2 beneath the uppermost GWBU. The soil-to-outdoor air exposure pathway is incomplete beneath the water table though.



ID No.

DC0060

Report Date:

November 2, 2011

The concentrations of vinyl chloride are below the 3.81 mg/LAir

GWInh-V PCL, which is the most restrictiveAir

GWInh-V PCL for chlorinated VOCs. The maximum concentration of vinyl chloride detected at the sitewas 3.2 mg/L in MW-7 on August 2, 2007. On February 25, 2010, the concentrations of vinyl chloridewere 2.1 mg/L in MW-7 (6 ft west of excavation area), 2.1 mg/L in MW-23 (100 ft west of excavationarea), and 0.72 mg/L in MW-24 (formerly under excavation area). In AMPs MW-6 and MW-7, theconcentrations of vinyl chloride were 0.33 and 1.5 mg/L on July 26 and 27, 2011. No AALs have beendefined for vinyl chloride in the uppermost GWBU.

Explain how the response action prevented COCs from migrating to surface water at concentrationsabove the PCLs for groundwater discharges to surface water if surface water was a factor.Not applicable.

Explain how the response action prevented human and ecological receptor exposure to the groundwaterPCLE zone.Not applicable.

Name of groundwater-bearing unit to which this informationapplies

Second GWBU

Repeat this section for each groundwater-bearing unit for which a different response action wasconducted.Groundwaterclassification

1 2 X 3

Was a modified groundwater response action used for any part of the groundwaterPCLE zone (§350.33(f)(2), (3), or (4))? X Yes NoIf yes, complete the appropriate portions of this report.

Explain how the removal or decontamination actions reduced the concentration of COCs to the criticalgroundwater PCL throughout the groundwater PCLE zone and prevented COC concentrations above thecritical groundwater PCL from migrating beyond the original boundary of the groundwater PCLE zone. IfCOC concentrations above the critical groundwater PCL ever migrated beyond the original boundary ofthe groundwater PCLE zone, explain the actions taken to address the increase in the PCLE zone.The response action did not address the second GWBU. DNAPL source contamination appears to existin the uppermost GWBU and in the clayey soils between the uppermost and second GWBU. MW-16 isthe closest well to the source area in the second GWBU and is located 23 ft west of the southwest cornerof the excavation area. The concentration of PCE has steadily increased in MW-16 from 2007 to 2011,where the concentration of PCE was 0.42 mg/L in August 2007, 3.8 mg/L in May 2009, 9.4 mg/L inFebruary 2010, and 17 mg/L in July 2011. No response actions are planned to reverse this trend.

A third GWBU potentially exists between 80 and 160 ft BGS. The Drinking Water Survey Report (March2006) identified an industrial well located at 3838 Majestic Street (Well No. 65-14-517), which is southand up/cross-gradient from the PCE plume, and another industrial well (Well No. 65-14-506) located nearthe intersection of Highway 610 and Homestead Road, which is northeast and up/cross-gradient of thePCE plume. The industrial water wells are screened from 284 to 299 ft BGS and from 316 to 336 ft BGS,and the boring logs for these wells identify sand from 82 to 164 ft BGS and from 96 to 161 ft BGS. Themaximum depth of the assessment at this site by CPT was 72 ft BGS in MC-3, which is located withinBuilding 1 and identifies silty clay. The maximum depth of contamination was identified by MIP in MC-2,which is located approximately 6 ft west of the excavation area, where PCE contamination was observedat the maximum MIP depth of 67 ft BGS. The APAR does not evaluate potential PCE contamination inthe potential third GWBU. The APAR was originally submitted to the TCEQ on November 12, 2010, andwas revised with new figures and re-submitted on September 8, 2011.



ID No.

DC0060

Report Date:

November 2, 2011

Explain how the response action prevented COCs from migrating to air at concentrations above the PCLsfor air if the groundwater-to-air PCLs (

AirGWInh-V) were exceeded.

The concentrations of chlorinated VOCs were significantly below theAir

SoilInh-V PCLs.

Explain how the response action prevented COCs from migrating to surface water at concentrationsabove the PCLs for groundwater discharges to surface water if surface water was a factor.Not applicable.

Explain how the response action prevented human and ecological receptor exposure to the groundwaterPCLE zone.Not applicable.

Waste Management

Describe the volume and final disposition or reuse location of waste or environmental media that wasremoved from the affected property during the response action, if not previously reported under STEERS.Provide copies of all manifests, other documentation of disposition, and landowner consent for reuse ofsoil in Appendix 8.

The following waste streams were generated during the response action:

Three loads of concrete were removed from the site on July 28, 2011 by MTZ Trucking, andtransported to Coastal Crushed Concrete in Houston, TX for recycling.

The excess soil in the second treatment batch was sampled on August 8, 2011. Sample WD-1and WD-1 (Duplicate) were collected on August 8, 2011, and submitted to ALS EnvironmentalLaboratory for analysis of VOCs by Method 8260B and VOCs in toxicity characteristic leachingprocedure (TCLP) leachate by Methods 1311 and 8260B. The concentrations of PCE in WD-1and WD-1 (Duplicate) were 0.0069 and 0.0079 mg/kg, and the concentrations of TCE, cDCE, andvinyl chloride were below the detection limit. The concentrations of VOCs in the leachate werebelow the detection limits. Three loads of soil, concrete, and debris were picked up from the siteon August 31, 2011 and delivered to Waste Management’s Atascocita Landfill in Humble, TX,where a total of 65.49 tons of material was disposed as class 2 non-hazardous waste.

55,500 gallons of treated wastewater were discharged to the City of Houston sanitary sewerbetween August 2 and 9, 2001, under a One Time Discharge Authorization. The wastewatervolume includes approximately 50,000 gallons of extracted groundwater, 5,000 gallons of waterused for hydraulic jetting of the 17 dewatering well-points, 250 gallons of IDW water, and250 gallons of decon water for the treatment system. The discharge limits in the Authorizationwere 1.0 mg/L of total benzene, toluene, ethylbenzene, and xylene (BTEX) compounds and30.0 mg/L of total petroleum hydrocarbons (TPH). Post-treatment wastewater confirmationsamples WWA-1 and WWA-2 were collected on August 1 and 8, 2011, and submitted to ALSEnvironmental Laboratory for analysis. Samples WWA-1 and WWA-2 were analyzed for VOCs byClean Water Act Method 624 and sample WWA-1 was analyzed for TPH by Method TX1005. Theconcentrations of chlorinated VOCs, BTEX compounds, and TPH were below the detection limits.The One Time Discharge Approval is provided in Appendix 8.

Wastewater was treated using a tray-aeration stripper, and the water and air waste streams weretreated with activated carbon. The spent carbon and the sediment in the bottom of the frac tankswere removed on August 18, 2011 and placed in roll-off container. The spent carbon andsediment were picked up from the site on August 31, 2011 and 9.12 tons of material weredelivered and disposed to Waste Management’s Conroe Landfill.

