UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6

1445 ROSS AVENUE, SUITE 1200DALLAS, TX 75202-2733

Installation Restoration Program Manager August 24, 2006Mr. Roderick W. Sewell Lone Star Army Ammunition Plant ATTN: SJMLS-IM Texarkana. TX 75505-9101

Re: Lone Star Army Ammunition Plant (EPA ID#TX721382183l) Five-Year Review for Unit 17-Old Demolition Area

Dear Mr. Sewell,

This letter documents the U.S. Environmental Protection Agency’s (EPA’s) concurrencein the protectiveness determinations in the Lone Star Army Ammunition Plant (Lone Star AAP)Five-Year Review Report for the Unit l7-Old Demolition Area National Priorities List (NPL)Site. This is the first five-year review for the site, which was triggered due to the implementationof the remedial action at the site.

This review is required by Section 121 {c} of the Comprehensive EnvironmentalResponse, Compensation and Liability Act of 1980, as amended (CERCLA). 42 U.S.C. § 9621{c}. and by Section 300.430 (f) (4) (ii) of the National Oil and Hazardous SubstanceContingency Plan (NCP), which require that a periodic review be conducted no less often thanevery five years after the initiation of remedial action at sites where hazardous substances,pollutants, or contaminants will remain onsite above levels that allow for unlimited use andunrestricted exposure. The U.S. Army, as lead agency for Lone Star Army Ammunition Plant,conducted this review.

According to EPA’s Comprehensive Five-Year Review Guidance (OSWER No.9355.7-03 B-P, June 200l), EPA’s role as the final remedy selection authority at an NPL siteunder the jurisdiction of another Federal agency or department requires that EPA retain finalauthority to make protectiveness determinations in connection with the site. Accordingly, EPARegions are to review Federal facility NPL Five-Year Review reports and protectivenessdeterminations for consistency with EPA’s Comprehensive Five-Year Review Guidance and theadequacy of the supporting basis, and should participate or comment throughout the five-yearprocess, as appropriate the EPA will either concur with any protectiveness determinations toensure protectiveness of human health and the environment or EPA may provide independentfindings. In this case, the US Army provided EPA with a draft of the Five-Year Review Reportfor Unit 17 – Old Demolition Area NPL Site at Lone Star Army Ammunition Plant, and EPAresponded with comments. These comments addressed the need to convey a clear and completedescription of the remedial action components. This description provides the informationrequired in order to determine whether the selected remedy is functioning as intended. Suchdescription also provides the necessary details to determine if the remedy is protective of humanhealth and the environment.

Internet Address (URL) • http:/www.epa.govRecycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Post-consumer)

2

In response, the US Army addressed these deficiencies and resubmitted a Final Five-YearReview Report. I have determined that the remedy selected/implemented for the Lone Star ArmyAmmunition Plant, Unit 17 – Old Demolition Area is protective of human health and theenvironment.

Approved By: Date:

DEPARTMENT OF THE ARMY k- 6 / s t) LONE STAR ARMY AMMUNITION PLANT i &&

TEXARKANA, TEXAS 75505-9101

.>nn r ~ i j i ~ i : A ~ j G - 7 Pz 2: 59

,$3;'g&/;'(,x ~ W A W C H August 4,2006

U.S. Environmental Protection Agency ATTN: Ruben Moya (6SF-AP) ,

1445 Ross Avenue, Suite 1200 Dallas, Tcxas 75202-2733

RE: h n e Star Army Ammunition Plant Old Demolition Area (ODA) Final Five-Year Review Report

Dear Mr. Moya:

Enclosed, for your revicw/concunance, arc revised pages for the Old Demolition Area Five-Year REvicw Report at Lone Star Army Amln~~nition Plant, Texarkana, 'I'exas.

I f you have any question,^, please give me a call a1 (903) 334-1328 or c-mail me at Sewell~lonesta.r~w.com. -

S incereiy,

Roderick W. Scwcll Installation Restoration Program Manager

Enclosure

CF; Maureen Hatfield Team I, Environmental Cleanup Section I1 (MC-127) Texas Commission on ~nvironmentd Quality P.O. Box 13087 Austin, TX 787 1 1-3087

DEPARTMENT OF THE AR -. ,.,, -- LONE STAR ARMY AMtwlUN*TION P l . 3 k b k. I V f W

TEXARKANA, TEXAS 7 5505-9101

Af3/i3p3/ T X BRAHCi-; May 12,2006

U.S. Environmental Protection Agency ATTN: Ruben Moya (6SF-AP) 1445 Ross Avenue, Suite 1200 Dallas, Texas 75202-2733

RE: Lone Star Army Ammunition Plant Old Demolition Arca (ODA) First Five-Year Review Report

Bear Mr. Moya:

Enclosed, for your review, is the first Fivc-Year Review Keport for thc Old Demolition Area at Lonc Star Army Ammunition Plant, Tcxarkana, Texas.

If you have any questions, plcasc give me a call at (903) 334-1328 or e-mail me at Sewel IR@lonestaraa~,com.

Roderick W. Sewell Installation Resloration Program Managcr

Enclosure

CF; Alan Etheredge Superfund Cleanup Section MC- 143 Texas Commission on Environmental Quality P.O. Box 13087 Austin, TX 7871 1-3087

Signature Page

Five-Year Review Report

Firat Five-Year Review Report for:

LSAAP- 017 (Old Demolition Area)

at Lone Star Amy Ammunition Plant

Texarkana, Texas

Approved by: .

LSAAP, Imhllation Rartoration Prwam Manager

Concuc

EPA Rogion 6, Remedial Project Manager Ruben Moya

Concur:

Date:

Date:

TCEQ Sonior Project Manager Maureen HatfSold

Table of Contents

List of Acronyms iii Executive Summary 1Five-Year Review Summary Form 2

1. Introduction 4 Purpose of the Review 4 Authority for Conducting the Review 4 Who Conducted the Review 4Other Review Characteristics 5

2. Site Chronology 5

3. Background 7 Location and History 6 Geology and Hydrology 6 History of Contamination 7 Initial Response 7 Basis for Taking Action 7

4. Remedial Actions 9 Remedy Selection 9 Remedy Implementation 9 System Operations/Operation and Maintenance (O&M) 10

5. Five-Year Review Process 10 Administrative Components 10 Community Notification and Involvement 11 Document Review 11 Data Review 11 Site Inspection 12 Interviews 13

6. Technical Assessment 13 Question A: Is the remedy functioning as intended by the decision documents? 13 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid? 14 Question C Has any other information come to light that could call into question the protectiveness of the remedy? 14 Technical Assessment Summary 14

