Final
Fourth
Five-Year Review Report
White Farm Equipment Company Site
Charles City
Floyd County, Iowa
Region 7
United States Environmental Protection Agency
Lenexa, Kansas
June 2014
Approved by:
Date:
U.S. EPA, Region 7
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WHITE FARM EQUIPMENT COMPANY SITE
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Executive Summary
The fourth five-year review has been completed at the White Farm Equipment Company Site
located in Charles City, Floyd County, Iowa.
The White Farm Equipment Company Site occupies approximately 20 acres and is covered by a
vegetated soil cap which is sloped to provide runoff. The site is located in a former sand and
gravel pit which was utilized by the White Farm Equipment Company as a solid waste landfill
for the disposal of approximately 650,000 cubic yards (cy) of wet scrubber sludges, foundry
sands, baghouse dusts, and other industrial wastes from 1971 until 1985.
The final remedy identified in the 1990 Record of Decision (ROD) for the White Farm
Equipment Company site included installation of a protective cap over the landfill material to
prevent direct contact and minimize infiltration and the transport of contaminants by surface
water runoff. Groundwater sampling was conducted as part of the remedial design and no
groundwater contamination above the groundwater performance standards was detected.
Therefore, in accordance with the Statement of Work in the 1991 Consent Decree, groundwater
treatment was not implemented. An Explanation of Significant Differences (ESD) was issued in
1992 which modified the type of cap to be installed, revised the time frame to complete
construction of the cap, and clarified the groundwater point of compliance. The remedy selected
in the ROD required long-term groundwater monitoring with the 1994 Operation and
Maintenance (O&M) Plan establishing the groundwater sampling to occur at the time of the five-
year reviews or on a 10-year frequency based on the results of the first five-year review
sampling.
A site visit was performed on August 27, 2013 and it was determined the cap continues to
prevent direct contact with the landfill materials and minimize infiltration and the transport of
contaminants by surface water runoff. Review of the analytical data from groundwater
monitoring efforts indicate that remedial action objectives (RAOs) identified in the Record of
Decision (ROD), as amended by the ESD, have been achieved. Specifically, the groundwater
contamination levels observed in previous sampling events have remained below the
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groundwater performance standards. Due to the low levels of contamination, the United States
Environmental Protection Agency (EPA) and Iowa Department of Natural Resources (IDNR)
agreed that a 10-year sampling frequency would be acceptable for this fourth five-year review;
therefore sampling did not occur as part of this five-year review.
Originally a Potentially Responsible Party (PRP) Site, the responsible party declared bankruptcy
in late 2000, and the site is now Fund-lead. To insure the integrity of the cap, continued
maintenance should be conducted by IDNR. Damage to two monitoring wells was observed
during the 2004 five-year review. Further damage to monitoring wells was identified during the
most recent site visit. It is recommended these wells be repaired or abandoned to reduce the risk
of vandalism and the introduction of contaminants to the ground water.
It is required that five-year reviews of the White Farm Equipment Company site continue
because contaminants remain at the site above levels which would allow for unlimited use and
unrestricted exposure. However, due to the limited risk posed by the site, the site was designated
Ready-for-Reuse and as of the time of this five-year review, is being purchased pursuant to a real
estate installment contract.
The remedy at the White Farm Equipment site is protective of human health and the
environment. All threats at the site have been addressed through capping of contaminated soils
and wastes on site, long-term groundwater monitoring, and an environmental covenant
(Attachment C) which imposes activity and use limitations to maintain the protectiveness of the
remedy.
The purchaser (to be referred to as 'installment purchaser' in this report), intends to utilize the
site for grazing of livestock, specifically sheep, and potentially seasonal haying. On May 25,
2011, in accordance with the environmental covenant, EPA and IDNR approved conditional use
of the site for the grazing of calves. Any additional uses of the property not specifically allowed
under the environmental covenant will require prior written approval from EPA and IDNR.
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Table of Contents
Executive Summary i
List of Acronyms v
Five-Year Review Summary Form vi
I.0 Introduction 1
2.0 Site Chronology 3
3.0 Background 4
3.1 Physical Characteristics 4
3.2 Land and Resource Use 4
3.3 History of Contamination 5
3.4 Initial Response 6
3.5 Basis for Response Action 6
4.0 Remedial Actions 6
4.1 Remedy Selection 6
4.2 Remedy Implementation 7
4.3 Operational and Functional Activities 8
5.0 Progress Since Last Review 9
6.0 Five-Year Review Process 11
6.1 Administrative Components 11
6.2 Community Involvement 11
6.3 Document Review 11
6.4 Data Review 12
6.5 Site Inspection 15
6.6 Interviews 16
7.0 Technical Assessment 17
7.1 Question A 17
7.1.1 Remedial Action Performance 17
7.1.2 System Operations and Maintenance 17
7.1.3 Implementation of Institutional Controls and Other Measures 18
7.2 Question B 19
7.2.1 Changes in Standards and To-Be-Considered Criteria 19
7.2.2 Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics 20
7.3 Question C 22
7.4 Technical Assessment Summary 22
8.0 Issues 24
9.0 Recommendations and Follow-Up Actions 25
10.0 Protectiveness Statements 26
II.0 Next Review 27
Figures
Figure 1: Location and Vicinity
Figure 2: Site Plan
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Tables
Table]: Chronology of Site Events
Table 2: Monitoring Well Sampling Results
Table 3: Issues
Table 4: Recommendations
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.14
.23
.24
Attachments
Attachment A: Figures
Attachment B: ARARs
Attachment C: Environmental Covenant
Attachment D: Public Notice
Attachment E: Site Inspection Checklist
Attachment F: Site Inspection Photographs
Attachment G: Groundwater and Soil Contaminants of Concern
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List of Acronyms
ALM Adult Lead Methodology
ARARs Applicable or Relevant and Appropriate Requirements
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act
CFR Code of Federal Regulations
cy cubic yards
EPA Environmental Protection Agency
ESD Explanation of Significant Differences
FS Feasibility Study
IAC Iowa Administrative Code
IDNR Iowa Department of Natural Resources
LDL Laboratory Lowest Detection Limit
MCL maximum contaminant level
NA not applicable
NCP National Contingency Plan
NPL National Priorities List
NS not sampled
O&M operation and maintenance
PQL Practical Quantitation Limit
PRP Potentially Responsible Party
PVC polyvinyl chloride
RAO Remedial Action Objective
RI Remedial Investigation
ROD Record of Decision
RPM Remedial Project Manager
SARA Superfund Amendments and Reauthorization Act
fxg/L micrograms per liter
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Five-Year Review Summary Form
Lead agency: State
Author name (Federal or State Project Manager): Shelley Brodie
Author affiliation: U.S. EPA Region 7
Review period: 07/02/2013 - 06/22/2014
Date of site inspection: 12/11/2013
Type of review: Policy
Review number: 4
Triggering action date: 06/22/2009
Due date (five years after triggering action date): 06/22/2014
Issues/Recommendations
issues and Recommendations identified in the Five-Year Review:
Issue Category: Monitoring
Issue: Damage to protective casing and well cap on Monitoring Well
WFE-5B
Recommendation: Repair protective casing and well cap on WFE-5B
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Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone
Date
No
No
State
EPA/State
September
2019
Issue Category: Monitoring
Issue: Damage to protective casing and rising on Monitoring Well WFE-
6A
Recommendation: Abandon Monitoring Well WFE-6A
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone
Date
No
No
State
EPA/State
September
2019
Issue Category: Site Access/Security
Issue: Missing hazardous chemical warning signage
Recommendation: Affix chemical warning signage per the
environmental covenant.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone
Date
No
No
Other
EPA/State
September
2015
Issue Category: Monitoring
Issue: Limited groundwater and ecological sampling
Recommendation: Perform limited sampling by direct-push
technology for groundwater and limited surface water and sediment
sampling. Perform sampling by use of in-house resources starting in
October 2014.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight
Party
Milestone
Date
No
No
EPA
EPA
September
2015
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Sitewide Protectiveness Statement (if applicable)
Protectiveness Determination:
Protective
Protectiveness Statement:
The remedy at the White Farm Equipment site is protective of human health and the
environment.
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1.0 Introduction
The purpose of five-year reviews is to determine whether the remedy at a site is protective of
human health and the environment. The methods, findings, and conclusions of reviews are
documented in five-year review reports. In addition, five-year review reports identify issues
found during the review, if any, and recommendations to address them.
The EPA is preparing this five-year review pursuant to the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) Section 121(c) and the National
Contingency Plan (NCP). CERCLA § 121(c) states:
If the President selects a remedial action that results in any hazardous substances, pollutants, or
contaminants remaining at the site, the President shall review such remedial action no less often
than each five years after the initiation of such remedial action to assure that human health and
the environment are being protected by the remedial action being implemented. In addition, if
upon such review it is the judgment of the President that action is appropriate at such site in
accordance with section [104] or [ 106], the President shall take or require such action. The
President shall report to the Congress a list offacilities for which such review is required, the
results of all such reviews, and any actions taken as a result of such reviews.
EPA interpreted this requirement further in the NCP; 40 CFR § 300.430(f)(4)(ii) states:
If a remedial action is selected that results in hazardous substances, pollutants, or contaminants
remaining at the site above levels that allow for unlimited use and unrestricted exposure, the
lead agency shall review such action no less often than eveiy five years after the initiation of the
selected remedial action.
EPA Region 7 has conducted a five-year review of the remedial actions implemented at the
White Farm Equipment Company Site in Charles City, Floyd County, Iowa. This review was
conducted from May 2013 through June 2014. This report documents the results of the review.
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This is the fourth five-year review for the White Farm Equipment Company Site. The triggering
action for this review is five years after the date of the third five-year review for the site, which
was completed June 2009. The five-year review is required due to the fact that metals and
volatile organic contamination remains on site above levels that allow for unlimited use and
unrestricted exposure.
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2.0 Site Chronology
A chronology of significant site events and dates is included in Table 1.
Table 1: Chronology of Site Events
Event
Date
Site discovery following complaints from the Floyd County Board of Health.
1980
Preliminary assessment completed.
10/30/1985
Site inspection completed.
09/19/1986
Site proposed for the National Priorities List (NPL).
06/24/1988
An Administrative Order on Consent was signed by EPA and two
responsible parties requiring completion of a site investigation.
04/14/1989
Remedial investigation (RI) completed by the responsible parties.
11/09/1989
Feasibility study (FS) and risk assessment completed.
06/1990
EPA-prepared focused FS completed.
07/1990
Final listing on the NPL.
08/30/1990
Record of Decision (ROD) was signed.
09/28/1990
A Consent Decree was signed by the responsible parties requiring that they
design and perform the site cleanup.