Potassium permanganate was delivered in 144 plastic buckets. The empty containers werecrushed and placed into six super sacks. The empty containers were delivered and disposed atthe US Ecology facility in Robstown, TX.



ID No.

DC0060

Report Date:

November 2, 2011

The waste disposal sample results are provided in Appendices 4 and 6, and the waste manifests and theOne Time Discharge Authorization are provided in Appendix 8.

Plume Management ZoneRACR Worksheet 2.0 Page _1_ of _3_

ID No. DC0060 Report Date: November 2, 2011

Complete this worksheet when a PMZ was used as part of the response action. Include in Attachment 2Aa map of the PMZ with alternate POE(s) and attenuation monitoring points identified and the currentgroundwater PCLE zone (if applicable). If a PMZ was not used, do not submit this worksheet.

Groundwater-bearing unit Uppermost GWBU

Repeat this worksheet for each groundwater-bearing unit for which a PMZ was used.Groundwater classification X 2 3

Is/was NAPL present? X Yes NoIf so, describe how the response action achieved the performance criteria in §350.33(f)(4)(E).The uppermost GWBU appears to contain DNAPL contamination, and the concentration of PCE appearsto be controlled by the solubility of PCE. The concentration of PCE was 110 mg/L in July 2011, whichapproaches its 200 mg/L solubility limit. Although the response action substantially remediated theprimary soil contamination above the uppermost GWBU, no response actions were performed to addressDNAPL contamination in the uppermost GWBU.

If this is a Class 2 groundwater, explain how the response action ensured that leachate from the surfacesoil and subsurface soil PCLE zones did not increase concentration of COCs greater than the measuredconcentrations at time of RAP submittal. (§350.33(a)(2))The objective of the response action was to prevent soil contamination from increasing the concentrationof PCE to above 110 mg/L in MW-7, which was the concentration on July 27, 2011 that coincides with thetime of the RAP submittal on July 25, 2011. Approximately 800 BCY of soil were excavated from theprimary source area, treated ex-situ with permanganate, and returned to its place of origin. Approximately112 BCY of soil was also treated between 18 and 22 ft BGS by in-situ permanganate mixing. The top ofthe uppermost GWBU is approximately 23 ft BGS beneath the excavation area. The concentrations ofPCE in seven grab samples (VE-1 IDW, VE-2 IDW, VE-3 IDW, VE-4 IDW, MW-24 IDW, BS-1, and BS-2)from the excavation area ranged from 44.7 to 2,600 mg/kg, and averaged 1,063 mg/kg. Five-pointcomposite soil samples TCA-1 and TCA-2 were collected after treatment from the first and secondtreatment batch, and the concentrations of PCE were 6.3 and 17 mg/kg, respectively. Additionally,approximately 50,000 gallons of groundwater was extracted from the source area during the responseaction, and then treated and discharged to the sanitary sewer.

Soil PCLE Zone No. 1, which is under the building, was not addressed during this response action. Theconcentrations of PCE in Soil PCLE Zone No. 1 are significantly less than in Soil PCLE Zone No. 2, andthey are not anticipated to increase the concentration of PCE in the uppermost GWBU to above theconcentrations at the time of RAP submittal.

Provide documentation that the COCs did not migrate beyond the downgradient boundary of the PMZ atconcentrations above the critical PCL. Include supporting documentation in Attachments 1A, 1B, and 2A.Groundwater was sampled on July 25 to 27, 2011 prior to the response action. Attachment 1A-1 showsthe PMZ boundaries for the uppermost and second GWBUs. Attachment 2A-1 shows the AALs for PCEand the initial, maximum, and latest concentrations of PCE in the AMPs, along with the concentrations ofPCE at the time of RAP submittal. Sample results are provided in Appendices 4 and 6.



List the attenuation action level determined for each attenuation monitoring point. Illustrate the attenuationmonitoring points, initial, maximum, and final groundwater PCLE zones (or groundwater concentrations ifless than the critical PCL) on the map in Attachment 2A.

COC AttenuationMonitoring Point

(well number)

Attenuation ActionLevel(mg/L)

Maximumconcentration

measured at theattenuation

monitoring point(mg/L)

PCE MW-7 110 110 (7/27/2011)

MW-6 76 76 (12/5/2005)MW-14 64 63.6 (3/27/2009)

MW-15 9.3 9.32 (5/21/2009)

MW-18 0.047 0.047 (2/25/2010)MW-19 0.016 0.016 (2/25/2010)MW-29 0.044 0.044 (2/24/2010)

MW-30 0.057 0.057 (2/24/2010)

Groundwater-bearing unit Second GWBURepeat this worksheet for each groundwater-bearing unit for which a PMZ was used.Groundwater classification 2 X 3

Is/was NAPL present? X Yes NoIf so, describe how the response action achieved the performance criteria in §350.33(f)(4)(E).Although no monitoring wells have been installed in the second GWBU beneath the source area, thepresence of DNAPL is presumed in the second GWBU. Monitoring MW-16 is located 23 ft west of thesouthwest corner of the excavation however, and the concentration of PCE was 17 mg/L at the time ofRAP submittal in July 2011. The presence of DNAPL can be assumed when the concentration of PCEexceeds 1% of its solubility limit, or 2 mg/L.

If this is a Class 2 groundwater, explain how the response action ensured that leachate from the surfacesoil and subsurface soil PCLE zones did not increase concentration of COCs greater than the measuredconcentrations at time of RAP submittal. (§350.33(a)(2))Not applicable.

Provide documentation that the COCs did not migrate beyond the downgradient boundary of the PMZ atconcentrations above the critical PCL. Include supporting documentation in Attachments 1A, 1B, and 2A.Groundwater was sampled on July 25 to 27, 2011 prior to the response action. Attachment 1A-1 showsthe PMZ boundaries for the uppermost and second GWBUs. Attachment 2A-2 shows the AALs for theCOCs and the initial, maximum, and latest concentrations of the COCs in the AMPs, along with theconcentrations of COCs at the time of RAP submittal. Sample results are provided in Appendices 4 and 6.



List the attenuation action level determined for each attenuation monitoring point. Illustrate the attenuationmonitoring points, initial, maximum, and final groundwater PCLE zones (or groundwater concentrations ifless than the critical PCL) on the map in Attachment 2A.

