FOURTH FIVE-YEAR REVIEW REPORT FOR
CITY OF PERRYTON WELL NO. 2 SUPERFUND SITE
OCHILTREE COUNTY, TEXAS

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Prepared by

U.S. Environmental Protection Agency
Region 6
Dallas, Texas


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FOURTH FIVE-YEAR REVIEW REPORT
CITY OF PERRYTON WELL NO. 2 SUPERFUND SITE
OCHILTREE COUNTY, TEXAS
EPA ID#: TX0001399435

This memorandum documents the U.S. Environmental Protection Agency's performance, determinations and
approval of the fourth five-year review for the City of Perryton Well No. 2 Superfund site (Site) under Section
121(c) of the Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S. Code
Section 9621(c), as provided in the attached Fourth Five-Year Review Report.

Summary of the Fourth Five-Year Review Report

The Site remedy for the single operable unit consists of long-term remedial actions to address contaminated
groundwater. The groundwater remedial actions began with pumping and treating contaminated groundwater
in Lower Zone Unit 3 and long-term monitoring. The protectiveness of the remedy is not anticipated to be
affected by climate change.

In 2011, EPA revised the groundwater remedy by establishing a Technical Impracticability (TI) Zone in the
Upper Zone/Lower Zone Unit 2, requiring institutional controls for the properties above the remaining
groundwater contamination and long-term monitoring. The city of Perryton adopted a city ordinance in April
2018 that applies to the entire area within the city limits. It prevents installation of a well that would create a
vertical migration pathway between the Upper Zone and the Lower Zone of the Ogallala aquifer and prevents
installation of a well that would cause migration of contaminants outside the TI Zone. Carbon tetrachloride
(CTC) concentrations remain in Lower Zone Unit 3 above the Record of Decision cleanup goal. However,
recent well installations have delineated the Lower Zone Unit 3 plume. In the Upper Zone/Lower Zone Unit
2, several wells at the TI boundary exceed the CTC cleanup goal, indicating more delineation is needed and
modification of the remedy may be necessary.

The EJScreen report (Appendix K) identifies three Environmental Justice (EJ) indices that exceed the 80th
percentile at either the national or state average level. The EJ indices flagged are Ozone, Superfund
Proximity, and Underground Storage Tanks. Public input was solicited through a public notice in the Perryton
Herald newspaper on 11/17/2022. Comments and Site interviews are included in Section IV, Community
Notification, Involvement & Site Interviews.

Actions Needed

The following actions must be taken for the remedy to be protective over the long term:

•	Delineate the Upper Zone/Lower Zone Unit 2 CTC plume and modify the remedy as appropriate.

•	Determine the source of contamination to groundwater and determine if additional remedial action is
needed to achieve remedial action objectives.

Determination

I have determined that the remedy for the City of Perryton Well No. 2 Superfund Site is currently
protective of human health and the environment in the short term. This five-year review report specifies the
actions that need to be taken for the remedy to remain protective over the long term.

I I C A nni I- Digitally signed by LISA PRICE

Lib A PKILt Date:202305 91724:12

-05 00

Lisa Price

Acting Director, Superfund and Emergency Management Division
U.S. Environmental Protection Agency, Region 6


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ISSUES/RECOMMENDATIONS

FOURTH FIVE-YEAR REVIEW REPORT
CITY OF PERRYTON WELL NO. 2 SUPERFUND SITE
OCHILTREE COUNTY, TEXAS
EPA ID#: TX0001399435

Issues iincl Rocom in oil cl :it ion s Identified in (lie l-'Yk:

OU(s): Sitewide

Issue Category: Remedy Performance

Issue: The Upper Zone/Lower Zone Unit 2 CTC plume has migrated beyond the current
TI Zone boundary.

Recommendation: Delineate the Upper Zone/Lower Zone Unit 2 CTC plume and
modify the remedy as appropriate.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight
Party/Support
Agency

Milestone Date

No

Yes

EPA

EPA/State

7/18/2026

OU(s): Sitewide

Issue Category: Remedy Performance

Issue: CTC concentrations in the Lower Zone Unit 3 are increasing and the CTC
concentrations exceeded the cleanup goal in eight wells in 2022.

Recommendation: Conduct an optimization study to determine the source of
contamination to groundwater and determine if additional remedial action is needed to
achieve RAOs.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight
Party/Support
Agency

Milestone Date

No

Yes

EPA

EPA/State

7/18/2026


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Table of Contents

LIST 01 ABBREVIATIONS AND ACRONYMS	3

I.	INTRODUCTION	4

Site Background	4

FIVE-YEAR REVIEW SUMMARY FORM	5

II.	RESPONSE ACTION SUMMARY	7

Basis for Taking Action	7

Response Actions	7

Status of Implementation	9

Systems Operations/O&M	13

III.	PROGRESS SINCE THE PREVIOUS REVIEW	13

IV.	FIVE-YEAR REVIEW PROCESS	14

Community Notification, Community Involvement and Site Interviews	14

Data Review	15

Site Inspection	19

V.	TECHNICAL ASSESSMENT	19

QUESTION A: Is the remedy functioning as intended by the decision documents?	19

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the

remedy selection still valid?	20

QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy?	21

VI.	ISSUES/RECOMMENDATIONS	21

OTHER FINDINGS	21

VII.	PROTECTIVENESS STATEMENT	22

VIII.	NEXT REVIEW	22

APPENDIX A - REFERENCE LIST	A-l

APPENDIX B - SITE CHRONOLOGY	B-l

APPENDIX C - PRESS NOTICE	C-l

APPENDIX D - SITE INSPECTION CHECKLIST	D-l

APPENDIX E - REMEDIAL ACTION AND SITE INSPECTION PHOTOS	E-l

APPENDIX F - DATA REVIEW FIGURES	F-l

APPENDIX G - CLEANUP GOAL REVIEW TABLES	G-l

APPENDIX H - VAPOR INTRUSION SCREENING-LEVEL RISK REVIEW	11-1

APPENDIX I - INTERVIEW FORMS	1-1

APPENDIX J - CITY WELL ORDINANCE	J-l

Tables

Table 1: Site COCs, by Media	7

Table 2: Summary of RAOs and Groundwater Remedy Components	8

Table 3: Final Groundwater COC Cleanup Goals	8

Table 4: Summary of Planned and/or Implemented Institutional Controls	11

Table 5: Protectiveness Determinations/Statements from the 2018 FYR Report	13

Table 6: Status of Recommendations from the 2018 FYR Report	14

Table 7: Lower Zone Monitoring Wells CTC Concentrations Above MCL (2019 to 2022)	16

Table 8: Select Upper Zone Monitoring Wells CTC Concentrations (2019 to 2022)	17

Table 9: City Supply Wells CTC Concentrations (2019to 2022)	17

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Table B-l: Site Chronology	B-l

Table G-l: Cleanup Goal Review for Groundwater COCs	G-l

Table H-l: Screening-Level Vapor Intrusion Evaluation	H-l

Figures

Figure 1: Site Vicinity Map	6

Figure 2: Institutional Control Map	12

Figure 3: Detailed Site Map	18

Figure F-l: Upper Zone Hydrograph	F-l

Figure F-2: Lower Zone Unit 2 Hydrograph	F-2

Figure F-3: Lower Zone Unit 3 Hydrograph	F-3

Figure F-4: Upper Zone/Lower Zone Unit 2 Potentiometric Surface Map, 2022	F-4

Figure F-5: Lower Zone Unit 3 Potentiometric Surface Map, 2022	F-5

Figure F-6: Upper Zone/Lower Zone Unit 2 CTC Plume, 2019	F-6

Figure F-7: Upper Zone/Lower Zone Unit 2 CTC Plume, 2022	F-7

Figure F-8: Upper Zone/Lower Zone Unit 2 CTC Concentrations Over Time	F-8

Figure F-9: Lower Zone Unit 3 CTC Plume, 2019	F-9

Figure F-10: Lower Zone Unit 3 CTC Plume, 2022	F-10

Figure F-11: Lower Zone Unit 3 CTC Concentrations Over Time	F-ll

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LIST OF ABBREVIATIONS AND ACRONYMS

ARAR

Applicable or Relevant and Appropriate Requirement

ASTP

Air Stripper Treatment Plant

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CFR

Code of Federal Regulations

COC

Contaminant of Concern

CTC

Carbon Tetrachloride

EJ

Environmental Justice

EPA

United States Environmental Protection Agency

FYR

Five-Year Review

HQ

Hazard Quotient

IC

Institutional Control

LTRA

Long-Term Remedial Action

MCL

Maximum Contaminant Level

MCLG

Maximum Contaminant Level Goal

|ig/L

Micrograms per Liter

MPMW

Multi-Port Monitoring Well

MW

Monitoring Well

NCP

National Contingency Plan

NPL

National Priorities List

O&M

Operation and Maintenance

OU

Operable Unit

P&T

Pump and Treat

PEX

Perryton Equity Exchange

PRP

Potentially Responsible Party

RAO

Remedial Action Objective

RI/FS

Remedial Investigation/Feasibility Study

RO

Reverse Osmosis

ROD

Record of Decision

RPM

Remedial Project Manager

TCEQ

Texas Commission on Environmental Quality

TDH

Texas Department of Health

TI

Technical Impracticability

TNRCC

Texas Natural Resource Conservation Commission

TWC

Texas Water Commission

UU/UE

Unlimited Use/Unrestricted Exposure

VISL

Vapor Intrusion Screening Level

VOC

Volatile Organic Compound

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I. INTRODUCTION

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to
determine if the remedy is and will continue to be protective of human health and the environment. The methods,
findings and conclusions of reviews are documented in FYR reports such as this one. In addition, FYR reports
identify issues found during the review, if any, and document recommendations to address them.

The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National
Contingency Plan (NCP) (40 CFR Section 300.430(f)(4)(ii)), and considering EPA policy.

This is the fourth FYR for the City of Perryton Well No. 2 Superfund site (Site). The triggering action for this
statutory review is the completion date of the previous FYR. The FYR has been prepared because hazardous
substances, pollutants or contaminants remain at the Site above levels that allow for unlimited use and
unrestricted exposure (UU/UE). The Site consists of one operable unit (OU), which addresses the groundwater
remedy. This FYR Report addresses the OU.

EPA remedial project manager (RPM), Nathaniel Applegate, led the FYR. Participants included Texas
Commission on Environmental Quality (TCEQ) project manager Scott Settemeyer, TCEQ Operation and
Maintenance contractor Emily Brickman from EnSafe, and Treat Suomi and Alison Cattani from EPA FYR
contractor Skeo. The review began on 11/1/2022.

Appendix A lists the resources referenced during the FYR. Appendix B provides a chronology of events at the
Site.

Site Background

The Site is in the city of Perryton (the city) in Ochiltree County in the northernmost part of the Texas panhandle.
The Site is a groundwater contaminant plume of dissolved carbon tetrachloride (CTC) and nitrate (Figure 1),
which has historically affected the city's Well No. 2 water supply well. Well No. 2 was a public drinking water
supply well operated by the city from 1946 to 1989, when the Texas Department of Health (TDH) identified CTC
in water samples and the city took the well out of service. Other contaminants detected include chloroform, lead,
nitrate and the herbicides atrazine and propazine.

In addition to the groundwater contaminant plume, the Site consists of two separate properties, the Well No. 2
property (the area where contamination was first observed) and the Perryton Equity Exchange (PEX) property
(indirectly linked to the groundwater contaminant plume) (Figure 2). Well No. 2 (also known as GW-02) was
located in a city-owned maintenance yard (also referred to as the City of Perryton Warehouse) at the intersection
of North Amherst Street and Santa Fe Avenue. The PEX is an elevated grain storage facility located south of the
maintenance yard and historical railroad tracks. Commercial businesses are along Main Street east of the
maintenance yard. Perryton's downtown commercial district is southeast of the maintenance yard.

The Ogallala aquifer at the Site is divided into two zones and five hydrostratigraphic units. The Upper Zone
consists of Unit 1 and Upper Unit 2; the Lower Zone consists of Lower Unit 2, Unit 3 and Unit 4. The city obtains
potable water primarily from Unit 3 of the Lower Zone, which is confined from the Upper Zone where most of
the contamination is present. Groundwater flows toward the north or northwest in the Upper Zone and toward the
south-southeast in the Lower Zone. Surface water resources in the area are limited due to the limited amount of
rainfall and high evaporation rates.

EPA and TCEQ have not identified any private wells within the contaminant plume. The city obtains drinking
water from 11 municipal supply wells within the Ogallala aquifer. Wells No. 1 and 2 (also known as GW-01 and
GW-02) served the portion of the city north of the Southwestern Railroad tracks. The southern public water
system consists of Well Nos. 3 through 11 (also referred to as GW-03 through GW-11), which serve the larger
portion of the city south of the railroad tracks. Well No. 2 was taken out of service in 1989 when contamination

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was detected. The city plugged and abandoned Well No. 1 in 2009 because this well could not produce sufficient
water to be used by the city as a replacement for Well No. 2. EPA plugged and abandoned Well No. 2 in 2011 to
eliminate the vertical migration pathway between the upper and lower zones of the Ogallala aquifer. Also in 2011,
the city upgraded the water supply system to meet demand by completing a water supply distribution extension
for the north side service area in Perryton. Well Nos. 3 through 11 continue to serve the larger portion of the city.

FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION

Site Name: City of Perryton Well No. 2

EPA ID: TX0001399435

Region: 6

State: Texas

City/County: Perryton/Ochiltree

NPL Status: Final

Multiple OUs?

No

Lead agency: EPA

Has the Site achieved construction completion?

Yes

REVIEW STATUS

Author name: Nathaniel Applegate, with additional support provided by Skeo

Author affiliation: EPA Region 6

Review period: 11/1/2022 - 6/15/2023

Date of site inspection: 11/9/2022

Type of review: Statutory

Review number: 4

Triggering action date: 7/18/2018

Due date (fiveyears after triggering action date): 7/18/2023

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Figure 1: Site Vicinity Map

Well No. 2
*

— Horizontal Boundary of Technical
' 1 Impracticability Zone

I I City of Perryton Maintenance Facility

£" "> Perryton Equity Exchange

Municipal Well

, Plugged and Abandoned Municipal
Well

N City of Perryton Well No. 2 Superfund Site

A City of Perryton, Ochiltree County, Texas

: z z. n: .

Disclaimer: This map and any boundary lines within the map are approximate and subject
to change. The map is not a survey. The map is for informational purposes only regarding
EPA's response actions at the Site. Map image is the intellectual property of Esri and is
used herein under license. Copyright © 2020 Esri and its licensors. All hghts reserved.
Sources: Esri, Maxar. the 2011 ROD and the 2022 Annual Report.

^Skeo

Last Modified: 4/17/2023

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II. RESPONSE ACTION SUMMARY

Basis for Taking Action

The city of Perryton began participating in the Texas Water Commission (TWC) Wellhead Protection Program in
1988 and subsequently requested sample analyses for volatile organic compounds (VOCs) in its water supply
system. The TDH sampled two wells and a storage tank in 1989. One well, Well No. 2, was found to have a CTC
concentration of 25 micrograms per liter ((.ig/L). which exceeded the maximum contaminant level (MCL) of 5
(ig/L. TDH removed Well No. 2 from service in June 1989.

In 1990, TWC collected soil samples to find a source of the groundwater contamination in Well No. 2, but no
CTC was detected. In 1991, the Texas Natural Resource Conservation Commission (TNRCC, formerly TWC)
investigated other potential sources of contamination but none were located. Between 1993 and 1996, EPA
completed several Site inspections and identified CTC and lead in groundwater samples above drinking water
criteria. Other contaminants detected in groundwater included chloroform, nitrate and the herbicides atrazine and
propazine. EPA also collected soil samples in 1996, but the sampling did not support attribution of hazardous
substances, pollutants or contaminants found in Well No. 2 to specific sources. Historically, the PEX facility has
used a fumigant mixture containing CTC in the grain storage bins and silos. While the use or storage of atrazine
or propazine at the PEX could not be confirmed, their occurrence with CTC in the groundwater is an indirect link
to the PEX facility.

In April 1996, EPA collected more groundwater samples and completed a streamlined risk assessment. EPA
determined that exposure to Site-related contaminants in groundwater presented a risk to future residents (Table
1). Propazine was not identified in the risk assessment as a contaminant of concern (COC) as the concentrations
were below risk-based levels. EPA added the Site to the Superfund program's National Priorities List (NPL) in
January 1999.

Table 1: Site COCs, by Media

C <)(

Mi'riiii

Atrazine

Groundwater

CTC

Chloroform

Lead3

Nitrate

Notes:

a. The Site's 1999 interim Record of Decision (ROD) identified lead as a
COC. However, EPA removed lead as a final COC in the 2002 ROD
and 2011 ROD Amendment because, following the replacement of a
rusted pump, the lead concentrations in groundwater remained below
drinking water criteria.

Response Actions

EPA selected an interim remedy in the Site's 1999 interim Record of Decision (ROD) to address the
contamination in Well No. 2 by providing limited hydraulic control of groundwater contamination until a full-
scale remedy could be implemented. The interim remedy consisted of pumping contaminated groundwater from
Lower Zone Unit 3 using Well No. 2 and treating the groundwater using an air stripper treatment plant (ASTP) to
reduce the CTC concentration in the extracted groundwater. Treated groundwater was then blended with water
from Well No. 1 to reduce concentrations of nitrate and atrazine for reuse by the city.

After completing the 2002 Remedial Investigation/Feasibility Study (RI/FS), EPA selected the final groundwater
remedy in the Site's 2002 ROD and amended the groundwater remedy for the Upper Zone/Lower Zone Unit 2 in
the Site's 2011 ROD Amendment. Table 2 lists the remedial action objectives (RAOs) and remedy components

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for the long-term remedial action. Table 3 provides a summary of the final cleanup goals. The remedy selected in
the 2011 ROD Amendment did not address atrazine because concentrations had remained below the MCLs since
the 2002 RI/FS.

Table 2: Summary of RAOs and Groundwater Remedy Components

RAO Ui'iiii'dx Component

I pper Z<»iii'/Lower Zone I nil 2'1

Prevent or minimize further migration of the
contaminant plume (plume containment) in the
Upper Zone/Lower Zone Unit 2.

Prevent the installation of water supply wells
within the Technical Impracticability (TI) Zone
that would either create a vertical migration
pathway between the contaminated Upper
Zone/Lower Zone Unit 2 and the restored Lower
Zone Unit 3, or cause the contaminants to
migrate outside of the TI Zone.

Waive MCLs for CTC and nitrate in the Upper Zone and for CTC in
the Lower Unit 2 of the Ogallala aquifer within the TI Zone.

Continue a long-term groundwater monitoring and reporting program
to evaluate containment of contaminated groundwater in the TI Zone
through natural attenuation processes.

