Fresno Sanitary Landfill Superfund Site Fresno County, California · 2017-05-12 · Fresno Sanitary...

F i r s t F ive-Ye ar Re v i ew Re por t f o r

Fresno Sanitary LandfillSuperfund Site

Fresno County, California

Submitted to

U.S. Environmental Protection AgencyRegion 9

September 2005

FIRST FIVE-YEAR REVIEW REPORT

FOR

FRESNO SANITARY LANDFILL SUPERFUND SITEFRESNO COUNTY, CALIFORNIA

September 2005

Prepared forContract No.68-W-98-225/WA NO. 052-TBTA-09DM

U.S. Environmental Protection AgencyRegion 9

75 Hawthorne StreetSan Francisco, California 94105

Contents

Section Page

Acronyms and Abbreviations viiFive-Year Review Summary Form ixIssues and Recommendations xiExecutive Summary ES-1

1.0 Introduction 1-1

2.0 Site Chronology 2-1

3.0 Site Background 3-13.1 Land and Resource Use 3-13.2 Physical Setting 3-2

3.2.1 Geology/Hydrogeology 3-23.3 History of Contamination 3-33.4 Initial Response 3-43.5 Basis for Taking Action 3-5

4.0 Remedial Actions 4-14.1 Remedial Action Selection and Implementation 4-1

4.1.1 OU-1 Selection and Implementation 4-14.1.2 OU-2 Selection and Implementation 4-44.1.3 Institutional Controls 4-6

4.2 Operation and Maintenance 4-84.2.1 OU-1 4-84.2.2 OU-2 4-114.2.3 Operation and Maintenance Costs 4-15

5.0 Five-Year Review Findings 5-15.1 Five-Year Review Process 5-15.2 Community Notification and Involvement 5-15.3 Documents Review 5-15.4 Data Reviewed 5-1

5.4.1 Groundwater 5-25.4.2 Air 5-165.4.3 Stormwater 5-185.4.4 Landfill Gas Condensate 5-195.4.5 Operations and Maintenance Activities, 1998 to 2003 5-19

5.5 Regulatory Review 5-235.6 Site Inspection 5-255.7 Interviews 5-35

iv

CONTENTS

6.0 Technical Assessment 6-16.1 Functioning of the Remedy as Intended by Decision Documents 6-1

6.1.1 OU-1 6-16.1.2 OU-2 6-2

6.2 Current Validity of Assumptions Used During Remedy Selection 6-36.3 Recent Information Affecting the Remedy 6-5

7.0 Issues and Recommendations 7-17.1 Issues Related to OU-1 and OU-2 7-17.2 Issues Related to Landfill (OU-1) 7-17.3 Issues Related to Groundwater (OU-2) 7-3

8.0 Protectiveness Statement 8-1

9.0 Next Five-Year Review 9-1

10.0 References 10-1

Tables

2-1 Chronology of Site Events 2-14-1 Extraction Well Information 4-54-2 OU-1 Operations and Maintenance Activities 4-84-3 OU-2 Operations and Maintenance Activities 4-134-4 Ou-1 and OU-2 Operations and Maintenance Costs 4-165-1 Groundwater Monitoring for OU-2 (as Required by the 2000 Performance

Monitoring Program Plan) 5-25-2 Fall 2004 Groundwater Monitoring 5-55-3 A-Aquifer Maximum Groundwater Concentrations of PCE, TCE, Vinyl Chloride,

and cis-1,2-DCE 5-95-4 B-Aquifer Maximum Groundwater Concentrations of PCE, TCE, Vinyl Chloride,

and cis-1,2-DCE 5-105-5 C-Aquifer Maximum Groundwater Concentrations of PCE, TCE, Vinyl Chloride,

and cis-1,2-DCE 5-115-6 Residential Wells Maximum Groundwater Concentrations of PCE, TCE, Vinyl

Chloride, and cis-1,2-DCE 5-125-7 Extraction Wells Maximum Groundwater Concentrations of PCE, TCE, Vinyl

Chloride, and cis-1,2-DCE 5-135-8 Phase 1 Groundwater Treatment Plant Influent and Effluent Concentrations of