COC AttenuationMonitoring Point

(well number)

Attenuation ActionLevel(mg/L)

Maximumconcentration

measured at theattenuation

monitoring point(mg/L)

PCE MW-16 10 17 (7/26/2011)

MW-20 0.5 0.039 (2/25/2010)MW-21 0.5 0.1 (2/25/2010)

MW-22 0.5 0.12 (7/26/2010)

TCE MW-20 0.5 0.0096 (2/25/2010)MW-21 0.5 0.0093 (2/25/2010)MW-22 0.5 0.0094 (7/26/2011)

cDCE MW-20 7 0.0057 (2/25/2010)MW-21 7 0.011 (2/25/2010)MW-22 7 0.0031 (7/26/2011)

VC MW-20 0.2 <0.001 (7/26/2011)MW-21 0.2 <0.001 (7/26/2011)MW-22 0.2 <0.001 (7/26/2011)

Institutional ControlsRACR Worksheet 4.0 Page _1_ of _2_


Complete this worksheet if an institutional control will be or has been used as part of the response action. Include in Appendix 3 copies of filed institutionalcontrols and drafts of the proposed institutional controls, copies of landowner concurrences, and a list of landowners from whom landowner concurrencewill be requested.Specify the property for which this applies. 6410 Cavalcade, Houston, TX (DC0060 property)Repeat this worksheet for each different property for which an institutional control will be used.

Institutional Control

Type of Institutional Control3

Property Ownership Anticipated oractual filing

date4Deed

noticeRestrictivecovenant

DCRPNo Further

Action (NFA)Certificate

Equivalentzoning or

governmentalordinance

Check ifpertinent tract

of land isowned by the

person

Check if the pertinenttract of land is owned

by an innocentowner or operator

Document use of commercial/industrial land use(§350.31(g))

X X Issued after NFAdesignation

Document use of physical or institutional control under RemedyStandard B §350.31(g))

Document notice of on-going long term response action(§350.31(h))

Document use of occupational inhalation criteria as RBELs(§350.74(b)(1))

Document variance from the default exposure factors(§350.74(j)(2)(L))

Document the use of a non-default soil exposure area(§350.51(l)(3)&(4))

Document WCU exclusion area (§350.33(f)(2))

Document establishing a PMZ (§350.33(f)(4)(C)(I)) X X Issued after NFAdesignation

Document the demonstration of technical impracticability(§350.33(f)(3)(F))

Relocation of soils containing COCs for reuse (§350.36(b)(4)and (c)(4))

Other (specify)

3Check the appropriate box(es) to indicate the type of institutional control required for the response action.

4Specify date or amount of time after RAP approval.

Institutional ControlsRACR Worksheet 4.0 Page _2_ of _2_


Complete this worksheet if an institutional control will be or has been used as part of the response action. Include in Appendix 3 copies of filed institutionalcontrols and drafts of the proposed institutional controls, copies of landowner concurrences, and a list of landowners from whom landowner concurrencewill be requested.Specify the property for which this applies. Offsite properties surrounding 6410 Cavalcade, Houston, TXRepeat this worksheet for each different property for which an institutional control will be used.

Institutional Control

Type of Institutional Control5

Property Ownership Anticipated oractual filing

date6Deed

noticeRestrictivecovenant

DCRPNo Further

Action (NFA)Certificate

Equivalentzoning or

governmentalordinance

Check ifpertinent tract

of land isowned by the

person

Check if the pertinenttract of land is owned

by an innocentowner or operator

Document use of commercial/industrial land use(§350.31(g))

Document use of physical or institutional control under RemedyStandard B §350.31(g))

Document notice of on-going long term response action(§350.31(h))

Document use of occupational inhalation criteria as RBELs(§350.74(b)(1))

Document variance from the default exposure factors(§350.74(j)(2)(L))

Document the use of a non-default soil exposure area(§350.51(l)(3)&(4))

Document WCU exclusion area (§350.33(f)(2))

Document establishing a PMZ (§350.33(f)(4)(C)(I)) X X To be determinedby TCEQ

Document the demonstration of technical impracticability(§350.33(f)(3)(F))

Relocation of soils containing COCs for reuse (§350.36(b)(4)and (c)(4))

Other (specify)

5Check the appropriate box(es) to indicate the type of institutional control required for the response action.

6Specify date or amount of time after RAP approval.




Performance Measures

List and describe the performance measures for each environmental medium containing a PCLE zonethat were used to determine if reasonable progress is being made by the response action in a timelymanner. Provide documentation that these performance measures were met. Attach additionalinformation if necessary.Performance measures for the excavation of soil include the volumes of soil and groundwater removedfrom the excavation, the mass of potassium permanganate added to the soils, and the reduction in theconcentrations of VOCs in soil.

The response action included the removal and ex-situ treatment of approximately 800 BCY of PCE-contaminated soil, and the return of the treated soil to its point of origin. The concentrations of PCE inseven grab samples (VE-1 IDW, VE-2 IDW, VE-3 IDW, VE-4 IDW, MW-24 IDW, BS-1, and BS-2) from theexcavation area ranged from 44.7 to 2,600 mg/kg, and averaged 1,063 mg/kg. Five-point composite soilsamples TCA-1 and TCA-2 were collected after treatment from the first and second treatment batch, andthe concentrations of PCE were 6.3 and 17 mg/kg, respectively. Assuming that excavated soil had anaverage concentration of 100 mg/kg of PCE and the dry-bulk density is 110 lbs per cubic foot, theexcavated soil had 238 lbs of PCE, which was presumptively remediated by two orders-of-magnitude fora reduction of approximately 235 lbs of PCE.

Approximately 112 BCY of soil was also treated between 18 and 22 ft BGS by in-situ permanganatemixing. The concentrations of PCE in BS-1 and BS-2 were 2,000 and 2,600 mg/kg. Assuming that basesoil had an average concentration of 1,000 mg/kg of PCE and the dry-bulk density is 110 lbs per cubicfoot, the excavated soil had 333 lbs of PCE, which was presumptively remediated by one order-of-magnitude for a reduction of approximately 300 lbs of PCE.

Approximately 50,000 gallons of groundwater were removed from the uppermost GWBU near the sourcearea. The average concentration of PCE in the three representative samples was 3.0 mg/L, which issignificantly less than the 110 mg/L of PCE detected in nearby MW-7 on July 27, 2011. The lowerconcentration is due to capture and blending of less-contaminated water surrounding the source area anddue to volatilization during vacuum extraction, discharge, and staging and recirculation in the two fractanks. The dewatering operations are estimated to have removed a minimum of 1.25 lbs of PCE from theuppermost GWBU, which is the product of 3.0 mg/L of PCE and 50,000 gallons of groundwater.

Using these assumptions, the response action removed approximately 550 lbs of PCE from the sourcearea.

The intermediate- and long-term effectiveness of treatment will be monitored by sampling groundwater inthe AMPs and analyzing for VOCs to assess the attenuation of contamination due to source removal andtreatment.

Problems

Complete the table for the response action. When the response action consisted of severalcomponents or multiple actions, complete one table for each major component or action.

Response Action Name/Designation: Soil response action for Soil Contamination Area No. 2

List the problems that were encountered during the response action, describe the impact of eachproblem, and the response to the problem.




Description of the Problem Impact Did thiscause a

responseaction

failure?

Corrective Response

Yes NoConfirmation samplescould not be collected.

Limits ability todetermine whethersourcecontamination iscomplete.

X The backhoe was used to retrievesamples BS-1 and BS-2 from 18 ftBGS at the bottom of theexcavation. Based on PIDreadings, the scope of work wasadjusted with the consent of theTCEQ project manager to includethe purchase of additionalpermanganate to perform in-situmixing at the bottom of theexcavation.