Implement institutional controls for properties above contaminated
groundwater.

I.iim or Zone I nil 3h

Restore the groundwater throughout the
contaminant plume in the Lower Zone Unit 3 to
its expected beneficial uses wherever
practicable.

Prevent or minimize further migration of the
contaminant plume.

Continue extracting groundwater from Well No. 2.

Continue operating the ASTP constructed as part of the 1999 interim
remedy to remove CTC and chloroform from the extracted
groundwater.0

Install a second extraction well at about 400 feet in depth, screened
across the saturated thickness of the Ogallala aquifer.

Use one of three options to address nitrate: ion exchange, blending
with water from other municipal supply wells, or disposal via the
sanitary sewer.

Install underground piping to convey extracted groundwater from the
second extraction well to the treatment plant and then to the South
Ground Storage Tank for blending with other supply wells.

Perform an annual remedy evaluation using operation and
maintenance (O&M) and groundwater monitoring data as well as
groundwater modeling.

Use the existing city ordinance requiring issuance of a permit to
install new wells to provide notice to EPA of any changes in the
exposure scenario at the Site.

Implement a groundwater monitoring program.

Notes:

a.	Components selected in the 2011 ROD Amendment.

b.	Components selected in the 2002 ROD.

c.	Although atrazine was identified as a COC during the remedial investigation, atrazine was below the cleanup goal
following the testing of the pump-and-treat (P&T) system.

Table 3: Final Groundwater COC Cleanup Goals

COC

I''in
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Status of Implementation

Lower Zone Unit 3

EPA completed the remedial design for the interim remedy in May 2001. EPA determined that the source of
nitrate in groundwater was leaking sewer lines joined together at a manhole 75 feet south of Well No. 2. The city
repaired the lines in February 2002. In addition, EPA constructed the ASTP next to Well No. 2 at the City of
Perryton Warehouse in February 2002. Well No. 2 was plumbed directly into the influent lines for the ASTP.
Treated water from the ASTP was blended with water from Well No. 1 in the North Ground Storage Tank to
reduce nitrate concentrations below the MCL prior to entering the water supply system. EPA began operation of
the interim groundwater pump-and-treat (P&T) system in November 2002.

In May 2003, EPA completed the remedial design for the long-term remedy selected in the 2002 ROD. Remedy
construction was completed in August 2003. The remedy included the installation of extraction well MW-17-EX,
construction of a reverse osmosis (RO) facility in the city's maintenance yard just south of Well No. 2 and
adjacent to the ASTP, and installation of monitoring wells. The treated effluent was discharged to the North
Ground Storage Tank for use as part of the city's municipal water supply. EPA began operating the treatment
system in September 2003. On September 30, 2004 (one year after construction completion), the Site entered the
long-term remedial action (LTRA) phase.

In August 2004, EPA shut down the RO unit because the nitrate cleanup goal was achieved in Well No. 2 and
MW-17-EX. EPA continued to operate the ASTP from November 2002 to April 2011, when the CTC cleanup
goal was achieved in Lower Zone Unit 3. Between November 2010 and January 2011, EPA plugged and
abandoned Well No. 2 to prevent recontamination of Lower Zone Unit 3.

After the cessation of P&T system operations and abandonment of Well No. 2, routine compliance monitoring
found exceedances of the CTC cleanup goal in port 3 of multi-port monitoring well 02 (MPMW02) and nearby
wells. In 2014, EPA expanded the monitoring well network to further delineate CTC in groundwater around
MPMW02-03 by installing five wells (MW-24, MW-25, MW-26D, MW-27 and MW-28). In 2016, EPA installed
three wells (MW-39, MW-40 and MW-41) to further delineate the southern extent of the CTC plume.

In May 2019, CTC concentrations in downgradient wells MW-40 and MW-41 exceeded the MCL (15.6
micrograms per liter | |ig/L| and 15.6 ng/L, respectively). This finding indicated downgradient CTC plume
expansion in Lower Zone Unit 3 in the direction of city supply Well No. 3 (GW-03). In June 2020, EPA
completed the installation and sampling of five Lower Zone Unit 3 wells (MW-42, MW-43, MW-44, MW-45R
and MW-46). Well installation activities were performed to delineate the downgradient extent of CTC in
groundwater of the Lower Zone Unit 3 of the Ogallala aquifer. Also in June 2020, EPA plugged and abandoned
monitoring wells MW-19-EX (to reduce a potential contaminant migration pathway) and MW-45 (replaced by
MW-45R). The Data Review section of this FYR Report includes more information about the current extent of
the CTC plume in the Lower Zone.

In 2020, the RO unit and ASTP were disassembled and removed. Removal and disposal included abandoned
piping, all piping supports and hangers that interconnect the equipment, mechanical appurtenances, valves and
fittings, electrical power distribution equipment, electrical devices and connections, and all associated conduit and
wire for power and controls. The buildings were left intact.

Upper Zone/Lower Zone Unit 2

Due to the presence of CTC contamination in the Upper Zone/Lower Zone Unit 2 and nitrate in the Upper Zone
above MCLs during operation of the treatment system, EPA installed two more extraction wells near Well No. 2
in December 2006 and January 2007. Development of these wells was difficult due to low yields and limited
hydraulic head. Therefore, EPA concluded that it was not feasible to remediate the Upper Zone/Lower Zone Unit
2 using P&T technology.

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In the 2011 ROD Amendment, EPA waived the MCLs for CTC and nitrate in the Upper Zone and for CTC in
Lower Zone Unit 2 within a Technical Impracticability (TI) Zone. EPA based this decision on the following:

•	The groundwater P&T system had successfully cleaned up the principal groundwater production unit
(Lower Zone Unit 3).

•	The upper units of the aquifer (Upper Zone Units 1 and 2, Lower Zone Unit 2) had not been cleaned up
and the contamination had not shown any significant changes since the P&T system began operating in
2002.

•	Well No. 2 had been plugged and abandoned to prevent contaminants in the Upper Zone/Lower Zone
Unit 2 from migrating downward along the well annulus and recontaminating the Lower Zone Unit 3
ground water.

Based on these factors, as well as the eight years of groundwater cleanup, monitoring data, and attempts to
improve the system performance, EPA concluded that the previously selected groundwater cleanup remedy could
not achieve the previously existing cleanup objective for the upper units of the Ogallala aquifer. The spatial extent
of the TI Zone was defined to be as small an area as possible while still encompassing the entire area over which
the MCLs for CTC and nitrate were exceeded within the Upper Zone/Lower Zone Unit 2 at the time of the ROD
Amendment.

EPA installed nine more conventional monitoring wells (MW-20, MW-21, MW-22, MW-23, MW-26S, MW-29,
MW-30, MW-31 and MW-32) in 2014 and six more conventional wells (MW-33, MW-34, MW-35, MW-36,
MW-37, and MW-38) in 2016. EPA used these wells to monitor groundwater at the TI Zone boundary and
provide information to verify the extent of the TI Zone and the number of properties where institutional controls
required by the 2011 ROD Amendment would be needed.

Since the 2011 ROD Amendment, the CTC plume in the Upper Zone/Lower Zone Unit 2 has migrated beyond the
TI Zone boundary. The lack of a P&T system, an increase in water level elevations, continuing source
contribution and lack of natural degradation of CTC may be contributing to Upper Zone/Lower Zone Unit 2
plume migration and increasing CTC concentrations. The Data Review section of this FYR Report includes more
information about the current extent of the CTC plume in the Upper Zone.

EPA will initiate an optimization study which will review the remedy implementation activities conducted to date
as well as the current extent of groundwater contamination in both the Lower Zone Unit 3 and the Upper
Zone/Lower Zone Unit 2.

Institutional Control (IC'l Review

The 2011 ROD Amendment required implementation of institutional controls. The institutional controls were
required to: 1) prevent the installation of a water supply well that would create a vertical migration pathway
between the contaminated Upper Zone/Lower Zone Unit 2 and restored Lower Zone Unit 3, and 2) prevent the
installation of a water supply well with an open-screen interval in the Upper Zone/Lower Zone Unit 2 that would
cause the contaminants to migrate outside the TI Zone (Table 4).

As per the 2011 ROD Amendment, options to meet the institutional control requirements included filing deed
notices for each property within the TI Zone or updating a 1988 city ordinance that required the issuance of a
permit to install new private wells within city limits to also prohibit the installation of wells within the TI Zone.
Site-specific institutional controls were implemented by the city of Perryton in April 2018 through the adoption of
Ordinance #1040-18 (Appendix J). The city ordinance applies to the entire area within the city limits and prevents
the installation of any well that would create a vertical migration pathway between the Upper Zone and the Lower
Zone of the Ogallala aquifer. It also prevents the installation of a well that would cause migration of VOCs
outside the TI Zone.

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Table 4: Summary of Planned and/or Implemented Institutional Controls

Motliii Thill











Dues Nul



IC s C ;illed





Tilli' of IC

Support I I /i i;

IC s

lor in Ihi'

1 m p.iii oil

IC

1 list riimi'iii

liilsi'ri nil

Ni'i'cli'd

Decision

I'iiri'i'lis)

Obji'iih i'

1 inpli'ini'iili'd iind

ClIITl'lll



Diii'unii'iils





Dull' (or pliinni'd)

C '• Hid it i< ins



















Prevent the installation of a











water supply well that would



Groundwater

Yes

Yes

All parcels
overlying
the CTC
contaminant
plume in the

Upper
Zone/Lower
Zone Unit 2

create a vertical migration
pathway between
the contaminated Upper
Zone/Lower Zone Unit 2 and
restored Lower Zone Unit 3.

City of Perryton
Ordinance #1040-18







Prevent the installation of a









water supply well with an open
screen interval in Upper
Zone/Lower Zone Unit 2 that
would cause the contaminants
to migrate outside the TI Zone.



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Figure 2: Institutional Control Map

r lgu

Lower Zone CTC Plume



The city ordinance applies to the
entire area within the city limits and
prevents the installation of any well
that would create a vertical migration
pathway between the Upper Zone and
the Lower Zone of the Ogallala
aquifer, and prevents the installation
of a well that would cause migration of
VOCs outside the Tl Zone.

A IE*. • .*^1

£9

	

Horizontal Boundary of
I—I Technical Impracticability Zone

	 City of Perryton Maintenance

I	1 Facility

Perryton Equity Exchange

Upper Zone CTC Plume (>5 M9'L)
(dashed where inferred)

Inferred Upper Zone CTC
	 Plume

Upper Zone CTC Plume

Lower Zone CTC Plume (>5 H9/L)
(dashed where inferred)

Inferred Lower Zone CTC
Plume

N City of Perryton Well No. 2 Superfund Site

A City of Perryton, Ochiltree County, Texas

i	1	1	1

Disclaimer: This map and any boundary lines within the map are approximate and subject to
change. The map is not a survey. The map is for informational purposes only regarding EPA's
response actions at the Site. Map image is the intellectual property of Esri and is used herein
under license. Copyright © 2020 Esri and its licensors. All rights reserved. Sources: Esri, Maxar
and the 2022 Annual Report.

^Skeo

Last Modified: 2/6/2023

12


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Systems Qperations/O&M

In July 2018, O&M responsibilities transferred to TCEQ. TCEQ conducts routine groundwater sampling and
ensures the wells are maintained in accordance with the Site's 2018 O&M Manual. EPA and TCEQ review the
groundwater sampling program annually to determine if wells, analytes or both can be eliminated from the
sampling program. The long-term groundwater monitoring program has been adjusted in terms of the numbers of
wells sampled, the analyte list and sampling frequency.

TCEQ conducts annual O&M inspection activities. The results are reported in annual O&M reports. During this
FYR period, the following issues were noted:

•	Damaged well pads.

•	Missing monitoring well bolts.

•	Well vaults with sediment and standing water.

•	Missing monitoring well locks.

•	Missing passive diffusion bags.

•	Sediment accumulation in some wells.

In 2020, EPA replaced the concrete well pads for monitoring wells MW-31, MW-33, MW-35, MW-36, MW-37
and MW-38. Also in 2020, EPA conducted a site-wide inspection of monitoring wells and replaced well vault lid
bolts, gaskets and locks. The 2021 inspection noted very few issues due to the previous year's maintenance
activities. However, the 2022 inspection indicated similar conditions as noted prior to 2021, including sediment
and silt in eight wells, seven damaged well pads, four cracked wells and standing water in 15 well vaults. Well
maintenance continues to be an issue at the Site. During the Site inspection, TCEQ indicated it would be
conducting maintenance on several wells.

III. PROGRESS SINCE THE PREVIOUS REVIEW

This section includes the protectiveness determinations and statements from the 2018 FYR Report (Table 5) as
well as the recommendations from the 2018 FYR Report and the status of those recommendations (Table 6).

Table 5: Protectiveness Determinations/Statements from the 2018 FYR Report

Ol #

I'roU'iin I'lii'ss
IK'U'rmin.ilion

ProU'cth i'lii'ss SiiiU'iiu'iii

Sitewide

Short-term
Protective

The remedy currently protects human health and the environment because
continued groundwater monitoring and reporting will evaluate changes in the upper
and lower zones of the aquifer, and the city of Perryton has adopted an ordinance
that implements drilling restrictions within the city limits. Well No. 2 was plugged
and abandoned to prevent further contaminant migration from the Upper Zone and
Lower Unit 2 into Lower Zone Unit 3. In addition, EPA established a TI Zone in
the Upper Zone and Lower Unit 2 where the MCLs for CTC and nitrate are waived
in the Upper Zone and for CTC in Lower Unit 2 of the Ogallala aquifer within the
TI Zone.

For the remedy to be protective over the long term, the following activities should
be completed:

•	Determine the cause of the CTC rebound in Lower Zone Unit 3, further
delineate the resulting CTC plume, and evaluate whether the 2002
groundwater remedy, or another remedial alternative, should be
implemented to achieve the remedial action objectives in the Lower Zone
Unit 3.

•	Fully delineate the CTC plume in the Upper Zone and determine if
adjustment of the TI Zone boundary or additional actions are warranted.

13


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Table 6: Status of Recommendations from the 2018 FYR Report

Ol #

IsslIC

Ki'i'umiiH'iKliilions

( III-IV111

Curmil Impk'iiK'nl.ilion

('nmpk'liun

Dsilc (if
iippliciiMn

Stilus

Still us Description





Determine the cause



While the cause of the
rebound is not yet known, in
June 2020, EPA completed the
installation and sampling of
five Lower Zone Unit 3 wells
(MW-42, MW-43, MW-44,
MW-45R and MW-46). Well
installation activities were
performed to delineate the
downgradient extent of CTC
in groundwater of the Lower
Zone 3 of the Ogallala aquifer.
Monitoring is ongoing. EPA
has requested an optimization
study to facilitate better site
characterization, review
remedy selection, design,
implementation, and
performance, and investigate
the rebound of CTC and the
current extent of contaminated
groundwater.



1

CTC has been detected
in additional
monitoring wells
screened in the Lower
Zone Unit 3 since the
previous FYR. Four
wells in Lower Zone
Unit 3 (MW-28, MW-
24, MPMW02-03 and
MW-41) exceeded the
cleanup goal for CTC
in 2016 versus one
well (MPMW02-03)
in 2012.

of the CTC rebound
in Lower Zone Unit
3, further delineate
the resulting CTC
plume, and evaluate
whether the 2002

groundwater
remedy, or another
remedial alternative,
should be
implemented to
achieve the remedial
action objectives in
the Lower Zone
Unit 3.

Ongoing

Not
Applicable

1

The CTC plume in the

Upper Zone has
expanded and exceeds

the MCL at the
northwestern boundary
of the TI Zone (MW-
31) and outside of the
southern boundary of
the TI Zone (MW-33).
A potential gap in the

monitoring well
network along the TI
boundary is a concern
northeast of the
MPMW03 and
MPMW06 well
locations.

Fully delineate the
CTC plume in the
Upper Zone and
determine if
adjustment of the TI
Zone boundary or
additional actions
are warranted.

Under
Discussion

Delineation of the CTC plume
in the Upper Zone is under

discussion. The EPA
requested an optimization
study that will evaluate the
need and options to further
delineate the plume and
determine if the TI Zone
boundary needs to be adjusted.

Not
Applicable

IV. FIVE-YEAR REVIEW PROCESS

Community Notification. Community Involvement and Site Interviews

A public notice was published in the Perryton Herald newspaper on 11/17/2022. It stated that the FYR was
underway and invited the public to submit any comments to EPA (Appendix C). The results of the FYR and the
report will be made available on the Site's profile page at http://www.epa.gov/superfund/citv-of-perrvton. During
the FYR process, interviews were conducted to document any perceived problems or successes with the remedy
implemented to date. The interviews are summarized below.

14


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TCEQ project manager Scott Settemeyer has many concerns about the remedy implementation and effectiveness
in both the Upper Zone/Lower Zone Unit 2 and the Lower Zone Unit 3. Mr. Settemeyer indicated that the CTC
plume in the Upper Zone/Lower Zone Unit 2 continues to expand and migrate beyond the TI Zone and these areas
are not being addressed by the current remedy. TCEQ recommends the installation of more groundwater
monitoring wells to determine the full extent of the CTC plume in the Upper Zone/Lower Zone Unit 2. Following
complete delineation of the CTC plume, TCEQ believes EPA should either expand the TI Zone to fully
encompass the extent of CTC contamination in the Upper Zone/Lower Zone Unit 2 or implement an appropriate
remedy to restore groundwater to its beneficial use.

In the Lower Zone Unit 3, Mr. Settemeyer indicated that the remedy does not meet the RAOs and that natural
attenuation in the Lower Zone Unit 3 is not occurring at a rate sufficient to control the groundwater plume.
The analytical data obtained from the May 2022 sampling event indicate that CTC concentrations in the Lower
Zone Unit 3 exceed the MCL, are continuing to increase since the P&T system was shut down, and are expanding
in the downgradient direction. Groundwater sampling conducted from 2019 through 2022 has confirmed that CTC
has migrated downgradient at concentrations above the MCL in the direction of city drinking water supply wells
GW-03 and GW-04. The continued increases in CTC concentrations may indicate an additional migration
pathway for contaminants in the Lower Zone.

Mr. Settemeyer believes the continued expansion and migration of CTC contamination at the Site suggest that
there might be source contamination in Site soils. TCEQ recommends more investigation in potential source
areas, such as locations of elevated CTC detections identified in the 2009 passive soil gas sampling during the
remedial investigation.

TCEQ's O&M contractor, EnSafe Inc., indicated many of the same concerns as TCEQ. TCEQ's contractor
indicated that the Site should undergo EPA remedy optimization and the Site should return to EPA for active
remedy implementation to achieve RAOs. TCEQ's contractor indicated many of the Site's monitoring wells are in
city streets and have deteriorated or damaged well pads. In 2023, eight well pads will be removed and replaced.