Select Constituents 5-135-9 VOC Mass Removal 5-155-10 Groundwater Extraction Rates and Percent Operations 5-205-11 Chemical-specific ARARs 5-265-12 Action-specific ARARs 5-287-1 Summary Table - Issues, Recommendations, and Follow-up Actions 7-5

v

CONTENTS

Figures

1-1 Site Location Map 1-34-1 Ground H2O Remedial Action Components 4-174-2 Groundwater Treatment System Process Flow Diagram 4-184-3 Location of Agricultural Irrigation Wells 4-195-1 Extraction and Monitoring Well Locations 5-395-2A A-Aquifer Groundwater Elevation Contours April 2000 5-405-2B A-Aquifer Groundwater Elevation Contours June 2004 5-415-3A B-Aquifer Groundwater Elevation Contours April 2000 5-425-3B B-Aquifer Groundwater Elevation Contours June 2004 5-435-4A C-Aquifer Groundwater Elevation Contours April 2000 5-445-4B C-Aquifer Groundwater Elevation Contours June 2004 5-455-5A PCE Concentrations in A-Aquifer April 2000 5-465-5B PCE Concentrations in A-Aquifer April 2004 5-475-6A TCE Concentrations in A-Aquifer April 2000 5-485-6B TCE Concentrations in A-Aquifer April 2004 5-495-7A VC Concentrations in A-Aquifer April 2000 5-505-7B VC Concentrations in A-Aquifer April 2004 5-515-8A PCE Concentrations in B-Aquifer April 2000 5-525-8B PCE Concentrations in B-Aquifer April 2004 5-535-9A TCE Concentrations in B-Aquifer April 2000 5-545-9B TCE Concentrations in B-Aquifer April 2004 5-555-10A VC Concentrations in B-Aquifer April 2000 5-565-10B VC Concentrations in B-Aquifer April 2004 5-575-11 PCE Concentrations in C-Aquifer April 2004 5-585-12 TCE Concentrations in C-Aquifer April 2004 5-595-13 VC Concentrations in C-Aquifer April 2004 5-605-14 Landfill Gas Flare, Condensate Sump, and Perimeter Probe Locations 5-61

Appendices

A Documents ReviewedB Community NotificationC Five-Year Review Site Inspection Checklist, Memo, and Interview Summary formsD Site Inspection Photographs

vi

E092005004SAC/324131/052550001(5YEARREVIEWREPORT_FINAL.DOC) viii

Acronyms and Abbreviations

µg/L micrograms per liter

ARARs applicable or relevant and appropriate requirements

bgs below ground surface

CCR California Code of Regulations

CDM Camp Dresser and McKee

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

City City of Fresno, California

COC constituent of concern

DCA dichloroethane

DCB dichlorobenzene

DCE dichloroethene

DOHS California Department of Health Services

DTSC Department of Toxic Substances Control

ESD Explanation of Significant Difference

FSL Fresno Sanitary Landfill (Site)

gpm gallons per minute

HDPE high-density polyethylene

LFG landfill gas

MCL maximum contaminant level

mg/L milligrams per liter

O&M operation and maintenance

OU operable unit

PCB polychlorinated biphenyl

PCE tetrachloroethene

POTW publicly-owned treatment works

ppbv parts per billion by volume

ppmv parts per million by volume

ACRONYMS AND ABBREVIATIONS

E092005004SAC/324131/052550001 (5YEARREVIEWREPORT_FINAL.DOC) IX

PTA packed tower aerator

ROD Record of Decision

RPM Remedial Project Manager

RWQCB Regional Water Quality Control Board

SCADA Supervisory Control and Data Acquisition

SJVAPD San Joaquin Valley Air Pollution Control District

SOW Scope of Work

TBC To Be Considered

TCA trichloroethane

TCE trichloroethene

TDS total dissolved solids

THM trihalomethane

USEPA United States Environmental Protection Agency

VOC volatile organic compound

E092005004SAC/324131/052550001 (5YEARREVIEWREPORT_FINAL.DOC) xii

Issues and Recommendations

Issues Related to OU-1 and OU-2

Issue

An institutional control needs to be in place to prohibit well installation and construction in the area around the FresnoSanitary Landfill that could cause contamination of that well or adversely affect the containment of the plume by theextraction wells. An institutional control also needs to be put in place to restrict certain uses of the site itself and protectthe landfill cap.