Lateral extent ofexcavation was limited byplacement of thedewatering well-points andthe scope of work.

Contaminated soilswere potentially notaddressed.

X During the in-situ mixing ofpermanganate, the backhoescraped soil from the sidewalls andmixed them with thepermanganate treated soils.

Lower extent ofcontamination was limitedby the access andpenetration depth of thebackhoe bucket, the abilityto retrieve the bucket, andthe sidewall stability.

Contaminated soilswere potentially notaddressed.

X Accessible soils from 18 to 22 ftBGS were addressed by in-situmixing of permanganate andseepage of ponded permanganatesolution. After placing treated soilin the southern side of theexcavation, the backhoe was ableto get closer to the bottom and theexcavation and continue to mixpermanganate.

Wet soils during in-situmixing.

Limits the ability tocompact the soil.

X The permanganate solution couldnot be diluted as much as desiredto increase the effectiveness of in-situ mixing. The treated wet soilswere placed on the side of theexcavation and blended withtreated soils from the soiltreatment cell to reduce themoisture content. Additionalpermanganate was placedbetween 8 and 10 ft BGS, but thepermanganate was not hydratedenough to treat the soilsadequately. However, therecovery of the water table willenhance the oxidation of PCE inthe shallower saturated soils.

Data Tables, Photographic Log,Plugging Reports, and

Field Activity Notes

RACR Appendix 4


Appendix 4.1: Concentrations of Volatile Organic Componds in the Uppermost Groundwater Bearing Unit

Good Neighbor Cleaners

DCRP No. 0060

Houston, Harris County, Texas

Sample

Location

Sample

Date

PCE

(mg/L)

TCE

(mg/L)

Cis-1,2-DCE

(mg/L)

Trans-1,2 DCE

(mg/L)

1,1-DCE

(mg/L)

VC

(mg/L)

1,1,2-TCA

(mg.L)

Benzene

(mg/L)

MTBE

(mg/L)

0.005 0.005 0.07 0.1 0.007 0.002 0.005 0.005 0.244

498 118 1,229 768 1,666 3.81 80.0 180 4,039

12/15/05 8.8 0.059 0.034 0.00097J <0.0006 0.0024 <0.0015 <0.0006 -

08/02/07 10.0 0.220 0.100 <0.0070 <0.0050 <0.0055 <0.0070 <0.0050 <0.010

03/27/09 19.8 0.225 0.167 <0.004 <0.004 0.0132 J <0.004 <0.004 <0.006

05/18/09 14.9 0.186 0.178 0.005 <0.004 0.0144 J <0.004 <0.004 <0.006

02/24/10 14 0.19 0.21 <0.030 <0.020 <0.040 <0.010 <0.010 <0.010

12/15/05 5.6 0.044 0.055 0.0018J <0.0006 0.004 <0.0015 <0.0006 -

08/02/07 38.0 0.490 1.0 <0.014 <0.010 0.036 J <0.014 <0.010 <0.020

03/27/09 38.9 0.432 1.17 0.023 J <0.01 0.0575 <0.01 <0.01 <0.015

05/18/09 41.9 0.591 1.72 0.0385 J <0.01 0.0865 <0.01 <0.01 <0.015

02/24/10 40 0.94 2.8 <0.030 <0.020 0.20 <0.010 <0.010 <0.010

12/15/05 4.1 0.049 0.068 0.0017J <0.0006 0.0016J <0.0015 <0.0006 -

08/02/07 13.0 0.270 0.330 <0.014 <0.010 <0.011 <0.014 <0.010 <0.020

03/27/09 NS NS NS NS NS NS NS NS NS

05/18/09 24.9 0.266 0.422 0.0082 J <0.004 0.0194 J <0.004 <0.004 <0.006

02/26/10 19 0.32 0.52 <0.030 <0.020 <0.040 <0.010 <0.010 <0.010

12/15/05 0.0026J <0.0007 0.0041J <0.0006 <0.0006 <0.0006 <0.0015 <0.0006 -

08/02/07 <0.00022 <0.00010 <0.00012 <0.00014 0.00042 J <0.00011 <0.00014 <0.00010 <0.00020

03/26/09 0.0522 0.00615 0.0506 0.0007 J 0.0379 0.00336 <0.0002 <0.0002 <0.0003

05/21/09 0.00397 0.00217 0.0914 0.00127 0.0484 0.00641 <0.0002 <0.0002 <0.0003

02/25/10 0.0068 0.0061 0.23 0.004 0.069 0.031 <0.00010 <0.00010 <0.00010

12/15/05 38 0.52 0.83 0.025 0.006 0.068 0.005 <0.0006 -

08/02/07 5.7 0.18 0.19 <0.0035 <0.0025 0.021 J <0.0035 <0.0025 0.27

03/27/09 11.8 0.257 0.358 0.0104 0.0031 J 0.0196 <0.002 <0.002 0.0195

05/21/09 5.77 0.152 0.237 0.00635 0.00195 J 0.0108 <0.001 <0.001 0.068


12/15/05 76 5.8 16 0.2 0.043 1.2 0.018 <0.0006 -

08/02/07 26 4.2 12 0.17 0.031 J 0.75 <0.014 <0.010 <0.020

03/26/09 44.4 4.24 14.9 0.195 0.0405 0.785 0.0183 0.00119 0.00044 J

05/22/09 44.5 5.5 17 0.262 0.0455 J 0.972 0.0195 J <0.01 <0.015

02/25/10 66 6.5 19 0.29 0.043 J 1.4 <0.010 <0.010 <0.010

07/26/11 72 5.7 22 0.34 0.06 J 1.2 <0.1 <0.1 <0.1

07/26/11 62 5.5 21 0.3 <0.5 0.33 <0.5 <0.5 <0.5

12/15/05 110 24 34 0.29 0.098 2.1 0.059 0.007 -

08/02/07 92 22 47 <0.035 0.16 J 3.2 <0.035 <0.025 0.23 J

03/26/09 62.4 11.6 27.5 0.204 0.0672 1.19 0.0309 0.00954 0.147

05/22/09 94.4 18.6 40 0.448 0.116 2.48 0.046 J <0.02 0.292

02/25/10 58 14 31 0.27 J <0.10 2.1 <0.050 <0.050 0.31 J

07/27/11 110 24 40 0.37 J <0.50 1.5 <0.50 <0.50 0.17 J

GWGWing PCL

MW-6

MW-7

MW-4

MW-5

AirGWInh-V PCL

MW-1

MW-2

MW-3

Page 1 of 3



DCRP No. 0060


Sample

Location

Sample

Date

PCE

(mg/L)

TCE

(mg/L)

Cis-1,2-DCE

(mg/L)

Trans-1,2 DCE

(mg/L)

1,1-DCE

(mg/L)

VC

(mg/L)

1,1,2-TCA

(mg.L)