7. Issues 14

8. Recommendations and Follow-up Actions 15

9. Protectiveness Statement(s) 17

10. Next Review 17

i

Table of Contents (Continued)

11. References 18

Figures

Figure 1 – LSAAP Old Demolition Area Site Map Appendix B Figure 2 – Old Demolition Area Construction Details Appendix B Figure 3 – Old Demolition Area Final Cover Plan Appendix B

Tables

Table 1 – Chronology of Site Events 5 Table 2 – Risk-Based Concentrations for Historically Detected Explosives at the ODA 8 Table 3 – Annual System Operations/O&M Costs 10 Table 4 – Time Series Plot of 2-am-4, 6-DNT and 4-am-2, 6-DNT 12 Table 5a – Historical Groundwater Analytical Data Summary Appendix D Table 5b – Historical Surface Water Analytical Data Summary Appendix D Table 6 – Issues 15 Table 7 – Recommendations and Follow-up Actions 17

Appendices

Appendix A - Photographs Documenting Site Conditions Appendix B - Figures Appendix C - Site Inspection Checklist Appendix D - Groundwater Data Summary Appendix E - Public Notice and Survey Appendix F - ARAR Review

ii

List of Acronyms

ARARs Applicable or Relevant and Appropriate RequirementsBRAC Base Realignment and ClosureCERCLA Comprehensive Environmental Response Compensation & Liability ActCFR Code of Federal RegulationsEPA (US) Environmental Protection AgencyFFA Federal Facility AgreementFFS Focused Feasibility Studyft FeetGO/CO Government Owned/Contractor OperatedIRP Installation Restoration ProgramLSAAP Lone Star Army Ammunition PlantMSL Mean Sea LevelNCP National Contingency PlanND Not DetectedNPL National Priorities ListODA Old Demolition AreaO&M Operations and MaintenanceRAO Remedial Action ObjectivesRI/FS Remedial Investigation/Feasibility StudyROD Record of DecisionTCEQ Texas Commission on Environmental QualityUSACE US Army Corps of EngineersUSAEC US Army Environmental Center

iii

Executive Summary

The remedy for the Old Demolition Area (ODA) site at the Lone Star Army AmmunitionPlant (LSAAP) in Texarkana, Texas included capping contaminated soils with a soil cover,institutional controls, and monitoring of groundwater and surface water. The site achievedconstruction completion with the signing of the Preliminary Close Out Report on September 24,2002. The trigger for this Five-Year Review was the actual start of construction on June 29,2001. LSAAP submitted a Final Close-out Report in 2004 to initiate the removal process of theODA from the National Priorities List (NPL).

From this Five-Year Review, recommendations for cap maintenance are to fill and repairwet depressions found on the landfill. Current compliance goals are achieved through monitoredgroundwater and surface water sampling, which will enter the annual sampling phase in 2007.Recommendations for optimization of the monitoring system are to reopen the ROD if changesin land use occur, reflect future monitoring data with the actual laboratory reporting limit,re-examine the compliance criteria, and abandon six monitoring welts no longer used to meetcompliance goals.

The assessment of this Five-Year Review found that the remedy was constructed in accordancewith the requirements of the Record of Decision (ROD). The remedy is performing as designedand is protective of human health and the environment.

Page 1

Five-Year Review Report

1. Introduction

1.1 The Purpose of the Review

The purpose of Five-Year Reviews is to determine whether the remedy at a site isprotective of human health and the environment. The methods, findings, and conclusions ofreviews are documented in Five-Year Review reports. In addition, Five-Year Review reportsidentify issues found during the review, if any, and recommendations to address them.

1.2 Authority for Conducting the Five-Year Review

The US Army Corps of Engineers (USACE) is preparing this Five-Year Review reportpursuant to Comprehensive Environmental Response Compensation and Liability Act(CERCLA) §121 and the National Contingency Plan (NCP). CERCLA §121 states:

If the President selects a remedial action that results in any hazardous substances,pollutants, or contaminants remaining at the site, the President shall review suchremedial action no less often than each five years after the initiation of such remedialaction to assure that human health and the environment are being protected by theremedial action being implemented. In addition, if upon such review it is the judgment ofthe President that action is appropriate at such site in accordance with section [104] or[106], the President shall take or require such action. The President shall report to theCongress a list of facilities for which such review is required, the results of all suchreviews, and any actions taken as a result of such reviews.

The USACE interpreted this requirement further in the NCP; 40 Code of Federal Regulations(CFR) g300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, orcontaminants remaining at the site above levels that allow for unlimited use andunrestricted exposure, the lead agency shall review such action no less often than everyfive years after the initiation of the selected remedial action.

1.3 Who Conducted the Five-Year Review

On behalf of Lone Star Army Ammunition Plant, the Fort Worth, Omaha, and TulsaDistricts of the USACE have conducted a Five-Year Review of the remedial actionsimplemented at the ODA site located at LSAAP. This report documents the results of the review.

1.4 Other Review Characteristics

This is the first Five-Year Review for the ODA site. The triggering action for this reviewis the initiation of the remedial action on the date of June 29, 2001. The Five-Year Review is astatutory review and is required due to the fact that hazardous substances, pollutants, orcontaminants remain on site above levels that would allow unrestricted use.

Page 4

2. Site Chronology

Site chronologies are listed in Table 1 below.

Table 1: Chronology of Site Events

Event Date

Old Demo Area Activities – disposal of various munitions (grenades,fuse, and bombs) by detonation

1943 through 1944

Preliminary Assessment and Site Inspection April 1984

Proposed to the National Priorities List (NPL) October 1984

NPL listing July 1987

Remedial Investigation/Feasibility Study Began August 1987

Superfund State Contract, Cooperative Agreement, or Federal FacilityAgreement signature

June 1990

Remedial Investigation/Feasibility Study complete May 1998

ROD signature August 1999

Remedial design complete February 2001

Actual remedial action start June 2001

Construction dates (finish) August 2002

Construction completion date September 2002

Final Close-out Report September 2004

Placed on BRAC Closure List July 2005

First Five-Year Review March 2006

Next Five-Year Review June 2011TBD - To be determined

3. Background

3.1 Location and History

Lone Star Army Ammunition Plant is a government-owned, contractor-operated(GO/CO) installation that has performed and maintained the various functions necessary to load,assemble, and pack ammunition items for the Army. LSAAP is located in northeastern Texas,about 12 miles west of Texarkana, Texas in central Bowie County. The installation consists ofapproximately 15,669 acres of which approximately 12,300 acres are unimproved. A chain-linkor barbed-wire fence encloses the entire installation.