11/12/1991
Explanation of Significant Difference (ESD) changing the capping material
and groundwater treatment requirements was issued.
07/13/1992
Remedial design completed.
03/30/1994
Remedial action consisting of capping the landfill materials was initiated.
06/27/1994
Remedial action completed.
09/08/1995
First Five-Year Review
09/29/1999
EPA deleted the site from the NPL.
10/30/2000
Second Five-Year Review
09/29/2004
Third Five-Year Review
06/22/2009
Environmental Covenant recorded
10/16/2009
Ready for Reuse Determination
06/15/2011
Property subject to an installment contract for purchase
12/20/2012
Fourth Five-Year Review
06/22/2014
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3.0 Background
3.1 Physical Characteristics
The White Farm Equipment Company site is located along the northern edge of the city of
Charles City in Floyd County, Iowa. The site occupies approximately 20 acres at the southeast
corner of Kellogg Avenue and Rotary Park Road. The site is in the location of a former oxbow
lake formed by a cutoff meander of the Cedar River. Remnants of the oxbow lake still exist
northwest and south of the site. The site is covered by a vegetated soil cap and is sloped to
provide runoff. The site drains to the wetlands (remnants of the oxbow lake) to the northwest
and south of the site and ultimately the Cedar River. The Cedar River is approximately 2,200
feet west-southwest of the site. Site maps showing the limits of the cap and locations of
monitoring wells are provided in Attachment A.
The 1989 RI included an evaluation of the groundwater aquifers present at the site. An alluvial
unconfined aquifer exists directly beneath the landfill area. A confined Cedar Valley aquifer,
which is used as a source of potable water by Charles City, is located below the unconfined
aquifer. A clay till layer exists between the two aquifer systems and no evidence of a hydraulic
connection between the systems has been found. Furthermore, the hydraulic gradient of the
alluvial unconfined aquifer is west-southwest, away from the Charles City municipal wells.
3.2 Land and Resource Use
The site is currently unoccupied and covered by a vegetated soil cap. A request was made by the
installment purchaser to graze calves in 2011, the request was granted conditional approval by
the EPA so long as the calves do not impair the protectiveness of the soil cap by causing erosion
or creating conditions which may damage the soil cap including destruction of the vegetative
cover. The installment purchaser began to graze livestock on the property in 2013, but sheep
were grazed instead of calves. Additionally, the installment purchaser has requested permission
to install a livestock well on the property, upgradient and outside the limits of the site but within
the property boundary, which would supply water for the sheep. The well would be installed by
the installment purchaser, secured with a lock, and operate on a portable generator to prevent the
ability for others to pump water from the well. The installment purchaser has also expressed
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interest in haying the field. The installment purchaser would hay the field by using non-intrusive
methods in order to maintain and protect the cap. The installment purchaser is also considering
removing livestock from the site and instead haying the field, in which case no well would need
to be installed. Installation of a livestock water well at the site is governed by the environmental
covenant.
The land use of the surrounding area is mainly agricultural and residential. A salvage yard is
located adjacent to the northeast portion of the landfill. The land use for the site, prior to being
purchased, and surrounding areas has not changed significantly since the Record of Decision
(ROD) and Explanation of Significant Differences (ESD) were issued.
3.3 History of Contamination
White Farm Equipment Company operated the disposal site on this property, which it leased
from H.E. Construction Company. In 1971, White Farm Equipment Company began disposing
of foundry sand, bag house dust, and other industrial wastes at the site. Disposal activities ended
in 1985.
In 1984, the (IDNR) required the White Farm Equipment Company to install monitoring wells
for assessing whether environmental impacts from disposal activities had occurred. In 1985,
EPA performed a preliminary assessment and from 1989 to 1990 a remedial investigation (RI),
feasibility study (FS), and risk assessment were prepared to identify the nature and extent of
contamination at the site.
The ROD, signed in 1990, specified a remedy including upgrading the landfill, installation of
additional groundwater monitoring wells, extraction and treatment of groundwater, and
long-term maintenance and monitoring. The site was added to the National Priorities List (NPL)
in 1990. Additional groundwater sampling conducted as part of the Remedial Design indicated
that there was no groundwater contamination above the groundwater performance criteria at the
point of compliance. Therefore, as discussed in the Statement of Work of the 1991 Consent
Decree, groundwater treatment and extraction was not implemented. An ESD was signed in
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1992 which modified the type of cap, revised the cap construction time frame, and clarified the
groundwater point of compliance.
3.4 Initial Response
In 1984 the IDNR required that the White Farm Equipment Company install monitoring wells to
assess whether disposal activities at the site had impacted the environment. An RI/FS was
performed by the responsible parties from 1989 to 1990.
3.5 Basis for Response Action
The landfill materials at the site were found to contain elevated levels of metals and low levels of
some organic contaminants. The contaminants of concern at the site identified in the risk
assessment included benzene in the groundwater and lead in the soil and landfill material. The
risk assessment identified ingestion of groundwater and direct contact with landfill material as
exposure pathways which posed unacceptable risks at the site.
4.0 Remedial Actions
4.1 Remedy Selection
The ROD for the White Farm Equipment Company site was signed on September 28, 1990, to
address the risks identified in the risk assessment. These risks included direct contact with
landfill material and ingestion of contaminated groundwater. The ROD selected a remedy to: 1)
control surface water runoff and infiltration through installation of a low permeability cap, and 2)
restore groundwater to allow its use as a potable water supply through extraction and treatment.
The 1991 Consent Decree required additional groundwater monitoring during the remedial
design to confirm the need for groundwater extraction and treatment. The remedial design
sampling indicated that no groundwater contamination existed above the groundwater
performance criteria at the point of compliance. Therefore, groundwater extraction and
treatment was not implemented. An ESD was issued July 13, 1992 that modified the type of cap
to be installed, revised the construction time frame, and clarified the groundwater point of
compliance. The major components of the final remedy for the site included the following:
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Implementation of institutional controls, including a restrictive covenant (replaced by an
environmental covenant in 2009).
Regrading the landfill to reduce runoff and erosion.
Capping of the landfill in accordance with State of Iowa solid waste landfill closure
requirements.
Conducting groundwater monitoring during the five-year reviews (did not occur during
this five-year review).
Performing operation and maintenance (O&M) of the fencing and landfill cover.
4.2 Remedy Implementation
In a Consent Decree in 1991, Allied Products Corporation agreed to perform the remedial design
and construct the remedial action. The remedial design and construction of the remedial action
were conducted in accordance with the ROD as modified by the ESD. The remedial design was
approved by EPA on March 30, 1994.
The remedial action construction activities consisted of installing the compacted cap, vegetating
the cap, installing perimeter fencing, and instituting deed restrictions. A restrictive covenant for
the property was recorded and filed on October 5, 1992, in Floyd County. The restrictive
covenant was replaced by an environmental covenant on October 16, 2009. The environmental
covenant currently imposes the following activity and use limitations for the property:
The construction, installation, maintenance, and use of any wells on the property for the
purpose of extracting water for human drinking purposes or for the irrigation of food or
feed crops.
The soil cap located on the property shall be maintained in good repair in order to
prevent direct contact with the landfill materials, reduce infiltration and leaching of
contaminants and minimize run-off transport of contaminants.
The soil cap located on the property shall not be excavated or disturbed except for minor
excavations necessary to install, maintain, or repair fences unless approved in advance in
writing by the EPA or its assigns.
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The fence located on the property shall be maintained in good condition and repair. The
hazardous chemical warning signs shall continuously be displayed in a conspicuous
place on said fence, and such signs shall be maintained in legible condition.
These restrictions run with the land and are binding on all owners. The remedial action was
constructed from mid-1994 to mid-1995, Construction completion was achieved when the Site
Closeout Report was completed on September 8, 1995. A copy of the environmental covenant is
included in Attachment C.
4.3 Operation and Maintenance Activities
O&M activities at the site since construction completion have been performed in accordance
with the O&M plan prepared for the site in January 1994. Post-closure site activities were
conducted by the responsible party since completion of the remedial action construction and
included inspection of the following items;
Final cover
Groundwater monitoring wells
Drainage facilities
Storm water retention areas
Access road
Perimeter fencing, gates, and signs
Under the O&M Plan, groundwater monitoring is to be performed concurrently with the five-
year review process. The O&M Plan allowed for the sampling frequency to be to a 10 year
period should the first five-year review sampling event show no parameter values over the
Practical Quantitation Limits (PQL). The sampling event for the first five-year review resulted
in non-detects for all contaminants which demonstrates none of the contaminants exceeded the
PQLs, Shortly after the October 2000 post closure site inspection, Allied Products Corporation
filed for bankruptcy. The site became Fund-lead with EPA and IDNR taking over responsibility
for maintenance of the site. Sampling was not performed for this five-year review with EPA and
IDNR agreeing to use a 10-year frequency due to the limited detections from previous sampling
events.
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Until Allied Products Corporation declared bankruptcy in 2000, they complied with a Consent
Decree which stated:
Within thirty (30) days after entry of this consent decree, the Owner Settling Defendant
shall submit for recording by the Recorder of Deeds, Floyd County, Iowa, a restrictive
covenant which shall run with the property comprising the Site and which prohibits the
construction, installation, maintenance, or use of any wells on the described property for
the purpose of extracting water for human drinking purposes or for the irrigation of food
or feed crops. Thereafter, each deed, title, or other instrument of conveyance for property
included in the Site shall contain such a restrictive covenant.
A restrictive covenant for the property was recorded and filed on October 5, 1992, in Floyd
County. An environmental covenant replaced the restrictive covenant October 16, 2009.
5.0 Progress Since Last Review
The protectiveness statement provided in the last five-year review in 2009:
The remedy at the White Farm Equipment site is protective of human health and the
environment. All threats at the site have been addressed through capping of
contaminated soils and wastes on site, long-term groundwater monitoring, and a
restrictive covenant that prohibits the installation of any wells for the purpose of
extracting water for human drinking purposes or for the irrigation of food or feed crops.
Three issues were identified in the last five-year review. None of these issues were considered to
have an impact on the current or future protectiveness of the remedy. The current status of these
issues is as follows:
Issue 1: Damaged protective casing to monitoring well WFE-5B.
The third five-year review in 2009 recommended that the casing on WFE-5B be repaired.
Originally this recommendation was made in the second five-year review in 2004. Based on the
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site inspection, repairs to WFE-5B were not completed. Additionally, the well cap was found to
be missing, with the well open to the environment. This issue has not been resolved and will
carry forward as a result of this five-year review.
Issue 2: Damaged protective casing and riser on monitoring well WFE-6A.