Benzene

(mg/L)

MTBE

(mg/L)

0.005 0.005 0.07 0.1 0.007 0.002 0.005 0.005 0.244

498 118 1,229 768 1,666 3.81 80.0 180 4,039

GWGWing PCL

AirGWInh-V PCL

12/15/05 19 2.4 4.2 0.046 0.0097 0.12 0.0019J <0.0006 -

08/02/07 14 3.5 5.1 <0.0070 <0.0050 0.1 <0.0070 <0.0050 <0.010



02/23/10 24 4.5 8 <0.015 0.013 J 0.22 <0.0050 <0.0050 <0.0050

12/15/05 0.0054 <0.0007 <0.0005 <0.0006 <0.0006 <0.0006 <0.0015 <0.0006 -

08/02/07 0.0036 0.00090 J <0.00012 <0.00014 <0.00010 <0.00011 <0.00014 <0.00010 <0.00020



02/25/10 0.41 0.044 0.062 0.00089 J 0.00027 J 0.0028 <0.0001 <0.0001 <0.0001

12/15/05 0.0041J <0.0007 <0.0005 <0.0006 <0.0006 <0.0006 <0.0015 <0.0006 -

08/02/07 <0.00022 <0.00010 <0.00012 <0.00014 <0.00010 <0.00011 <0.00014 <0.00010 <0.00020

03/26/09 0.0552 0.00565 0.00962 <0.0002 <0.0002 0.00028 J <0.0002 <0.0002 <0.0003

05/22/09 0.00629 0.00128 J 0.00228 <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 <0.0003

02/26/10 0.044 0.0027 0.0036 <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

08/02/07 <0.00022 <0.00010 <0.00012 <0.00014 <0.00010 <0.00011 <0.00014 <0.00010 <0.00020

03/27/09 0.0654 0.00153 J 0.00209 <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 <0.0003

05/22/09 0.00113 J <0.0006 <0.0002 <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 <0.0003

02/24/10 <0.00030 <0.00010 <0.00020 <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

08/02/07 <0.00022 <0.00010 <0.00012 <0.00014 <0.00010 <0.00011 <0.00014 <0.00010 <0.00020

03/27/09 0.0562 0.00144 J 0.00169 <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 <0.0003

05/21/09 0.0176 <0.0006 0.00053 J <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 <0.0003

02/24/10 <0.00030 <0.00010 <0.00020 <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

08/02/07 0.0024 <0.00010 <0.00012 <0.00014 <0.00010 <0.00011 <0.00014 <0.00010 <0.00020

03/27/09 0.0209 0.00087 J 0.00099 J <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 <0.0003

05/21/09 0.0713 0.00147 J 0.00162 <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 <0.0003

02/24/10 0.06 0.001 0.00071 J <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

08/02/07 18 0.65 1.1 <0.014 <0.010 0.1 <0.014 <0.010 <0.020

03/27/09 63.6 1.13 1.68 0.0575 0.0175 J 0.068 <0.01 <0.01 <0.015

05/21/09 51 1.42 2.18 0.072 0.026 J 0.089 0.019 J <0.01 <0.015

08/19/09 41 0.771 1.09 0.04 J <0.0002 0.062J <0.02 <0.02 <0.03

02/24/10 43 1.2 1.7 <0.030 <0.020 0.092 J <0.010 <0.010 <0.010

07/25/11 41 0.86 1.3 0.055 J <0.1 <0.1 <0.1 <0.1 <0.1

08/02/07 3.9 0.024 0.014 <0.0014 <0.0010 <0.0011 <0.0014 <0.0010 <0.0020

03/27/09 5.54 0.0261 0.0142 <0.001 <0.001 <0.0005 <0.001 <0.001 <0.0015

05/21/09 9.32 0.0534 0.0304 <0.002 <0.002 0.0012 J <0.002 <0.002 <0.003

02/24/10 3.8 0.26 0.13 <0.030 <0.020 <0.040 <0.010 <0.010 <0.010

07/25/11 0.037 0.00068 J 0.00097 J <0.001 <0.001 <0.001 <0.001 <0.001 <0.001

05/21/09 <0.0006 <0.0006 <0.0002 <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 <0.0003

02/24/10 0.01 0.00015 J <0.00020 <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

05/21/09 <0.0006 <0.0006 <0.0002 <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 <0.0003

02/25/10 0.047 0.00093 J 0.00095 J <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

07/25/11 0.0069 <0.001 0.00028 J <0.001 <0.001 <0.001 <0.001 <0.001 <0.001

MW-18

MW-9

MW-10

MW-11

MW-12

MW-13

MW-14

MW-15

MW-17

MW-8

Page 2 of 3



DCRP No. 0060


Sample

Location

Sample

Date

PCE

(mg/L)

TCE

(mg/L)

Cis-1,2-DCE

(mg/L)

Trans-1,2 DCE

(mg/L)

1,1-DCE

(mg/L)

VC

(mg/L)

1,1,2-TCA

(mg.L)

Benzene

(mg/L)

MTBE

(mg/L)

0.005 0.005 0.07 0.1 0.007 0.002 0.005 0.005 0.244

498 118 1,229 768 1,666 3.81 80.0 180 4,039

GWGWing PCL

AirGWInh-V PCL

05/21/09 0.00094 J <0.0006 <0.0002 <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 0.00084 J

02/25/10 0.016 0.00028 J 0.00053 J <0.00030 <0.00020 <0.00040 <0.00010 <0.0000 0.00027 J

07/25/11 0.014 0.00033 J 0.00045 J <0.001 <0.001 <0.001 <0.001 <0.001 <0.001

08/19/09 58.2 11.8 37.9 0.383 0.039 J 2.08 <0.02 <0.02 <0.03

02/25/10 58 9.3 <0.10 0.32 J <0.10 2.1 <0.050 <0.050 <0.050

08/19/09 122 4.56 6.09 0.046 J <0.02 0.18 <0.02 <0.02 <0.03

02/25/10 77 8.5 14 <0.15 <0.10 0.72 <0.050 <0.050 <0.050

MW-25 02/25/10 68 0.84 0.84 <0.15 <0.10 <0.20 <0.050 <0.050 <0.050

MW-26 02/24/10 NS NS NS NS NS NS NS NS NS



02/24/10 0.044 0.034 0.0015 <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

07/26/11 0.0013 0.026 0.014 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001

02/24/10 0.057 0.0013 0.0026 <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

07/26/11 0.0013 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001

MW-31 02/24/10 <0.00030 <0.00010 <0.00020 <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

MW-32 02/24/10 0.0012 <0.00010 <0.00020 <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

MW-33 08/30/10 <0.0003 <0.0001 <0.0002 <0.0003 <0.0002 <0.0004 <0.0001 <0.0001 0.0007

MW-34 08/30/10 <0.0003 <0.0001 <0.0002 <0.0003 <0.0002 <0.0004 <0.0001 <0.0001 0.0008 J

MW-35 08/30/10 <0.0003 <0.0001 <0.0002 <0.0003 <0.0002 <0.0004 <0.0001 <0.0001 <0.0001

MW-36 08/30/10 <0.0003 0.19 0.016 0.0013 0.00028 J 0.0029 <0.0001 <0.0001 <0.0001

MW-37 08/30/10 <0.0003 <0.0001 <0.0002 <0.0003 <0.0002 <0.0004 <0.0001 <0.0001 0.0012

Notes: <

J -

BOLD - Exceeds Screening CriteriaGW

GW Ing for Class 1 Groundwater.