Recommendation

USEPA recommends that an Explanation of Significant Difference (ESD) be prepared for the site. The ESD will includethe following recommendations with regard to institutional controls for the site. The OU-1 Record of Decision (ROD)relied on the State Water Resources Control Board and Integrated Waste Management Board regulations for closureand post-closure maintenance requirements to ensure integrity of the landfill cap and protect public health and safetyby preventing public contact with the waste. However, the State Water Resources Control Board and the IntegratedWaste Management Board regulations cited in the Landfill ROD (Title 22, Chapter 15 and Title 14, Division 7,respectively) have been superseded and replaced by Title 27. Thus, the ESD will cite to the Title 27 regulations thatpertain to closure and post-closure maintenance requirements. The ESD will also recommend that the City of Fresnoexecute and record a restrictive covenant for the property that would bind current and future owners and restrict certainuses of the site itself, including residential use, and prohibit use of the groundwater underneath the site.

Issues Related to the Landfill (OU-1)

Issue

During the first compliance testing, the flare did not achieve 98 percent destruction efficiency. The second compliancetesting occurred in April 2005, but the report will not be available for this Five-Year Review.

Recommendation

The second compliance testing report will not be available for this Five-Year Review. Therefore, the secondcompliance testing Report will include how to address any problems identified with the performance of the flare.Additionally, resolutions will be identified for all outstanding recommendations included in the First Compliance TestingReport Fresno Sanitary Landfill Jensen Avenue Fresno California (July 2004).

This includes evaluating data collected as part of the second compliance testing to determine the mass of VOCs in theexhaust air from the groundwater treatment packed tower aerator (PTA) to account for all VOC sources. Because ofthe correlation between the VOC concentrations in groundwater and the potential VOC emissions in the exhaust airfrom the PTA, future scheduled compliance tests should include review and discussion of the total VOC influentgroundwater concentrations. This review should include verification that no significant increases in total VOCs haveoccurred over time. Only if significant changes are found, would retesting the PTA exhaust air emissions be necessary.

Issue

The absence of dioxin testing of the flare has been an issue raised in the past.

Recommendation

Perform modeling to evaluate what dioxin emissions level from the flare stack would result in a 10-6 excess cancer riskto the maximally-exposed individual (probably a worker at the adjacent sports complex or a neighbor). If the level ofemissions necessary for a 10-6 increase in cancer risk is much higher than expected from the landfill flare, then dioxintesting may not be called for at this time.

Consider reviewing data (when available) from a similar landfill site where dioxin testing has been performed recently.These data may assist in drawing further conclusions about the potential need for testing at Fresno Sanitary Landfill.

Perform sampling if analysis above indicates flare stack emissions level may exceed health protective standards (10-6

ISSUES AND RECOMMENDATIONS

E092005004SAC/324131/052550001 (5YEARREVIEWREPORT_FINAL.DOC) XIII

excess cancer risk or 200 pg/m3).

Additional recommendation: In evaluating the performance of the flare, consideration should be given to modifying thestack so that dioxin testing could be easily accomplished in the future, particularly if system re-engineering already willbe necessary to bring the flare into compliance.

Issue

There has not been an ecological risk assessment conducted at the site. A review of ecological reports for the sitefound that a screening-level ecological risk assessment should have been conducted. (USEPA 2003a) The squirrel baitcurrently dispensed around the landfill and the heat of the flare that kills birds and bees could both be a threat toendangered species in the area.

Recommendation

Conduct a screening-level ecological risk assessment or an acceptable alternative assessment that evaluates theprotectiveness of the remedy (i.e., ensure there are no exposure pathways connecting landfill contaminants andecological receptors) and identifies any current adverse impacts of the remedy on the environment.

Issue

Debris and water were found in some of the gas monitoring wells (MMW4 at depths of 5 feet, 25 feet, and 45 feet andMMW3 at 5 feet) Also, one of the wells (MMW5 at 25 feet deep) detected methane at 13.4 percent by volume.

Recommendation

Maintenance should be conducted on the gas monitoring wells. MMW5 is located close to the waste and not near theproperty line. If the methane levels do not decrease, the City of Fresno may need to install an additional well betweenMMW5 and the property line along Jensen Avenue.

Issues Related to the Groundwater (OU-2)

Issue

The vertical migration of constituents appears to be increasing the concentration of tetrachloroethene in the C-Aquifer.

Recommendation

Continue to monitor the concentration changes in well clusters.

Use the groundwater model to predict how vertical migration of constituents of concern can be reduced, and considerthe results of this analysis in evaluating the effectiveness of the Phase 1 remedial action for groundwater cleanup asappropriate.