The third five-year review recommended that well WFE-6A be abandoned. Originally this
recommendation was made in the second five-year review in 2004. During the most recent site
inspection, the well riser was found detached and laying in the underbrush nearby, likely due to a
vehicle striking the well casing and dislodging the pad, casing, and riser. It is recommended the
remaining portion of the well below the ground surface be abandoned, as the well is beyond
repair.
Issue 3: Missing well labels.
The third five-year review recommended that labels be attached to the monitoring wells. During
the site inspection, no labels were observed on wells WFE-5B, WFE-5A, or WFE-6B. Well
WFE-6A was found to be destroyed, and wells WFE-7A and WFE-7B could not be visually
inspected due to overgrowth and standing water which prevented access to the wells. It is
recommended a permanent well label be affixed to all monitoring wells.
Issue 4: Limited groundwater and ecological sampling
Perform limited sampling by direct-push technology for groundwater and limited surface water
and sediment sampling to supplement the groundwater sampling done in 2008, as part of the
O&M. Ecological sampling was recommended previously but not performed due to dry
conditions. Perform sampling by use of in-house resources starting in October 2014.
Other significant items that have occurred since the 2009 five-year review include:
EPA has completed the Ready-for-Reuse process for the site
An Environmental Covenant has been issued for the site
H.E. Construction Company has entered into a real estate installment contract in order to
sell the site to an installment purchaser
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6.0 Five-Year Review Process
6.1 Administrative Components
The five-year review process was conducted by Shelley Brodie, the EPA Region VII Remedial
Project Manager (RPM) for the site (prior to 4/4/14) and by Elizabeth Hagenmaier, the EPA
Region VII Remedial Project Manager (RPM) for the site (as of 4/4/14), supported by Kenneth
Kamp, Paul Speckin, and Cathy Forget of the U.S. Army Corps of Engineers, Kansas City
District.
6.2 Community Involvement
A public notice regarding the initiation of the FYR was placed in the Charles City Press on
January 28, 2014, notifying the public of the start of the FYR process. The completed FYR
report will be available at the Site information repository, the Charles City Public Library, 106
Milwaukee Mall, Charles City, IA 50616; the EPA Superfund Division Records Center, 11201
Renner Boulevard, Lenexa, Kansas 66219; and IDNR offices, 502 E. 9th Street, Des Moines, IA
50319. A copy of the public notice can be found in Attachment D.
6.3 Document Review
The following documents were reviewed as part of the current five-year review:
Final Draft Remedial Investigation Report, November 9, 1989.
Final Revised Risk Assessment, White Farm Equipment Landfill Site, Charles City,
Iowa, June 15, 1990.
Operation and Maintenance Plan for the White Farm Equipment Landfill Site, January
1994.
Groundwater monitoring results from 1999, 2004, and 2008
Record of Decision, September 28, 1990.
Explanation of Significant Differences, July 13, 1992.
Second Five-Year Review Report, September, 2004.
Consent Decree, lodged July 14, 1992, filed September 18, 1992, signed by the
Defendants November 1991.
Third Five-Year Review Report, June, 2009.
Environmental Covenant, October 2009.
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Contract for Deed, December 20, 2012.
6.4 Data Review
Due to the low levels of contamination in previous sampling events, EPA and IDNR agreed on
January 8, 2014, a 10-year sampling frequency will be used. No groundwater monitoring was
performed for this five-year review, the next groundwater sampling event will occur with the
next five-year review in 2019. A 10-year sampling frequency was allowed under the 1994 O&M
Plan if contaminant levels were demonstrated to be below the PQL during the first five-year
review. All samples from the first five-year review were shown to be non-detect, which
demonstrates the values to be below the Quantitation Limit. Groundwater monitoring at the
White Farm Equipment Company Site was completed as part of the previous five-year reviews in
June 1999, May 2004, and December 2008 for inclusion in the first, second, and third five-year
reviews.
Groundwater samples were collected in 2008, from four of the six existing monitoring wells
(WFE-5A, WFE-6B, WFE-7A, and WFE-7B). These groundwater samples were analyzed for
the presence of benzene, cadmium, chromium, and lead and the results were compared with the
groundwater performance criteria set for the site. Low flow sampling techniques were used for
the first two wells sampled (WFE-5A and WFE-7A). Low flow sampling was initiated on WFE-
6B, but a bailer was used to actually collect the sample due to failure of the flow control panel
prior to collecting the sample using this technique. Failure of the control panel was thought to be
caused by the extreme low temperatures. A bailer grab sample was also collected from well
WFE-7B due to the inoperable control panel. These samples were not filtered in the field and
were preserved and containerized in accordance with the Quality Assurance Project Plan
(QAPP).
Table 2 presents the results of the samples collected for the first, second, and third five-year
reviews as well as the groundwater performance standards. The groundwater performance
standard for benzene was set in the ROD. The groundwater performance standards for cadmium,
chromium, and lead were set in the 1991 Consent Decree.
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As presented in Table 2, the levels of benzene, cadmium, chromium, and lead in the groundwater
have continuously remained well below the groundwater performance standards set for the site.
The four monitored analytes have rarely had detections above the quantitation limits. The
limited number of low detections of metals were from the side gradient wells and likely not site
related. Additionally, in the 2008 sampling event, the field crew disturbed the sedimentation
within the well while measuring the depth prior to sampling WFE-7A. This increase in
sedimentation in the well is likely the source of the very low levels of chromium and lead
detected.
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Table 2: Monitoring Well Sampling Results
Monitoring
Well
Analyte (pg/L)
Benzene
Cadmium
Chromium
Lead
1999
2004
2008
1999
2004
2008
1999
2004
2008
1999
2004
2008
WFE-5A
1.0 U
1.0 U
0.50 U
0.44 U
3.0 U
1.00 UJ
0.88 Bu
15.0 U
2.00 U
1.9 U
50.0 U
1.00 U
WFE-5B
1.0 U
1.0 U
NS
0.44 U
3.0 U
NS
0.97 Bu
15.0 U
NS
1.9 U
50.0 U
NS
WFE-6A
1.0 U
1.0 U
NS
0.44 U
3.0 U
NS
0.88 Bu
15.0 U
NS
1.9 U
50.0 U
NS
WFE-6B
1.0 U
NS
0.50 U
0.44 U
NS
1.00 UJ
0.96 Bu
NS
2.00 U
1.9 U
NS
1.00 U
WFE-7A
1.0 U
NS
0.50 U
0.44 U
NS
1.00 UJ
0.88 Bu
NS
2.04
1.9 U
NS
1.12
WFE-7B
1.0 U
NS
0.50 U
0.44 U
NS
3.1
1.1 Bu
NS
2.00 U
1.9 U
NS
1.00 U
Performance
Standard
1.0
5.0
100.0
50.0
Notes:
* The groundwater performance standard for benzene was set in the ROD. The groundwater performance standards for cadmium, chromium,
and lead were set in the 1991 Consent Decree.
The federal Maximum Contaminant Level (MCL) for lead has changed to 15 micrograms per liter (pg/L).
1999 samples were collected by the responsible party's contractor on June 22 and 23, 1999.
2004 samples were collected by EPA's contractor, on March 30 and 31, 2004.
2008 samples were collected by US Army Corps of Engineers on Dec. 4 and 5, 2008
All values are in micrograms per liter (pg/L).
NS - No sample was collected. In 2008 sampling event, well WFE-5B cap was not functional and frozen shut and WFE-6A was damaged and
could not be sampled.
B - The result is estimated. The analyte is between the Instrument Detection Limit and the Contract Required Quantitation Limit.
u - The analyte was considered non-detected during data validation on the bases of blank detections.
U - Not detected above reporting limit listed.
J - The identification of the analyte is acceptable; the reported value is an estimate.
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6.5 Site Inspection
A site inspection was conducted on August 27, 2013. The purpose of the site inspection was to
identify the existing condition of the remedy and any changes which could negatively affect the
protectiveness of the remedy. The site inspection included visual assessment of the final cover,
the groundwater monitoring wells, the drainage channels and storm water retention areas, the
access road, the perimeter fencing, gates, and signs. Photos from the site inspection are included
in Attachment F.
The cover was inspected by walking the site perimeter and assessing the condition and coverage
of vegetation, as well as to identify any small erosion features along the slopes. The cover
appeared to be in good condition with few volunteer trees in the central area of the site. The
installment purchaser intends to remove the volunteer trees in order to hay the field. Some
volunteer trees were also noted along the perimeter of the landfill, outside of the drainage swales,
and near the sedimentation basins. Both the EPA and Iowa DNR had no concerns regarding the
presence of the volunteer trees. It is not believed these present an imminent risk to the integrity
of the landfill cover. The perimeter fence and gates were in good condition and "No
Trespassing" signs were present and legible.
The installment purchaser had grazed sheep for two months prior to the site inspection; the
landfill cap integrity and vegetative cover did not appear to be impacted from the grazing of the
sheep. The installment purchaser identified the desire to use the site for haying instead of
grazing due to a lack of precipitation to sustain vegetation for grazing. The installment purchaser
would utilize a non-intrusive seeding method which would not impact the landfill cap. Any
agricultural use of the site is subject to the environmental covenant and requires prior written
approval by EPA.
Two of the monitoring wells located along Kellogg Road, west of the site, were damaged.
Monitoring well WFE-6A has been destroyed from above ground surface. Monitoring well
WFE-5B is missing the well casing locking cover, as well as the PVC riser cap. The monitoring
wells located south of the site, WFE-7A and 7B were not able to be visually inspected due to
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vegetative overgrowth and standing water. The previous site inspection noted the wells were in
good condition. Based on the distance of wells WFE-7A and 7B from the road and difficulty to
access the wells, it is unlikely substantial damage or vandalism would have occurred at the wells.
Well WFE-5A was observed to be in good condition.
The Charles City Library was visited to check the status of the administrative record; all files
were current including the most recent five-year review performed in 2009. The Floyd County
Recorder's Office was also visited to check the status of the deed and to verify the environmental
covenant was attached. All documents found at the County Recorder's Office identified cross-
references which led to the environmental covenant. All documentation was found to be current
and reflected the environmental concerns which exist at the site.
6.6 Interviews
Interviews with Shelley Brodie, EPA RPM; Bob Drustrup IDNR PM; and Matt Ross, the
installment purchaser, were conducted through discussions during the site inspection; a formal
interview form was not drafted for this five-year review due to the limited comments. Since the
last FYR, EPA, IDNR, and the installment purchaser have received no complaints or concerns
from the community or adjacent land owners regarding the site. Mr. Ross indicated there has
been no vandalism or unauthorized intrusion onto the site since he has been under contract to
purchase the property. Mr. Ross also indicated he had originally intended to graze sheep on the
site but found the lack of precipitation during the summer months did not support enough
vegetative growth to support this activity. He was proposing instead to hay the site and indicated
he would use a no-till drilling method to plant the seed to minimize disturbance of the cover.