The ODA is located in the south-central portion of LSAAP and is entirely containedwithin the installation boundaries. See Figure 1 in Appendix B for the site location. The ODA

Page 5

consists of 17.4 acres, which are fenced and posted, and was used by the Army to detonateexplosives during World War II.

3.2 Geology and Hydrology

The ODA is predominantly bare ground and grassland with woody vegetation occurringprimarily around the perimeter. A majority of the ODA is located on a broad hillside that slopesto the south-southeast at an average slope of 3 percent. Elevations range from 334 feet (ft) abovemean sea level (MSL) along the west-central side of the ODA to 312 ft above MSL at theeast-central side. No buildings are located in the vicinity of the ODA.

The ODA is underlain by the Eocene-aged Wilcox Group and the Paleocene-agedMidway Group. Deposited in a fluvial and deltaic system, the Wilcox Group varies in thicknessand is thinnest (10 ft or less) in the northern and eastern portions of the ODA. The MidwayGroup was deposited in a shallow marine environment; and at the ODA, is relativelyimpermeable clay that forms a barrier to groundwater flow. The saturated thickness of theWilcox Group in the vicinity of the ODA is highly variable, thus the groundwater surface moreclosely reflects features of the Midway surface than it does features of the topographical surface,thereby deflecting groundwater flow by limiting the volume of groundwater that could flow ontoor off of the ODA.

Groundwater flow is directed primarily towards the southeast, south-southeast, and eastacross the ODA. Groundwater flow south of the south drainage feature is variable, at timesdirected to the north and at times to the south. Groundwater flow patterns suggest that very littleupgradient groundwater flows onto the ODA. Thus, most of the groundwater beneath the ODAlikely originates as surface water infiltration at the surface of the ODA, not as “upgradient” flowfrom the northeast. Groundwater discharges to surface water within the ODA at a seep arealocated between the ODA and the south drainage feature as evidenced by the potentiometricsurface elevation of the groundwater being higher than the ground surface elevation at thislocation.

3.3 History of Contamination

The ODA was established in 1943 and was used briefly for open detonation ofoff-specification munitions (grenades, fuses, and bombs) until it closed in 1944. No activityoccurred at the ODA from 1944 to 1986. In 1986 the ODA was cleared of vegetation by theArmy to expose, collect, and destroy explosive debris. The predominant ordnance debris at theODA was found to be 20-mm projectile fragments. Ordnance debris was found to be present inall locations of the ODA with two exceptions, observations of sparse ordnance debris was foundin the north and northeast areas.

3.4 Initial Response

A Phase I remedial investigation/feasibility study (RI/FS) was conducted in 1987 thatincluded several sites on the installation. In 1990 a Phase II RI/FS began that only focused on theODA. During the Phase II RI/FS, it was determined that additional monitoring wells wererequired to characterize the groundwater. In 1991, a Phase III RI/FS determined that drymonitoring wells in the network were to be abandoned and the ODA should be capped. ln 1994during the Phase IV investigation, five monitoring wells were installed, 38 groundwater, 69 soil,and four surface water samples were collected and analyzed for total metals and explosives.

Page 6

Tetryl and 2,4,6-trinitrotoluene were the only explosives detected in the source material.

3.5 Basis for Taking Action

A focused feasibility study (FFS) was completed in May 1998 that addressed the ODA asa military landfill and described the presumptive remedy for the ODA. In June 1990, the (US)Environmental Protection Agency (EPA), Region 6, the Texas Water Commission, now calledthe Texas Commission on Environmental Quality (TCEQ), and the Army entered into aCERCLA Section 120 Agreement, referred to as the Federal Facility Agreement (FFA). TheFFA established the documentation required for the development and implementation of theremediation for all releases of hazardous constituents from the ODA and a mutually agreed uponschedule.

The appropriateness of the selected containment remedy was based on the followingfactors: 1) the Army having continued control of LSAAP, and therefore, limited public access, 2)land use at LSAAP remaining commercial/industrial, and 3) the land remaining in control of theArmy until LSAAP is closed completely as decreed by the Army Headquarters. EPA, TCEQ,and the Army agreed that should any of the listed land uses change, the ROD would bere-opened and the ODA risk assessment would be re-evaluated for appropriate receptors. LSAAPwas added to the Base Realignment and Closure (BRAC) list in 2005, and while no change inland use is currently anticipated; it is recommended that the ROD be reopened if changes occur.

It was determined in the ROD that since the selected remedy eliminates potentialcarcinogenic risks from soil; the remaining risk from the groundwater was within the EPA’sacceptable risk management range. Therefore, it was determined that groundwater and surfacewater would be monitored for explosives to ensure protection of human health, welfare, or theenvironment. Table 2 reflects the maximum concentrations of explosives historically detected atthe ODA and the conservative carcinogenic risk-based criteria for human health and aquatic life.

Table 2: Risk-Based Concentrations for Historically Detected Explosives at the Old Demolition Area

Explosive

MaximumConcentration

Detected(µg/L)

1in 1,000Risk-Based

Concentrationfor Human

Health* (µg/L)

1in 1,000,000Risk-Based

Concentrationfor Human

Health* (µg/L)

Risk-BasedConcentration

for AquaticLife** (µg/L)

1,3,5-Trinitrobenzene 0.25 SFNA SFNA ACNA

1,3-Dinitrobenzene 0.21 SFNA SFNA 354

2,4-Dinitrotoluene 2.78 658 0.7 ACNA

2,4,6-Trinitrotoluene 9.27 14,900 15 404

2-Amino-4,6-dinitrotoluene 3.72 SFNA SFNA 3740

4-Amino-2,6-dinitrotoluene

1.65 SFNA SFNA ACNA

HMX 2.74 SFNA SFNA 3790

Nitroglycerine 108 213 0.2 345

Nitrobenzene 0.81 SFNA SFNA ACNAPage 7

Explosive

MaximumConcentration

Detected(µg/L)

1in 1,000Risk-Based

Concentrationfor Human

Health* (µg/L)

1in 1,000,000Risk-Based

Concentrationfor Human

Health* (µg/L)

Risk-BasedConcentration

for AquaticLife** (µg/L)

Pentaerythritol tetranitrate 1323 SFNA SFNA 2,147,890

RDX 4.47 4,065 4.1 910

Tetryl 8.22 SFNA SFNA ACNAACNA - Aquatic Risk-Based Concentration Not Available; SFNA - Oral Slope Factor Not Available, µg/L - micrograms per liter * Risk-based concentrations for human health assume an industrial worker drinks 1 liter of water a day, 200 days a year for 20 years.** Risk-based concentrations for aquatic life were provided by the TCEQ.