Issue

The extraction wells have been operating at lower flow rates than designed. This leads to issues such as incompletecontainment of the plume and non-functioning flow meters.

RecommendationReplace flow meters.

Review flow rate data after the extraction well rehabilitation activities. Semi-annual or annual well rehabilitationactivities may be necessary if the data are found to result in improved flow rates.

Review groundwater elevation data since the decommissioning of the agricultural wells.

The Phase 1 evaluation should assess the implications of the low extraction rates.

ISSUES AND RECOMMENDATIONS

E092005004SAC/324131/052550001 (5YEARREVIEWREPORT_FINAL.DOC) XIV

Protectiveness StatementA protectiveness determination of the remedies for both OU-1 and OU-2 cannot be made at this time until furtherinformation is obtained and actions are completed. The information and actions required for OU-1 includedemonstration that the flare performs adequately to prevent/eliminate emission levels that are unsafe, resolution of thepotential dioxin emissions issue (i.e., perform modeling or sampling and/or review data from similar landfill site), andcompletion of a screening-level ecological risk assessment. It is expected that these actions will take no more than6 months to complete.

The information and actions required for OU-2 include demonstration of adequate capture and migration control of thecontamination plume through capture-zone analysis. The Phase I evaluation will assess the overall efficacy andprotectiveness of the remedy. This evaluation will provide recommendations for any further modifications and isanticipated to be complete in early 2006.

The action required for both operable units relates to institutional controls. For the remedy to be protective in thelong-term, institutional controls such as execution and recordation of a restrictive covenant for the property that wouldbind current and future owners and restrict certain uses of the site itself, including residential use and prohibit use ofthe groundwater underneath the site, need to be implemented. It is anticipated that this action would be completed by2007.

As the required information is obtained and actions are completed at each of the operable units, the protectivenessdetermination will be made.

E092005004SAC/324131/052550001 (5YEARREVIEWREPORT_FINAL.DOC) ES-1

Executive Summary

A Five-Year Review of the Fresno Sanitary Landfill (FSL) Superfund Site (the site) in FresnoCounty, California was completed in September 2005. The Five-Year Review was requiredby statute and performed because hazardous substances, pollutants, or constituents remainat the site at concentrations above levels that would allow for unrestricted use andunlimited exposure. The triggering action for this review was mobilization for onsiteconstruction, which occurred in June 2000.

From 1935 to 1987, the 145-acre site was used as a landfill for a variety of municipal wastes(USEPA 1993a). The landfill footprint is approximately 4,200 feet long and 1,250 feet wide,with an average height of 45 feet. It is in a primarily agricultural area; however, there areseveral residences nearby. In June of 1984, the California Department of Health, now theDepartment of Toxic Substances Control, conducted a preliminary inspection in response tocomplaints from nearby residents. Offsite migration of methane and volatile organiccompounds (VOCs) was found in the groundwater. Numerous investigations wereconducted and, in October of 1989, the FSL was listed on the National Priorities List.

Additional investigations were conducted, and a methane barrier was constructed after thesite was listed on the National Priorities List. As part of the initial response in 1991, avacuum was added to the methane barrier. An in-home landfill gas (LFG) assessment wasperformed to assess the potential for migration of LFG into homes. Based on this work,vapor intrusion of LFG constituents was determined not to be a problem. Therefore, thevacuum system on the LFG barrier was discontinued. In the early 1990s, the City of Fresno(City) began providing bottled drinking water and installing and maintaining wellheadtreatment systems for some nearby residences. Currently, 13 residences north and south ofthe FSL receive bottled water. The City also purchased four homes along the southwestboundary of the site (Slater 2005). A portion of the site has been redeveloped into a regionalpark and sports complex including soccer and softball fields as well as picnic facilities(CDM 2003a).

In 1993, the first Record of Decision (ROD) was signed. The 1993 ROD called for an interimremedy, Operable Unit No. 1 (OU-1). This included the landfill cover, storm watermanagement, and LFG collection and treatment, as well as migration monitoring.

The second ROD was signed on September 30, 1996 (USEPA 1996). It pertains to OU-2,which includes a groundwater monitoring system, a landfill perimeter groundwatercontainment system, a plume perimeter containment system, and an aquifer restorationsystem. The ROD specifies a phased implementation approach starting with the perimeterextraction and, ultimately, restoration of the aquifer to beneficial use. In September of 1997,a Consent Decree was signed whereby the City agreed to initiate a groundwater monitoringprogram, begin construction of OU-1, and design and construct OU-2.