Perryton city manager David Landis and director of public works Brandon Knapp indicated there have been no
applications for private well installation during this FYR period. They requested a copy of the latest groundwater
sampling report. EPA will send an electronic copy of the most recent sampling report.

Data Review

TCEQ conducts annual groundwater monitoring at the Site in accordance with the 2018 Sampling and Analysis
Plan. The groundwater monitoring program includes gauging and sampling multi-port and conventional
monitoring wells and a city supply well (Figure 3). Monitoring is generally conducted in May. However, in 2020,
sampling was conducted in August. Groundwater samples are analyzed for VOCs. However, only CTC results are
reported. Nitrate and chloroform are COCs but neither has exceeded their respective MCLs since the remedial
investigation. Atrazine concentrations were below the MCL after testing of the original P&T system.

This FYR reviewed annual monitoring reports from 2019 through 2022. The data summary below focuses on the
most recent data collected at the Site (May 2022) with historical context provided as appropriate.

Groundwater Elevation

In the 2022 Annual O&M Report, TCEQ provides hydrographs and potentiometric maps for the Upper Zone, the
Lower Zone Unit 2 and the Lower Zone Unit 3. As seen in the hydrographs (Figures F-l through F-3 in Appendix
F), groundwater elevations in both zones have continued to increase since the treatment system stopped operating
in 2012.

During this FYR period, groundwater flow in the Upper Zone/Lower Zone Unit 2 across the TI Zone is north to
northwest. The 2022 Upper Zone/Lower Zone Unit 2 potentiometric surface map is included as Figure F-4 in
Appendix F. In the Lower Zone Unit 3, groundwater flow is generally south to southeast toward city supply wells
GW-03 and GW-04 (Figure F-5 in Appendix F). The 2022 Annual O&M Report noted a slight easterly flow

15


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component has historically been identified near MPMW02 and MW-27, with similar easterly groundwater flow
patterns observed in 2012, 2014 and May 2019.

Lower Zone Unit 3

The 2019 and 2022 CTC distributions in the Lower Zone Unit 3 are shown in the respective plume maps (Figure
F-9 and F-10 in Appendix F). The highest CTC concentrations occur at Lower Zone Unit 3 wells MW-24 and
MW-28, both of which are near former Well No. 2 (referred to as GW-02 in the Annual Reports). In total, eight
Lower Zone Unit 3 monitoring wells exceeded the CTC MCL in 2022 (Table 7). As seen in Table 7, CTC
concentrations and the number of exceedances have increased in these Lower Zone wells.

The downgradient extent of the Lower Zone Unit 3 CTC plume (south of MW-40 and MW-41) is delineated by
wells installed in 2020, including downgradient monitoring wells MW-42, MW-43 and MW-44 (Figure F-10 in
Appendix F). City supply Well No. 3 (GW-03) is about 3,000 feet southeast of the known extent of the Lower
Zone Unit 3 CTC plume (from MW-41). However, CTC concentrations below the MCL have been detected in
MW-45R/MW-46, which are about 1,900 feet northwest of GW-03. TCEQ conducted travel-time calculations in
2019 between MW-41 and GW-03 that indicated groundwater could reach GW-03 in seven years, i.e., by 2026. In
2019 TCEQ calculated the contaminant velocity, accounting for dispersion, adsorption and retardation, the results
indicated that CTC could reach GW-03 in 25 years. In May 2022, CTC was detected below the MCL in
downgradient delineation wells MW-42 (0.59 J (j.g/L), MW-43 (0.98 J (ig/L), MW-44 (2.62 jig/L) and MW-46
(0.7 J (j.g/L). TCEQ will continue to evaluate the detections in these wells during future events to gauge Lower
Zone Unit 3 CTC mobilization, trends, and nature and extent.

Table 7: Lower Zone Unit 3 Monitoring Wells CTC Concentrations Above MCL (2019 to 2022)

l.owor /one I nil 3
Moniiorin» \\ ell

CTC Coiu'i'iilmlion
(iii>/l.)

2019

2020

2021

2022

MW-28

15.7

15.7

13.7

16.7

MPMW03-3

7.29

5.68

6.04

7.2

MW-24

13.6

15.9

12.5

17

MPMW02-3

11.1

12

9.27

10.8

MPMW01-3

4.74

4.06

3.38

5.15

MW-40

15.6

13.6

11.8

16.3

MW-41

15.6

13.7

12.5

17

MPMW04-5

5.62

10.3

6.75

8.99

Notes:

Source: Table 6, 2022 Annual O&M Report.
Bold = exceeds CTC MCL of 5 \ig/L

Upper Zone/Lower Zone Unit 2 (TI Zone)

The 2019 and 2022 CTC distributions in the Upper Zone/Lower Zone Unit 2 are shown in the respective plume
maps (Figures F-6 and F-7 in Appendix F). Based on the current groundwater monitoring network, the general
extent of the CTC plume has remained consistent. However, as noted in previous sections, there are several areas
of the plume that are currently not delineated. These areas include the area upgradient of MW-33, side gradient of
MPMW01 (to the west) and MPMW03 and MPMW06 (to the northeast and east), and downgradient of MW-31.
Figure F-8 in Appendix F shows concentrations overtime. Generally, the Upper Zone well concentrations appear
stable, with some wells showing both increases and decreases overtime.

Monitoring well MW-33 is located outside the TI Zone boundary and concentrations currently exceed the CTC
MCL. This well was installed in 2016 and has exceeded the CTC MCL since installation. During this FYR period,
concentrations in the well ranged from 17.5 (ig/L in 2019 to 24.5 (ig/L in 2022 (Table 8). Two other perimeter
wells currently exceed the CTC MCL and are located near the TI Zone boundary (Table 8). The contamination
downgradient of these wells may not be fully delineated (Figure F-7 in Appendix F). Table 8 shows the
concentrations over time for these wells.

16


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Table 8: Select Upper Zone Monitoring Wells CTC Concentrations (2019 to 2022)

I |)|K'|- Zone
Monitoring N\ oil

CTC Coiu'enlralion

2019

2020

2021

2022

Outside the TI Zone Boundary

MW-33

17.5

23.5

18.9

24.5

Near the TI Zone Boundary

MW-32

28.0

27.7

23

36.2

MW-31

37.5

31.3

27.5

44.3

Notes:









Source: Table 5, 2022 Annual O&M Report.







If a duplicate sample was taken, the higher of the two concentrations is shown in this table.



Bold = exceeds CTC MCL of 5 ng/L







City Wells

From 2019 through 2021, TCEQ sampled city supply Well No. 3 (GW-03). In 2022, GW-03 was not operational
and city supply Well No. 4 (GW-04) was sampled instead. The results are shown in Table 9. City supply wells
downgradient of the Lower Zone CTC plume continue to be unaffected by the Site.

Table 9: City Supply Wells CTC Concentrations (2019 to 2022)





CTC Coiu'enlralion



Cilj Supply Well




-------
Figure 3: Detailed Site Map



RLi
HKr.

* ^1'











'



Horizontal Boundary of Technical
I I Impracticability Zone

I I City of Perryton Maintenance Facility

L..J Perryton Equity Exchange

Upper Zone Monitoring Well

Lower Zone Monitoring Well

Multi-Port Monitoring Well

^ Municipal Well



N City of Perryton Well No. 2 Superfund Site

A City of Perryton, Ochiltree County, Texas

i	1	1

n	/inn	ann

Disclaimer: This map and any boundary lines within the map are approximate and subject to
change. The map is not a sutvey. The map is for Informational purposes only regarding EPA's
response actions at the Site. Map image is the intellectual property of Esri and is used herein
under license. Copyright © 2020 Esri and its licensors. All rights reserved. Sources: Esri, Maxar,
the 2016 Groundwater Monitoring Report and the 2022 Annual Report.

^Skeo

Last Modified: 4/17/2023

18


-------
Site Inspection

The Site inspection took place on 11/9/2022. Participants included EPA RPM Nathaniel Applegate, TCEQ project
manager Scott Settemeyer, TCEQ O&M contractor Emily Brickman from EnSafe, and Treat Suomi from EPA
FYR contractor Skeo. The purpose of the inspection was to assess the protectiveness of the remedy. A completed
checklist and Site inspection photos are included in Appendix D and Appendix E, respectively.

Participants met and discussed the status of the Site and viewed the buildings where the previous treatment
equipment was removed. They then viewed the monitoring wells at the Site. Many wells needed repair. TCEQ
and its contractor conducted a full inventory and were working on a plan for maintenance. Finally, they met with
city of Perryton representatives to discuss the status of the Site.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents?

Lower Zone Unit 3

The 2002 groundwater P&T remedy component is no longer operating at the Site. Contaminant concentrations in
all monitoring wells screened in the Lower Zone Unit 3 were below the MCL by 2008, and the P&T remedy had
achieved the RAOs and goals for Lower Zone Unit 3 groundwater. The P&T system was shut down in 2011 after
plugging and abandonment of Well No. 2. Groundwater monitoring has continued at the Site. CTC was detected
above the MCL beginning in February 2012 in MPMW02 port 3 (Lower Zone Unit 3). Long-term monitoring of
Lower Zone Unit 3 is ongoing, and concentrations continue to increase. In 2020, EPA dismantled the P&T
system.

The increase in CTC concentrations may be the result of CTC migrating from the Upper Zone to the Lower Zone
Unit 3 during the 30-day abandonment of Well No. 2. Alternatively, CTC may be leaking downward along an
existing monitoring well, or there may be more migration pathways outside of Well No. 2 or monitoring well
MPMW02. In 2020, EPA installed more Lower Zone wells to delineate the downgradient edge of the CTC plume.
CTC was detected in these wells. While current concentrations are below MCLs and the Lower Zone plume is
currently delineated, the EPA has not implemented a remedy at the site that will prevent continued downgradient
migration of CTC and achieve the RAO of restoring the groundwater to beneficial reuse. Additionally, natural
degradation processes are not occurring at a rate sufficient to control the groundwater plume. TCEQ conducted
analysis indicating that, without intervention, contamination will reach supply Well No. 3 and Well No. 4 in seven
to 25 years. Annual monitoring will continue. EPA has requested an optimization study which will review the
remedy implementation activities conducted to date, the current extent of groundwater contamination in the
Lower Zone Unit 3, and the potential for a naturally occuring hydrodynamic interconnection and communication
between the upper and lower zones.

Upper Zone/Lower Zone Unit 2

The remedy is not functioning as intended in the Upper Zone/Lower Zone Unit 2 of the aquifer. In September
2011, EPA waived the groundwater cleanup goals in the Upper Zone/Lower Zone Unit 2 through designation of a
TI Zone. EPA determined that the P&T remedy, or an alternate technology, was not capable of reaching the
cleanup goals for CTC and nitrate in the Upper Zone/Lower Zone Unit 2 under the conditions found at the Site. In
addition, the ROD Amendment indicated that the contamination in the Upper Zone was not migrating, and
concentrations were stable.

Several wells at the edge of the TI boundary (MW-31, MPMW03 and MPMW06) or outside the TI Zone (MW-
33) exceed the CTC cleanup goal. More delineation and adjustment to the TI boundary is warranted for the CTC
plume in the Upper Zone. An increase in water levels, continuing source contribution and lack of natural
degradation of CTC may be contributing to Upper Zone plume migration, increasing CTC concentrations and

19


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acting as a source of contamination to the Lower Zone Unit 3. TCEQ believes that there may be remaining source
area at the PEX property that is continuing to leach into groundwater. EPA has requested an optimization study
which will review the remedy implementation activities conducted to date as well as the current extent of
groundwater contamination in the Upper Zone/Lower Zone Unit 2.

According to the 2011 ROD Amendment, Site-specific institutional controls are warranted to prevent installation
of water supply wells that could create a vertical migration pathway between the Upper Zone and Lower Zone
Unit 3. Site-specific institutional controls were implemented by the city of Perryton in April 2018 through the
adoption of Ordinance #1040-18 (Appendix J). These institutional controls prevent the installation of water
supply wells that could create a vertical migration pathway or allow for horizontal migration of contamination
outside the TI Zone. Since the current Upper Zone CTC plume likely extends past the TI Zone boundary, the
institutional control cannot not be fully effective. City officials indicated there have been no applications for
private well installations near the Site.

TCEQ is responsible for O&M activities at the Site. Monitoring well maintenance continues to be an issue, with
silt observed in several wells, sediment and standing water observed in the well vaults, and general issues with
well security. TCEQ and EPA should determine if more actions are needed to prevent further degradation and to
address the current issues.

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the
remedy selection still valid?

The cleanup levels established for groundwater COCs remain valid. The goals were based on chemical-specific
applicable or relevant and appropriate requirements (ARARs). Except for chloroform, the MCLs have not
changed (Table G-l in Appendix G). The MCL for chloroform has become more stringent. However, the
maximum detected concentration of chloroform measured at the Site prior to the remedial investigation is well
below the new MCL of 80 ng/L, which applies collectively to chloroform and several other chemicals associated
with the drinking water chlorination process.

The 2011 RAO of preventing or minimizing further migration of the contaminant plume (plume containment) in
the Upper Zone/Lower Zone Unit 2 has not been achieved. The CTC plume in the Upper Zone has expanded and
migrated beyond the current TI Zone boundary. More delineation is warranted to revise the TI Zone boundary.
Additional investigations should be conducted to determine if a source area is present and if additional remedial
actions are needed. The 2002 RAOs for the Lower Zone Unit 3 have also not been achieved, as CTC was detected
in eight wells at concentrations above the cleanup goal in 2022. Additional evaluations are needed to determine
the cause of the CTC rebound in the Lower Zone Unit 3, further delineating the resulting CTC plume, and
evaluating whether the 2002 groundwater remedy, or another remedial alternative, should be implemented to
achieve the RAOs in the Lower Zone Unit 3.

There have been no changes in Site conditions that would suggest the presence of new exposure pathways. A
passive soil gas survey was completed along the PEX grain silos in September 2009 to address a recommendation
from the first FYR Report to assess the potential exposure of CTC through vapor intrusion. The highest CTC
mass was recorded in the samplers along the silos, near MW-1 IS. While the passive soil gas results do not
provide CTC concentration data, the results did provide an indication of where the highest potential
concentrations of CTC vapors could be expected if a building was constructed for human occupation in the source
area. However, a vapor intrusion risk evaluation was not conducted because the exposure pathway was deemed
incomplete for current exposures.

This FYR included a screening-level vapor intrusion evaluation to determine if the vapor intrusion exposure
pathway poses future health concerns due to the presence of CTC in the Upper Zone (Table H-l, Appendix H).
Using the highest CTC concentrations detected in the Upper Zone in 2022, the vapor intrusion evaluation
indicates that vapor intrusion is currently unlikely to be an exposure pathway of concern for industrial and

residential exposures. However, evaluation of the vapor-intrusion-to-indoor-air pathway is recommended prior to

20


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construction of any structures in the source area that can be occupied to ensure the vapor intrusion conclusions
have not changed, especially if CTC concentrations continue to increase overtime.

QUESTION C : Has any other information come to light that could call into question the protectiveness of the
remedy?

No other information has come to light that could call into question the protectiveness of the remedy. As of this
FYRthe protectiveness of the remedy is anticipated to not be affected by climate change.

VI. ISSUES/RECOMMENDATIONS

Issues/Recommendations

()l (s) without Issues/Recommendations Identified in (ho l-'Yk:

None

Issues and Recommendations Identified in the l-'Yk:

OU(s): Sitewide

Issue Category: Remedy Performance

Issue: The Upper Zone/Lower Zone Unit 2 CTC plume has migrated beyond the current
TI Zone boundary.

Recommendation: Delineate the Upper Zone/Lower Zone Unit 2 CTC plume and
modify the remedy as appropriate.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight
Party/Support
Agency

Milestone Date

No

Yes

EPA

EPA/State

7/18/2026

OU(s): Sitewide

Issue Category: Remedy Performance

Issue: CTC concentrations in the Lower Zone Unit 3 are increasing and the CTC
concentrations exceeded the cleanup goal in eight wells in 2022.

Recommendation: Conduct an optimization study to determine the source of
contamination to groundwater and determine if additional remedial action is needed to
achieve RAOs.

Affect Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight
Party/Support
Agency

Milestone Date

No

Yes

EPA

EPA/State

7/18/2026

OTHER FINDINGS

An additional recommendation was identified during the FYR. This recommendation does not affect current
and/or future protectiveness.

• Conduct necessary well maintenance, including degradation of wells pads and other issues, and determine
if additional actions are needed to prevent further degradation.

21


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• Conduct an optimization study of the site to make recommendations on further site characterization,
review the past remedy implementation activities, remedy selection, design, implementation, and
performance, and investigate the rebound of CTC and the current extent of contaminated groundwater in
both the Upper and Lower Zones.

VII. PROTECTIVENESS STATEMENT

Sitewide Protectiveness Statement

Protectiveness Determination:

Short-term Protective

Protectiveness Statement:

The remedy currently protects human health and the environment because continued groundwater
monitoring and reporting will evaluate changes in the upper and lower zones of the aquifer. A city of
Perryton ordinance implements drilling restrictions within the city limits. However, for the remedy to
be protective over the long term, the following actions need to be taken: delineate the Upper
Zone/Lower Zone Unit 2 CTC plume and modify the remedy as appropriate; determine the source of
contamination to groundwater and determine if additional remedial action is needed to achieve RAOs.

VIII. NEXT REVIEW

The next FYR Report for the City of Perryton Well No. 2 Superfund Site is required five years from the
completion date of this review.

22


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APPENDIX A - REFERENCE LIST

Field Sampling Plan, Version 5.0. City of Perryton Well No. 2 Superfund Site. Remedial Investigation/Feasibility
Study, Perryton, Texas Prepared by CH2MHill. October 2016.

Final Annual Operation and Maintenance Report, Fiscal Year 2019. Prepared by EnSafe. August 2019.

Final Annual Operation and Maintenance Report, Fiscal Year 2020. Prepared by EnSafe. December 2020.

Final Annual Operation and Maintenance Report, Fiscal Year 2021. Prepared by EnSafe. September 2021.

Final Annual Operation and Maintenance Report, Fiscal Year 2022. Prepared by EnSafe. September 2022.

First Five-Year Review Report, City of Perryton Well No. 2 Superfund Site, Ochiltree County, Texas. August
2008.

Interim Record of Decision, City of Perryton Well No. 2 Superfund Site, Ochiltree County, Texas. EPA Region 6.
September 1999.

Operation and Maintenance Manual, Remedial Investigation/Feasibility Study, City of Perryton Well No. 02 Site.
Prepared by EA Engineering, Science, and Technology, Inc., PBC. July 2018.