4. Remedial Actions

4.1 Remedy Selection

The selected remedial action authorized by the ROD included the following components:a) clearing surficially exposed source material, b) re-grading, leveling, and placing a soil coverover the ODA, c) constructing erosion berms along the northern and eastern ODA perimeters andwithin the fenced area, d) re-vegetating the soil cover and berms, e) construction of a barrierfence and placement of warning signs, f) institutional controls including the utilization of deedrecordation and permitting procedures to restrict the use of the land and the groundwater in theODA area, and g) conduct groundwater monitoring.

Compliance goals were established by the ROD to evaluate the effectiveness of the soilcover in conjunction with erosion control berms at the ODA that minimize infiltration ofprecipitation and resulting leaching of source material chemicals to groundwater. Thesecompliance goals are separate and distinct from the NCP requirement that a five-year review beconducted to evaluate whether the response action remains protective of public health, welfare,or the environment. To evaluate the effectiveness of the soil cover, compliance goals, based onhuman health and aquatic-life criteria, for evaluating the surface water and groundwater will becompared to the monitoring data.

The human health based criteria are: if groundwater and/or surface water explosives aredetected at or below the maximum concentration detected historically for that explosive, theArmy will monitor quarterly for three years and annually for an additional 2 years. Thecompliance goals based on aquatic life risk-based criteria are: if the surface water explosives aredetected above the maximum concentration detected historically for the explosive, the Army willconduct quarterly monitoring for that explosive until the concentration returns to historicalmaximum concentration or until the concentration of explosives exceeds the risk-basedconcentration for aquatic life.

4.2 Remedy Implementation

Engineering controls consisted of re-grading and leveling the ODA so that a 24-inch soilcover cou1d be placed on the surface. The cover was constructed by LandTec Engineers from

Page 8

Arlington, TX (see Figure 2 in Appendix B, for the construction details). The intermediate soilcover was constructed of 18-inches of compacted clayey soil with a slope of 1.5% to 10%. Thefinal 6-inches were a vegetative cover soil that is capable of sustaining native growth (see Figure3 in Appendix B for the final cover plan). Warning signage was posted along a single cable fenceto mark the ODA boundaries within the installation. Institutional controls included restrictingfuture land use of the ODA by filing a deed recordation with the local county, controlling thegroundwater well permits to prevent future ingestion of groundwater, and installing erosioncontrol berms to control soil erosion within the fenced area.

4.3 System Operations/O&M

To assess the effectiveness of the selected remedy operations and maintenance (O&M)controls were established. These include: conducting periodic inspections of the soil cover,berms, and cable fencing that marks the ODA boundaries, performing preventative maintenanceand repairs, semi-annual mowing, and performing quarterly groundwater and surface watermonitoring for three years, then annually for an additional two years. Annual O&M costs wereestimated in the ROD to be approximately $99,300; Table 3 reflects the actual O&M annualcosts for the ODA (refer to the Site Inspection Checklist found in Appendix C for a breakdownof the O&M costs).

Table 3: Annual System Operations/O&M Costs

Dates Total Cost

From To

July 2003 September 2004 $93,843

September 2004 September 2005 $93,804

September 2005 September 2006 $47,347

5. Five-Year Review Process

5.1 Administrative Components of the Five-Year Review Process

Members of the Army, USACE, EPA, and TCEQ were notified of the initiation of thefive-year review process in January 2006. The ODA Five-Year Review team was led by FrankRoepke of Tulsa District USACE and Roxanne Welch of Fort Worth District USACE. Membersfrom the Omaha District USACE, LSAAP, EPA, TCEQ, US Army Environmental Center(USAEC), and the US Army BRAC office also assisted in the review.

The review team established a review schedule whose components included:

Community Involvement; Document Review; Data Review; Site Inspection; Local Interviews; and Five-Year Review Report Development and Review.

Page 9

5.2 Community Notification and Involvement

Activities to involve the community in the five-year review were initiated with a noticesent to the local Texarkana Gazette newspaper that a five-year review was to be conducted onFebruary 16, 2006 and a survey concerning the ODA was made available to the public at theTexarkana Public Library. The notice and survey invited the public to submit any comments toLSAAP. None of the survey forms were completed by the community. Since the ODA site iscompletely contained within the boundaries of the installation, the community has expressed nocurrent interest.

5.3 Document Review

This five-year review consisted of a review of relevant documents including pastinvestigations and groundwater monitoring data. A list of documents that were reviewed can befound in Section 11.0.

5.4 Data Review

Groundwater and surface water monitoring has been conducted at the ODA site sinceNovember 2002. The fourth quarter of monitoring for the third year of sampling took place inMarch 2006, this event completed the required three years of quarterly monitoring; the first yearof annual sampling will begin in 2007. TCEQ requested that perchlorate be analyzed installationwide around the 2002 timeframe. It was determined that if perchlorate was not detected above4.0 µg/L during the initial sampling; then the analyte would be discontinued. During the initialNovember 2002 sampling event, only one sample was reported at 2.7 µg/L.

In general, most contaminants were detected at their highest levels during the firstsampling event. This initial high level followed by decreasing contaminant levels in subsequentsampling events may well have been the result of removal activities eliminating significantsource material during the soil cover placement.

The evaluation of the groundwater and surface water processes at the site was achievedby evaluating the monitoring data against the risk-based criteria goals listed in Table 2. Sinceconstruction completion in 2002, 8 of the 9 contaminants remained below their respectivehistorical levels in all sampling events. The exception is 4-amino-2, 6-dinitrotoluene, whichexceeded the criteria goal in monitoring well ODA-5 during the initial November 2002 samplingevent. Subsequent sampling events find this compound and 2-amino-4, 6-dinitrotoluene to beholding consistent and below their respective maximum historical concentration levels (shown inTable 4). Quarterly analysis of surface water samples taken in seep areas adjacent to the ODAfound that all levels of contaminants of concern were below detection. Recent and historicalmonitoring results for the contaminants are shown in Table 5, located in appendix D.

The monitoring record (shown in Table 5) indicates that the groundwater and surfacewater process conceptualized in the ROD are proceeding essentially as expected. The soil coversystem continues to protect the public by preventing undesirable and unplanned exposures in thepresent and future.