In an effort to initiate control of VOC-impacted groundwater prior to construction andstartup of the Phase 1 groundwater remediation system, the City implemented the earlygroundwater remedial action (Early Action). The Early Action program consisted of

EXECUTIVE SUMMARY


installing groundwater extraction wells (planned for use as part of the Phase 1 groundwaterremedial action), modular wellhead treatment systems (hydraulic venturi air strippers), andconveyance and discharge piping. Design and implementation of the Early Action wasperformed with oversight of the United States Environmental Protection Agency, but notrequired in the Consent Decree. Early Action system startup occurred in May of 1999(CDM 2003b).

OU-1 was constructed from June 2000 to September 2001. The final cover included theinstallation of the foundation layer, the LFG collection system, the LFG treatment system,the high-density polyethylene geomembrane, drainage geocomposite, filter and cushiongeotextile, vegetative soil layer, and the landfill access road. The final cover is in goodcondition. The LFG gathered in the gas collection system is conveyed via piping to the flareto be burned.

Startup on OU-2 occurred in September 2001. Currently, Phase 1 (landfill perimetercontainment) is in progress. There are 31 monitoring wells in the A-Aquifer, 27 in theB-Aquifer, and 13 in the C-Aquifer. Five extraction wells (PW-1 through PW-5) operatealong the western downgradient edge of the landfill in the A-Aquifer. The extractedgroundwater is treated with a packed tower aerator. The treated water is sent to thedetention basins onsite, where some of the water is used for irrigation of the park. TheVOC-contaminated air is conveyed to the flare, where it is burned along with the LFG.

The groundwater treatment plant effluent discharge has been meeting the effluent dischargelimits as set forth in the Clean Water Act, Title 33, Code of Federal Regulations, Parts 301and 302 for the time that it has been operational. There have been occasions during this timewhen the treatment system was not operating due mainly to power failure and/or routinemaintenance. The extraction wells that are part of the treatment system are currentlyoperating at an 80 to 90 percent capacity. The downtime for the extraction wells is primarilydue to a lowered water table and the subsequent inability to maintain appropriate flows.The lowered water table is due to regional-scale municipal and agricultural well pumping.

Analysis of groundwater monitoring has been focused on the main constituents of concern:trichloroethene, tetrachloroethene, and vinyl chloride. Plume maps and concentrationtrends are included in semi-annual monitoring reports. While concentrations in general arestable, the data seem to indicate an upward trend in cis-1,2-dichloroethene concentrations ina number of the monitoring wells. There is possible vertical migration carryingtetrachloroethene downward to the C-Aquifer. These issues are currently underinvestigation by the City and will be addressed in the Phase 1 evaluation report to becompleted in early 2006.

A protectiveness determination of the remedies for both OU-1 and OU-2 cannot be made atthis time until further information is obtained and actions are completed. The informationand actions required for OU-1 include demonstration of adequate flare performance,resolution of the potential dioxin emissions issue (i.e., perform modeling or samplingand/or review data from similar landfill site), and completion of a screening-level ecologicalrisk assessment. It is expected that these actions will take no more than 6 months tocomplete.

EXECUTIVE SUMMARY


The information and action required for OU-2 includes demonstration of adequate captureand migration control of the contamination plume through capture-zone analysis. ThePhase 1 evaluation will assess the overall efficacy and protectiveness of the remedy. Thisevaluation will provide recommendations for any further modifications and is anticipatedto be completed in early 2006.

The action required for both operable units relates to institutional controls and wouldinclude execution and recordation of a restrictive covenant for the property that would bindcurrent and future owners and restrict certain uses of the site itself, including residentialuse, and prohibit use of the groundwater underneath the site. It is anticipated that thisaction would be completed by 2007.

As the required information is obtained and actions are completed at each of the operableunits, the protectiveness determination will be made.

E092005004SAC/324131/052550001 (5YEARREVIEWREPORT_FINAL.DOC) 1-1

SECTION 1.0

Introduction

The United States Environmental Protection Agency (USEPA) conducted a Five-YearReview of the remedial actions implemented at the Fresno Sanitary Landfill (FSL)Superfund Site (the site) in Fresno County, California (Figure 1-1). This review wasconducted from February to June 2005. To assist USEPA, CH2M HILL has prepared thisreport documenting the results of the Five-Year Review. This report has been prepared inaccordance with USEPA’s guidance document, Comprehensive Five-Year Review Guidance(USEPA 2001).