Preliminary Close-Out Report, City of Perryton Well No. 2 Superfund Site, Ochiltree County, Texas. EPA Region
6. September 2003.

Record of Decision, City of Perryton Well No. 2 Superfund Site, Ochiltree County, Texas. EPA Region 6.
September 2002.

Record of Decision Amendment, City of Perryton Well No. 2 Superfund Site, Ochiltree County, Texas. EPA
Region 6. September 2011.

Second Five-Year Review Report, City of Perryton Well No. 2 Superfund Site, Ochiltree County, Texas. April
2013.

State Superfund Program Field Sampling Plan for the Operations and Maintenance Activities at the City of
Perryton Well No. 2, Federal Superfund Site. Prepared by EnSafe Inc. August 2018.

Technical Memorandum for Field Investigation Activities, Revision 01. Perryton Well No. 2 Superfund Site
Remedial Investigation/Feasibility Study. Prepared by EA Engineering, Science, and Technology, Inc., PBC.
November 2020.

Third Five-Year Review Report, City of Perryton Well No. 2 Superfund Site, Ochiltree County, Texas. July 19,
2018.

A-l


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APPENDIX B - SITE CHRONOLOGY

Table B-l: Site Chronology

l'.\ I'111

Dsilc

TDH discovered CTC in city supply Well No. 2

May 9, 1989

The city took Well No. 2 out of service

June 1989

The city completed a Plan of Action recommending installation of an air stripper to remove
CTC from water pumped by Well No. 2

September 1990

TDH concurred with the city's Plan of Action

October 1990

TWC confirmed the presence of CTC in Well No. 2

November 1990

TNRCC investigated the potential sources of CTC in groundwater

May 1991

TNRCC forwarded the Site to EPA for further investigation under Superfund

August 1992

EPA Site inspection indicated that the Site was eligible for further evaluation under
Superfund

February 1993

EPA completed an expanded Site investigation of soil and groundwater and confirmed
contamination in Well No. 2

April 11, 1996

EPA proposed the Site for listing on the NPL

September 29, 1998

EPA finalized the Site's listing on the NPL

January 19, 1999

EPA completed an engineering evaluation and cost analysis to evaluate treatment options
to address Site contamination

August 12, 1999

EPA issued an interim ROD to install and operate the ASTP for Well No. 2; EPA began
the Site's remedial investigation and feasibility study

September 29, 1999

EPA began the remedial action

September 28, 2000

EPA completed the remedial design of the ASTP

May 23,2001

EPA completed the construction of the ASTP and began system operation

February 2002

EPA completed the remedial investigation and feasibility study and issued a ROD that
expanded operation of the ASTP, added a second extraction well (MW-17-EX), and
constructed the RO treatment facility to treat nitrate contamination

September 26, 2002

EPA signed the Site's Preliminary Close-Out Report

September 30, 2003

EPA shut down the RO unit because the nitrate cleanup goal was achieved in Well No. 2

August 2004

EPA completed the remedial action

September 29, 2004

EPA began the LTRA

September 30, 2004

EPA signed the Site's first FYR Report

September 9, 2008

EPA plugged and abandoned Well No. 2 to prevent recontamination of Lower Zone Unit 3

January 2011

EPA discontinued operating the P&T system when the CTC cleanup goal was achieved in
Lower Zone Unit 3

April 2011

EPA signed a ROD Amendment that included a TI waiver for CTC and nitrate in the Upper
Zone and for CTC in Lower Zone Unit 2, a long-term groundwater monitoring program
and implementation of institutional controls

September 29, 2011

EPA signed the Site's second FYR Report

April 23,2013

EPA plugged and abandoned 10 monitoring wells (MW-05D, MW-05S, MW-08, MW-09,
MW-10, MWCL-13D, MWCL-13S, MW-14, MW-15 andMW-16) and two extraction
wells (MW-18-EX and MW-17-EX); EPA installed four Upper Zone monitoring wells
(MW-20 through MW-23) and one Lower Zone Unit 3 monitoring well (MW-24)

April 2014

EPA installed five Upper Zone monitoring wells (MW-26S and MW-29 through MW-32)
and four Lower Zone Unit 3 monitoring wells (MW-25, MW-26D, MW-27 and MW-28)

June 2014

EPA completed the LTRA

September 30, 2014

EPA installed one Upper Zone monitoring well (MW-38) and three Lower Zone
monitoring wells (MW-39, MW-40 and MW-41)

October 2016

City of Perry ton adopted Ordinance #1040-18 to prevent the installation of a well that
would create a vertical migration pathway between the contaminated Upper Zone and the
Lower Zone of the Ogallala aquifer, and to prevent the installation of a well that would
cause migration of VOCs outside the TI Zone

April 17, 2018

EPA signed the Site's third FYR Report

July 19,2018

B-l


-------
V.\onl

Dsilc

O&M responsibilities transferred to TCEQ

July 30, 2018

EPA completed the installation and sampling of five Lower Zone Unit 3 wells (MW-42,
MW-43, MW-44, MW-45R and MW-46)

June 2020

EPA plugged and abandoned MW-45 and MW-19-EX

June 2020

EPA disassembled and removed the RO unit and ASTP

July 2020

B-2


-------
APPENDIX C - PRESS NOTICE

LEGAL NOTICE





1

f

City of Perryton Well No. 2 Superfand Site

Public Notice
U.S. Environmental Protection Agency, Region 6

November 2022

The U.S. Environmental Protection Agency. Region 0 will
be conducting the fourth five-year review of remedy imple-
mentation and performance ai die City of Perryton Well No.
2 Supeifiind sire (die Site) in Perryton. Texas.

"Die Sue is a groundwater contaminant plume of carbon
tetrachloride. Historically, it lias affected a public water
supply well r C icy- of Perryton Well No. 2). Hie remedv in-
cluded groundwater pimping and treatment, and plugging
and abandonment of Well No. 2. Groundwater monitoring
is ongoing.

The five-year' review- will detemnne rf die remedy for die
site remains protective of human health and die environ-
ment. The live-year review is scheduled for completion in
September 2025

The Five-Year Review Report will be
made available to die public at the Sue $
local information repository

Perry Memorial Library

22 S.E. 5tti Street
Perrvton, Texas "79070
(806) 435-5801

Site status updates aie available oil die
internet at

www. eo a. soy.' suoerluud'citv - ot-peimon.

Ail media inquiries should be directed to
the EPA Press Office at (2141 665-2200.

For more information about die Site, please contact:

Nathaniel Apple gate

EPA Remedial Project Manager
{214) 665-2114
or by email at applegate nathanielepa.gov

Jatietta Coats
EPA Community Involvement Coordinator
(214) 665-7308
or 1-S00-SS7-6063 ('toll-free)
or by email at mats..jangliai5L£}ia..oQv

C-l


-------
APPENDIX D - SITE INSPECTION CHECKLIST

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: City of Perryton Well No. 2

Date of Inspection: November 9, 2022

Location and Region: Perryton, Texas 6

EPA ID: TX0001399435

Agency, Office or Company Leading the Five-Year
Review: EPA Region 6	

Weather/Temperature: 71 degrees F/cloudy

Remedy Includes: (check all that apply)

I I Landfill cover/containment
I I Access controls
Rl Institutional controls
153 Groundwater pump and treatment
~ Surface water collection and treatment
|~1 Other:	

I I Monitored natural attenuation
I I Groundwater containment
~ Vertical barrier walls

Attachments: Q Inspection team roster attached

I I Site map attached

II. INTERVIEWS (check all that apply)

1. O&M Site Manager

Emily J. Brickman. PG TCEO contractor with Ensafe Inc.
Name	Title

Interviewed Q at site ~ at office ~ by phone Phone: 	

Problems, suggestions ^ Report attached: Appendix I

2 O&M Staff

Scott Settemever

Name

Interviewed Q at site Q at office Q by phone
Problems/suggestions Report attached: Appendix I

TCEO Project Manager
Title
Phone:

Date

Date

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). Fill in all that apply.

Agency Citv of Perrvton
Contact David Landis
Name

Problems/suggestions 153

Citv Manager
Title

Report attached: Appendix I

11/09/2022 806-435-4014

Date

Phone

Agency Citv of Perrvton
Contact Brandon Knapp. P.E.
Name

Problems/suggestions ^ Report attached:

Director of
Public Works.
Engineering
Title

Appendix I

11/09/2022
Date

Phone

Agency	

Contact 	

Name

Problems/suggestions ~ Report attached:

Title

Date

Phone

Agency.
Contact

Name

Title

Date

Phone

D-l


-------


Problems/suggestions 1 1 Report attached:









Agency
Contact

Name Title
Problems/suggestions | | Report attached:

Date

Phone



4.

Other Interviews (optional) Q Report attached:











IH. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1.

O&M Documents









1 1 O&M manual Readily available

1 1 Up to date

M N/A





1 1 As-built drawings Readily available

1 1 Up to date

M N/A



1 I Maintenance logs Q Readily available
Remarks:

1 I Up to date

[21 N/A



2.

Site-Specific Health and Safety Plan

1 I Readily available

[~| Up to date £<

N/A



1^1 Contingency plan/emergency response plan

1 I Readily available

1 I Up to date £<

N/A



Remarks:







3.

O&M and OSHA Training Records

Remarks:

1 1 Readily available

l~l Up to date ^

]N/A

4.

Permits and Service Agreements









1 I Air discharge permit

1 I Readily available

1 I Up to date £<

N/A



1 1 Effluent discharge

1 1 Readily available

1 1 Up to date ^

]N/A



|	| Waste disposal, POTW

1 1 Readily available

1 1 Up to date ^

]N/A



1 1 Other permits:

1 I Readily available

1 I Up to date £<

N/A



Remarks:







5.

Gas Generation Records

Remarks:

1 1 Readily available

l~l Up to date ^

]N/A

6.

Settlement Monument Records

Remarks:

1 I Readily available

[~| Up to date £<

N/A

7.

Groundwater Monitoring Records

Rl Readily available

15^1 Up to date EH N/A



Remarks:







8.

Leachate Extraction Records

1 I Readily available

I"! Up to date £<

N/A



Remarks:







9.

Discharge Compliance Records









1 1 Air Readily available

1 1 Up to date

M N/A





1 I Water (effluent) Q Readily available

1 I Up to date

[21 N/A



D-2


-------
Remarks:

10. Daily Access/Security Logs

[~| Readily available Q Up to date N/A

Remarks:



IV. O&M COSTS

1. O&M Organization



1 1 State in-house

Contractor for state

I	| PRP in-house

1 1 Contractor for PRP

1 1 Federal facility in-house

1 1 Contractor for Federal facility

2. O&M Cost Records



1 1 Readily available

1 1 Up to date

1 1 Funding mechanism/agreement in place ^ Unavailable

Original O&M cost estimate:

1 1 Breakdown attached

Total annual cost by year for review period if available

From: To:

| | Breakdown attached

Date Date

Total cost

From: To:

| | Breakdown attached

Date Date

Total cost

From: To:

| | Breakdown attached

Date Date

Total cost

From: To:

| | Breakdown attached

Date Date

Total cost

From: To:

| | 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 ~ N/A

A. Fencing

1. Fencing Damaged Location shown on site map 1 1 Gates secured Rl N/A

Remarks:



B. Other Access Restrictions

1. Signs and Other Security Measures

1 I Location shown on site map ^ N/A

Remarks:



C. Institutional Controls (ICs)

D-3


-------
1. Implementation and Enforcement

Site conditions imply ICs not properly implemented

I~1 Yes



No

~ n/a

Site conditions imply ICs not being fully enforced

l~l Yes

ISI

No

~ n/a

Type of monitoring (e.g.. self-reporting, drive bv): Self-reporting









Frequency:









Responsible partv/agencv: Citv of Perrvton









Contact









Name Title

Date



Phone

Reporting is up to date

1 1 Yes

~

No

IXI N/A

Reports are verified by the lead agency

1 1 Yes

~

No

IEI N/A

Specific requirements in deed or decision documents have been met

IEI Yes

~

No

~ n/a

Violations have been reported

1 1 Yes

~

No

Kl N/A

Other problems or suggestions: ~ Report attached

2. Adequacy	Q ICs are adequate	^ ICs are inadequate	Q N/A

Remarks: Site-specific institutional controls were implemented bv the citv of Perrvton in April 2018
through the adoption of Ordinance #1040-18 (Appendix J). The citv ordinance applies to the entire area
within the citv limits and prevents the installation of any well that would create a vertical migration
pathway between the Upper Zone and the Lower Zone of the Qgallala aquifer. It also prevents the
installation of a well that would cause migration of VOCs outside the TI Zone.

D. General

1.	Vandalism/Trespassing Q Location shown on site map ^ No vandalism evident
Remarks:	

2.	Land Use Changes On Site	^ N/A
Remarks:	

3.	Land Use Changes Off Site	^ N/A
Remarks:	

VI. GENERAL SITE CONDITIONS

A.	Roads	Q Applicable ^ N/A

B.	Other Site Conditions

Remarks:	

VII. LANDFILL COVERS	~ Applicable N/A

VIII.	VERTICAL BARRIER WALLS	~ Applicable ^ N/A

IX.	GROUNDWATER/SURFACE WATER REMEDIES ^Applicable ~ N/A

A.	Groundwater Extraction Wells, Pumps and Pipelines	Q Applicable ^ N/A

B.	Surface Water Collection Structures, Pumps and Pipelines Q Applicable ^ N/A

C.	Treatment System	^ Applicable Q N/A

D-4


-------
1.

Treatment Train (check components that apply)

1 1 Metals removal Q Oil/water separation Q Bioremediation
1 I Air stripping Q Carbon adsorbers
I"! Filters:

1 1 Additive (e.g., chelation agent flocculenf):
n Others:

1 1 Good condition Q Needs maintenance
1 1 Sampling ports properly marked and functional
1 1 Sampling/maintenance log displayed and up to date
1 1 Equipment properly identified
1 1 Ouantitv of groundwater treated annually:

1 1 Ouantitv of surface water treated annuallv:

Remarks: The AASTP and RO unit were decommissioned.

2.

Electrical Enclosures and Panels (properly rated and functional)

15^1 N/A O Good condition Q Needs maintenance

Remarks:

3.

Tanks, Vaults, Storage Vessels

15^1 N/A O Good condition Q Proper secondary containment Q Needs maintenance
Remarks:

4.

Discharge Structure and Appurtenances

15^1 N/A O Good condition Q Needs maintenance
Remarks:

5.

Treatment Building(s)

1^1 N/A Q Good condition (esp. roof and doorways) Q Needs repair

1 1 Chemicals and equipment properly stored

Remarks:

6.

Monitoring Wells (pump and treatment remedy)

15^1 Properly secured/locked ^ Functioning ^ Routinely sampled ^ Good condition
1 1 All required wells located Q Needs maintenance Q N/A
Remarks:

D. Monitoring Data

1.

Monitoring Data

1^1 Is routinely submitted on time ^ Is of acceptable quality

2.

Monitoring Data Suggests:

1 1 Groundwater plume is effectively contained Q Contaminant concentrations are declining

E.

Monitored Natural Attenuation

D-5


-------
1.

Monitoring Wells (natural attenuation remedy)

15^1 Properly secured/locked ^ Functioning ^ Routinely sampled Q Good condition

15^1 All required wells located ^ Needs maintenance Q N/A

Remarks: TCEO's contractor conducted some maintenance prior to the 2021 inspection. Therefore,
fewer issues with sediment and standing water were observed. The 2022 inspection indicated similar
conditions as noted prior to 2021. including sediment and silt in eight wells, seven damaged well pads,
four cracked wells and standing water in 15 well vaults. Well maintenance continues to be an issue at the
Site. During the site inspection. TCEO indicated it would be conducting maintenance on several wells.

X. OTHER REMEDIES

If there are remedies applied at the site and 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.

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 designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).

The remedy currently includes groundwater monitoring. The 2002 groundwater P&T remedy component
is no longer operating at the Site. Contaminant concentrations in all monitoring wells screened in the
Lower Zone Unit 3 were below the MCL by 2008, and the P&T remedy had achieved the RAOs and goals



for Lower Zone 3 groundwater. The P&T system was shut down in 2011 after plugging and abandonment



of Well No. 2. Groundwater monitoring has continued at the Site following shutdown of the P&T system.
CTC was detected above the MCL beginning in February 2012 in MPMW02 port 3 (Lower Zone Unit 3).
Long-term monitoring of Lower Zone Unit 3 is ongoing and concentrations continue to increase. A TI
Zone is in place in the Upper Zone. However, several wells at the edge of the TI boundary fMW-31.
MPMW03 and MPMW06) or outside of the TI Zone (MW-33) exceed the CTC cleanup goal. More
delineation and adiustment to the TI boundary is warranted for the CTC plume in the Upper Zone. An
increase in water levels, continuing source contribution and lack of natural degradation of CTC may be
contributing to Upper Zone plume migration and increasing CTC concentrations. TCEO believes that
there may be remaining source area at the PEX property that is continuing to leach into groundwater. An
institutional control is in place preventing the installation of groundwater wells that may cause migration
of the plume.

B.

Adequacy of O&M

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

O&M is adeauate. However, freauent issues are noted with the monitoring wells due to their location in
high traffic areas. This continues to be an issue. Maintenance is ongoing.

C.

Early Indicators of Potential Remedy Problems

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

Several issues have been noted and need to be addressed to ensure future protectiveness. See earlier
sections of this FYR Report.

D.

Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Several actions are needed to ensure future protectiveness. See sections of this FYR Report.

D-6


-------
APPENDIX E - REMEDIAL ACTION AND SITE INSPECTION PHOTOS

City of Perryton warehouse facility
E-l


-------
Decommissioned monitoring well MW-19

Monitoring well MW-31

E-2


-------
Monitoring well MW-34, in need of repair

Swale on PEX property, potential source area

E-3


-------
APPENDIX F - DATA REVIEW FIGURES

Figure F-l: Upper Zone Hydrograph1

Figure 5. Upper Zone Groundwater Bearing Unit Hydrograph Data

*2 2700.00

2680.00

10/28/1995

4/19/2001

10/10/2006

4/1/2012

9/22/2017

3/15/2023

9/4/2028

¦	MPMWOl-1

¦	MPMW03-2

¦	MW-19-EX
» MW-23

¦	MW-31
-MW-37

¦	MW-17-EX P&T Ends

• MPMW01-2
-MPMW04-1
¦MW-20

-	MW-26S

-	MW-32
MWCL-07S

¦ Well No. 2 P&T B

-MPMW02-1
-MPMW04-2
» MW-21

-	MW-29
» MW-33

-	MWCL-11S

• MW-17-EX P&T Begins

• MPMW03-1
¦ MPMW06-1

-	MW-22
» MW-30

-	MW-36

Well No. 2 P&T Ends

-	MW-19-EX P&A

City of Perryton Wei No. 2

EI I	Federal Superfund Site

Perryton, Ochiltree County, Texas

1 Source Final Annual Operation and Maintenance Report, Fiscal Year 2022.

F-l


-------
Figure F-2: Lower Zone Unit 2 Hydrograph2

Figure 6. Lower Zone Groundwater Bearing Unit - LZ 2L Hydrograph Data

2685.00

2655.00

10/28/1995

• MPMWQ1-3

¦	MW-38

¦	MW-19-EX P&A

4/19/2001	10/10/2006	4/1/2012 9/22/2017 3/15/2023	9/4/2028

MPMW02-2	• MPMW03-3	> MPMWQ4-3 • MPMW06-2

Well No. 2 P&T Ends	— •— MW-17-EX P&T Ends	Well No. 2 P&T Begins • ••••• MW-17-EX P&T Begins

MW-34	i MW-35

EJMSAFE

City of Perryton Well No. 2
Federa' Sjperfund Site
Perryton, Ochiltree County c Texas,

2Source Final Annual Operation and Maintenance Report, Fiscal Year 2022.