NS Not Sampled

MW-19

- The material was analyzed for, but was not detected. The associated numerical value is the sample quantitation or detection limit, which has been adjusted forsample weight/sample volume, extraction volume, percent solids, sample dilution or other analysis specific parameters.

The analyte was analyzed for, but the associated numerical value may not be consistent with the amount actually present in the environmental sample or may not beconsistent with the sample detection or quantitation limit. The value is an estimated quantity.

MW-29

MW-30

MW-23

MW-24

Page 3 of 3

Appendix 4.2: Concentrations of Volatile Organic Compunds in the Second Groundwater Bearing Unit

Good Neighbor Cleaners (DCRP 0060)


Sample

Location

Sample

Date

PCE

(mg/L)

TCE

(mg/L)

Cis-1,2-DCE

(mg/L)

Trans-1,2 DCE

(mg/L)

1,1-DCE

(mg/L)

VC

(mg/L)

1,1,2-TCA

(mg/L)

Benzene

(mg/L)

MTBE

(mg/L)

0.5 0.5 7 10 0.7 0.2 0.5 0.5 24.4

498 118 1,229 768 1,666 3.81 80.0 180 4,039

08/09/07 0.42 0.063 0.11 JH 0.0011 0.00051 J 0.0037 <0.00014 <0.00010 0.00039 J

03/26/09 3.1 0.71 3.96 0.0171 0.0077 0.0491 <0.0002 0.0005 J 0.003

05/22/09 3.76 0.777 3.86 0.0156 0.00785 0.0483 <0.001 <0.001 0.00255 J

02/25/10 9.4 1.5 3 <0.030 <0.020 0.088 <0.010 <0.010 <0.010

07/26/11 17 1.9 3.1 0.04 J <0.1 <0.1 <0.1 <0.1 <0.1

05/21/09 0.0172 0.00216 0.00811 <0.0002 <0.0002 0.00012 J <0.0002 <0.0002 <0.0003

02/25/10 0.039 0.0096 0.0057 0.0096 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

07/26/11 0.021 0.007 0.0012 0.00025 J <0.001 <0.001 <0.001 <0.001 <0.001

05/21/09 0.0048 <0.0006 <0.0002 <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 <0.0003

02/25/10 0.1 0.0093 0.011 <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

07/26/11 0.027 0.0048 0.0016 0.00027 J <0.001 <0.001 <0.001 <0.001 <0.001

05/18/09 0.00734 <0.0006 0.00065 J <0.0002 <0.0002 <0.0001 <0.0002 <0.0002 <0.0003

02/25/10 0.05 0.0047 0.0031 <0.00030 <0.00020 <0.00040 <0.00010 <0.00010 <0.00010

07/26/11 0.12 0.0094 0.017 0.0014 <0.001 <0.001 <0.001 <0.001 <0.001

Notes: <

J -

BOLD - Exceeds Screening CriteriaGW

GWClass3 for Class 3 Groundwater.

MW-22

AirGWInh-V PCL

- The material was analyzed for, but was not detected. The associated numerical value is the sample quantitation or detection limit, which has been adjusted

for sample weight/sample volume, extraction volume, percent solids, sample dilution or other analysis specific parameters.

The analyte was analyzed for, but the associated numerical value may not be consistent with the amount actually present in the environmental sample or may

not be consistent with the sample detection or quantitation limit. The value is an estimated quantity.

GWGWClass3 PCL

MW-16

MW-20

MW-21

Page 1 of 1

Appendix 4.3: Cumulative Analytical Results for Volatile Organic Compounds in Soil

Good Neighbor Cleaners (DC0060)


Sample

Location

Depth

(ft bgs)

Date

Sampled

PCE

(mg/kg)

TCE

(mg/kg)

Cis-1,2-

DCE

(mg/kg)

Trans-1,2-

DCE

(mg/kg)

1,1-DCE

(mg/kg)

VC

(mg/Kg)

Benzene

(mg/kg)

C/I Tier 1 TotSoilComb PCL 408.4 207.6 6,389 1,213 6,393 15.07 179.3

C/I Tier 1 GWSoilIng PCL 0.0502 0.0336 0.2483 0.4902 0.0501 0.0223 0.0257

C/I Tier 1 AirSoilInh-V PCL 1,584 214.9 17,043 1,289 7,307 71.64 273.5

C/I Tier 1 AirGW-SoilInh-V PCL 8,407 1,114 80,667 5,272 16,686 71.26 1,551

B1 3-5 09/16/04 <0.0064 <0.0064 <0.0064 <0.0064 <0.0064 <0.0025 -

B2 0-3 09/16/04 <0.0059 <0.0059 <0.0059 <0.0059 <0.0059 <0.0024 -

B3 0-3 09/16/04 0.021 <0.0058 <0.0058 <0.0058 <0.0058 <0.0023 -

B5 4-6 09/16/04 <0.0066 <0.0066 <0.0066 <0.0066 <0.0066 0.0026 -

B6 0-3 09/16/04 0.016 0.0088 15 0.69 0.25 3 -

B7 1-3 09/16/04 23 0.7 2 0.012 <0.0063 0.25 -

B16 0-3 09/16/04 5.3 0.51 2.8 0.013 <0.0059 0.0034 -

B17 3-5 09/16/04 <0.0061 <0.0061 <0.0061 <0.0061 <0.0061 <0.0024 -

SB-19 4-5 7/31/2007 <0.00051 <0.00051 <0.00068 <0.00085 <0.00085 <0.00051 -

SB-20 2-3 7/31/2007 <0.00054 <0.00054 <0.00072 <0.00090 <0.00090 <0.00054 -

SB-21 3-4 7/31/2007 <0.00059 <0.00059 <0.00079 <0.00099 <0.00099 <0.00059 -

SB-22 2-3 7/31/2007 <0.00066 <0.00066 <0.00088 <0.0011 <0.0011 <0.00066 -

SB-23 2-3 7/31/2007 <0.00056 <0.00056 <0.00075 <0.00094 <0.00094 <0.00056 -

Surface Soil Samples

Page 1 of 3




Sample

Location

Depth

(ft bgs)

Date

Sampled

PCE

(mg/kg)

TCE

(mg/kg)

Cis-1,2-

DCE

(mg/kg)

Trans-1,2-

DCE

(mg/kg)

1,1-DCE

(mg/kg)

VC

(mg/Kg)

Benzene

(mg/kg)