Ms. Brodie, EPA and Mr. Drustrup, IDNR did not have any concerns with this proposed use of
the site but indicated Mr. Ross should submit a request in writing so that this site use could be
formally documented and approved in accordance with the environmental covenant. There were
no other issues or concerns expressed during the site inspection regarding current and proposed
use of the site or protectiveness of the remedy.
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7.0 Technical Assessment
The five-year review must determine whether the remedy at a site is protective of human health
and the environment. The EPA guidance describes three questions used to provide a framework
for organizing and evaluating data and information and to ensure all relevant issues are
considered when determining the protectiveness of a remedy. These questions are assessed for
the site in the following paragraphs. At the end of the section is a summary of the technical
assessment.
7.1 Question A
Is the remedy functioning as intended by the decision documents?
YES
7.1.1 Remedial Action Performance
Review of documents, ARARs, risk assumptions, and the results of the site inspection indicate
the remedy for the site is functioning as intended by the ROD, and as modified by the ESD. The
landfill cap has prevented direct contact with contaminated landfill materials and minimized
surface water runoff and infiltration. Analytical results from the previous five-year review
groundwater sampling efforts indicate groundwater has not exceeded performance criteria.
7.1.2 System Operations and Maintenance
The operation and maintenance of the cap has been effective. The installment purchaser has
initiated removal of vegetative growth along the fence line, as well as removal of volunteer trees.
"No Trespassing" signs along the fence line were legible and in good condition, but a hazardous
chemical warning sign was not present at the entry gate which had been present during the
previous five-year review. The environmental covenant requires chemical warning signs be
present at the site. Repairs to damaged wells or abandoning the wells are recommended to
minimize any risk of vandalism or introduction of contaminants to the groundwater. Although
sampling has not been performed as part of this five-year review, the results of previous
sampling events were found to be below the performance criteria with no evidence of off-site
transport. The O&M Plan allows for a 10-year sampling frequency due to the low contaminant
levels originally detected during the first five-year review, and further supported by the
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subsequent sampling events. EPA and IDNR have consented to a 10-year sampling frequency.
Consideration should be given to to re-developing the well network prior to the next sampling
event, which would occur during the next five-year review in 2019, due to the time between
sampling events. Brush clearing in the area of WFE-7A and WFE-7B would allow for easier
access to the wells for sampling.
7.1.3 Implementation of Institutional Controls and Other Measures
The environmental covenant went into effect on October 16, 2009. The environmental covenant
imposes the following activity and use limitations for the property:
The construction, installation, maintenance, and use of any wells on the property for the
purpose of extracting water for human drinking purposes or for the irrigation of food or
feed crops.
The soil cap located on the property shall be maintained in good repair in order to
prevent direct contact with the landfill materials, reduce infiltration and leaching of
contaminants and minimize run-off transport of contaminants.
The soil cap located on the property shall not be excavated or disturbed except for minor
excavations necessary to install, maintain, or repair fences unless approved in advance in
writing by the EPA or its assigns.
The fence located on the property shall be maintained in good condition and repair. The
hazardous chemical warning signs shall continuously be displayed in a conspicuous
place on said fence, and such signs shall be maintained in legible condition.
The Property may not be used for any residential, commercial, recreational or
agricultural purposes unless approved in advance in writing by the EPA or its assigns.
These restrictions run with the land and are binding on all owners. The Floyd County Recorder's
Office was visited during the five-year review site visit to check the status of the deed and to
verify the environmental covenant was attached. All documents found at the County Recorder's
Office identified cross-references which led to the environmental covenant. All documentation
was found to be current and reflected the environmental concerns which exist at the site. A copy
of the environmental covenant is included in Attachment C.
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Although "No Trespassing" signs were documented at the site and in good condition, no
hazardous chemical warning signs were observed. Due to the historical low levels of
contamination at the site, current use of the site, and lack of exposure pathways, this issue is not
considered to be significant or a concern to the protectiveness of the remedy.
7.2 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?
YES
7.2.1 Changes in Standards and To-Be-Considered Criteria
The cleanup goals identified in the ROD for the soil at the site were calculated from the risk
assessment and assume direct contact and ingestion of soil and a hazard index of 1. The
contaminants of concern identified in the 1990 Risk Assessment in soil were lead, arsenic, and
benzo(a) pyrene. The RAO was to prevent direct exposure to the soil and prevent offsite
transport of potentially contaminated materials. Therefore, all soil cleanup goals were achieved
with the completion of the cap construction. Additionally, the contaminant concentrations in the
groundwater at the point of compliance continue to meet site ARARs which are the site specific
groundwater performance criteria as noted in Table 2.
EPA set the cleanup goals in the ROD for groundwater at the lower of either the MCLs or
groundwater action levels set in the Iowa Administrative Code. The contaminants of concern
and respective cleanup goals identified in the ROD were benzene at 1 microgram per liter
(|ig/L), lead at 50 ^g/L, cadmium at 5 |ig/L, and chromium at 100 |ig/L. The groundwater action
level for lead has changed from 50 ng/L to 15 (ig/L because the maximum contaminant level
(MCL) set in the Safe Drinking Water Act was changed. However, the remedy remains
protective because the groundwater monitoring conducted during the five-year reviews, remedial
design, and the RI, has consistently found the groundwater lead concentrations at the point of
compliance to be well below the MCL. Furthermore, the risk assessment indicated that lead
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contamination did not drive the groundwater ingestion risks at the site. Therefore, preparation of
an ESD documenting the changed action level is not recommended.
7.2.2 Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics
The 1990 Human Health Risk Assessment used slightly different methodology than is used
today. To determine chemicals of potential concern (they used the term "indicator chemicals1')
for inorganics in groundwater, the downgradient sample results were compared to two times the
background concentrations. If they exceeded two times background, that chemical was then
compared to the MCL or MCLG for that chemical. These results are summarized in Appendix
G.
Similarly, they selected "indicator chemicals" for soil if metals were detected above background
concentrations. Additionally, organic contaminants were detected in some of the landfill
material samples. However, these organic contaminants were not detected in samples of native
soils from beneath the landfill materials. They were screened out in the risk assessment, but not
included in a "rescreening" as part of the five year review since they were not detected in any
soils or groundwater from the site.
Other inorganics were detected in the landfill material also. Arsenic was detected above the
2014 Risk Screening level for industrial soil. However, it is well within background range of
concentrations in soil. Other inorganics were detected above naturally occurring concentrations,
but are less than the 2014 RSLs.
The risk assessment completed for the site identified benzene as the sole driver of the
groundwater exposure pathway and lead as the sole driver for the soil exposure pathway. With
the transfer of ownership in 2013, a new exposure pathway was qualitatively evaluated as part of
the five year review. The installment purchaser will be using the site for grazing sheep or other
livestock as well as for growing feed for livestock. Based on the site information provided and
subject to the conditional approval of this land use by EPA, this land use change in exposure
pathways will not pose an unacceptable risk at the site for the following reasons.
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The landfill is still well protected by the cap, and therefore the direct contact with
contaminated soil pathway is incomplete.
The cap also eliminates the complete pathway due to ingestion of crops grown in
contaminated soil, as well as incidental ingestion of soil by the grazing livestock.
The 2013 site visit determined that the cap was intact, and as long as the cap is
adequately maintained all pathways involving direct contact with soil by animals or
humans should be considered incomplete.
Additionally, the new installment purchaser is proposing to install a new livestock well on the
property but outside and upgradient of the landfill cap, and outside of the limits of the landfill
cover. However, in accordance with the environmental covenant, use of the property for grazing
sheep or growing feed for livestock must be approved in advance in writing by EPA. Installation
of a livestock well may be protective under the remedy if:
It is upgradient of any potential contamination and outside of the area of the soil landfill
cap
It will not be used for human consumption or irrigation, in accordance with the
environmental covenant
Results from sampling of the well water are consistent with historical sampling
EPA recommends the use of the adult lead methodology (ALM) when assessing human health
risks associated with lead exposures at non-residential areas of CERCLA sites rather than
calculating a hazard index for exposure to lead-contaminated soil as was done in the 1990 risk
assessment prepared for the White Farm Equipment Company site (USEPA, 2009). However,
the cap at the site had no signs of degradation at the site visit in 2013, and is still adequate to
prevent exposure to the landfill materials and minimize surface water runoff and infiltration.
Therefore, since there is no complete exposure pathway to potentially contaminated soils,
recalculation of the cleanup levels for the site using the ALM Model is not necessary.
The EPA toxicity values for benzene have been modified since the risk assessment at White
Farm was completed. The cancer slope factor for benzene used in the 1990 risk assessment for
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the White Farm Equipment Company site was 2.9x10"2 (mg/kg-day)"1. Toxicity information for
benzene was modified in 2000; however, the slope factor used in 1990 falls within the current
range of oral slope factors published by EPA, which is 1.5xl0"2 to 5.5x10"2 (mg/kg-day)"1.
Additionally, benzene does not affect the proteetiveness of the remedy since it has not been
detected in the monitoring events, and there are land use controls at the site to prevent human
consumption of groundwater under the landfill.
Some state entities, notably, the New Jersey Department of Environmental Protection, have
released new toxicity values for chromium. Chromium was not identified as a COC in the ROD
after being characterized in the 1989 RI as having no chromium release at the site. EPA
chromium toxicity values have not changed since the risk assessment was completed and the
State of Iowa has not revised the IAC to address new toxicity values for chromium. The new
chromium toxicity values being used by New Jersey do not impact the proteetiveness of the
remedy at the site at this time. There are no receptors using the groundwater which would create
a complete pathway for chromium exposure and the land use controls at the site prevent human
consumption of groundwater under the landfill.
7.3 Question C
Has any other information come to light that could call into question the proteetiveness of the
remedy?
NO
No new ecological targets have been identified at the site. Because of the bankruptcy of the
responsible party the site is Fund-lead and O&M is conducted by IDNR. No other events have
occurred within the last 5 years which would affect the proteetiveness of the remedy. No
evidence of flooding or other natural disaster was observed or reported for the site. The
installment purchaser has utilized the site in compliance with the environmental covenant. There
is no other information which calls into question the proteetiveness of the remedy.
7.4 Technical Assessment Summary
Based on the data reviewed and the site inspection, the remedy is functioning as intended by the
ROD, and as revised by the ESD. There have been no changes in the physical conditions of the
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WHITE FARM EQUIPMENT COMPANY SITE
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site which would affect the protectiveness of the remedy. The concentrations of benzene,
cadmium, chromium, and lead have continually been below the groundwater performance
standards. Wells WFE-5B and WFE-6A, in their current condition, are an open conduit for
potential vandalism. It is recommended damage to monitoring well WFE-5B be repaired so that
the well may be utilized for long-term monitoring of the groundwater. It is recommended
monitoring well WFE-6A be abandoned since the well is beyond repair and all above ground
portions of the well have been destroyed. Permanent well labels should be attached to
monitoring wells.