F-2


-------
Figure F-3: Lower Zone Unit 3 Hydrograph3

Figure 7. Lower Zone Groundwater Bearing Unit - LZ 3 Hydrograph Data

2676.00

10/10/2006

» MPMW02-4
• MW-24

¦	MW-39

O Weil No. 2 P&T Ends

¦	MW-42

4/1/2012	9/22/2017 3/15/2023	9/4/2028

¦ M PMW03-4	• M P MW03-5

•	' (VW-2S	• MW-26D

•	MW-40	» MW-41

— MW-17-EX P&T Ends	¦ Wall No. 2 P&T Begins

•	MW-43	• MW-44

2646.00

10/28/1995
-^^"MPMW01-4
MPMW04-4
• — MW-27
MWCL-07D

	MW-17-EX P&T

» MW-45R

4/19/2001
MPMW02-3
¦ MPMW04-5
• MW-28
MWCL-11D
Begins • MW-19-EX P&A
9 MW-46

City of Perryton Wei No. 2

PJlf C J\ f_ I	Federal Superfund Site

i	Perryton, Ochiltree County, Texas

3Source Final Annual Operation and Maintenance Report, Fiscal Year 2022.

F-3


-------
Figure F-4: Upper Zone/Lower Zone Unit 2 Potentiometric Surface Map, 20224

MW-3G :

2feiS'iSj

MPMW03-01 2700 92
MPMW03-02 2700 90

MPMWOfedlP^

iMvvr3i,
¦2700:274

MW-26Si
i2701I'3l"i^

GW-021

p&aW

A MgMW02 01

MW-23
52691.1'

\m-21

2701::$

v"" ^

|MWGirj,1Sl

MW-3S
(aeTdw?

MHMWOi i:i
MPMnVr:i-r:? rrssa -«)

MPMijVai%!2703:39^
jMe wjojffimofst)

EMliiX6WCKM#r

" QEOLOGV

. isim _ .\i
^'CENSfc?-,^

MVVCL-07SJ
(2G9S.92) '*

LEGEND

FIGURE 3

UPPER ZONE POTENTIOMETRIC SURFACE MAP
MAY 2022
CITY OF PERRY70N WELL NO. 2
FEDERAL SUPERFUND SITE
FERRYTGN, OCHILTREE COUNTY, TEXAS

: Dianas rnoM i bstsrza. 
-------
Figure F-5: Lower Zone Unit 3 Potentiometric Surface Map, 2022s

MAIN MAP
*--„AREA'

MW-42* MW-43i* _

MPWWO 3-03.(2^7.6S);
MPM WO 3-04 (2656:09)';
J MPMW03-05;3S54.96^

GW-02

MI>MW02-02 (266K64)
,M5MW02-D3j(2«5 ^52)
TMPMW02;04 26S4JIQ

MF?MW04-03^(26££J56)
¦*MJgMW04-04!( 26*54:72} <
MPMW04-05 2663.00

MPMW01 -03; (2€&fl -04]^^
MPMW01-04 (265^.1.2) i
!fMf»MW01if05 2653 22 W jm

MW-40:.

;• fMflVA^KKA'N

* GEOLOlJV
V . 121&* _ -

y'}i£j*><5

FIGUR£9

LOWER ZONE POTENTIOMETRIC SURFACE MAP
MAY 2022
CTTV OF PERRYTON WELL NO. 2

LEGEND

LOWER ZONE ;17; KONTTTJRIHG'

RAILROAD

5 Source: Final Annual Operation and Maintenance Report, Fiscal Year 2022.

F-5


-------
Figure F-6: Upper Zone/Lower Zone Unit 2 CTC Plume, 20196

Mpwvwn.a

1-8.51
2 8. fO

*13.9 JL-PR

MW-32 I

21.«/2#.0

' ' ' G£OLOGV

12164 „ v

^V//CEN5«;.^

WWCL-D7S

LEGEND

UPPER ZONE (U2) MONITORING WELLS

GROUNDWATER R.CW DIRECTION

I I CITY OF PERRYTON MAINTENANCE FACILITY
MAY 2019 CARBON TETRACHLORIDE CONCENTRATION
(DASHED WHERE INFERRED)

5 -10 imA.

10 - 20 moA
2D - 30 pg/L
30 -40 part.

, > 40 |kj/L

DRAINAGE FLOW DIRECTION

NOTE:

-	GW-Q2 WAS DIGITIZED FROM HISTORICAL AERIAL IMAGERY

-	11.4/113 = SAMPLE RESLfLT/DUFUC«TE RESULT

-	RED TEXT INDICATES EXCEEDAKCE OF 5 MICROGRAMS PER LITER

-	MW-19-Bt HAS A 40 TOOT SCREEN, LONGER THAN OTHER UZ WEILS
AND IS DILUTING CTC. MW-19-EX DATA WAS NOT USED TO CONSTRUCT
THE KCCONTOURS

DRAINAGE SWALE FEALTTURES

OTHER
] PCX FACILITY FEATURES

CITY OF PERRYTON FEATURES
1 OTHER FEATURES

UZ UNIT 2

MONITOR WELL COUFLER (UZ UNIT 1)
MONITOR WELL COUFLER (UZ UNIT 2)
MULTIPOPT MONITOR WELL
PLUGGED & ABANDONED

REQUESTED BY;

NAD 1983 (2011) STATE FUWE
TEXAS NCRTHFffiT

DRAWN BY:

9/4/3319

PERRYTON EQUITY EXCHANGE

FIGURE 10

D15TRlBLmON OF CARBON TETRACHLORIDE
IN UPPER ZONE MAY - 2019
CITY OF PERRYTON WELL NO. 2
FEDERAL SUPERFUND SITE
PERRYTON, OCHILTREE COUNTY, TEXAS

EN SAFE

6Source Final Annual Operation and Maintenance Report, Fiscal Year 2019.

F-6


-------
Figure F-7: Upper Zone/Lower Zone Unit 2 CTC Plume, 20227

;IHPWWWI1.2H

1 - 7.73
I 2-9.O5f0.O3

I MPMW02 <11

EWILYlBRidWAN
,"' geology

121W- .j

FIGURE 10

DISTRIBUTION OF CARBON TETRACHLORIDE
IN UPPER ZONE MAY - 2022

OTV OF RERRVTOtt MAINTENANCE FACILITY

HORIZONTAL BOUNDARY OF TECHNICAL IMPRACTICABILITY ZONE HQIES:

GROUNDWATER FLOW DIRECTION

DRAINAGE FLOW DIRECTION





-2.39

- 5-3?

1 Source. Final Annual Operation and Maintenance Report, Fiscal Year 2022.

F-7


-------
Figure F-8: Upper Zone/Lower Zone Unit 2 CTC Concentrations Over Time8

Figure 11 - Upper Zone Wells - Carbon Tetrachloride Over Time

0.00

t MPMW-02-1

•	MPMW-03-1
9 MWCL-11S

•	MW-22
¦ MW-26S
9 MW-31*

9 MW-32*

•	MW-33*

MW-21

Cleanup Standard - MCL

•	•••• Well No. 2 P&T Begins

—Well No. 2 P&T Ends

•	• •* • MW-17-EX P&T Begins

—• — MW-17-EX P&T Ends

9 MW-19-EX P&A
* detnotes Upper Zone
monitoring localion where
contaminants have migrated
outside the Technical Impracticability
(Tl) Zone at concentrations exceeding
the cleanup standard or 5 pg/L or
Upper Zone monitoring location
upgradient of the II Zone indicative
of migration of contaminants past
the Tl Zone boundary.

EN SAFE

8Source Final Annual Operation and Maintenance Report, Fiscal Year 2022.

F-8


-------
Figure F-9: Lower Zone Unit 3 CTC Plume, 20199

9Source Final Annual Operation and Maintenance Report, Fiscal Year 2019.

F-9


-------
Figure F-10: Lower Zone Unit 3 CTC Plume, 2022"'

LEGEND

LOWER ZONE (LZ) MONITORING WELLS	PERRVI ON EQUITY EXCHANGE

H$r 12 utwr 2	| | CTTY OF PERRYTON MAINTFEMANCE FACILITY
*^r 12 UNIT 3 HORIZONTAL BOUNDARY OF TECHNICAL IMPRACTICABILITY ZONE*

©L MOMTTOR WEL COUPLER (LZ UNIT 3)	may 2(322 CARBON TETRACHLORIDE CONCENTOATTON

9 MULTTPORT MONITOR WELL	fOASHEDWHERE INFERRED)

PLUGGED & ABOND0NED	I 5 ts 10 Ufl/l
» GROUNDWATER FLOW DIRECTION 10 Ua'L

rPTES;

-	GW-02 WAS DIGITIZED FllCM HISTORICAL AERJAl TMAGERY
-11.4/11.# ~ SAMPLE RESU LT/DUPUCATF RESULT

-	J = ESTTHAT0D VALUE

-	U = WOT DETECTED ABOVE LAB DETECTION LIMIT

-	RED TEXT INDICATES EXCEETWNCE OF 5 MICROGRAMS PER LITER

-	MW-1ID HAS A lO-FOOT WELL SCREEN; MOST OTHER LZ WELLS

HAVE 20-FOOT SCREENS. DATA FROM MW-11D TS NOT REPRESENTATIVE
OF LZ AND WAS NOT USED TO COWSTRUCT THESE JSOCOMTOlJtS.

-	TECHNICAL IMPRACTICABILITY ZONE IS APPLICABLE FOR THE UZ AND LZ ZU

l0Source: Final Annual Operation and Maintenance Report, Fiscal Year 2022.

F-10


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Figure F-ll: Lower Zone Unit 3 CTC Concentrations Over Time11

0.00

Figure 13. Lower Zone - Carbon Tetrachloride Over Time







1
1
1
1
1

1

















1
1
1
1
1

I



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¦MW-28
MW-24
MW-40*

¦	MW-41*

-MPMW-01-3

¦	MPMW-01-3

¦	MPMW-02-3
¦MPMW-04-5*

» Cleanup Standard - MCL
Well No. 2 P&T Begins
•Well No. 2 P&T Ends

¦	MW-17-EX P&T Begins
i MW-17-EX P&T Ends

* demotes Lower Zone Unit 3
monitoring location where
contaminants have migrated
downgradient from the source area
at concentrations exceeding
the cleanup standard of 5 pg/L.

EN SAFE

uSource: Final Annual Operation and Maintenance Report, Fiscal Year 2022.

F-ll


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APPENDIX G - CLEANUP GOAL REVIEW TABLES

CERCLA Section 121(d)(1) requires that Superfund remedial actions attain "a degree of cleanup of hazardous
substance, pollutants, and contaminants released into the environment and of control of further release at a
minimum which assures protection of human health and the environment." The remedial action must achieve a
level of cleanup that at least attains those requirements that are legally applicable or relevant and appropriate. In
performing the FYR for compliance with ARARs, only those ARARs that address the protectiveness of the
remedy are reviewed.

Groundwater A RA lis

The 2002 ROD identified chemical-specific ARARs for the Site's groundwater COCs as the MCLs specified
under the Safe Drinking Water Act. The 2011 ROD Amendment waived the chemical-specific ARARs, which are
the MCLs for CTC and nitrate in the Upper Zone and for CTC in Lower Zone Unit 2 of the Ogallala aquifer
within the TI Zone. However, outside the TI Zone, the remedial goals still apply. This review compared current
federal MCLs to those used in the 2002 ROD for the groundwater COCs. Except for chloroform, none of the
MCLs has changed since the 2002 ROD was published (Table G-l).

In the Stage 2 Disinfectants and Disinfectants Byproducts Rule, promulgated January 4, 2006 (effective March 6,
2006), a maximum contaminant level goal (MCLG) of 70 ng/L was set individually for chloroform. Chloroform
concentrations in groundwater at the Site have remained below the cleanup goal of 100 ng/L as well as the current
MCL of 80 ng/L for total trihalomethanes (which includes chloroform, dibromochloromethane,
bromodichloromethane and bromoform) and the MCLG for chloroform of 70 ng/L. The maximum detected
chloroform concentration in the September 2012 groundwater sampling event was 16 ng/L in MWCL-1 IS, which
is below the current MCL and MCLG for this COC.

Table G-l: Cleanup Goal Review for Groundwater COCs

COC

2002 KOI)
Alt Alt

(iil>/l.)

( 111-IT 111

I'l'lllTill
MCI."

/l.)

Chiiiii>i'

Atrazine

3

3

none

CTC

5

5

none

Chloroform

100

80 (70)b

more stringent

Nitrate

10,000

10,000

none

Notes:

a.	The source for the MCLs is https://www.epa.gov/ground-water-and-drinking-
water/national-primarv-drinking-water-regulations (accessed on 1/12/2023).

b.The	remedial goal for chloroform of 100 |ig/L was based on the MCL for total
trihalomethanes, which includes chloroform, dibromochloromethane,
bromodichloromethane and bromoform. In March 2006, EPA set an MCLG of 70
|ig/L for chloroform. The MCLG is health based but is not an enforceable value.

G-l


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APPENDIX H - VAPOR INTRUSION SCREENING-LEVEL RISK REVIEW

The vapor intrusion pathway was evaluated during the 2018 FYR using EPA's vapor intrusion screening level
(VISL) calculator to determine if the vapor intrusion exposure pathway poses future health concerns due to the
presence of CTC in the Upper Zone. During this FYR period, the highest CTC concentration was detected in
Upper Zone Well MW-31. Use of Upper Zone data is preferred in evaluating the vapor intrusion pathway because
this zone would be the closest zone to an overlying foundation. As shown in Table H-l, the concentration for
CTC in MW-31 results in a noncancer hazard quotient (HQ) below 1.0 for both default future industrial and
residential exposures. In addition, the CTC groundwater concentration is within EPA's risk management range of
1 x 10"6 to 1 x 10"4 for future industrial and residential land use.

These screening-level results are conservative and likely overestimate risk because the VISL calculator does not
take into account that contaminants attenuate from the groundwater surface through the soil column, which is
about 232 feet from the land surface. These results suggest the vapor intrusion pathway is unlikely to be an
exposure pathway of concern at this time. However, evaluation of the vapor-intrusion-to-indoor-air pathway is
recommended prior to construction of any occupiable structures to ensure the vapor intrusion conclusions have
not changed based on any change in contaminant conditions over time.

Table H-l: Screening-Level Vapor Intrusion Evaluation

(¦(>(¦

(•niundw iiu-r
(onci'iilmlion
2022

(ii»/1.)-'

2022 VISI.C iikuliilor h
(sncrsiuc iii'< >n nclw siier U'liiiK'nil lire 25"()

Induslriiil r.xnosuri'

Ki'sirii'iiliiil r.\|»>MiiT

( ;iikti- Kisk

Nonciiiu'i'r HQ

C iinci'r Kisk

NolU'.IIK'lT HQ

CTC

44.3 (MW-31)

2x 10"5

0.1

1 x 10"4

0.5

Notes:

a.	The CTC concentration is from Table 5 of the 2022 Annual O&M Report.

b.	VISL calculator accessed 1/12/2023 at https://www.epa.gov/vaporintrusion/vapor-intrusion-screening-level-
calculator.

H-l


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APPENDIX I - INTERVIEW FORMS

CITY ()l PKRRYTON NYEI.I. NO. 2 SI I'KRI I M) SITE
MYE-YEAR REYIENY INTERYIENY EOR.M

Site Name: City of Perryton Well No. Superfund Site

EPA ID: TX0001399435

Interviewer name: Nathaniel Applegate

Interviewer affiliation: EPA

Subject name: David Landis, City Manager

Subject affiliation: City of Perryton

Subject contact information: 806-435-4014

Interview date: 11/09/2022

Interview time: 1:30 p.m.

Interview location: City Hall, Perryton, Texas

Interview format: In Person

Interview category: Local Government

1.	Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place
to date?

Yes.

2.	Do you feel well-informed regarding the Site's activities and remedial progress? If not, how might EPA
convey site-related information in the future?

I feel well informed. In terms of remedial progress, we like knowing when you are here sampling.

3.	Have there been any problems with unusual or unexpected activities at the Site, such as emergency response,
vandalism or trespassing?

No.

4.	Are you aware of any changes to state laws or local regulations that might affect the protectiveness of the
Site's remedy?

No.

5.	Are you aware of any changes in projected land use(s) at the Site?

No.

6.	Has EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can EPA
best provide site-related information in the future?

Yes, anyone that wants to know anything has access to what they need.

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

No additional comments, I appreciate you updating us.

1-1


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8. Do you consent to have your name included along with your responses to this questionnaire in the FYR
Report?

Yes.

1-2


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CITY ()l PERRYTON WELL NO. 2 SI PERI-T M) SITE

i iye-year reyieny interyieny i orm

Site Name: City of Perryton Well No. Superfund Site

EPA ID: TX0001399435

Interviewer name: Nathaniel Applegate

Interviewer affiliation: EPA

Subject name: Brandon Knapp, P.E. Director of
Public Works. Engineering	

Subject affiliation: City of Perryton

Subject contact information: bknapp@perrvton.net

Interview date: 11/9/2022

Interview time: 1:30 p.m.

Interview location: City Hall, Perryton, Texas

Interview format: In Person

Interview category: Local Government

1.	Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place
to date?

Yes.

2.	Do you feel well-informed regarding the Site's activities and remedial progress? If not, how might EPA
convey site-related information in the future?

I feel well informed and have no recommendations for conveying future site-related information.

3.	Have there been any problems with unusual or unexpected activities at the Site, such as emergency response,
vandalism or trespassing?

Not that I am aware of.

4.	Are you aware of any changes to state laws or local regulations that might affect the protectiveness of the
Site's remedy?

No.

5.	Are you aware of any changes in projected land use(s) at the Site?

I am unaware of any.