The purpose of the Five-Year Review process is to evaluate whether the remedy at the site isprotective of human health and the environment. The methods, findings, and conclusions ofreviews are documented in Five-Year Review Reports. In addition, Five-Year ReviewReports identify any deficiencies found during the review and provide recommendationsfor addressing these deficiencies.

This review is required by federal statue. USEPA must implement Five-Year Reviewsconsistent with the Comprehensive Environmental Response, Compensation, and LiabilityAct of 1980 (CERCLA). CERCLA Section 121(c), as amended, states:

If the President selects a remedial action that results in any hazardoussubstances, pollutants, or contaminants remaining at the Site, the Presidentshall review such remedial action no less often than each five years after theinitiation of such remedial action to assure that human health and theenvironment are being protected by the remedial action being implemented.

Consequently, this Five-Year Review Report has been completed because hazardoussubstances, pollutants, or constituents remain at the site above levels that allow forunrestricted use and unlimited exposure.

This is the first Five-Year Review Report for the FSL. The triggering action for this reviewwas the mobilization for onsite construction in June of 2000 (USEPA 2004). This reportevaluates the FSL remedial objectives, as stated in the two Records of Decision (RODs).

The FSL Superfund Site consists of approximately 145 acres and is divided into twooperable units (OUs). The source area, or landfill itself, defines OU-1. Onsite and offsitecontaminated groundwater comprise OU-2.

This report covers both OU-1 and OU-2. It is organized into sections that describe thehistory and setting of the site, remedial action decisions and implementation, and anevaluation of remedial actions. These sections are:

Section 2.0 - Chronology of site events.

Section 3.0 - Land use, site setting, the history of contamination, and initial response.

SECTION 1.0: INTRODUCTION


Section 4.0 - The remedial action implemented at the FSL, current status of the remedy,and treatment system operations and maintenance (O&M) activities and cost.

Section 5.0 - Activities performed during the Five-Year Review process.

Section 6.0 - Technical assessment of the remedial action implemented at the site.

Section 7.0 - Issues at the site are identified and recommendations are provided.

Section 8.0 - Protectiveness statement for the FSL.

Section 9.0 – Next Five-Year Review

Section 10.0 - List of works cited during the preparation of this document.

Redding

Sacramento

Stockton

Bakersfield

SanBernardino

Source: CDM, 2004.

SanDiego

LosAngeles

Fresno

Not to Scale

htron

S a n i t a r yL a n d f i l l

324131.FR.01_Figure 1-1 Site Location_7/21/05_ez_sfo

FIGURE 1-1SITE LOCATION MAPFRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CA


SECTION 2.0

Site Chronology

Table 2-1 provides a chronology of events at the site.

TABLE 2-1Chronology of Site EventsFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Event Date

Unlined landfill accepted waste. 1935 - 1987

City filed a CERCLA Section 103(c) notification. May 1981

City began process of closing FSL by filing a Negative Declaration with RWQCB. August 1981

City tested and found the presence of VOCs at concentrations greater than MCL ingroundwater around the perimeter of the landfill. DOHS (DTSC) conducted preliminaryinspection in response to complaints from nearby residents. Found offsite migration ofmethane and reviewed the documentation of VOCs in groundwater.

1983/1984

Environmental Impact Report for landfill closure, closure, and post-closure maintenanceplan and a grading and drainage plan report prepared.

1989

Site listed on National Priorities List. October 1989

Unilateral Order No. 90-19 issued to the City to apply an active vacuum system to themethane barriers and to install a landfill gas extraction system.

September 19, 1990

USEPA and City signed Administrative Consent Order No. 90-22 where City agreed toconduct RI/FS.

September 21,1990

Administrative Consent Order No. 90-23 issued by USEPA to modify 90-19 to stilldevelop a vacuum system for the methane barriers and to implement a monitoringprogram to ensure that residents near the landfill were not exposed to vinyl chloride intheir homes.

February 1991

Feasibility study conducted for source control OU. January 1993

ROD for OU-1 signed. USEPA selected cleanup for OU-1 (capping, constructing gascollection system, building stormwater management system and, if necessary, a leachatecollection system.