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8.0 Issues
Table 3: Issues
Affects Protectiveness
Issue #
Issue
(Y/N)
Current
Future
1
Damage to protective casing and missing well
cap on Monitoring Well WFE-5B
N
N
2
Destruction to protective casing and riser on
Monitoring Well WFE-6A
N
N
3
Missing hazardous chemical warning signs
N
N
4
Limited groundwater and ecological sampling
N
N
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9.0 Recommendations and Follow-Up Actions
Below is a list of recommended actions to address the issues identified in section 7.0 above.
Table 4: Recommendations and Follow-Up Actions
Issue
#
Recommendations/ Follow-
up Actions
Party
Responsible
Oversight
Agency
Milestone
Date
Affects
Protectiveness
(Y/N)
Current
Future
1
Repair protective casing and
well cap on WFE-5B to
prevent potential vandalism
IDNR
EPA
Sep. 2019
N
N
2
Abandon Monitoring Well
WFE-6A
IDNR
EPA
Sep. 2019
N
N
3
Post hazardous chemical
warning signs at site boundary
Site Owner
EPA/1DNR
Sep. 2015
N
N
4
Perfonn limited sampling by
direct-push technology for
groundwater and limited
surface water and sediment
sampling. Perform sampling
by use of in-house resources
starting in October 2014.
EPA
EPA
Sep. 2015
N
N
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10.0 Protectiveness Statements
The remedy at the White Farm Equipment site is protective of human health and the
environment.
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11.0 Next Review
The next five-year review for the White Farm Equipment Site is required by June 22, 2019, five
years from the date of this review.
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Attachment A
Figures
-------
Area of Interest
0 455 910
N
Feet
1,820 2,730 3.640
DRAWN BV
DATE
October 2008
White Farm
Equipment
Dump Site
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Attachment B
ARARs
-------
Chemical-Specific ARARs
Regulation
Requirement Synopsis
Comments
567 IAC §133.2
(455B, 455E)
Establishes hierarchy to
be used to establish
cleanup levels for
groundwater.
Groundwater performance standards
were set based on the hierarchy
presented in the regulation.
Groundwater was required to meet
the performance standards at the
point of compliance which was set
at the limits of the landfill.
Compliance with groundwater
performance standards is measured
through monitoring conducted
during the five-year reviews.
Action-Specific ARARs
567 IAC §103.2(13)
Provides closure
requirements for solid
waste landfills.
A cap was installed over the landfill
materials that met the requirements
of the regulation.
Location-Specific ARARs
40 CFR Part 6,
Appendix A
Describes EPA policy
on implementing
Executive Order 11990
for Wetlands Protection.
A cap was installed over the landfill
materials to minimize surface water
runoff to the adjacent wetlands.
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Attachment C
Environmental Covenant
-------
ENVIRONMENTAL COVENANT
This Environmental Covenant is entered into by and between H.E. Construction, Inc. ("I-I.E.
Construction"), an Iowa Corporation, as both "Grantor" and "Holder" pursuant to the Iowa Uniform
Environmental Covenants Act codified at Chapter 4551 of the Iowa Code.
RECITALS
WHEREAS, H.E. Construction, whose mailing address is 3011 190Ih Street, Charles City, IA
50616, is the owner in fee simple of that real property legally described on Attachment 1 hereto, the
"Property;"
WHEREAS, the White Farm Equipment Dump Superfund Site ("Site") is located on the
Property, which the EPA, pursuant to Section 105 of the Comprehensive Environmental Response,
Compensation and Liability Act ("CERCLA"), 42 U.S.C. § 9605, placed on the National Priorities List
("NPL"), set forth at 40 C.F.R. Part 300, Appendix B, by publication in the Federal Register on August
30, 1990;
WHEREAS, on November 13, 1989, the Site was listed on the State of Iowa's Registry of
Confirmed Hazardous Waste or Hazardous Substance Disposal Sites ("Iowa Registry") pursuant to Iowa
Code § 455B.426 et al, which provides in pertinent part:
a. A person shall not substantially change the manner in which a hazardous waste or
hazardous substance disposal site on the registry...is used without the written approval of
the director.
b. A person shall not sell, convey, or transfer title to a hazardous waste or hazardous
substance disposal site which is on the registry., .without the written approval of the
director. Iowa Code § 455B.430
A statement that the Site was listed on the Iowa Registry was filed in book 44, at page 390, in the Office
of the Recorder of Deeds of Floyd County, Iowa;
WHEREAS, in a Record of Decision dated September 28, 1990, the EPA Region VII Regional
Administrator selected a "remedial action" for the Site that consisted of installing a soil cover on landfill
materials, fencing the perimeter of the site to restrict access to landfill materials, installation of a
groundwater treatment system, and deed restrictions to limit future property use and well installation.
WHEREAS, Allied Products Corporation, H.E. Construction and the United States entered into a
Consent Decree ("Consent Decree") pursuant to the Comprehensive Environmental Response,
Compensation, and Liability Act, 42 U.S.C. § 9601 et seq. In this Consent Decree, Allied Products
Corporation agreed to conduct the "remedial action" selected in the ROD, in order to respond to the
release or threat of release of hazardous substances into the environment on the Property. The remedial
action is an "environmental response project," as defined in Iowa Code § 4551.2(5). This Consent
Decree was styled "United States of America v. Allied Products Corporation and H.E. Construction,
Inc." and was entered under Civil Action No. C92-2043, in the United States District Court for the
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Northern District of Iowa, on July 14, 1992.
WHEREAS, a copy of the Administrative Record for the remedial action, including the Consent
Decree, Record of Decision, Explanation of Significant Differences, and Five-Year Reviews, is located
at the Charles City Public Library, 106 Milwaukee Mall, Charles City, Iowa 50616.
WHEREAS, pursuant to the Consent Decree, H.E. Construction agreed to, among other things,
provide access to the Property to the United States Environmental Protection Agency ("EPA") for the
purposes of implementing, facilitating, and monitoring the environmental response project required to be
performed under the Consent Decree, and file a Restrictive Covenant that imposes activity and use
limitations on the Property that would run with the Properly and bind subsequent owners;
WHEREAS, on October 5, 1992, H.E, Construction filed a Restrictive Covenant in book 50, at
page 453 and 454, in the Office of the Recorder of Deeds of Floyd County, Iowa;
WHEREAS, H.E. Construction and EPA agree that it is appropriate at this time to revoke,
rescind, and terminate the Restrictive Covenant and supersede the Restrictive Covenant with this
Environmental Covenant.
WHEREAS, H.E. Construction desires to grant to itself as Holder, as that term is defined in Iowa
Code § 4551.2(7), this Environmental Covenant for the purpose of subjecting the Property to certain
activity and use limitations as provided in the Iowa Uniform Environmental Covenants Act;
WHEREAS, as hazardous substances remain at the Property at levels which do not allow for
unlimited use of, and unrestricted exposure at, the Properly, H.E. Construction 'is subjecting the Property
to the activity and use limitations contained herein;
NOW THEREFORE, H.E. Construction hereby states and declares as follows;
' - Parties: In addition to H.E. Construction, who is the owner of the Property and Holder
hereunder, the EPA and the Iowa Department of Natural Resources ("IDNR") and any successor agency,
is a party to this Environmental Covenant. EPA and IDNR arc each an "Agency" hereunder as defined
in Iowa Code § 4551.2(2), and may enforce this Environmental Covenant as provided in Iowa Code §
4551.11 and paragraph 4 below.
2. Activity and Use Limitations: The following activity and use limitations are hereby
imposed on the Property;
a. The construction, installation, maintenance or use of any wells on the Property for
the purpose of extracting water for human drinking purposes or for the irrigation
of food or feed crops shall be prohibited;
b. The soil cap located on the Property shall be maintained in good repair in order to
prevent direct contact with the landfill materials, reduce infiltration and leaching
of contaminants and minimize run-off transport of contaminants;
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c. The soil cap located on the Property shall not be excavated or disturbed except for
minor excavations necessary to install, maintain, or repair fences unless approved
in advance in writing by the EPA or its assigns;
c. The Property may not be used for any residential, commercial, recreational or
agricultural purposes unless approved in advance in writing by the EPA or its
assigns; and
e. The fence located on the Property shall be maintained in good condition and
repair. The hazardous chemical warning signs shall continuously be displayed in
a conspicuous place on said fence, and such signs shall be maintained in legible
condition.
3. Running with the Land: This Environmental Covenant shall be binding upon H.E.
Construction and its successors, assigns, and Transferees in interest, and shall run with the land, as
provided in Iowa Code § 4551.5(1), subject to amendment or termination as set forth herein. The term
"Transferee," as used in this Environmental Covenant, shall mean any future owner of any interest in the
Property or any portion thereof, including, but not limited to, owners of an interest in fee simple,
mortgagees, easement holders, and/or lessees.
4. Enforcement: Compliance with this Environmental Covenant may be enforced as
provided in Iowa Code § 4551.11. Failure to timely enforce compliance with this Environmental
Covenant or the activity and use limitations contained herein by any party, shall not bar subsequent
enforcement by such party and shall not be deemed a waiver of the party's right to take action to enforce
any non-compliance. Nothing in this Environmental Covenant shall restrict any person from exercising
any authority under any other applicable law.
5. Notice of Non-Compliance: Grantor and any subsequent Transferee of the Property shall
notify EPA as soon as possible of any conditions that would constitute a breach of the activity and use
limitations specified above in Paragraph 2.
6. Rights of Access: Grantor grants to the Holder and to EPA and IDNR's agents,
contractors, and employees, an irrevocable, permanent and continuing right of access at all reasonable
times to the Property for implementation, monitoring or enforcement of this Environmental Covenant
and the aforementioned Consent Decree. Nothing herein shall be deemed to limit or otherwise affect
EPA's right of access and entry under federal law.
7. Notice of Proposed Conveyance: Grantor or its Transferee shall, at least 30 days prior to
the conveyance of any interest in the Property or any portion thereof, give written notice to EPA of the
proposed conveyance, including the name and address of the proposed Transferee, and the date on
which the notice of the Consent Decree and this Environmental Covenant was given to the proposed
Transferee, and that all of the provisions of the Consent Decree continue in full force and effect,
notwithstanding any such transfer.