6.	Has EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can EPA
best provide site-related information in the future?

Yes, I think that everyone is informed as best they can. All the information is on the site profile page.

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

Nothing to add.

1-3


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8. Do you consent to have your name included along with your responses to this questionnaire in the FYR
Report?

Yes.

1-4


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F:';. e-Ve:-J it^r.-.ev. 5or.::

City of PenytauWell! 2 Smerftnd "ate
Per. ton Texas
December I '¦ 2012



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1 Wh.?.* iz your oveiali irupre-.tion of the project. in^lucai? cUamip. maintenance. and reme

s :t:v:t:e. > ? .	lt:,k ¦"

L"pr-i 2ou-? "isid L-jivri- Zone Unit ;

The Upper Zone >:YZ'< ;.nd the Lowe Zona iLZ'i Unit 2 of the Q galls b 3quite: are jmt
zon'.ulered ie hull, ionics of potable *v?.te: :'o: the araa ?.nd tie non*:. were determined by
the U.S. ZnvuoaiiiiDTaL Protection Asm-zy i'U S EPA) to ":e technical]}- eripnK n.cabk to
remediate zo^cetRanoi^ of carbon tet:sehlende ;C TC) in jrrotindwate: na pimp mdnear
:TSri) • As part of th« September 2C1 I R*ccra of D«cumk: iJIOD!- Amendment (U S. EFA
1"! II": ? 7^cl'ji:.:."I "mpi - :r-zy:i'.:~ ¦ T J ¦ "'¦'¦:•:" :.:e	C	Le"-il -2.M2.'

for C7C ix stoundivater v. a: r.cued fo: the UZ and LZ Unit 1 to cieate a definsa TI Zone m
pioxmuty to the City of Penytoa maintenance yaid and the Penyton Ecuity Exchange :FZX'
::he -.ouice none for C TC <. The 2011 R.OD Asiezdmant alio included longr-term
gicimdwaTer monitoring az.d reporting to et-j It^.te chemical; cf concern in rrourdv.-?.te:
w.ihis. the TI Zon« thi oufh a?, rural pi o:e-:ei a ad provided to: '.aipieineatscioE. of
mttittraora.] control; to prevent :r. Italian on cf water supply well; that could pcttifciy -create a
">?:t::3i irupsnci: p^;h\fo: CTC :.;i-.Id e:;i-o'.-= ]-=:¦= pro: :.

Lone-term pourcwarsrEiiciiitciinz dat.i collected by the Texa:, C omni::'.:cu on

Ei:v:: ciime i:~l C;TCEO- pi:	eat:: iis.ce 21:I> uuh.-re tIi?; ccjiosiitisum*.: of

C7C ie the UZ and 1Z Unit 2 exceed the MCL ?Jid the CTC plume ha:, migrated and

Id feet, njoi: "<_"Z and LZ Urn 2 wells ocaased id concenti atxa d'jrais PJrT actum. wxcfa could suggest
mo'rilcacoD of the ihalie^v iource area ccaceatnnxis x retetica ® tie P&7 z^eaoiTOier te.-c.er.-. Oiaer die-,

im"hs.i'«-3ffir:rj€lc..aJiic>3i±ca:«ltl3a:OTapaif i3d3naJQ,jeaceoctter.TZ Hos-y.w. tHFjirFr.^-" " -
derenniuti a£t cxitfmratKa. psien: in ria 1C sxd LZ Unit 2 wtii act being adirsi-ed ty Lie P&T iTiiaa. aod
that PJcT would aot be eStcivt to recediare the:.e grorjaAvarer-besT-Jtz xle >V 'j HPA 200E;

1

1-5


-------
Fn e-Taar Iiitervisiv f cam

City o;PeiritMiWellIT;. 2 :upf the TI Zone to tie nonh\ve:t mmoi
M\V-31 and likely tenveen M\Y-5~ and Iv'W-iO >. to :he ¦ztzzz (MTV-'3. npfn»;i-:a:c zc€^mio anticipated for the
sxrsnt of th? piuire: Lo7.-ei. ei, the UZ md LZ Unt 2 C 7€ phnne La; nutated beyond tlis
TI Z•;¦:¦.i bsu:. :l;.:y re thi ;.c rhv. e:t. v-'i.: ; ov.'h :: I'.crLi-r ¦ >::" :he 1 ire

Aiti.v. of CTC MCL i6xcesiiE.ee-: out: id* of the TI Zone botirdmy iz the UZ sad LZ Unit 2
have not been addj€.;:«d by hi: tone zl ROD',, are outude of areas covered by Hictiratiosisl
:s:;t;el; com id pv.- :e:^s ::.3. :-:zi	•.sir: ::C mi jrrsnci:	v fc-: CTC

•>.veZ ha; beer, oi n-ere to be installed-withm areas cf The CTC plume.

The TI Zer>e boundary doe: not fuiiy encapsulate the CTC MCL e:ccee dance zone and
require: modification Ad iiucnal »Teund:vaTei monitcnnE: well: are ne-idti to determine the
rill extent of the CTC piume il the UZ and LZ Urn: 2

Additionally. ±e 2C11 3.0 D zmendment for CTC of the UZ and LZ Unit 2 included
containment of contaminated groundwater within the TI Zone through naTiiia] proc-;::?;:
howevei. tbe ROD amen tJient goes cl to .tate " . .nar-iral Hten^anon mechanism; to reduce

the C'0r.t32i3H3zt eonoentr ation-: at tb? Sire are limited m :heii effectiveness." Cmi?Et
soimdwater data indicates that averase pK m the UZ and LZ Unit 2 aie stionsrly acidic,
below 5 standard unit: Rata;. of hydrolysis. -or abLotie-d&fradation or reduction. which likely
cor.tibu.te tc natucal attenuation of CTC in zrouE.dwatei: c:e pH- and teir.peiar.ue - depends nt.
T,vhich can strongly inrluence the rate of CTC de^-adacoti. Hydroiy;;: ofCTC under scick-r
coxa::;-;-:; :?.z be ;!cv.-e: th?i;	br.;€-c,-,"-.y-.i: cc-nincj;: 'vhi;L i; 1:L<»>.-

;or.!nbuUj:g to the lack cf nature] arfanuanan of C TC at the Site

The current remedy for the UZ and LZ Uiut 2 i: not piotsrnve of human health md the
eii\-L>ciiininr cue to MCL e:;ceedance; out: ide of the TI Zone boundaiy. the h.ck of
in:nti;non;.l control: for MC L e:-: :eed?.n;?: cintide cf the TI Zone bcimdsry, ano. the bet of
containment cf C TC due to natiual piece:: Ac con; :hould be taker, by the U S EFA and a
leinedy miendbrent :hould be unplenrented for ie UZ and LZ Unit 2

Lov.fi Zont t'aut .4

The Lowe: Zcn± Unit 3 > LZ 5"i of the OgaZab aquifer i: considered the msui comte cf

3t•=:!.' thi	;-. :r.:ien.T.v v,:edby rh^ C:r- of rr:vyrc-;; :•:	v.-;.ti:

-supply.

In 1 .W9. the U.S. EPA i::ued an Inter.m KOD (U S EPA. Septembei 1?»99> defediijE the
m;tali3t;cn of 2 P&T ;y;teoi with an air ;aippai on Well No. 2 to provide ccnrsol on further
conraaimarroiigncon and to mre CTC pnoi to di:rhc.:^s to the Cm- cf Fen-;, ton '.v^.ter
diinibutxon -.yiten The Inte:ixi K.CO ;:ated that the mtaun lemediai action 
-------
Ftve-Year Liteview Form
City ofl^rvtacAVeUKo I 'Sraericid Site
iter,"tea Tea-.
z^-n^ixri: :

ill net c onetime tie final remedy. and ia: the hiteiini 1_4 would be eoticistent wr.li the fnia:
acuon -.elected for the gicurduater at the Site (U.S. EPA September i 959 > In February 2SCO.,
'construction of an au-itnppe: teames; plant (ASTF1 i,ra: couip leted Tie final ?J3~> wa;
rv.ued en September 26 20C2. ?.nd identified the selected remedy for the Site a:

- l-y.-'-Jz:! C'T-i> r.::o!:	N,;- ¦¦¦ i.v:.i:.vv;; E\;.\icn-:-- nV'.' .i'\V

Lc '!j-Tc} t'. M?wi!ot i»g " The pmpcie of the FA. wa: to prevent futher mipaticn of CTC
:-i:d :lea:: v.p the ::A : ted n-i-i.ir.dwarer :-f the II : ;h n:l,:i'..j v:?:e: :

Fiill-csie opera tier, of the AS TP began in N overr.b er 2002 with the piunp in g ef Well No. 2
CTC fu-t decreated below tie MCL in Well No 2 in October 2CCS. - year. after pumping
:ta«ed. On Septeoifcej 2E. 200T tie FiT :y:tezi w.v. tint down to evaluate CTC rebound.
App:c::mi3tely 1 ncntli Later. the CTC :oneent:r>:ion m ".Veli 2, Thi:

reconiffiezdation wa: made even though hi:to::cal data iom the :ebound evaluation
indicated that lebcund o: C TC m the 12 would occur Additionally. the final poundtvater
-.ample collected from Well No 2. in September 2003 had a CTC concen trad or. of 6 ug L.
exce-edinz the I'-'ICL >;c,ee Table 2 in the Second Five-Yea: R-iiew Report [U.S. EPA 201 f;>.
theiefore. the remedial me.vAue: of the 2C02 ROD allowing for :e:toia*jen of the Site
gicundwiT'j to an ume:tncted drmhizg v.-atei :upply had not been mat. Nonethele::.
operation of Well No 2 cea:ed si pan of the active P«5cT ",yiT«m ASTP. and the well v,~3z
abandoned iz ."annay 2C11 The September 20: L ROD Amendment iU.S EPA 2Cl 11 kept
the 2OCT ROD cleanup standard of 5 uz L foi the LZ 3 but did not provide an alternate
lemedial 3:tion objective to addre;; potential seboxmd of CTC in the LZ 1 Fiuthennoie. the
2011 FvOD .imendiiient iU S EPA 2011) ir.cheated that naan al attematoa wsi sot
:o=.:ideied a liable approach tc a :hie'. e the MC L due to limited effectivenei^ a- the Site,

CTC gicimdwater data for the LZ ; pcit-abandonment of Well No 2 have :hown iiftufiexit
leoound. mcreaiing concent:atior.: over time, pel-nt^at exeeedance: of the 2-1C L. and plume
«:-:paruor m the diiecticii of the C ily cf Feny»n diiriiuig water Viippiy well: Data mdicote
plume mitabilir.- expannon and a b.ci of :edu:hon of CTC due to the failiue of the remedy
and the inabilir,- ofcartiial attenuator.pioce-.ie: to remediate the CTC plume:. The
t or. nil tied MCL exceedar.ee: in LZ S vreli-. in-ic ate the potential pieience of other paxway:
'De:ide: hi:t02ical Well No. 2; foi hydiauhe coonecticn henveen the UZ and LZ which could
allov.' fos veir.eal r^igranor. of CTC over tune.

A: con:ludei in multiple TCEQ Oparatioa: and 2.1amt€n^nce E.epo:t:. many i::ue: har®
been identified m the namedy peifoimance. rat the mott tignficart r. the LZ 3 CTC data
v,"hr:h indicate CTC ha: rebounded ard mipated downgiadiert at concendaticn: ato'/e the

MCL in the duection of the :ity djinimg wates :upply well: CtW-03 and GW-C4 The data

3

1-7


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Frve-Y»ar Ifffernew Fanr.
C !-• o: Perr-i:-ii Well Kc I Superfod "I-ne
SsTrtcti Texas
1.".. 1 >21

uiAcate tii? LZ remedy ha; failed. Xamedial Actioa Objective; (RAO:"; not achieved,
and tie RAO: ire cmTaatly not bring met for the LZ 3. Additional anion '-hoiiid be taken bv
die U.S. EPA to fulfill tie RAO:.

2. *Vbz: ic your a;c«:cm«Q.T of the cxmest perfomiaiiie of the remedy in place st fhe Site?

Vpjwi Zou-? .tad L>jTi-er Zone Urnr 1

At the time of the TI Zcce aetmcaiy e:tarl::tmi«iT in 2 CI1. tii« UZ and LZ U*^r 2 C HI
potuieLwater plume wa: contained within tie II Zone C TC paimdwaier data rioai 2022 fo:
the UZ and LZ Uric 2 indicate the CTC plume Lr: expand*d at concentration: above the
MC L it zl3 -iiitenor.: outride of tlis TI Zone The C TC plume :: miastmz and r. no: .'.table.
Mi^i.inoE of the CTC plime may be us :eipoaie to plugfiB.gr and abandonment of Well No. 2
and the :"ib;eq.ueat in:rea:e m wsler level ekvancm 3:roc. the Site, Additionally. tie CTC
plicae i. not dearadinz through narural proce-.-.e: :-ueh a: natural attenuation. anaeiobi; or
absoti; des12djc.ee. o: dilution: heweve;. concents anon: of CTC mtha UZ a ad LZ Unit 2
have been stable to

The current remedy fo; the UZ ?,nd LZ Unit 2 i: not pro:-=:r.ve of hum an health. and the
'Eiucimni: due Ic !>'CL exeeedance: out:ide of the TI Zone botindary. the bxk of
in vtinra on?.] control: for MC L e:-i:eedaa:«: out:ide of die TI Zone boundary. and th® lack of
contamnaent of CTC due to natural piccei'.e: Action', -.hould be liken by the U.S EPA and
a remedy amendment :hould be implemented for tie UZ and LZ Unit 2

Lower Zone Unit }

The £z£ R.OD wa; i::ued on September 26. 2'0O2. and indicated that a " .,-rezpenze action
11 iT_- >;-t	k>protect The public hraith or vt el/are w rJit- i'.-i ;¦ i-i!f?irnr/r c>r»,' acjuai or

f'ji'ijsirtwii re'eazez c/hazardous zubitance: rnrn the r- n cumect or the actual o» threated
j Wtc;*-; ofpolhtfantz or cor.ianpumtz from thiz Site which mm pt-eze?:; .i<> immt}:ent a<:d

zahztantm! endangi-tmev,' t®public health e> •• elfate.

The final S.OD CUS EPA 2332) idainiiadthe ;eiected remedy fertile LZ 3 a: "Aite-matr'? 4:
Expanded Optranen cfiTrR .V?. 2 hjm Additional Extraction Wei! axd LoKg-Iertx

Mcnitoung. ' which included 20 yea:: oi more of pumping ai Well No. Z snd approximataly
10 yssr:. of punipiiiz at a :e;ord -a;-rtra;tioa«'€ll Notable :T3t€Biaat:. withm lie 5 in si ROD

mclaaec

The rt'm i das t », £az'inz v. i!l afor tezwratwn of;!;? 5iiV g^ou'idt-ater to a>:
ufj-fZTricied d> inking ti aar zupph

"Upon compifticu of ike temed-. nc hazardotiz zubzuvsce: c-r p?lluta?;;z '-i HI
i emaiii *•< i7jrr»i rfe lire abo^e Ictelz thsrptwenf unlimiied uze a*
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Ftve-Y?ar Iner.:^ Form

C ity o: Patron We'd! "z- 2 SBperfind ;a:«
Per,10a Tea;
D«ao±arIv 2022

' Ri'zto atioti t>f :ke gromsmvah-r ?kr®}i%>i$Bt the ce>uqkwar. 1 plum 1 fr fr expected
briutfaa! me: ivherc ei practicable Tht objective- n ill > eqaite n ct?jWi longer

tmen ame ;o acbrr '.1 iih an pptm.mm period of 1C i car; bnit n hch msiv M&r up
rc> :6

C0ntj.1u1r13r.011 unaffected by pumpm g vrs.z expected co div.ipate with die pmpote of tie ?^4
to present further migration cf C TC and co clear, up tie affected §2 ouncwatei to dimkmz
water ttandard; The RA induced contmaeir. pumping of Well No 2 with a pumping rate of
approximately 12C gallon: peraacute. approximately l72.800 igalleiit pa day. or 65.0"r2.0CC

gallon: pe: year.

In September 200". 5 year: after fell-tune operation of tie AST? and p-jnipma of Weil No. 2
"bep.n. the PifeT tyttem -aa: ;hut down to evaluate CTC leboond m a prcpored 6-month
thidy Well No 2 v,*a: tampkd one month after shutting down the PAT tyttem and the CTC
roncennratios rebo-.mded to 2 7 9 tig L The iebcund ob reived ir. Well No 2 indicated that
CTC ismained 21 the Site in. the 12 5 above action levek ari tie remedy Lad nor returned tie
grcuijdy.aMi to an umertncted diinhmg water ttrppiy. The U.S EPA uiteipreted the rebound
data at an indication that C TC wat uiigratme iotvn the annultr. at Well 2-lc, 2 when. m fact
the :ebounc *.vat iikaly artoerated with a larger C TC plume '.vtthn 'he 1Z J which war being
hydiauli;ally ccntrolied da? tc puinpmg ofWellNo. 2.

Groundv.-ate: ramplmz tompleted m AprJ 2C0S indicated CTC contautraticiit in LZ 3 tvelb
were below the MC L The U S. EPA mteipreted the April 2008 low lev?I LZ 3 C TC data at
an indication that the remedy had tu; ceti fully adueved lie RAO: although tLe rebound
ttudy conducted 1 year earlier had thotm that C TC would rebound tn the LZ 3 if die PicT
tyrSem war that down

The U.S. EPA only campled Wei] No. 2 one mere time, m September 2CCS The final
aeuiidivatei' -.ample toliected fi on; Well No. 2. m September 20OS. had a CTC concentration
of 6 he I. «:•: tee ding the MC L 1 tee Table 2 in the Set and Five-Year Re-nstv ?.«port
[L-.S. EPA 2C13];. The e:::eedaa:€ of the MCL at Will 2'-"c 2 it Septembet 2DOS indicated
that the E-40t cf the Fmal 20C2 ROD (rettcj aticn of th-s ;p.cunctva:si to b^asficial ute) had
not been achieved 2^onethele:t. operation or Well No 2 t«a:ed at past of the active P«6T
tytteni ASTP. and tha well wat abaadoned m Janzaiy 2011.

The September 2C11 ?XO Ainendment EPA 23111 kept the 2C02 ROD cleanup
ttandard of 5 ug L fo: the LZ I but did not provide m alternate EACf o: remedy 10 addieti
potential letotuid of CTC 111 the 1Z :>. By dncoistirmmf: the P&T -.yttem and having ao
lemedy tc ad'iret: LZ 3' rebound, the U S. EPA effeenreh- naplemented a >ic further acricv
alternative for the 1Z 3.