September 1993

Administrative Consent Order (90-22) between City and USEPA amended (94-07) toinclude design of landfill cap and other components of system.

December 1993

Remedial investigation for OU-2 completed. May 1994

Risk assessment completed. September 1994

Feasibility study completed, as required by 1990 Consent Order; it provided alternativesfor OU-2.

July 1996

ROD for OU-2 signed. USEPA selected remedy for groundwater: three-phasedcontainment and remediation.

September 1996

SECTION 2.0: SITE CHRONOLOGY


TABLE 2-1Chronology of Site EventsFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Event Date

Consent Decree signed. It included agreements to initiate groundwater monitoringprogram and early groundwater remedial action, including constructing OU-1, developingremedial design, and constructing and conducting cleanup for OU-2.

September 1997

Remedial design for OU-2 approved. November 1998

Operation of Early Action system. May 1999 –September 2001

Construction of the OU-2 groundwater treatment facility began.

Final elements of Phase 1 groundwater monitoring network in place.

July 1999.

Construction of landfill cap, gas control wells, and water treatment system began. June 2000

Final Cover (OU-1) remedial action completed. September 2001

OU-2 Phase 1 treatment system startup. September 2001

Regional Park and Sports Complex constructed. 2001

Final Inspection of OU-1 by USEPA and DTSC. December 2002

Remedial Action Report submitted. OU-1 complete closure occurred in May 2003. June 2003

OU -2 Phase 1 Groundwater Remedial Action Evaluation Report completed. December 2003

First Compliance testing reported – 98 percent destruction was not achieved by the flare. July 2004

Quarterly groundwater monitoring. Currently, Phase 1 monitoring includes measuringwater levels and water quality analysis of wells in the A-, B-, and C-Aquifers andextraction wells. Water quality is also measured at residential wells.

On-going quarterly

Notes:

CDHS California Department of Health Services.

City City of Fresno.

DTSC Department of Toxic Substances Control.

MCL maximum contaminant level.

RI/FS remedial investigation/feasibility study.

RWQCB Regional Water Quality Control Board.

VOC volatile organic compound.


SECTION 3.0

Site Background

The FSL is located in Fresno County, California. Figure 1-1 presents a map showing thelocation of the site. This section provides site background including the land and resourceuse, the physical setting, the history of contamination, and the initial response to cleanupthe contamination.

3.1 Land and Resource UseFrom 1935 to 1987, the site was used as a landfill for a variety of municipal wastes(USEPA 1993a). Since then, the landfill has been closed and is undergoing remedial actions.Recently, part of the site has been redeveloped into a Regional Park and Sports Complex.The complex includes soccer and softball fields. The landfill itself has been covered and isrevegetated. Land to the west, east, and south of the landfill contains stormwater detentionponds. An administrative building lies just west of the landfill and is used by City of Fresno(City) employees who maintain the site.

The land within 1 mile of the site has been used in the past for farming, rural habitation,industrial uses, and some commercial uses (CDM 1994). Land use in the vicinity of the FSLis currently primarily agricultural, with several residences nearby (USEPA 1993a). WesternElementary School is 0.5 mile east of the site, and Fresno Wastewater Treatment Plant is3 miles west of the site (CDM 1994). According to the City, there are no plans to change theland use either at the site or in the surrounding vicinity in the future.

Historically, groundwater was used residentially. There were eight municipal wells within3 miles of the site at the time of 1993 ROD. Over 350,000 people received water from ablended supply that included water from those wells (USEPA 1993a).

The Fresno Colony Canal, an unlined irrigation supply, runs along the eastern side of thelandfill. The canal used to extend through what is now the FSL. After the landfill expansionin 1945, the canal was replaced by an 18-inch concrete pipeline. The water supply pipelinewas used to carry water from the Fresno Colony Canal to fields west of the landfill(CDM 1994). The pipeline was eventually relocated to the south end of the landfill in 1996.The pipeline under the landfill was plugged and abandoned (CDM 2001a). Water from thecanal is used for local irrigation. The water from George’s Lake, a detention pond west ofthe landfill, is also used for irrigation when the canal is low on water (Slater 2005).

In December 1991, the United States Fish and Wildlife Service compiled a list of potentialsite endangered and threatened species. The endangered Fresno kangaroo rat was the onlylisted species that lives in the area. The spotted bat was the only candidate species listed,meaning the bat is a candidate to be listed as an endangered or threatened species, butsubstantial biological information was not available at the time to confirm a listing(USDOI 1991).