Page 10

5.5 Site Inspection

On February 15, 2006, the following list of attendees inspected the ODA:

• Mr. Frank Roepke (frank.roepke@swt03.usace.army.mil) from Tulsa District USACE • Ms. Roxanne Welch (janet.r.welch@swf02.usace.army.mil) from Fort Worth District

USACE, • Mr. Roderick Sewell from LSAAP (Roderick.sewell@us.army.mil) from LSAAP, • Mr. Greg Lyssy (Lyssy.gregory@ega.gov) from EPA, Region 6, • Mr. Tom Erny (terny@tceg.state.tx.us) from TCEQ, Region 5, • Ms. Stephanie Sigler (Steghanie.i.sigler@us.army.mil) from USAEC, and • Mr. Richard Lafreniere (Richard.lafreniere@hqda.army.mil) from US Army BRAC

The purpose of the inspection was to assess the protectiveness of the remedy and verifycurrent site controls and usage. The inspection revealed no significant issues regarding the soilcover, the drainage structures, or the fence. Examination of the cover revealed some wetdepressions located in the center of the landfill and near the east side of the landfill (see SitePhotographs in Attachment A). One burrow-hole, made by a small animal, was found on thelandfill; however there were no indications that this would develop into a problem. A formerinlet from an irrigation water line is located on the west side of the landfill and the borrow pitlocated on the north side did not compromise the integrity of the landfill.

Page 11

The institutional controls that are in place include prohibitions on the use or disturbanceof groundwater, excavation activities, disturbance of the cover, and any other activities oractions that might interfere with the implemented remedy. No activities were observed thatwould have violated the institutional controls. The cover and the surrounding area wereundisturbed, and no new uses of groundwater were observed. Other than the observations notedabove, the site appears to have been operated in accordance with the recommendations addressedby the ROD.

5.6 Interviews

Interviews were conducted with Army personnel that were familiar with the site. Mr.Roderick Sewell, Installation Restoration Program (IRP) Manager, was interviewed and escortedthe review team representatives during the on-site inspection. No significant problems regardingthe site were identified during the interview. Mr. Mark Norman, Project Manager withGeo-Marine, Inc., was interviewed by phone concerning the rnonitoring of the groundwater andsurface water at the ODA. The company has observed that a couple of the wells do go dry;however, all wells are in good working condition. No significant problems regarding themonitoring were identified during the interview.

6. Technical Assessment

6.1 Question A: Is the remedy functioning as intended by the decisiondocuments?

A review of current documents, Applicable or Relevant and Appropriate Requirements(ARARs), risk assumptions, and the results of the site inspection indicate that the remedy isfunctioning as intended by the ROD. This indication is further supported from the findingsduring the site inspection. Erosion control berms are functioning correctly. Both the berms andthe soil cover are vegetated well. The barrier fence and warning signs were found to be in goodcondition. Additionally, the deed recordation has prevented exposure to, or ingestion of, thegroundwater.

The groundwater monitoring data also supports that the remedy is functioning asintended; no contaminants have been detected above the compliance levels stated in the ROD,with one exception. That exception was a single detection of 4-amino-2,6-dinitrotoluene detectedin monitoring well ODA-5 in November, 2002. Since then, no detections have exceeded thecompliance levels.

6.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels, andremedial action objectives (RAOs) used at the time of remedy selection stillvalid?

There have been no changes in the physical conditions of the site that would affect theprotectiveness of the remedy. There also have been no changes to the receptors, pathways ofexposure, or toxicity values. The RAOs are still appropriate for the site and there is no change tothem that would affect the protectiveness of the remedy. In addition, there have been no changesto the risk assessment methodologies that could affect the protectiveness of the selected remediesfor the site.

Page 12

6.3 Question C: Has any other information come to light that could call intoquestion the protectiveness of the remedy?

No other information that would affect the protectiveness of the remedy was noted.Deficiencies noted during the site inspection have been summarized below in Section 7 and willbe addressed to ensure that the remedy is protective of human health and the environment.Recommendations and follow-up actions for issues noted are summarized below in Section 8.

6.4 Technical Assessment Summary

According to the data reviewed and the site inspection, the selected remedy appears to befunctioning as intended. ln general, there appear to have been no significant changes in thephysical conditions of the site that would adversely affect the protectiveness of the selectedremedy. There have been no change to the risk assessment methodology that could affect theprotectiveness of the selected remedy. There is no other information that calls into question theprotectiveness of the selected remedy.

7. Issues

After evaluating the site, the following issues for optimization include:

1) Several wet depressions were noted during the site visit (see photos in AppendixA).

2) LSAAP was placed on the 2005 BRAC list.

3) Groundwater monitoring reports reflect “ND” or “Not Detected” instead of theactual laboratory reporting limits for each chemical of concern.

4) Perchlorate was not detected above the 4.0 µg/L during the initial sampling event;however it is still reported as “ND” in the groundwater monitoring reports.

5) Currently the ROD does not clearly address termination of groundwatermonitoring when the compliance criteria have been achieved.

6) Six monitoring wells no longer contribute to the achievement of compliancegoals.

These issues uncovered during the review process concerning the protectiveness of the remedyare summarized in the table below.

Page 13

Table 6: IssuesNo. Issues Affects Current

Protectiveness(Y/N)

Affects FutureProtectiveness

(Y/N)

1 Several wet depressions were noted at the ODA duringthe site visit

N Y

2 LSAAP was placed on the 2005 BRAC list N Y

3 Groundwater monitoring reports reflect the laboratorydata as “ND”

N N

4 Perchlorate still reported in the groundwater monitoringreports as “ND”

N N

5 Re-examine compliance criteria N N

6 Six wells that no longer contribute to the achievement ofcompliance goals

N N

8. Recommendations and Follow-up Actions

The following recommendations for optimization are:

1) Recommend to fill and repair the wet depressions.

2) Recommend reopening the ROD if changes in the land use occur.

3) Recommend that future laboratory data reports and groundwater monitoringreports reflect the actual laboratory reporting limits for each chemical of concernand not “ND” or “Not Detected”.

4) Since perchlorate was not detected above the 4.0 µg/L during the initial samplingevent, recommend that future groundwater monitoring reports do not shown theanalyte as “ND”, but rather “NA” for “Not Analyzed”.

5) Recommend, when the ROD is reopened, to re-examine the compliance criteria.Currently the ROD does not clearly address termination of groundwatermonitoring when the compliance criteria have been achieved. As it is stated now,“the Army will monitor quarterly for three years and annually for an additionaltwo years” implies that the monitoring will cease when these dates have been met.