From 2C02 to at least September 2009. during the paiiod when \V«112Co 2 m-at pimtpinsr.
large volume: of water we:e hems leiaoved from the hyd:cgeologic :y:tem and the
dittr.button and miEi'ation cf lie C TC ti'ime in both the UZ and LZ tva: b-emg coaa clled "by

5

1-9


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Frre-Yssr Jtrer1. zew Form
City ofParcvras Well K-? 2 Strefrad Sire
pHTVtOH TeCSSi
DecarSwrlC' 1022

p-.imp mg Wh«n puxupEtf: at Weil 2Co 2 stopped, watej level: of both the UZ asd LZ beza-
to mciea:e in ie:po:i:e to lie di::ontir.Ucnoc. of pumping a'- tie :y:fttu tnsd to iea,ei natural

ric -.u:-;;',e-:_v.:I	: :-::i	v. .-.:e: level:. have :::.;:e.-.i v.: ?:¦ :eer

'-ir.ee the ce:;j.tto- of pinupm? The observed Hiourdwatei level mcieace r. likely
le^utasexsingr CTC p:eviou;ly :orbed to toil pore upace: m tie vadose zone aad •coxraiV.icsgr
:CTC -:.v.: ¦¦:¦ jr::::: :"•¦:! re: Tie ::i\vW	CTC r:v.'. :: i: :¦•.'•¦ :e:r.2 :.

by the eicundivater '.yrem azd mobilized. thu: pradhticmf CTC p Mindwatei plume: n'eatej
in :ire and d;:tnbimon thin '.vbst ha; been o'Mer. ed m the put

Undoubtedly tie RAO: and remedy e:t;.bli.-.hed fa: tie LZ 5 in both the firs! ROD and the

2011 ROD Amendment have failed and will continue to fail until niftier i enieanl acton, n
r.-l-:€ii

In accordance with the final ROD >'U.S. EPA 2002) and the 5eptenber 10:1 ROD
Amendment': >,U S. EFA 23111 ' .I.vcjiiit'nr ofthe- ins, " a r>ev: ie:po:.:e a;tier, i: n.~«::ary
foi the LZ ;• srrourdTvatei ro protect the public health and tie enraoEiiieut nom ;.n actual
releate of harardou: Viibttanee:. [jitc the envLioimeiit which may p:e;eat an imminent and
tubtraanal endsiagerinejit to pubis: health or wellai e.

Souj c* Ar*n

Bated on the hittc-ncj.l Site history and pjoce;: knowledge. C TC tva: u.:ed :.t tie ?EX for

approximately 45 y=?j~. i from 1940 to 1S"85 j ?».elei',e: a: :pili: or a: regular application of
CTC us likely source: of CTC m Site toil, :oil vspoi. asd groundwater ;C H2M Hiil 2C'C 1)
Seceadaay :our:e: of contammitio:: mzlude ci: thai ee: to the on-,ite d: image and diichai ee:

to the drama se swale between the PEX aid the city z^aiztetiaice £?e:hty.

Cc-llecticn of toil -.ample: and evaluano:: or tie turface and cabanface toil «>:po:u:e
pathway i: ab:er.t fi'OE tie hr.toncal jeeoid: foi tie Site. Additionally, tie tail siipottn'-e
pathtny ard the pjotecnor. of jrouzdrrite: fiou: - oil leacimg "o p'oundp.-atej have r.ct been
mve:ttgs,ted ci included m the RCO ittued by tie "J S. EFA Tie :otirce ai-ea foi tie CTC
:oi:ta2:iEaTiDi. is. ;oil iat ret been, dehneated or lemediated and it liieiy jctins a: a
tortus tiin? '..ciace for CTC in jioiizdTVitei Th< lack of data related to CTC aatiu^e sue.
extent m tojl and fie potecnal foj CTC coQrentijf.cti: that could ir.ich to fro'iind^-stti are
;oz:id«ed a :ier.ific3i:t data p.p and s:e recommended foi additional data colkcncn and or
othe: acti'.'itie: a-d 2t:€t:ment of pjogxet: toward conipleTion of the ) -emed2.ti mvestiganon,.

5 Wiat sie tie fniut:iie of the TI Zone,

«

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Fr.Wenr lE.Te-.iew Form
CityoiPsrynsiTVeyi:? I SicsrfodSra
Peruon. 7ere*
Zfeeaijez III Oil

In 2022, CTC m: defected il 15 of 26 UZ'LZ Unit 2 '.imp lei linking m concentration from
3 S-3 uz 1 to 44 5 tig 1 (14 of the:* detection: exceeded the MCL1 The UZ ani LZ Unit 2
CTC pjiEae ic centered around tie ?EX drainage :w:il« inea: M\V-22"« :md expend; to tie
northwe: t toward dcwngj adient MW-3 i In 2022. the Biarnmum C TC concern stioa in the
UZ LZ Ur.it 2 ws,: 44 ; ug L and occtured in doim gradient TI Zone boundary well B,3T.V-3 *.,
The UZ LZ Unit 2 € TC phirae ic not delineated to the north',ve:t. north?i::. ea'.t. j.ni '.outh.
Gap; iz the UZ moa.jTor.rf '.veil nerwoik limit tie delisextioti a i:e-„'.m«nt. Additionally. the
UZ LZ Unit 2 CTC groundwater plrnae i: not fully contained m the current TI Zone aid
occih: id 3.3es'. ouciide of the 'TI Zona to the noiihweit. noithaait ea:t. louth, ard we:t.

I: should be noted that ware- lever., of tie UZ ard LZ Unit 2 axe mere?.dag m reiponse to
diiccntinmticn of pumping and the plufsmg j.nd abandonment c f hiitcn: si Well No. 2
which W3: used a; an extraction well The obnrved sr ounduater elevation uicieaie maybe
leiponuble to: mobilization. of a CTC '.ource :cne and plume expansion, m the UZ and 1Z

Unit 2.

Tmj«-;ene-: inalym f:om appioiiimately 20C2 to 2022 o:CTC concentrations in
gioimdwater of the UZ and LZ Ue.it 2 axe included in the annual O&M lepc-rt:- and include
refe:er.c6i to activity of the P
-------
Fcve-Yaar Inte-MiTvFarn:

City ofPsoic-ii Will 1; 'ii^erad Site
Jem ton. Tea5

rw^trv-:: :co:

CT€ data indicate die LZ 3 CTC plume i: expm&nj in tbs directioncf the City Supply Well
No, 3 Historical ztoundivatei data foi iowr.gra-cbent LZ 3 well MPMWC^-f1 dare: to 2002

ipr.erto the P.vT r.^cemL how-e-.« lines 2013. CTC eoneentoaoa: ;nIv!PMTT04-? h;.v«
exceeded the MCI and continue to exhibit ;jic3€3-.e:e: trend:. Adcmoniliy. data from
doivr.gradient MW-4C and MW-4I ako :bow mcnea;i&2 CTC cor-cer.fcsaoE; ;m;e 2016
».vh«n :he:e Tell: were firct '.nmpled, Well MFMW02-3. located adjacent *3 the hiifoucal
WellNc. 2 al;o ditpby: in:i eating CTC concents an on: winch clonlv :o: jehta to the
termination of the S'ScT :y:tem.

Time-.er.e: ma iy::t of CTC m tbs LZ 3 fcoai approximately 2002 to 2022 ivitn 3 tfsrer.ce: to
activity of die P&T :y:ten: are included iz. the .inxraal0 ,i:M report. Tie time-:«rie: data
indicate: CTC at MPMVC2-? r.nd MPMWC4-? were well abov» tcw MC L -piim to pumping.
C TC denea:ed ausing- the period of active FicT, and CTC ha: increased to lev*,; abors the
MCL :inc« PJtT ended The decrease in CTC : oncer, csjn on observed zt MFM~\V j2-3 and
M?MW"0--5 dmiaspimpm?indicate: the PicT :y:tenitv:-: caprusmg and diluts-z CTC at
th*LZ 3 moniToim? well locations. Once FScT ya; end? J n only rcnk s yeai for CTC
sancencs.non: a: MPMWC2-3 to return to levels a?ov« the MCL C TC data fioir. both
1.1TPMWC2-3 and M?M\VC4-r: currently display increasing oend:

Tune-:er.e: shta :ol CTC it MW-24. MW-2S. jnd MPMWC1 appear stable over tune
Downgradiest well; MW-43 3rdMTV-41 have only beer. '.amplea :in:e 2016. however,
increasing trends at these 1c cation: may b« mdieatr.-* of downs: adient CTC plume
expansion.

A re'.isw of analytical data compared to :einedie: established by the U.S. EPA for LZ 3
indicate

•	CTC x groundwater 1; not being contained thioiiEr.natural piose::a;.

•	CTC ccEcennanon: 111 LZ wells exceed tie MCI and in some case: are increasing.

•	The LZ 3 plume 1: expanding. and

•	Tke implemented RA: are act performing .1: intended.

4 I: fksre a rontmucu: on-lite O&M pie:e~ce" If sc. plea:e describe snff leioonsibiiitie: and
activities Alternatively. pl«a:e de: :nbe itiff i-e:pon:ibilir.e: and tre fieguescy of : ite
m;pfiCEoa: and aoa-.inei if there r: not a cont-jiuo'j.: on-:ite	p:e:«ti;?

The TCEQ :c runentlv condustins CktM a;r.',-.n«: wiaici. in:lud? routine aonasl
Eicundwatai : amplin z of tie S:re": monitor vrell: md j.naly-i: of ie : ample: idi CTC
A.nn'ial p-oiindvrstej : jinplm; w completed dining }»lay of eaci. vezr. Dwizz tbs annual
pound^ratrr sampling evert, the Site and monitoring -a'ell: ?.ie m:peced ?nd photosapliad
to dccumenr the condition of impoitant Site f-eirj.i«: Fmdinar: fi os tie uivpectior. and
sampling aie leport-sdm an annual OS:: ! Repcit p:c-ad«d to the TCEQ. A: n«d-ad, the
TCEQ will sale mmos rep an: to the niciizTor-n? iv-iZ n'trsoik to maintain the irtefnn- of
the monitoring iv.ten:

8

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Frre-Yasr Irrer-.teiv Fora:
C ity o: Pertytt-r. 'Veil! > 2 inpefod Sits
rCTacti less-
:; 1C-1I

5,	Hs-'5 there :-eer. any :tgmtkant change", m :tte GtfcM requuemen:: maintenance - chechi]*:
o: lamplm? routine: '.ir.ce- :tart-u? or m the lact five yeas: 7 If to. do they affect the
psotecTiveie'.: oi etfectrvene-:-, of the : entedy" Flea:a detent* chacze: and impact:

40 CF5L '503 455'fVi 1 > ttate: that.

"Operasw: and mamtemwe • O&M* measure: at* initiated qft^r rhe nmed} ha: ackir-vd
the remedial ii>cnon vbjeatc: and nrmedianon foab ir, the ROD, and i: def£* mived to it
operant!,al tv:d functional ecicepr far p ound- or ;usface-wan'* reirotation acriciz cot tS7eii

undit 500

The Site ha: acr achievsJ tie ?,_AO: and. or remediation goal: establithe 3 :n tli-s filial ROD
lU.5. EPA 2002 •, oi tie September 2011 ROD Amendment ("J S. EPA 201:) for both the UZ
ana IZ Unt 2 and tie 1Z :, The Site should undergo U.S. EPA remedy c-pfjaiization.
annual gi ojjadtvater mor.rtorjig' thoiild continue. aid the Site tliouid letnrE. to the U.S. EPA
for lEnplemeEtacC'it of an a:r.ve remedy to a-thieve tli-= rdemned KAOx mclirdms ret-Totano::
af IZ :• :o at. -.utte tm ited dr. ill wate: i"'

Since 201". the TCEQ hat perforated O&M activitie: a: the Site. uitludmz miroaJ
soundsvater '.iuiplms aitdl-jpoitir.g Oi:!-.! report: documenfeBS these activities -.vert

finalized to FYc 19 tiuousL 22 and have been ponded to the U 5. EPA

6.	Have there beet iinet-tpected O&M diincuitie: o: eoti: at tie Si:-? tixce ttait-u? oi ix. tie .act
5ve yea: i"1 If to. pleate provide cfeta-r

Lov.er Zone U'lic J1 'A'-?3L Intf-ulanc-nt

A: ideticif.ee ir the TCEQ FYI9 OiM isport. ui May 2CI ? diuiuE the tecond campling

event for dowr.p-s-dbeni LZ Uruf i mc-mtonjjs well: MvV-40 and MW-4I C'TC m
Kcuaiwatai exceeded the MCL for the fir.t time at both location: ¦! 15.6 .is L at MW-4C and
I5.c |i 1 at MW-41 >. Thete weie no- well: to- delineate tins natme and etcfeirr c?the 2.32L
esc^edaneec domna-adisat of MW--0 ar.d MW-41 The FY 19 O&M sepc-it mdr>ied travel
tune c3liiiz well: MW-42. MW-43.1-^\Y-44.	aid

!*.!W-46 ui lime 2C2D. mcreatiiiz the nuEiser of tampims: locanor.: included m the amiial
O&I'.i taEtpliza ^vent.

T^.'eli FA[j -iir-

I'-Iaoy of the Site aioiutonus welb located ir. z:ty tueen have o.eteno-atec. and hare damaeed
weZ pad:. In oae uittar.ee routine ate of a titow plow dtaine win:ei tzsoath-. theated c:T the

o

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F rc e-Tear lEterraiv F onx
City ofPanyK-s,Weill"? I i-TipsfiodSite
PsTitoa Tex?.-
Dereoite 10 2032

;iu £s;e completion of a jEooitormg well Tii: well completion bad to be repriced a:: c on a:
po: ::b.e to lemove tie ob:ts,ele m the cm* tTieet. In FY2o. eight pcuEdwitej mcnitcim?
well pad; will be removed and uphced to addre;:- an;tK:g well pad: with agmtKant
yui :l:u. damage,

7 Hive there beer, cpportumtie: to optimize OtfcM actratie: 01 tamplreg " Plea:®

daccnb« change: and any remitin.s or de;j.ed :o:t :avmf; or unpioved effiesenae:

Flujsiu? ."•lid Abaiidonisein o: M^V-19-ZX

Lr. Deeembe: 2306. additional '.hallow eMtiacncn ivells were mttaliad adjacent to Well No 2
;M\Y IS-EX and MYC- 13-EX't to determin* the feasibility of F&I rb: the UZ A: reported ir
th« FY19 O.tM report. etstnittton. well MW- i 9-EX tad not had a CTC det«:tion sixes
November 2012 although othe: nearby nio-intoi-mr well; consistently kad CTC dsteenon: It
Wi'. identified that M'V-19-EX wa; con: muted witi a - 0-foot screen tecnon from 250 »
290 feet heloxv pound turfs :e while otkei U2 morion.-? wells neai MV.~-IP-EX have
icreen tecnon: of 10 to 20 feet. The longe: icreen :e:uon of MP-1S-EX ws: ideziified sz
allowing for mixing and dilution of p-ouE.d-.va®] wiiei could : educe the CTC obiervition at
both MW-19-EX and otiei adjacent incmfcim? '.Tell;. The U S. EPA plugged and
abandoned MW-1P-EX m Jure 202C and :mc? tin; nee. UZ and LZ Unit 2 pliant dyr.-mie:
appea: moie colteuve and are less impacted by the dilution facilitated by auxins: at the
historical MW-I9-EX. Additionally. with riepInsExg and abandonment o£I-.!T\'-19-EX. die
cumber of :.\mple locr-tton: included in the annual CAM sampling event decreased by one.

TVestbay Multipart Mouirot tag Well;

The n'ousdwate; mcnitonns well nenvo: k include; zsuexlz and sampling: e: r>cth Weitbay
Multipart 1r.on1tcn.n2 well: and conventional well installation: Ganging and tamping of
We: tbay Muitipor! nioniEonas well: m. tailed at tie Sua le quired ontite a-aainig by
'\Ve;tb?,y lr.'.nnn:ent:. TLiee employee: fiooi EnSafe coinplered the Wettbay tjaixk-g ta
Aupiit 20 i S as d be-came trrtifeed Lev si 1 ^"ectb ay Operswn At least cae camfied
Wettbsv pei'3to: ha: been mtluded in eac'n of tie annual pound-.vate: ".ampluis el. ent:
facil'.taTUiE :ncce:;fkl fauaug ?.nd tatupLiiig of tLe;e ccmpiex frciiidwater mcnitonuz -n eliv
Addinon.illy, -ie EaSafe team, complete: thi fatigmg and tampang ever.: c-ver 1'1
contfrcutiv-e ijy; without leading ths to masur^ze co .t tr-.vms: to the p:eject

-i. Dc you have any comment:. '.uzietnoE:'. or recciuiuend.-.non: :er?.idiaE O&M activme: ?nd
tcdeduj?: st tie Site"

The CTC plume: m both the UZ and 1Z Unit 2 and tlw LZ : i:e m:p-3tLr.g. -jnttabie. and. in
•,cm« mttance:. di'.piay increa-tLaE coaeemxatioa; c. ii time Tie current temedy for the UZ
and LZ Un:t 2 1: not pjoteettve of hun:An heakb and tie eavuonment due to MCL
ezee-edance: otind-e of fie TI Zone boimdaiy, tie lick of in:nr;in.on.al cceScoI: fos MCL
es-; a«-dance: o:;*-.ide of tie TI Zone b-ouadary. and the lack of ;ontajnr:er.r of CTC d*j.e to
natural proca;:s; The U.S. ERA :hould sxpand the izonitoniiE well netwoiL x- deir.ea.te tie

10

1-14


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Fire-Yaar Iarcrv.e-.v Fonr.
Qiy ofJswice, "Veil ?C;< I 'ii^erfccid ins
Penrjim, Jess.:-
LfesDiber 21' 1022

UZ and LZ Ua: 2 CTC n o-inJv.-ates plume axd the resedy ib: tie UZ and LZ Unit I:kouid
be amended and upas.ted to reflect file iimficay-t plume €zpar,;ior. ofcarved 3* the Site

Action;. :houid be rakes, ty the U S. EFA 3ad a remedy amendment itcuJd be implemented

for the UZ sad LZ Ue.it 2, The remedy *:7abh;b«d for the LZ 3 m bori the tiii.il ROD and
the 2011 ROD Amendment fo: tie LZ : La.", failed ana 1: coatEuiag to fail while ike U 5,
EPA ha: mplesierted v.-Lit appear; to b« jw/firrfftr •acri^i; A new leipon:.? action, Aould
be Enpleiaer-ied by the L" $ EPA for the LZ 5 sjotmcwa-ra- :o prate;! the public health and
the emuoraueBT from an aerial :e;e„v,e cf hazx den-: .ub.t.-i-ce: into the envuoiiment which
m3y preiert zz. Loioiinent and -,ub"3n7i2.I ead^czermeat to public EealiL 01 welfare.