4
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8. Groundwater Hazard Statement: Iowa Code § 558.69 requires submission of a
groundwater hazard statement and notice if "hazardous waste," as defined in Iowa Code §§
455B.41 1(3), 455B.412(2) or section 455B.464, is present on real property. If hazardous waste is
present, the groundwater hazard statement must state that the condition is being managed in accordance
with IDNR rules. Grantor and all subsequent Transferees required to submit a groundwater hazard
statement under Iowa Code § 558.69 for the Property shall make reference to this Environmental
Covenant in any instrument conveying an interest in the Property. The notice shall be substantially in
the following form:
THE INTEREST CONVEYED HEREBY IS SUBJECT TO AN ENVIRONMENTAL
COVENANT, DATED 2009, RECORDED IN THE OFFICE OF THE
RECORDER OF DEEDS OF FLOYD COUNTY, IOWA, ON 2009, AS
DOCUMENT BOOK , PAGE .
THE ENVIRONMENTAL COVENANT CONTAINS THE FOLLOWING ACTIVITY AND
USE LIMITATIONS:
A. THE CONSTRUCTION, INSTALLATION, MAINTENANCE OR USE OF
ANY WELLS ON THE PROPERTY FOR THE PURPOSE OF EXTRACTING
WATER FOR HUMAN DRINKING PURPOSES OR FOR THE IRRIGATION
OF FOOD OR FEED CROPS SHALL BE PROHIBITED; ¦
B. THE SOIL CAP LOCATED ON THE PROPERTY SHALL BE MAINTAINED
IN GOOD REPAIR IN ORDER TO PREVENT DIRECT CONTACT WITH
THE LANDFILL MATERIALS, REDUCE INFILTRATION AND LEACHING
OF CONTAMINANTS AND MINIMIZE RUN-OFF TRANSPORT OF
CONTAMINANTS;
C. THE SOIL CAP LOCATED ON THE PROPERTY SHALL NOT BE
EXCAVATED OR DISTURBED EXCEPT FOR MINOR EXCAVATIONS
NECESSARY TO INSTALL, MAINTAIN, OR REPAIR FENCES UNLESS
APPROVED IN ADVANCE IN WRITING BY THE EPA OR ITS ASSIGNS;
D. THE PROPERTY MAY NOT BE USED FOR ANY RESIDENTIAL OR
AGRICULTURAL PURPOSES UNLESS APPROVED IN ADVANCE IN
WRITING BY THE EPA OR ITS ASSIGNS; AND
E. THE FENCE LOCATED ON THE PROPERTY SHALL BE MAINTAINED IN
GOOD CONDITION AND REPAIR. THE HAZARDOUS CHEMICAL
WARNING SIGNS SHALL CONTINUOUSLY BE DISPLAYED IN A
CONSPICUOUS PLACE ON SAID FENCE, AND SUCH SIGNS SHALL BE
MAINTAINED IN LEGIBLE CONDITION.
5
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9. Notice upon Conveyance: Grantor and any subsequent Transferee shall notify EPA
within ten (10) days following each conveyance of an interest in the Property, or any portion thereof.
The notice shall include the name, address, and telephone number of the Transferee, and a copy of the
deed or other documentation evidencing the conveyance.
10. Representations and Warranties: Grantor hereby represents and warrants to EPA that
Grantor has the power and authority to enter into this Environmental Covenant, to grant the rights and
interests herein provided and to carry out all of Grantor's obligations hereunder, and that Grantor is the
sole owner of the Property and holds fee simple title which is free, clear, and unencumbered.
11. Amendment or Termination: This Environmental Covenant may be amended or
terminated by consent signed by EPA, IDNR and Grantor or its Transferee. Within thirty (30) days of
signature by all requisite parlies on any amendment or termination of this Environmental Covenant,
Grantor or its Transferee shall file such instrument for recording with the Office of the Recorder of
Deeds of Floyd County, Iowa, and shall provide a file- and date-stamped copy of the recorded
instrument to EPA.
12. Severability: If any provision of this Environmental Covenant is found to be
unenforceable in any respect, the validity, legality, and enforceability of the remaining provisions shall
not in any way be affected or impaired.
13. Governing Law: This Environmental Covenant shall be governed by and interpreted in
accordance with the laws of the State of Iowa.
14. Recordation: Within thirty (30) days after the dale of the final required signature upon
this Environmental Covenant, Grantor shall record this Environmental Covenant with the Office of the
Recorder of Deeds of Floyd County, Iowa.
15. Effective Date: The effective date of this Environmental Covenant shall be the dale upon
which the fully executed Environmental Covenant has been recorded as a deed record for the Property
with the Office of the Recorder of Deeds of Floyd County, Iowa.
16. Distribution of Environmental Covenant: Within thirty (30) days following the
reccording of this Environmental Covenant, Grantor shall, in accordance with Iowa Code § 4551.7,
distribute a file- and date-stamped copy of the recorded Environmental Covenant to: (a) each signatory
hereto; (b) each person holding a recorded interest in the Property; (c) each person in possession of the
Property; (d) each municipality or other unit of local government in which the Property is located; and
(c) any other person designated by EPA.
17. Notice to EPA: Any document, notice, or other item required by this Environmental
Covenant to be given to EPA shall be sent to:
Superfund Division Director
U.S. Environmental Protection Agency, Region VII
901 North 5lh Street
Kansas City, Kansas 66101
6
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EPA may change the recipient title unci address from lime lo lime and will provide written notice to
Holder or its Transferee of any such changes.
18. Termination of Declaration: ll is the intention of the parties for this Environmental
Covenant to supersede and take the place of the Restrictive Covenant referred to above. Accordingly,
thai Restrictive Covenant is hereby revoked, rescinded, and terminated.
The undersigned represents and certifies that he/she is authorized to execute this Environmental
Covenant on behalf of Holder. EPA and 1DNR.
IT IS SO AGREED:
GRANTOR:
Date: 1 Q
Name (print): fA~C W 6"' A- , Qt I CX-{ft'} d
Title:_
UL
2L£l£)C[
STATE OE ~T7> A
COUNTY OE JEXg_i^_A_
On this Surlily of Ini-- , 2()09-before me a Notary Public in and for said stale,
persona 11 y appeared a-it»¦ L., fel.^^lAf-WvMEl , -PVW, A^-CT- 1 TITLE I , of
I I.E. Construction. Inc.. known to me to be the person who executed the within Environmental Covenant
in behalf of said corporation and acknowledged to me that he/she executed the same for the purposes
therein staled.
yT tLARRY R. STEWART
Commission No.: 107620
iMBi My ComroiasioaExpiic3
,OWA n / I
Notary Pub
JLA/
V
7
-------
HOLDER:
Name (pnnQr^trjyrTle^ j^ yylK' pLZ.-
Title:. ~l~
_Date: ) r\
H
STATE Of 'ICUx?^
COUNTY OF T17! p ^ A
On this 2l1 (-lay ol' (f\'
personally appeared^i^^ X/{
)
. 2l,
iCfa$An
-------
AGENCY:
FOR THE U.S. ENVIRONMENTAL PROTECTION AGENCY
By: ^ Date: >
Name (printer- "^Fon ia" \ ATP1A
Title: "HP. *!>mszsv»V. , Cx.dpg-^Sr( itf reiwa
STATE OF 6 )
COUNTY OF nJo ij^ )
On this 6>f ii day of Dch , 2009, before me a Notary Public in and for said state,
personally appeared Cecilia Tapia (or her designee), the Director of EPA Region Vll's Superfund
Division, known to me to be the person who executed the within Environmental Covenant in behalf of
EPA and acknowledged to me thai she executed the same for the purposes /herein stated.
Notary Public
KENT JOHNSON
notary pumjc
STATE OF KANSAS.
My Appl. Exp. 7/1~S///
9
-------
AGENCY:
FOR THE IOWA DEPARTMENT OF NATURAL RESOURCES
:-7. "" '*
By:.
Date:
Name (print):.
Title: tX'rfc *\f)/
JO -<6-0^
STATE OF
\tm
COUNTY OF
Ml
On this day of () , 2009, before me a Notary Public in and for said state,
personally appeared the Director of the Iowa Department of Natural Resources or the lawful designee of
the Director who executed the foregoing instrument, and acknowledge that this person executed the
same for the purposes therein stated.
LISA NISSEN
|A V COMMISSION NO. 721371
~jga * I MY COMMISSION EXPIRES
lovt* I -o-< 7IQ.
Notary Public
10
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Attachment D
Public Notice
-------
U.S. Environmental Protection Agency
(EPA) Region 7 Starts the Fourth Five-Year
Review for the White Farm Equipment
Company Dump Superfund Site, Charles
City, Floyd County, Iowa
EPA has started the fourth Five-Year Review at the White Farm Equipment Company
Dump Superfund site. The review is required by the Superfund law to make sure
completed cleanups continue to protect human health and the environment.
The contaminants of concern at the site include heavy metals such as arsenic, chromium,
and lead, among others, and volatile organic compounds (VOCs) from former waste
disposal practices on site.
The third Five-Year Review found that the site remedy remains protective. The final
report of the fourth Five-Year Review will be available on the EPA Region 7 website at:
http://www.epa.gov/region7/cleanup/index.htm
EPA encourages community members to ask questions and report any concerns about
the site. A paper copy of the Five Year Review report and detailed information about
the site is available at the following locations:
Charles City Public Library EPA Records Center
106 Milwaukee Mall 11201 Renner Boulevard
Charles City, Iowa Lenexa, Kan.
Questions or requests for site information and/or the five-year review process can be
submitted to:
Ben Washburn
U.S. Environmental Protection Agency
Community Involvement Coordinator
11201 Renner Boulevard, Lenexa KS, 66219
Toll free: 800-223-0425
Email: washburn.ben@epa.gov
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Attachment E
Inspection Checklist
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Site Inspection Checklist
I. SITE INFORMATION
Site name: White Farm Equipment Company Site
Date of inspection: 27 August 2013
Location and Region: Charles City, Floyd County,
Iowa
EPA ID: 1AD065210734
Agency, office, or company leading the five-year
review: U.S. EPA Region 7
Weather/temperature: Sunny, mid-80's
Remedy Includes: (Check all that apply)
El Landfill cover/containment
Rl Access controls
0 Institutional controls
CD Groundwater pump and treatment
~ Surface water collection and treatment
~ Other:
l~l Monitored natural attenuation
CD Groundwater containment
CD Vertical barrier walls
Attachments:
Inspection team roster attached
l~~l Site map attached
I. INTERVIEWS (Check all that apply)
I. O&M site manager
Name
Title
Interviewed CD at site CD at office CD by phone Phone no.
Problems, suggestions; CD Report attached
Date
2 O&M staff
Name Title
~ I * i i
at site LJ at office LJ by phone Phone no.
Problems, suggestions; CD Report attached
Date
Five-year Review Report - 1
-------
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 1DNR
Contact Bob Drustrup Project Manager 515-281-8900
Name Title Date Phone no.