6) Recommend removing wells from the ODA that no longer contribute to theachievement of compliance goals. The following six wells have not been sampledsince the RI Phases were conducted in the 1990’s and are recommended forabandonment: ODA-16, ODA-19, ODA-22, ODA-23, ODA-26 and ODA-30.Further justifications for well abandonment include:

• ODA-16 is located topographically on the south side of the drainage.Wells ODA-5 and ODA-6 are closer to the source and are better points forcompliance monitoring.

Page 14

• ODA-19 had an average hydraulic conductivity of 1.05 ft per day, duringthe RI Phases in the 1990’s. No explosives were detected historically inthis well.

• ODA-22 was recommended to be abandoned before the soil coverconstruction, due to it’s proximity to the construction area. However, dueto funding constraints, was not abandoned.

• ODA-23 is located topographically on the south side of the drainage.Wells ODA-5 and ODA-6 are closer to the source and are better points forcompliance monitoring.

• ODA-26 was completed as a piezometer.

• ODA-30 was replaced by ODA-12 which is closer to the site and in thesame water-bearing unit as ODA-30.

Recommendations and follow-up actions to the issues presented in Section 7 are alsosummarized presented in the table below.

Table 7: Recommendations and Follow-up ActionsIssue Recommendations and Follow-up

ActionsParty

ResponsibleOversight

AgencyMilestone

DateAffects

Protectiveness(Y/N)

1 Fill and repair depressions LSAAP TCEQ 2006 N Y

2 Reopen ROD if changes in land useoccur

LSAAP TCEQ 2011 N Y

3 Groundwater monitoring reports reflectthe laboratory data as actual reportinglimits.

Geo-Marine,Inc.

TCEQ 2006 N N

4 Report perchlorate as “NA” in thegroundwater monitoring reports

Geo-Marine,Inc.

TCEQ 2005 N N

5 Re-examine compliance criteria LSAAP TCEQ 2011 N N

6 Remove and abandon wells that nolonger contribute to the achievementof compliance goals

LSAAP TCEQ 2006 N N

9. Protectiveness Statement(s)

The remedy at the LSAAP ODA is protective of human health and the environment, andin the interim, exposure pathways that could result in unacceptable risks are being controlled.

Because the remedial actions at the ODA are protective, the site is protective of humanhealth and the environment.

10. Next Review

The next Five-Year Review should be completed by June 30, 2011.

Page 15

11. References

1. Record of Decision. Old Demolition Area at Lone Star Army Ammunition PlantTexarkana, Texas. July 7, 1999.

2. Soil Cover and Erosion Control Old Demolition Area Lone Star Army Ammunition PlantBowie County, Texas. Day 8 Zimmerman, March 2001.

3. Final Cover Evaluation Report Old Demolition Area Lone Star Army Ammunition PlantTexarkana (Bowie County), Texas. Day & Zimmerman, August 2002.

4. Final Old Demolition Area Recommendations for Selecting Existing Wells and SitingNew Compliance Monitoring Wells at the Old Demolition Area. AGEISS Environmental,Inc., April 20, 2001.

5. Final Quarter One through Quarter Three Monitoring Report, ODA, AGEISSEnvironmental, Inc., August 2003.

6. Draft Final 4th Quarter Monitoring Report, ODA LSAAP, Geo-Marine, Inc., October2003.

7. Draft Final 1st Quarter Monitoring Report, ODA, LSAAP, Geo-Marine, Inc. December2003.

8. Draft Final 2nd Quarter Monitoring Report, ODA, LSAAP, Geo-Marine, Inc., March2004.

9. Federal Facility Agreement, Old Demolition Area at Lone Star Army Ammunition Plant,Texarkana, TX, June 1990.

Page 16

Appendix A

Photographs Documenting Site Conditions

Appendix B

Figures

Appendix C

Site Inspection Checklist

Five-Year Review Site Inspection Checklist

Page 16

I. SITE INFORMATION

Site name: Old Demolition Area

Location and Region: Lone Star AAP

Agency, office, or company leading the five-year review: USACE

Date of inspection: 2/15/2006

EPA ID: TX721382183 1

Weatherltemperature: cloudy, 64" F

Remedy Includes: (Check all that apply) cl Landfill cover/containment r Monitored natural attenuation r, Access controls r Groundwater containment cl Institutional controls (deed record) r Vertical barrier walls r Groundwater pump and treatment r Surface water collection r Other:

Attachments: r Inspection team roster attached r Site map attached

11. INTERVIEWS (Check all that apply)

1. O&M site manager Name Rod Sewell Title IRP Manager Date 211 5/06

Interviewed J at site cl at office r by phone Problems, suggestions: summarized in the report

2. O&M staff

Name Title Date Interviewed r at site r at office r by phone (Phone no. ) Problems, suggestions:

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

Agency TCEQ Contact Alan Etheredge

Name Title Date Phone no. Problems; suggestions: summarized in the report

(512) 239-2034

Agency EPA Contact Ruben Moya

Name Title Date Phone no. Problems; suggestions: summarized in the report

(2 14) 665-2755

Agency Contact

Name Title Date Phone no. Problems; suggestions; r Report attached

Agency Contact

Name Title Date Phone no. Problems; suggestions; r Report attached

1 4. Other interviews (ovtional) r Raort attached.

Page 17

111. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1. O&M Documents r O&M manual r Readily available Up to date T NIA r, As-built drawings r, Readily available Up to date T NIA I? O&M logs r Readily available TUp to date r NIA Remarks:

2. Site-Specific Health and Safety Plan r Readily available I' Up to date r NIA I' Contingency planlemergency response plan Readily available r Up to date r NIA Remarks

3. O&M and OSHA Training Records r Readily available r Up to date T NIA Remarks

4. Permits and Service Agreements r Air discharge pennit r Readily available r Up to date r, NIA r Effluent discharge r Readily available T Up to date r, NIA l? Waste disposal, POTW r Readily available r Up to date r, NIA I? Other permits r Readily available T Up to date r, NIA Remarks:

5. Gas Generation Records r Readily available r Up to date r, NIA Remarks:

6. Settlement Monument Records r Readily available r Up to date J NIA Remarks:

7. Groundwater Monitoring Records J Readily available r Up to date T NIA Remarkx

8. Leachate Extraction Records r Readily available r Up to date J NIA Remarks:

9. Discharge Compliance Records r Air r Readily available r Up to date r, NIA r Water (effluent) r Readily available TUptodate @N/A Remarks