B1 20-21.5 09/16/04 <0.0062 <0.0062 <0.0062 <0.0062 <0.0062 <0.0025 -

B2 9-11 09/16/04 <0.0064 <0.0064 0.0074 <0.0064 <0.0064 0.0036 -

B3 6-8 09/16/04 <0.0064 <0.0064 <0.0064 <0.0064 <0.0064 <0.0026 -

B4 9-11 09/16/04 <0.0064 <0.0064 <0.0064 <0.0064 <0.0064 <0.0026 -

B4 13-15 09/16/04 <0.0061 <0.0061 0.0078 <0.0061 <0.0061 0.0031 -

B5 11-12 09/16/04 <0.0061 <0.0061 <0.0061 <0.0061 <0.0061 <0.0024 -

B6 8-9 09/16/04 4 0.21 1.6 0.1 0.2 0.021 -

B7 9-10 09/16/04 16 0.77 1.4 0.022 <0.0067 0.03 -

B7 12-14 09/16/04 3.8 0.41 1.1 <0.0060 <0.0060 0.061 -

B8 10-11 09/16/04 0.055 <0.0064 0.019 <0.0064 <0.0064 0.021 -

B8 14-15 09/16/04 <0.0060 <0.0060 0.035 <0.0060 <0.0060 0.021 -

B9 10-12 09/16/04 0.0085 <0.0063 0.018 <0.0063 <0.0063 <0.0025 -

B9 13-15 09/16/04 0.017 0.015 0.57 <0.0059 <0.0059 0.018 -

B10 14-15 09/16/04 <0.0060 <0.0060 <0.0060 <0.0060 <0.0060 <0.0024 -

B11 17-18 09/16/04 <0.0061 <0.0061 <0.0061 <0.0061 <0.0061 <0.0024 -

B12 8-9 09/16/04 <0.0063 <0.0063 0.14 <0.0063 <0.0063 0.2 -

B12 14-15 09/16/04 0.041 0.044 0.14 0.0079 <0.0058 0.0085 -

B13 14-15 09/16/04 <0.0059 <0.0059 0.017 <0.0059 <0.0059 <0.0024 -

B14 10-12 09/16/04 0.036 0.095 0.83 0.048 <0.0061 0.07 -

B14 17-18 09/16/04 <0.0062 <0.0058 0.012 <0.0058 <0.0058 <0.0023 -

B15 11-12 09/16/04 0.077 0.13 0.57 0.067 <0.0059 0.082 -

B15 19-21 09/16/04 0.084 0.088 0.77 0.016 <0.0060 0.0086 -

B16 14-15 09/16/04 0.059 0.097 0.13 <0.0059 <0.0059 <0.0023 -

B17 14-15 09/16/04 0.049 0.035 0.12 <0.0059 <0.0059 <0.0024 -

B18 8-9 09/16/04 230 0.19 29 0.032 <0.032 <0.013 -

B18 17-18 09/16/04 12 0.55 4.7 0.027 <0.0059 0.018 -

BS-1 18 08/01/11 2,000 15 31 <2.3 <2.3 <0.93 <2.3

BS-2 18 08/01/11 2,600 17 120 <12 <12 <4.8 <12

SB-19 9-10 7/31/2007 <0.00056 <0.00056 <0.00074 <0.00093 <0.00093 <0.00056 -

SB-19 19-20 7/31/2007 0.0037 J 0.0013 J <0.00082 <0.0010 <0.0010 <0.00062 -

SB-20 8-9 7/31/2007 <0.00054 <0.00054 <0.00071 <0.00089 <0.00089 <0.00054 -

SB-20 17-18 7/31/2007 <0.00058 <0.00058 <0.00078 <0.00097 <0.00097 <0.00058 -

SB-21 8-9 7/31/2007 0.00076 J 0.0036 J 0.1 0.0032 J <0.00092 0.0075 -

SB-21 18-19 7/31/2007 0.078 0.058 0.46 0.01 <0.00092 0.087 -

SB-22 10-11 7/31/2007 <0.00057 <0.00057 <0.00076 <0.00094 <0.00094 <0.00057 -

SB-22 19-20 7/31/2007 <0.00049 <0.00049 <0.00066 <0.00082 <0.00082 <0.00049 -

SB-23 12-13 7/31/2007 0.011 0.0065 0.027 <0.00092 <0.00092 0.0043 -

SB-23 17-18 7/31/2007 0.006 0.0043 J 0.017 <0.00094 <0.00094 0.0021 J -

SB-24 19-20 2/12/2010 21 3.6 5 <0.024 <0.024 0.55 0.034

SB-25 19-20 2/12/2010 0.0026 <0.00045 0.0058 <0.00045 <0.00045 <0.00045 <0.00045

SB-26 19-20 2/12/2010 <0.00054 <0.00045 <0.00045 <0.00045 <0.00045 <0.00045 <0.00045

SB-27 19-20 2/15/2010 <0.00061 <0.00051 <0.00051 <0.00051 <0.00051 <0.00051 <0.00051

SB-28 19-20 2/15/2010 <0.00051 <0.00043 <0.00043 <0.00043 <0.00043 <0.00043 <0.00043

SB-29 19-20 2/15/2010 <0.00053 <0.00044 <0.00044 <0.00044 <0.00044 <0.00044 <0.00044

SB-30 19-20 2/15/2010 0.059 0.0220 0.037 <0.00041 <0.00041 0.0013 <0.00041

SB-31 19-20 2/15/2010 3.2 0.83 1.5 0.0045 0.0028 0.037 <0.00045

SB-32 19-20 2/15/2010 <0.00052 <0.00043 0.00059 <0.00043 <0.00043 <0.00043 <0.00043

Saturated Soil Samples

Page 2 of 3




Sample

Location

Depth

(ft bgs)

Date

Sampled

PCE

(mg/kg)

TCE

(mg/kg)

Cis-1,2-

DCE

(mg/kg)

Trans-1,2-

DCE

(mg/kg)

1,1-DCE

(mg/kg)

VC

(mg/Kg)

Benzene

(mg/kg)





MW-23 IDW 0-39 8/13/2009 2.18 0.549 <0.00107 <0.00107 <0.00107 0.00631 -

MW-24 IDW 0-39 8/18/2009 97 0.24 0.26 0.00133 0.00211 <0.00103 -

VE-1 IDW 0-20 8/18/2009 70.3 1.02 3.13 <0.0610 <0.0610 <0.0610 -

VE-2 IDW 0-20 8/18/2009 44.7 0.401 2.06 0.039 0.00499 <0.00109 -

VE-3 IDW 0-20 8/19/2009 731 7.63 6.91 0.0873 0.17 <0.00611 -

VE-4 IDW 0-20 8/19/2009 1,900 21.6 25 0.445 0.196 <0.0604 -

TCA-1Surface

Composite 8/4/2011 6.3 0.0085 0.0037 J <0.004 <0.004 <0.0016 <0.004

TCA-2Surface

Composite 8/8/2011 17 0.0046 <0.0046 <0.0046 <0.0046 <0.0018 <0.0046

TCB-1Surface

Composite 8/1/2011 150 0.71 3.2 <0.27 <0.27 <0.11 <0.27

TCB-2Surface

Composite 8/4/2011 210 0.76 5.1 <0.24 <0.24 <0.095 <0.24

WD-1Surface

Composite 8/8/2011 0.0069 <0.0059 <0.0059 <0.0059 <0.0059 <0.0024 <0.0059

WD-1 (Dup)Surface

Composite 8/8/2011 0.0079 <0.0059 <0.0059 <0.0059 <0.0059 <0.0024 <0.0059

WD-1

(Leachate)

Surface

Composite8/8/2011 <0.034 <0.022 NR NR <0.026 <0.020 <0.020

WD-1 (Dup)

(Leachate)

Surface

Composite8/8/2011 <0.034 <0.022 NR NR <0.026 <0.020 <0.020

Notes: <-

J-

NR Not reported.