Problems; suggestions; EH Report attached No significant concerns with the site.
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; EH Report attached
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; ED Report attached
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; EH Report attached
4. Other interviews (optional) K Matthew Ross, land user. No significant concerns with the site.
Five-year Review Report - 2
-------
111. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1. O&M Documents
1 1 O&M manual ED Readily available ED Up to date ED N/A
1 1 As-built drawings ED Readily available ED Up to date ED N/A
1 1 Maintenance logs ED Readily available ED Up to date ED N/A
Remarks There are no facilities at the site so no O&M documents are available at the site.
2
Site-Specific Health and Safety Plan dl Readily available ED Up to date
1 1 Contingency plan/emergency response plan ED Readily available ED Up to date
Remarks
M N/A
M N/A
3.
O&M and OSHA Training Records ED Readily available EH Up to date
Remarks
N/A
4.
Permits and Service Agreements
CD Air discharge permit EH Readily available EH Up to date
ED Effluent discharge ED Readily available ED Up to date
ED Waste disposal, POTW ED Readily available ED Up to date
ED Other permits ED Readily available ED Up to date
Remarks
M N/A
[El N/A
M N/A
IEIn/a
5.
Gas Generation Records ED Readily available ED Up to date ^ N/A
Remarks
6.
Settlement Monument Records ED Readily available ED Up to date
Remarks
M N/A
7.
Groundwater Monitoring Records ED Readily available ED Up to date
Remarks Groundwater samoline has not been performed since the previous inspections.
[El N/A
no records
were available for review.
8.
Leachate Extraction Records ED Readily available ED Up to date
Remarks
M N/A
9.
Discharge Compliance Records
ED Air ED Readily available ED Up to date ^ N/A
ED Water (effluent) ED Readily available ED Up to date ^ N/A
Remarks
10.
Daily Access/Security Logs ED Readily available ED Up to date
Remarks
M N/A
Five-year Review Report - 3
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IV. O&M COSTS
1. O&M Organization
I I State in-house EH Contractor for State
I I PRP in-house EH Contractor for PRP
I I Federal Facility in-house EH Contractor for Federal Facility
[Xl Other PRP is bankrupt so IDNR is responsible for O&M
O&M Cost Records
I I Readily available EH Up to date
I I Funding mechanism/agreement in place
Original O&M cost estimate EH Breakdown attached
Total annual cost by year for review period if available
From
To
1 1 Breakdown attached
Date
Date
Total cost
From
To
1 1 Breakdown attached
Date
Date
Total cost
From
To
1 I Breakdown attached
Date
Date
Total cost
From
To
1 1 Breakdown attached
Date
Date
Total cost
From
To
1 1 Breakdown attached
Date
Date
Total cost
3. Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons:
V. ACCESS AND INSTITUTIONAL CONTROLS ^Applicable EH N/A
A. Fencing
1. Fencing damaged EH Location shown on site map EH Gates secured EH N/A
Remarks Fencing was in good condition, vegetation which had begun to grow alone the fencing has
been cleared bv the site user.
B. Other Access Restrictions
1. Signs and other security measures EH Location shown on site map EH N/A
Remarks Four signs were identified along the fenceline during the inspection, all signs were in good
condition and legible.
Five-year Review Report - 4
-------
C. Institutional Controls (ICs)
Implementation and enforcement
Site conditions imply ICs not properly implemented CD Yes [X] No IZI N/A
Site conditions imply ICs not being fully enforced CD Yes S No CD N/A
Type of monitoring (e.g., self-reporting, drive by) Inspection of capped areas and access controls
Frequency Annual inspection bv State of Iowa
Responsible party/agency EPA and 1DNR
Contact
Name Title Date Phone no.
Reporting is up-to-date CD Yes CD No CD N/A
Reports are verified by the lead agency CD Yes CD No 0 N/A
Specific requirements in deed or decision documents have been met CD Yes ~ No ~ N/A
Violations have been reported ~ Yes ~ No 13 N/A
Other problems or suggestions; CD Report attached
2, Adequacy Q ICs are adequate CD ICs are inadequate CD N/A
Remarks
D. General
1. Vandalism/trespassing CD Location shown on site map S No vandalism evident
Remarks Damage has occurred to Monitoring Well WFE-6A. however it is not believed to have been
intentional
2. Land use changes on site CD N/A
Remarks The new land user has grazed sheep on the site and also intends to plant and harvest hay.
3. Land use changes off siteH N/A
Remarks
VI. GENERAL SITE CONDITIONS
A. Roads 13 Applicable CD N/A
Roads damaged CD Location shown on site map H Roads adequate CD N/A
Remarks
Five-year Review Report - 5
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B.
Other Site Conditions
Remarks
VII. LANDFILL COVERS 13 Applicable ~ N/A
A.
Landfill Surface
1.
Settlement (Low spots)
Areal extent
Remarks
~ Location shown on site map ^ Settlement not evident
Depth
2
Cracks
Lengths Widths
1 1 Location shown on site map ^ Cracking not evident
Depths
Remarks
3.
Erosion
Areal extent
Remarks
1 1 Location shown on site map ^ Erosion not evident
Depth
4.
Holes
Areal extent
Remarks
1 1 Location shown on site map ^ Holes not evident
Depth
5.
Vegetative Cover ^ Grass E] Cover properly established ^ No signs of stress
¦ Trees/Shrubs (indicate size and locations on a diagram)
Remarks Small volunteer trees were identified, but the land user is in the process of havine them
removed as Dart of havine the site.
6.
Alternative Cover (armored rock, concrete, etc.) ^ N/A
Remarks
7.
Bulges
Areal extent
Remarks
1 1 Location shown on site map ^ Bulges not evident
Height
8.
Wet Areas/Water Damage
1 1 Wet areas
1 1 Ponding
1 1 Seeps
EH Soft subgrade
Remarks
Wet areas/water damage not evident
~ Location shown on site map Areal extent
1 1 Location shown on site map Areal extent
1 1 Location shown on site map Areal extent
~ Location shown on site map Areal extent
Five-year Review Report - 6
-------
9.
Slope Instability ED Slides EH Location shown on site map E] No evidence of slope instability
Areal extent
Remarks
B.
Benches EH Applicable E3 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 EH Location shown on site map EH N/A or okay
Remarks
2
Bench Breached EH Location shown on site map EH N/A or okay
Remarks
3.
Bench Overtopped EH Location shown on site map EH N/A or okay
Remarks
C.
Letdown Channels EH Applicable ^ 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 EH Location shown on site map EH No evidence of settlement
Areal extent Depth
Remarks
2.
Material Degradation EH Location shown on site map EH No evidence of degradation
Material type Areal extent
Remarks
3.
Erosion EH Location shown on site map EH No evidence of erosion
Areal extent Depth
Remarks
Five-year Review Report - 7
-------
4.
Undercutting EH Location shown on site map ^ No evidence of undercutting
Areal extent Depth
Remarks
5.
Obstructions Type E3 No obstructions
1 1 Location shown on site map Areal extent
Size
Remarks
6.
Excessive Vegetative Growth Type
1 1 No evidence of excessive growth
1 1 Vegetation in channels does not obstruct flow
1 1 Location shown on site map Areal extent
Remarks
D.
Cover Penetrations EH Applicable 13 N/A
1.
Gas Vents ED Active EH Passive
EH Properly secured/locked EH Functioning EH Routinely sampled
EH Evidence of leakage at penetration EH Needs Maintenance
~ N/A
Remarks
EH Good condition
2.
Gas Monitoring Probes
EH Properly secured/locked EH Functioning EH Routinely sampled
EH Evidence of leakage at penetration EH Needs Maintenance EH N/A
Remarks
EH Good condition
3.
Monitoring Wells (within surface area of landfill)
EH Properly secured/locked EH Functioning EH Routinely sampled
EH Evidence of leakage at penetration EH Needs Maintenance 1 1 N/A
Remarks
EH Good condition
4.
Leachate Extraction Wells
EH Properly secured/locked EH Functioning EH Routinely sampled
EH Evidence of leakage at penetration EH Needs Maintenance EH N/A
Remarks
EH Good condition
5.
Settlement Monuments EH Located EH Routinely surveyed
Remarks
~ N/A
Five-year Review Report - 8
-------
E.
Gas Collection and Treatment EH Applicable 0N/A
1.
Gas Treatment Facilities
1 1 Flaring EH Thermal destruction EH Collection for
1 1 Good condition EH Needs Maintenance
Remarks
reuse
2
Gas Collection Wells, Manifolds and Piping
EH Good condition EH Needs Maintenance
Remarks
3.
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
EH Good condition EH Needs Maintenance EH N/A
Remarks
F.
Cover Drainage Layer EH Applicable
13 N/A
1.
Outlet Pipes Inspected EH Functioning
Remarks
~ N/A
2.
Outlet Rock Inspected EH Functioning
Remarks
~ N/A
G.
Detention/Sedimentation Ponds K Applicable
~ N/A
1.
Siltation Areal extent Depth
~ N/A
[x] Siltation not evident
Remarks
2.
Erosion Areal extent Depth
R1 Erosion not evident
Remarks
3.
Outlet Works ^ Functioning EH N/A
Remarks
4.
Dam EH Functioning ^ N/A
Remarks
Five-year Review Report - 9
-------
H
Retaining Walls EH Applicable ^ N/A
1. Deformations EH Location shown on site map [D Deformation not evident
Horizontal displacement Vertical displacement
Rotational displacement
Remarks
?
Degradation EH Location shown on site map ^ Degradation not evident
Remarks
I.
Perimeter Ditches/Off-Site Discharge EH Applicable EH N/A
1.
Siltation EH Location shown on site map ^ Siltation not evident
Areal extent Depth
Remarks
2.
Vegetative Growth EH Location shown on site map EH N/A
Vegetation does not impede flow
Areal extent Type
Remarks
3.
Erosion EH Location shown on site map ^ Erosion not evident
Areal extent Depth
Remarks
4.