A: outlined 11140 CFR J5DO -i 5«'fR 1 O&M : 11 culd be innated nirw the leciedy ha:
achieved die SAO:-, RAO: :"o: both the UZ 3rd LZ Unit 1 and th? LZ 3 have not been,
achieved The Site ihoLd undergo U S. EFA remedy cptuinza'noL. OocM ihcuid cease, and
the Site :.hould re Hut. to the U.S EPA fcr uupl-mentation of an active remedy to 3:hi«ve the

ideETifisd RAO;. uiciudins: leiTounos: of LZ 5 to an ujneiiricced drinking ".rate mpply.

9, Do von ;oz'.«ct to have your 11 sine included along with voe reopen:ei to tbi: ijuS'.aciii.iiie
m the FYS. report""

nniilv J. 3:ieiniia. ?G iTX 121€4>

11

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CITY OF PERRYTON WELL NO. 2 SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Namf: C ifv of Penvton Well No. 2

EPA IB: TXOOOI3!W>435

Imei viewer saute: Treat Suoini

IuleiTOwer affiliation; Skeo

Subject name; Scoff Setteiiieyei

Subject affiliation: Texas (. ommission cm
EmireiiiiifQt.il Quality (TCEQ)	

Subject contact iiifoimarion: (51! > 239-3429

IiiteniMV date: N A

Internet time: N A

Intel view location; N A

Iutei view format lcircle one): In Person

Phone

Mas!

Email

Other:

Iutei view catesorv: Start Agencv

I . What is your overall impression of the project, including cleanup, maintenance and reuse
activities las appropriate)'1

I'dix-i Zone aud Lower Zone I'uit 2

Tlie carbon tetrachloride (CTC) plume in die Upper Zone and Lower Zone Unit 2 continues
to expand and migrate beyond the established limits of the Technical Impracticability iTD
Zone These areas where CTC has migrated outside of the TI Zone are not being addressed
by a remedy established m the 2002 Record of Decision l'ROD) or the 2011 ROD
Amendment, and the U.S. Environmental Protection Agency (U.S. EPA i has indicated that
they do not have any immediate plans on expanding the TI Zone boundary Therefore, the
potential exists for receptors outside the TI Zone to become exposed to C TC at
concentrations above the Maximum Contaminant Level (MCL i.

Furthermore, due to the continued expansion and migration of the CTC plume m the Upper
Zone and Lower Zone Unit 2. the groundwater plume is currently not delineated. Additional
groundwater monitoring wells are needed to determine the fall extent of the CTC plume in
the Upper Zone and Lower Zone Unit 2 and info mi the establishment of an appropriate
remedy for the areas where CTC has migrated outside of the TI Zone. TCEQ believes this
delineation is critical to ensure protection of the municipal water well located downgradient
of the groundwater plume

Lower Zone Uuit 3

At tins time, the Lower Zone Unit 3 does not meet Remedial Action Objectives (RAOs'j. As
TCEQ commented at the Third Five Year Review. C TC concentrations have rebounded since
decommissioning of the air stripper, indicating that the system did not permanently
decontaminate the aquifer fo the MCLs as specified m the 2011 ROD .Amendment. Based on
groundwater sampling since that tune, it is evident that natural attenuation, which is
identified in the ROD as the contingency remedy, is not occurring at the site at a rate to
sufficiently control the groundwater plume. For example, the concentration of CTC observed
at monitoring well MPMWD4-05 first exceeded the MCL m 2019 and has continued to

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increase since that tune. Additionally, die concentrations of CTC observed at downgraclient
monitoring wells MW-40 and MW-41. which axe located within the central core of the CTC
plume, have been increasing since 2016 when these weils were first sampled In fact, the
concentrations of CTC observ ed in these two wells during the May 20-22 Operation and
Maintenance >0
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aquifer and the Lower Zone. Wliiie the City of Penyron adopted an ordinance 111 20IS that
places restrictions on the installation of water wells within the C ity's inn its in order to
prevent exposure to contaminated groundwater associated with the site, die current Upper
Zone and Lower Zone Unit 2 II Zone boundary does not fully encapsulate the C TC MCL
exceedance zone and may require modification.

Lower Zoiie Unit 3

The September 2011 ROD Amendment states "The ground water pump and treat system has
successfully cleaned up the principal ground water production unit (Unit 3} m the Lower
Zone of the Ogallala aquifer thai was contaminated with carbon tetrachloride and nitrate."
However, the last groundwater sample collected from Well No. 2 m September 2008 had a
CTC concentration of 6 f.ig;L and exceeded the MCL. Therefore, the remedial measures of
the 2002 ROD allowing for restoration of the site groundwater to an unrestricted drinking
water supply were not met. Nonetheless, the piaiip and treat system was decommissioned.
Weil No. 2 was abandoned m January 2011. and the September 2311 ROD Amendment was
issued.

Analytical data obtained from groundwater samples collected during the May 2019 O&M
event indicated that CTC had migrated at concentrations exceeding the MCL further
downgradient in the Lower Zone Unit 3 toward the drinking water supply well GW-03. The
downgradient extent of die CTC plume in die Lower Zone Unit 3 was not adequately
delineated, and the U.S. EPA installed five downgradient monitoring wells m June and July
2020 to delineate the plume. Subsequent groundwater sampling events indicate that the CTC
plume in the Lower Zone Unit 3 is currentlv delineated.

The analytical data obtained from the May 2022 sampling event indicates rhar CTC
concentrations in the Lower Zone exceed the MC'L. are continuing to increase since the
pump and treat system was shut down, and are expanding in the downgradient direction.
Groundwater sampling conducted from 2019 through 2022 has confirmed that CTC has
migrated downgradient at concentrations above the MCL in die direction of the city drinking
water supply wells GW-03 and GW-04. Therefore, the RAGs for the Lower Zone Unit 3.
including restoration of groundwater to beneficial use standards and prevention of migration
of the contaminant plume, are not being achieved.

Source Area

The continued expansion and migration of CTC contamination in the Upper Zone and Lower
Zone Unit 2 and the Lower Zone Unit 3 aquifers at the site suggest that there may still be
source contamination present m site soils. The TCEQ recommends additional investigation in

potential source areas, suck as locations of elevated CTC detections identified m the 2009
passive soil gas sampling conducted during the Remedial Investigation..

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or
remedial activities from residents in the past five years1

No.

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4.	Has your office conducted any site-related activities or communications iti the past five
years ^ If so. please describe the purpose and results of these activities.

Since 2017. the TC'EQ has performed O&M activities at the site, including annual
groundwater sampling and reporting. O&M reports documenting these activities were
finalized in Fiscal Years (FY) 19 through 22 and have been provided to the U S EPA.
Additionally, the TC EQ provides sample result letters to affected property owners following
each sampling event.

5.	Are you aware of any changes to state laws that might affect the protectiveness of the Site's
remedy1

No.

6 Are you comfortable with the status of the instinuion.il controls at the Site? If not. what are
the associated outstanding issues'1

In 2018. the City of Perryton adopted an ordinance which places restrictions on the

installation of water wells within the City" s limits in order to prevent exposure to
contaminated groundwater associated with the site. As long as this ordinance is not modified
or rescinded, then the TC'EQ has no objection to the implemented institutional controls.

7.	Are you aware of any changes in projected land use{s) at the Site'1
No.

8.	Do you have any comments, suggestions or recommendations regarding the management or
operation of the Site's remedy

Upper Zone and Lower Zone Unit 2

The TC'EQ recommends the installation of additional groundwater monitoring wells to
determine the full extent of the CTC plume m the Upper Zone and Lower Zone Unit 2.
Following complete delineation of the CTC plume, the U.S. EPA should either expand the TI
Zone to fully encompass the extent of CTC contamination in the Upper Zone and Lower
Zone Unit 2 or implement an appropriate remedy to restore groundwater to beneficial use.

Lower Zone Uuit 3

The TC'EQ recommends that the U.S. EPA implement an appropriate groundwater response
because the groundwater in the Lower Zone Unit 3 does not meet the RAGs identified m the
2002 ROD and the 2011 ROD Amendment and further evaluate the potential for the CTC
plume to impact city supply wells GW-03 or GW-04.

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Source Area

The Tt £Q recommends that the I'.S EPA perform further investisation of the source area at
the site, including the collection and analysis of strategically located soil samples, to
determine whether a continuing source is present that is contributing to the expansion and
migration of CTC m groundwater.

Remedy Optimization

The TC EQ requests that this site be submitted to the U S. EPA's Super fund Remedy
Optimization program in order to identify .ind support an effective, efficient, and timely
remedy to address groundwater contamination and protect city supply wells.

9. Do you consent to have your name included along with your responses to this questionnaire
in the FYR report7

Yes..

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APPENDIX J - CITY WELL ORDINANCE

CITY OF PERRYTON
ORDINANCE #1040-18

AN ORDINANCE AMENDING ORDINANCE #790, AND ORDINANCE #791, AND THE CITY OF
PERRYTON CODE OF ORDINANCES SECTIONS 8-517 THROUGH 6-522, CHAPTER 25,
INDIVIDUAL WATER SUPPLIES; FURTHER, REPEALING ALL OTHER ORDINANCES,
RESOLUTIONS OR ORDERS IN CONFLICT HEREWITH.

NOW, THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF PERRYTON, TEXAS;

That Ordinances #790 and 791, arid the City of Perryton Code of Ordinances Sections 8-517 through 6-
522, Chapter 25, Individual Water Supplies, which shall be amended to read as follows:

SECTION 6-517 THROUGH 6-522

CHAPTER 25
INDIVIDUAL WATER SUPPLIES

25.1	GENERAL

Suitable water for potable purposes is often impacted by the activities of flora, fauna, and man.

Organisms introduced into potable water sources may cause illness or disease. Additionally, imminent
and substantial endangerment to public health and safety or the environment may occur if hazardous
substances are released into groundwater sources of potable water. Detailed technical information
concerning any phase of water supply or treatment may be obtained upon request from the Texas
Commission on Environmental Quality (TCEO), Office of Water, Water Supply Division.

The Qgallala Aquifer is the groundwater used as the source for the City of Perryton's (City)
municipal water supply system. In an effort to protect the Qgallala Aquifer as a continuing source for the
City's municipal water supply system, the provisions and requirements of this Code implement reasonable
restrictions upon all water wells located within the City limits.

An investigation of the Ogatlala Aquifer as part of the City of Perryton Well No. 2 Superfund Site
has identified the presence of volatile organic compounds above the federal and state drinking water
standards to an estimated depth of 345 feet below ground surface. Further cleanup of the groundwater
above 345 feet was determined to be technically impracticable by the United States Environmental
Protection Agency (EPA).

In order to protect the groundwater as a water supply for the City's municipal water system and to
prevent exposure to volatile organic compounds, the City places the following reasonable restrictions
upon all water wells located within the City limits. The objectives of the water well restrictions are to
prevent the installation of a well that would create a vertical migration pathway between the contaminated
section of the Ogallala aquifer and the lower uncontaminated section of the aquifer and to prevent the
installation of a water supply well that would cause the volatile organic compounds to migrate outside the
technical impracticability zone (Tl Zone) because the migration of underground water is not easily
monitored, or controlled. The entire area within the City limits, which may increase in size with
annexation, shall be considered as the Tl Zone.

25.2	WELL CONTRUCTION

25.2.1	New Wells within Citv Limits: All newly constructed water wells within the City limits shall
comply with the Technical Requirements codified in Texas Administrative Code (TAG) Title 16, Chapter
76, and any subsequent revisions, and shall meet the construction standards of public drinking water
wells found at 30 TAC § 290.41(c)(3)(B-D) or any superseding regulation.

25.2.2	Water Source of Wells: The Tl Zone is an area where concentration of volatile organic
compounds in the groundwater exceeds the federal and state drinking water standards. It is not feasible
from a physical perspective using currently available remediation technologies due either to
hydrogeologic or chemical-specific factors to reduce the concentration of these chemicals throughout the
Tl Zone within a reasonable time.

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All newly constructed water wells within the Tl Zone shall produce groundwater from sources
located below 345 feet bgs. No water well within the Tl Zone shall produce groundwater from sources
located above 345 feet bgs. The City will notify the TCEQ upon issuance of a permit for a water well to be
installed below 345 feet bgs within the Tl Zone.

Since these restrictions are an integral part of the EPA's plan to prevent exposure to volatile
organic compounds and containment of the contaminated groundwater within the Superfund Site, and
given the City's goal to ensure that the Superfund Site remains protective of human health and the
environment, the City will not modify or repeal Figure 1, Sections 25.2.1 (as it relates to the Tl Zone), or
25.2.2 without prior written notice to the EPA and the TCEQ and written consent of the TCEQ,

25.2.3 Issuance of Permit: After having first obtained a permit from the North Plains Ground
Water Conservation District, the Plumbing Inspector or his designated representative shall issue all
permits in accordance with the provisions and requirements of this code. All applications for permits shall
give the correct location of the property where the well is to be drilled, including the name of the owner of
such property,

25,2 4 Planning Material; All planning material for the construction of the well shall be submitted
to the Plumbing Inspector before construction begins. Plans for residential wells may be submitted by the
well driller.

25.3	METERS

25.3.1	Well Meter: All residential or commercial water wells within the City limits shall be metered
by a City-provided and -maintained water meter.

25.3.1.1 Meter Bypass: If a meter bypass is installed, it must include a stop with a locking device.
The lock shall be provided and maintained by the City.

25.3.2	Public Water System: If a residential or commercial water system is connected to the
public water system, it shall be metered by a City supplied meter. Also, at the point of connection, both
systems will be protected by lockable double check assemblies. The City shall possess all keys. The
double check assemblies and the initial test shall be the responsibility of the property owner.

25.3.2.1 Check Valve: A double check assembly shall be installed between the residential or
commercial water system.

25.4	WELL DRILLERS

25.4.1 License Required: AH persons who engage in or work at the actual drilling or alteration of
a water well shall possess a license with the Texas Commission of Licensing and Regulation or
successor organization as required by Texas Occupations Code §§ 1901.151 and 1902.151.

25.5	WATER SYSTEM

25.5.1 Plumbing: AH plumbing shall be in accordance with the City of Perryton Plumbing Code.

PASSED AND APPROVED, on this the 17® day of April, 2018.

ATTEST:

Kim Fowler, City Secretary

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APPENDIX K- EJSCREEN REPORT

&EPA ' •

EJScreen Report (Version 2.1)

1 mile Ring around the Area, TEXAS, EPA Region §
Approximate Population; 6,212
Input Area (sq. miles): 4.42
City of Perryton Well #2 Superfund Site

Selected Variables State

Percentile

USA
Percentile

Environmental Justice Indexes

EJ Index for Particulate Matte

2

29

EJ Index for Ozone

84

95

EJ Index for Diesel Particulate Matter'

33

40

EJ Index for Air Toxics Cancer Risk*

21

53

j EJ Index for Air Toxics Respiratory

9

32

EJ Index for Traffic Proximity

31

48

EJ Index for Lead Paint

79

79

EJ Index for Superfund Proximity

92

95

EJ Index for RMP Facility Proximity

52

71

EJ Index for Hazardous Waste Proximity

3

4

EJ Index for Underground Storage Tanks

77

84

EJ Index for Wastewater Discharge

N/A

N/A

EJ Index for the Selected Area Compared to All People's Blockgroups in the State/US

n

I

¦V

EJIndexes

instate Percentile 11 USA Percentile

February 03, 2023

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a^SttiPntecBon	EJScreen Report (Version 2.1)

1 mile Ring around the Area, TEXAS, EPA Region 6

Approximate Population: 6,212
Input Area (sq. miles): 4.42
City of Perryton Well #2 Superfund Site

Sites reporting to EPA

Superfund NPL

1

Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDF)

0

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iOk	United Slates	_	...	. ..

^yrHA tn™o™emaip,«ecti°n	EJScreen Report (Version 2.1)

1 mile Ring around the Area, TEXAS, EPA Region 6
Approximate Population: 6,212
Input Area (sq. miles): 4.42
City of Perryton Well #2 Superfund Site

Selected Variables

Value

State

Avg.

%ile in
State

USA
Avg.

%ile in
USA

Pollution and Sources

Particulate Matter 2.5 (ng/m3)

6.59

9.5

1

8.67

9

Ozone (ppb)

50

40

91

42.5

89

Diesel Particulate Matter* (ng/m3)

0.0965

0.211

16

0.294

<50th

Air Toxics Cancer Risk" (lifetime risk per million)

20

31

19

28

<50th

Air Toxics Respiratory HI"

0.2

0.35

8

0.36

<50th

Traffic Proximity (daily traffic count/distance to road)

36

570

16

760

20

Lead Paint (% Pre-1960 Housing)

0.23

0,14

72

0.27

51

Superfund Proximity (site count/km distance)

1.2

0.084

99

0.13

98

RMP Facility Proximity (facility count/km distance)

0.24

0.94

34

0.77

43

Hazardous Waste Proximity (facility count/km distance)

0.015

0.72

1

2.2

1

Underground Storage Tanks (count/km3)

3.5

2.3

76

39

70

Wastewater Discharge (toxicity-weighted concentration/m distance)

N/A

0.38

N/A

12

N/A

Socioeconomic Indicators

Demographic Index

61%

46%

70

35%

84

People of Color

67%

59%

58

40%

76

Low Income

56%

33%

80

30%

85

Unemployment Rate

5%

5%

57

5%

56

Limited English Speaking Households

12%

7%

76

5%

87

Less Than High School Education

31%

16%

81

12%

92

Under Age 5

9%

7%

72

6%

80

Over Age 64

7%

13%

27

16%

16

"Diesel particular matter, air toxics cancer risk, and air toxics respiratory hazard index are from the EPA's Air Toxics Data Update, which is the Agency's
ongoing, comprehensive evaluation of air toxics in the United States. This effort aims to prioritize air toxics, emission sources, and locations of interest for
further study. It is important to remember that the air toxics data presented here provide broad estimates of health risks over geographic areas of the country,
not definitive risks to specific individuals or locations. Cancer risks and hazard indices from the Air Toxics Data Update are reported to one significant figure and
any additional significant figures here are due to rounding. More information on the AirToxics Data Update can be found at: https://www.epa.gov/haps/air-
toxics-data-u pdate.

For additional information, see: www.epa.gov/environmentaliustice

EJScreen is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysis, or outreach. It does not
provide a basis for decision-making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial
uncertainty in their demographic and environmental data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this
screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see
EJScreen documentation for discussion of these issues before using reports. This screening tool does not provide data on every environmental impact and
demographic factor that may be relevant to a particular location. EJScreen outputs should be supplemented with additional information and local knowledge
before taking any action to address potential EJ concerns.

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