10. Daily Access/Security Logs r Readily available r Up to date r, NIA Remarks:

- Page 18

IV. O&M COSTS

1. O&M Organization r State in-house r Contractor for State T PRP in-house r Contractor for PRP r Federal Facility in-house v Contractor for Federal Facility Remarks: Day & Zimmennan ( O M ) , Geo-Marine Inc. (groundwater monitoring)

2. O&M Cost Records r Readily available J Up to date r Funding mechanisdagreement in place Original O&M cost estimate I? Breakdown attached

Total annual cost by year for review period if available: [$I 5Wyear for mowinglmaintenance and $47Wyear for groundwater and surface water monitoring]

From r Breakdown attached Date Date Total cost

From I? Breakdown attached Date Date Total cost

From I? Breakdown attached Date Date Total cost

From I? Breakdown attached Date Date Total cost

From r Breakdown attached Date . - Date - ' Total cost

5. Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS v Applicable T NIA

4. Fencing

Fencing damaged r Location shown on site map 1, Gates secured T NIA

Remarks: Gate consists of a single strand removable cable

B. Other Access Restrictions

I. Signs and other security measures r Location shown on site map I? NIA

Remarks: Signs in place on all sides of the ODA

Page 19

C. Institutional Controls (ICs)

1. Implementation and enforcement Site conditions imply ICs not properly implemented TYes cl No TNIA Site conditions imply ICs not being fully enforced TYes cl No TNIA

Type of monitoring: groundwaterlsurface water monitoring Frequency: quarterly for the frrst three years, then annually Responsible partylagency: Geo-Marine, Inc.

Contact: Mark Norman, Project Manager, (5 12) 347-7588

Name Title Date Phone no.

Reporting is up-to-date cl Yes TNo TNIA Reports are verified by the lead agency cl Yes T No T NIA

Specific requirements in deed or decision documents have been met cl Yes T No T NIA Violations have been reported TYes TNo v N I A Remarks:

Deed recordation is onfile with the local county to enforce land use restrictions

2. Adequacy cl ICs are adequate T ICs are inadequate T NIA Remarks:

D. General

1. Vandalismltrespassing r Location shown on site map cl No vandalism evident Remarks

2. Land use changes on site cl NIA Remarks

3. Land use changes off sitel- NIA

Remarks: LSAAP justplaced on the 2005 BRAC list

VI. GENERAL SITE CONDITIONS

A. Roads cl Applicable T NIA

1. Roads damaged T Location shown on site map 9 Roads adequate T NIA

Remarks:

Page 20

B. Other Site Conditions

Remarks

VII. LANDFILL COVERS v Applicable I' NIA

A. Landfill Surface

1. Settlement (Low spots) r Location shown on site map r Settlement not evident Area extent Depth

Remarks: wet depressions noted

2. Cracks r Location shown on site map v Cracking not evident Lengths Widths Depths Remarks

3. Erosion r Location shown on site map cr Erosion not evident Areal extent Depth

Remarks:

4. Holes r Location shown on site map Holes not evident Area extent Depth

Remarks: One gopher hole noted

5. Vegetative Cover v Grass v Cover properly established r No signs of stress r TreesIShrubs (indicate size and locations on a diagram)

Remarks:

6. Alternative Cover (armored rock, concrete, etc.) v NIA Remarks

7. Bulges r Location shown on site map 9 Bulges not evident Area extent Height Remarks

Page 2 1

8. Wet AreasIWater Damage I' Wet areadwater damage not evident J Wet areas r Location shown on site map Areal extent r Ponding r Location shown on site map Areal extent J Seeps r Location shown on site map Areal extent

Soft sub-grade r Location shown on site map Areal extent

Remarks: Wet depressions noted. A seep ispresent which is sampled along with the monitoring wells.

9. Slope Instability r Slides r Location shown on site map J No evidence of slope instability Area extent Remarks

B. Benches r Applicable J N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench r Location shown on site map I- okay Remarks

2. Bench Breached l? Location shown on site map r okay Remarks

3. Bench Overtopped r Location shown on site map r okay Remarks

C. Letdown Channels r Applicable J N/A (Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

1. Settlement l? Location shown on site map I' No evidence of settlement Area extent Depth Remarks

2. Material Degradation r Location shown on site map r No evidence of degradation Material type Areal extent Remarks

3. Erosion r Evidence of Erosion r No evidence of erosion Area extent Depth

Remarks:

Page 22

4. Undercutting r Evidence of undercutting T No evidence of undercutting

Remarks:

5. Obstructions Type I' No obstructions r Location shown on site map Areal extent Size Remarks

6. Excessive Vegetative Growth Type r No evidence of excessive growth r Vegetation in channels does not obstruct flow r Location shown on site map Areal extent Remarks

D. Cover Penetrations r Applicable J NIA

1. Gas Vents r Activer Passive r Properly securedAocked J? Functioning r Routinely sampled r Good condition

Evidence of leakage at penetration r Needs Maintenance T NIA Remarks:

2. Gas Monitoring Probes r Properly securednockefl Functioning r Routinely sampled r Good condition I? Evidence of leakage at penetration r Needs Maintenance r NIA Remarks

3. Monitoring Wells (within surface area of landfill) r Properly securedllocked r Functioning r Routinely sampled r Good condition r Evidence of leakage at penetration r Needs Maintenance T NIA Remarks

4. Leachate Extraction Wells (dual purpose: same as gas vent wells) Properly secured/locked I' Functioning r Routinely sampled r Good condition Evidence of leakage at penetration r Needs Maintenance T NIA

Remarks

5. Settlement Monuments r Located r Routinely surveyed T NIA Remarks:

Page 23

E. Gas Collection and Treatment r Applicable J NIA

1. Gas Treatment Facilities I? Flaring r Thennal destruction r Collection for reuse r Good conditionr Needs Maintenance Remarks

2. Gas Collection Wells, Manifolds and Piping r Good conditionr Needs Maintenance Remarks

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) r Good conditionr Needs Maintenance T NIA Remarks

F. Cover Drainage Layer Applicable 9 NIA

1. Outlet Pipes Inspected r Functioning r NIA Remarks

2. (Outlet Rock Inspected I? Functioning r NIA Remarks:

G. DetentionISedimentation Ponds r Applicable 9 NIA

1. Siltation Area extent Depth r NIA I' Siltation not evident Remarks

2. Erosion Area extent Depth r Erosion not evident Remarks

3. Outlet Works I? Functioning r N/A Remarks

4. Dam r Functioning T NIA Remarks

Page 24

H. Retaining Walls r Applicable J NIA

1. Deformations r Location shown on site map r Deformation not evident Horizontal displacement Vertical displacement Rotational displacement Remarks