TCLP Toxicity characteristic leaching procedure.

BOLD Exceeds C/I Tier 1 TotSoilComb for 0.5-acre source.

BOLD Exceeds C/I Tier 1 GWSoilIng for 0.5-acre source.

BOLD Exceeds C/I Tier 1 AirSoilInh-V for 0.5-acre source.

BOLD Exceeds C/I Tier 1 AirGW-SoilInh-V for 0.5-acre source.

TCLP Analyses Reported in mg/L

The analyte was analyzed for, but the associated numerical value may not be consistent with the amount actually present in the

environmental sample or may not be consistent with the sample detection or quantitation limit. The value is an estimated quantity.

The material was analyzed for, but was not detected. The associated numerical value is the sample quantitation or detection limit,

which has been adjusted for sample weight/sample volume, extraction volume, percent solids, sample dilution or other analysis

specific parameters.

Investigation Derived Waste (IDW) Samples

Response Action Treatment Cell Samples and Waste Disposal Samples

Page 3 of 3

Appendix 4.4: Concentrations of Volatile Organic Componds in the Wastewater Generated During Response Action Dewatering Operations

Good Neighbor Cleaners (DCRP0060)


Sample

Location

Sample

Date

PCE

(mg/L)

TCE

(mg/L)

Cis-1,2-DCE

(mg/L)

Trans-1,2 DCE

(mg/L)

1,1-DCE

(mg/L)

VC

(mg/L)

Benzene

(mg/L)

Toluene

(mg/L)

Ethyelbenzene

(mg/L)

Xylene (total)

(mg/L)

MTBE

(mg/L)

TPH (mg/L)

(nC6-nC12)

TPH (mg/L)

(>nC12-nC28)

TPH (mg/L)

(>nC28-nC35)

TPH (mg/L)

(C6-C35)

0.005 0.005 0.07 0.1 0.007 0.002 0.005 1 0.7 10 0.244

1 1 1 1 30 30 30 30

WWB-1 08/01/11 0.74 0.31 1 <0.001 0.00059 J 0.01 0.0016 0.014 0.0041 - 0.0073 - - - -

WWB-2 08/03/11 2.7 0.43 1.8 0.0082 J <0.01 0.015 <0.01 0.0076 J 0.0018 J - 0.01 - - - -

WWB-3 08/04/11 3.3 0.51 2.1 0.01 <0.01 0.018 <0.01 0.0044 J <0.01 - 0.012 - - - -

WWB-4 08/08/11 3.1 0.48 2.1 0.0099 <0.005 0.017 <0.005 0.0028 J 0.00071 J - 0.012 - - - -

WWA-1 08/01/11 <0.005 <0.005 - <0.005 <0.005 <0.002 <0.005 <0.005 <0.005 <0.01 - <0.49 <0.49 <0.49 <0.49

WWA-2 08/08/11 <0.005 <0.005 - <0.005 <0.005 <0.002 <0.005 <0.005 <0.005 <0.01 - - - - -

Notes: <-

J -

BOLD - Exceeds GWGWIng PCL.

BOLD - Exceeds Sewer Discharge Limit.

- The material was analyzed for, but was not detected. The associated numerical value is the sample quantitation or detection limit, which has been adjusted for sample weight/sample volume, extraction volume, percent solids, sample dilution or other analysis

specific parameters.

The analyte was analyzed for, but the associated numerical value may not be consistent with the amount actually present in the environmental sample or may not be consistent with the sample detection or quantitation limit. The value is an estimated quantity.

GWGWing PCL

Wastewater Samples from Response Action Dewatering - Samples Collected After Discharge and Storage in 20,000 Frac Tank and Before Treatment

Wastewater Samples from Response Action Dewatering - Samples Collected After Treatment by Air Stripping and Carbon Treatment and Before Discharge to Sanitary Sewer

Sewer Discharge Limits

Page 1 of 1

Appendix 4.5: Concentrations of Volatile Organic Componds in the Air Samples Collected on the West Property Boundary During Soil Handling Operations

Good Neighbor Cleaners (DCRP0060)


Sample

Location

Sample

Date

PCE

(ppmV)

TCE

(ppmV)

Cis-1,2-DCE

(ppmV)

Trans-1,2 DCE

(ppmV)

1,1-DCE

(ppmV)

VC

(ppmV)

Benzene

(ppmV)

Toluene

(ppmV)

Ethyelbenzene

(ppmV)

Xylene (total)

(ppmV)

MTBE

(ppmV)

100 100 200 200 200 1 1 200 100 100 -

AWB-1 08/01/11 0.02 0.0014 0.0041 <0.0005 <0.0005 0.00044 J 0.0017 0.16 0.004 0.009 <0.0005

AWB-2 08/02/11 0.002 <0.0005 0.00026 J <0.0005 <0.0005 <0.0005 0.0002 J 0.00056 <0.0005 0.00031 J <0.0005

AWB-3 08/04/11 0.0012 <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 0.00018 J 0.00055 <0.0005 0.00031 J <0.0005

AWB-4 08/08/11 0.00025 J <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 0.00031 J 0.00088 <0.0005 0.00035 J <0.0005

Notes: <

J -

NIOSH TWA - National Institute for Occupational Safety and Health (NIOSH) recommended exposure limit for time-weighted average (TWA) concentrations for up to a 10-hour work-day during a 40-hour

workweek.

Air Samples were Collected in Summa Canisters as 8-Hour Time-Weighted Average Samples

- The material was analyzed for, but was not detected. The associated numerical value is the sample quantitation or detection limit, which has been adjusted for sample weight/sample

volume, extraction volume, percent solids, sample dilution or other analysis specific parameters.

The analyte was analyzed for, but the associated numerical value may not be consistent with the amount actually present in the environmental sample or may not be consistent with the

sample detection or quantitation limit. The value is an estimated quantity.

NIOSH TWA

Page 1 of 1

Laboratory Data Packages RACR Appendix 6


Waste Disposition RACR Appendix 8


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