Discharge Structure ^ Functioning EH N/A
Remarks
VIII. VERTICAL BARRIER WALLS ~ Applicable M N/A
1. Settlement EH Location shown on site map EH Settlement not evident
Areal extent Depth
Remarks
9
Performance MonitoringType of monitoring
EH Performance not monitored
Frequency 1 1 Evidence of breaching
Head differential
Remarks
Five-year Review Report - 10
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IX. GROUNDWATER/SURFACE WATER REMEDIES ~ Applicable ~ N/A
A. Groundwater Extraction Wells, Pumps, and Pipelines EH Applicable ^ N/A
1. Pumps, Wellhead Plumbing, and Electrical
I I Good condition EH All required wells properly operating EH Needs Maintenance ~ N/A
Remarks
Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
I I Good condition EH Needs Maintenance
Remarks
3. Spare Parts and Equipment
I I Readily available EH Good condition EH Requires upgrade EH Needs to be provided
Remarks
B. Surface Water Collection Structures, Pumps, and Pipelines EH Applicable ^ N/A
1. Collection Structures, Pumps, and Electrical
I I Good condition EH Needs Maintenance
Remarks
Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
EH Good condition EH Needs Maintenance
Remarks
3. Spare Parts and Equipment
EH Requires upgrade EH Needs to be provided
1 1 Readily available
I I Good condition
Remarks
C. Treatment System
EH Applicable K
N/A
1. Treatment Train (Check components that apply)
n Metals removal EH Oil/water separation EH Bioremediation
I I Air stripping EH Carbon adsorbers
EH Filters
EH Additive (e.g., chelation agent, flocculent)
I I Others
I I Good condition EH Needs Maintenance
EH Sampling ports properly marked and functional
I I Sampling/maintenance log displayed and up to date
I I Equipment properly identified
I I Quantity of groundwater treated annually
I I Quantity of surface water treated annually
Remarks
Five-year Review Report - 11
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2
Electrical Enclosures and Panels (properly rated and functional)
1 1 N/A EH Good condition EH Needs Maintenance
Remarks
3.
Tanks, Vaults, Storage Vessels
EH N/A EH Good condition EH Proper secondary containment EH Needs Maintenance
Remarks
4.
Discharge Structure and Appurtenances
EH N/A EH Good condition EH Needs Maintenance
Remarks
5.
Treatment Building(s)
EH N/A EH Good condition (esp. roof and doorways) EH Needs repair
EH Chemicals and equipment properly stored
Remarks
6.
Monitoring Wells (pump and treatment remedy)
EH Properly secured/locked EH Functioning EH Routinely sampled EH Good condition
EH All required wells located EH Needs Maintenance EH N/A
Remarks
D. Monitoring Data
1.
Monitoring Data
EH Is routinely submitted on time EH Is of acceptable quality
2.
Monitoring data suggests:
EH Groundwater plume is effectively contained EH Contaminant concentrations are declining
E.
Monitored Natural Attenuation
1.
Monitoring Wells (natural attenuation remedy)
EH Properly secured/locked EH Functioning EH Routinely sampled EH Good condition
EH All required wells located ^ Needs Maintenance EH N/A
Remarks Wells WFE 7A and 7B could not be located due to overerowth and standine water. Well WFE
6A was found detached, the below 2rade Dortion of the well could not be identified. Well WFE 5A was
found to have a missins well casine caD. as well as a missine well caD.
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.
Five-year Review Report - 12
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XI. OVERALL OBSERVATIONS
A. Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).
See report text.
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.
See report text. ¦
Five-year Review Report - 13
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C. Earlv 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 future.
See report text.
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
See report text.
Five-year Review Report - 14
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Site Inspection Team Roster
Personnel
Representing
Phone Number
Kenneth Kamp
U.S. Army Corps of Engineers
816-389-3642
Paul Speckin
U.S. Army Corps of Engineers
816-389-3592
Five-year Review Report - 15
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Attachment F
Inspection Photos
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WHITE FARM EQUIPMENT SITE INSPECTION PHOTOS 27-AUGUST-2013
Monitoring Wells WFE 5A (right) and SB (left). Note the missing protective casing lid and missing well
cap.
Monitoring Well WFE 6B, well casing lid was slightly damaged but still functional.
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Remnants of Monitoring Well WFE 6A, the PVC well riser was found laying in the brush (center), a chunk
of concrete was found uprooted near the spot where the well should be located (bottom left).
Close up of the PVC riser for Monitoring Well WFE 6A.
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Landfill cap, notice small volunteer tree at left-center. Photo taken from interior north east corner,
facing south by southeast.
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Volunteer trees located along the northeast fence line, land user intends to have them removed in order
to hay the field. Photo taken from interior north east corner, facing east.
Drainage channel along eastern fence line.
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.Vf t4 * . »> f* t- r 17 'Rfc-vM" "
*
Retention area and overflow structure at southeast corner of site.
Volunteer trees located along southern fence line. The standing water in the background is where
Monitoring Wells 7A and 7B are located.
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»f
Typical signage. Four signs were identified during the site inspection. Photo taken at southern fence
line, facing south.
Western fence line and drainage channel. Photo taken from north end of site, facing south.
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Attachment G
Groundwater and Soil Contaminants of Concern
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Soils Chemicals of Concern from 1990 HHRA (Previously called Indicator Chemicals)
Chemical
May 2014
Industrial Soil
RSLs
(ma^kg)
Basis*
Maximum detected
concentrations mg/kg
(ROD, 1990)
Does the maximum
detected
concentration exceed
the RSL?
Arsenic
3
c
13
Yes
Barium
22000
n
26
No
Cadmium (Diet)
98
n
89
No
Chromium (III)
180000
n
210
No
Chromium (VI)
6.3
c
<1.2
No
Copper
4700
n
410
No
Lead
800
(1)
9700
Yes
Manganese
2600
n
2100
No
Nickel Soluble Salts
2200
n
390
No
Zinc
35000
n
11000
No
Benzo (b) Fluoranthene
2.9
c
680
Yes
Benzo (k) Fluoranthene
29
c
680
Yes
Benzo (a) Pyrene
0.21
c
3600
Yes
Naphthalene
17
c
3700
Yes
Phenanthrene
NA
980
Phenol
25000
n
930
No
Samples collected from landfill materials (above native material) contained variable concentrations of metals
Note: The 1990 HHRA states that Cr VI was analyzed for and not detected above background concentrations.
c= RSL based on potential excess cancer risk of 1 x 10-6.
n=RSL based on non-cancer effects with an HI of 0.1.
(1) EPA has no consensus RfD or CSF for inorganic lead. EPA considers lead to be a special case because of the difficulty in
identifying the classic "threshold" needed to develop an RfD.
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Groundwater Chemicals of Concern from 1990 HHRA (Previously called Indicator Chemicals)
CHEMICAL
CAS No.
Maximum detected
filtered concentration
(mg/L)
Old MCL used in
HHRA(l) (mg/L)
Current MCL
(mg/L)
Carcinogenic SL
TR=1.0E-6
(mg/L)
Noncarcinogenic
SL
HI=0.1
(mg/L)
Is the maximum
detected greater
than MCL or
Health based
standard?
Arsenic, Inorganic
7440-38-2
0.003
0.05
0.01
0.000052
0.0006
Yes
Barium
7440-39-3
0.19
1
2
0.38
No
Iron
7439-89-6
0.82
0.3 (Secondary)
0.5 (Secondary)
1.4
Yes
-Lead and Compounds
7439-92-1
0.009
0.05
0.015 (action level)
No
Manganese (Non-diet)
7439-96-5
7.7
0.05 (Secondary)
0.05 (Secondary)
0.032
Yes
Zinc and Compounds
7440-66-6
0.19
5(Secondary)
5(Secondary)
0.47
No
Benzene
71-43-2
0.025
0.005
0.005
0.00045
0.0033
Yes
Ethylbenzene
100-41-4
0.045
Not listed
0.7
0.0015
0.081
Yes
Xylenes
1330-20-7
0.39
Not listed
10
0.019
Yes
-Acenaphthene
83-32-9
0.017
Not listed
NA
0.053
No
-Naphthalene
91-20-3
0.02
Not listed
NA
0.00017
0.00061
Yes
Toluene
108-88-3
0.072
Not listed
1
0.11
No
Note that there was only one groundwater sample (WFE-1) that contained detections of organic chemicals
1) Table 2-2 in the HHRA identified contaminants by media that were detected above background concentrations. Table 4-4 stated the MCLs in
1990 HHRA. Based on Safe Drinking Water Act 47 FR 10998 March 2, 1982 and 52 FR 25712 July 8, 1987 Safe Drinking Water Act 51 FR 11412
April 2, 1986. Current MCL is based on the the 2012 version of the SDWA.
2) RSL is May 2014 based on residential groundwater use
3) Maximum detected filtered groundwater concentration from Table 1-3 in the 1990 HHRA
4) Secondary MCLs are non-enforcable MCL's
5) Lead action level 0.015 mg/L.
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AIC and AIS (Formerly Table 4-1 of the 1990 HHRA)
Acceptable Intake Ingestion Route
Current Toxicity
Indicator Chemical
(1990 HHRA)
Values (b)
Subchronic (AIS)
Chronic (AIC)
RfD (chronic)
mg/kg/day
mg/kg/day
mg/kg/day
Arsenic
0.001
0.001
0.0003
Barium
0.05
0.05a
0.2
Cadmium
0.0005
0.001
Chromium (III)
1
1.5
Chromium (VI)
0.003
Copper
0.037
0.037
0.04
Iron
0.7
Lead
0.0014
NA
Manganese
0.5
0.2
0.024
Nickel
0.02
0.02a
0.02 (non-diet)
Nitrate-Nitrogen
1.6 (soluble salts)
Zinc
0.2
0.2
0.3
Benzene
0.004
Ethylbenzene
0.1
0.1
Toluene
0.4
0.3
0.08
Xylenes, total
4
2a
0.2
Acenaphthene
0.06
Benzo (a) pyrene
NA
Benzo (b) fluoranthene
NA
Benzo (k) fluoranthene
NA
Naphthalene
0.4
0.4
0.02
Phenanthrene
NA
Phenol
0.04
0.3
a - Source: R&D, IRIS Database (revised 3/1/88)
(b) Regional Screening Levels Updated May, 2014; Retrieved 6-12-2014
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Carcinogen Toxicity (Formerly Table 4-2 of the 1990 HHRA)
Ingestion Route
Current Toxicity
(1990 HHRA)
Values (b)
Potency Factor
Oral Slope Factor
Indicator Chemical
mg/kg/day
(mg/kg-day)"1
Arsenic
1.5a
1.5
Barium
Cadmium
Chromium (III)
Chromium (VI)
0.5
Copper
Iron
Lead
Manganese
Nickel
Nitrate-Nitrogen
Zinc
Benzene
0.029a
0.055
Ethylbenzene
0.011
Toluene
Xylenes, total
Acenaphthene
Benzo (a) pyrene
11.5
7.3
Benzo (b) fluoranthene
0.73
Benzo (k) fluoranthene
0.073
Naphthalene
Phenanthrene
Phenol
a - Source: R&D, IRIS Database (revised 3/1/88)
(b) Regional Screening Levels Updated May, 2014; Retrieved 6-12-2014
Note: The 1990 HHRA used a Potency Factor whereas current toxicity values are
calcuted by an Oral Slope Factor.
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