2. Degradation r Location shown on site map r Degradation not evident Remarks

I. Perimeter DitchesIOff-Site Discharge J Applicable NIA

1. Siltation r Location shown on site map J Siltation not evident Area extent Depth Remarks

2. Vegetative Growth r Location shown on site map r NIA J Vegetation does not impede flow Area extent Type Remarks:

3. Erosion r Location shown on site map J Erosion not evident Area extent Depth Remarks

4. Discharge Structure r Functioning J NIA Remarks

VlIL VERTICAL BARRIER WALLS r Applicable 9 NIA

1. Settlement r Location shown on site map I? Settlement not evident Area extent Depth Remarks

2. Performance Monitoring Type of monitoring r Performance not monitored Frequency Evidence of breaching Head differential Remarks

Page 25

IX. GROUNDWATERISURFACE WATER REMEDIES Applicable 9 NIA

A. Groundwater Extraction Wells, Pumps, and Pipelines r Applicable T N/A

1. Pumps, Wellhead Plumbing, and Electrical r Good conditionr All required wells properly operating r Needs Maintenance r NIA Remarks

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances l? Good conditionr Needs Maintenance Remarks

3. Spare Parts and Equipment r Readily available r Good conditionr Requires upgrade r Needs to be provided Remarks

B. Surface Water Collection Structures, Pumps, and Pipelines r Applicable T NIA

1. Collection Structures, Pumps, and Electrical r Good condition r Needs Maintenance Remarks

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances r Good condition Needs Maintenance Remarks

3. Spare Parts and Equipment r Readily available r Good conditionr Requires upgrade r Needs to be provided Remarks:

Page 26

C. Treatment System r Applicable r NIA

1. Treatment Train (Check components that apply) r Metals removal r Oiywater separation r Bioremediation r Air stripping r Carbon adsorbers r Filters r Additive (e.g., chelation agent, flocculent) r Others r Good condition r Needs Maintenance r Sampling ports properly marked and functional r Samplinglmaintenance log displayed and up to date

Equipment properly identified Remarks:

2. Electrical Enclosures and Panels (properly rated and functional) I' NIA r Good condition I' Needs Maintenance Remarks

3. Tanks, Vaults, Storage Vessels r N/A r Good condition r Proper secondary containment r Needs Maintenance Remarks

4. Discharge Structure and Appurtenances I' NIA I? Good condition r Needs Maintenance Remarks

5. Treatment Building(s) r NIA I' Good condition (esp. roof and doorways) r Needs repair r Chemicals and equipment properly stored Remarks

6. Monitoring Wells (pump and treatment remedy) r Properly secured/locked r Functioning r Routinely sampled r Good condition r All required wells located r Needs Maintenance r NIA Remarks

D. Monitoring Data 1. Monitoring Data

r Is routinely submitted on time r Is of acceptable quality

Page 27

D. Monitored Natural Attenuation

1. Monitoring Wells (natural attenuation remedy) l? Properly secured/locked Functioning r Routinely sampled r Good condition r All required wells located r Needs Maintenance T NIA Remarks

X. OTHER REMEDIES

If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction. NIA

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and fimctioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.).

Remedy (cap) is meant to prevent dermal absorption and incidental ingestion exposure to source material, control soil erosion within the fenced area, and minimize infzltration to groundwater. The remedy appears to be finctioning as designed.

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy.

O&Mprocedures seem adequate. Some depressions were noted in the cap which the installation intends to repair.

Page 28

C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the h ~ e .

D. Opportunities for Optimization

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

Page 29

Appendix D

Groundwater Data Summary

Appendix E

Public Notice and Survey

LONE STAR ARMY AMMUNITION PLANT 5-YEAR REVIEW SURVEY

Site Name: Lone Star AAP - Old Demolition Area Subject: 5-Year Review Information Survey Date: February 2006

Contact Information Name: Roderick Sewell

Title: IRP Manager

Organization: Lone Star h y Ammunition Plant

Telephone: (903) 334-1328 Address: Highway 82 West City, State, Zip: Texarkana, TX 75501

Individual Information (for future site information)

Name: Address: City, State, Zip:

Company: Telephone (optional):

Suwey Questions:

1. Are you familiar with the Old Demolition Area site at Lone Star AAP?

2. What is your impression of the project (general sentiment)?

3. What effect has the site operations had on the surrounding community?

4. Are you aware of any community concerns regarding the site?

5. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency responses from local authorities? (If so, please give details.)

6. Do you feel well informed about the site's activities and progress?

7. Do you have any comments, suggestions, or recommendations regarding the site?

Appendix F

ARAR Review

Old Demolition Area at Lone Star Army Ammunition Plant Texarkana, Texas: ARAR Review

An ARAR review was performed for the site in accordance with the EPA guidancedocument, “Comprehensive Five-Year Review Guidance,” EPA 540-R-01-007, OSWER No.9355.7-03B-P June 2001.

--------------------------------------------------------------------------------------------------------------------

Changes in standards and TBCs

Documents provided for review of ARAR analysis were limited to:

1. Record of Decision, June 7, 1999 2. Final Recommendations for Selecting Existing Wells and Siting New Compliance

Monitoring Wells, April 2001 3. Final Quarter One through Quarter Three Monitoring Report, August 2003 4. Draft Final 4th Quarter Monitoring Report, October 2003 5. Draft Final 1st Quarter Monitoring Report, December 2003 6. Draft Final 2nd Quarter Monitoring Report, March 2004

ARARs Identified in the ROD Requiring Evaluation During the Five-Year Review:

A review of Tables 9-1 and 9-2 of the subject ROD indicates that only location specific andaction specific ARARs were identified. For the purpose of this 5 year review, it is assumed thatlocation specific and action specific ARARs identified for the Presumptive Remedy werecomplied with during the implementation of the remedial action. Table 10-1 of the RODsummarizes the no action alternative (alternative 1) and the Presumptive Remedy (alternative 2)alternative evaluation. Under the compliance with ARARs entry, “No chemical-specific ARARsavailable is entered in the table under both alternative 1 and alternative 2.

Further, section 11.0 (page DS-35) states, under the ARARs bullet – Chemical-specific, locationspecific, and action specific ARARs were used to develop RAOs. Currently, there are nochemical specific ARARs for the COCs.

As required by EPA guidance a review of ROD listed action and location specific ARARs wasconducted. No new promulgated standards were found that would bring into question theprotectiveness of the remedy relative to the ARARs listed in Tables 9-1 and 9-2 of the ROD. Theremedy remains protective from an ARARs perspective.