SECTION 3.0: SITE BACKGROUND


3.2 Physical SettingThe FSL sits at 265 feet above sea level in the eastern part of the San Joaquin Valley. It isapproximately 10 miles south of the San Joaquin River and 20 miles southwest of the SierraNevada Mountains. The natural topography of the area is low relief.

The FSL is located in a sunny region that experiences hot, dry summers and moderatewinters. Temperatures range throughout the year from 37 to 98 degrees F. The wind ispredominantly in a northwest direction. Annual precipitation is approximately 10.5 inches;the wet season is from November to April.

The approximately 145-acre FSL is located 4 miles southwest of the City of Fresno in FresnoCounty, California. It is in a primarily agricultural area; however, there are severalresidences to the north and one residence to the south. Three roads border FSL: JensenAvenue to the north, West Avenue to the East, and North Avenue to the south. Agriculturalfields border the site to the west, and Marks Avenue lies beyond the fields.

The landfill itself is a 4,200 feet long by 1,250 feet wide rectangle. The side slope gradientsrange from 2 feet horizontal to 1 foot vertical (2:1) on the west side to a more gradual10:1 slope on the east side (CDM 1994). The landfill rises to an average height of 45 feet, andthe surrounding grade is essentially flat.

3.2.1 Geology/HydrogeologyThe FSL is located in the San Joaquin Valley. The San Joaquin Valley is the southern portionof the Central Valley (the northern part is called the Sacramento Valley and the middlesection is the Sacramento – San Joaquin Delta). The Central Valley is known for its flatterrain. The Central Valley is composed of alluvial plains, flood plains, and dissecteduplands. The majority of the groundwater originates as runoff from the surroundingmountains: the Coast Ranges to the west and the Cascades and Sierra Nevadas to the east.

The Central Valley is in a structural trough approximately 400 miles long and from 20 to70 miles wide and comprises more than 20,000 square miles. The trough is filled to greatdepths by marine and continental sediments, which are the result of millions of years ofinundation by the ocean and erosion of the rocks that form the surrounding mountains.

The geology under the FSL consists of interbedded layers and lenses of clay, silt, sand, andgravels. These layers, which are considered Older Alluvium of Quaternary age (Qoa),extend to around 500 feet below ground surface (bgs). Continental and marine sedimentaryrock from the Cretaceous and Tertiary periods forms the next layer. At about 4,500 feet bgs,there is a composite of granitic and metamorphic rocks of the Sierra Nevada foothills.Sparser amounts of Younger Alluvium (Qya), flood-basin deposits, and sand dunes alsoexist on the surface of the valley floor. Quaternary sand dunes (Qsd) are abundant south ofFresno (CDM 1994).

The A-Aquifer is found at approximately 50 to 95 feet bgs. The A-Aquifer is mostly fine- tomedium-grained, poorly-graded sand with interbedded layers of both coarse-grained sandsand very fine-grained stiff clayey silts. The ponds associated with the Fresno RegionalWastewater Facilities, located northeast of the site, have created a water table high orrecharged mound. Regional hydraulic conductivity has been calculated from 1 to 3 feet per



day. Local flow rates based on groundwater monitoring data are approximately 1 foot peryear. Below the A-Aquifer is an aquitard composed of red-brown sandy clay, gray clayeysilt and brown-gray clayey silt. According to the American Geological Institute, an aquitardis a confining bed that retards but does not prevent the flow of water to or from an adjacentaquifer. The B-Aquifer spans from approximately 110 to 150 feet bgs. The B-Aquifer iscomposed of thick, inter-layers of stiff clayey silt and poorly-graded, very fine tomedium-grained sand that contains coarse-grained mica flakes. The aquitard below theB-Aquifer is composed of thick clayey silt layers like those in the B-Aquifer. The C-Aquiferis from approximately 200 to 240 feet bgs. The C-Aquifer is composed of inter-layeredwell- and poorly-graded sand and clayey silt. The sand grains include up to largegravel-sized volcanic pumice (pyroclastic) material (CDM 2001b; CDM 1999c).

The regional groundwater flow direction in this area is from east to west. There are somelocalized influences as a result of both pumping and man-made ponds. Due to the dryweather conditions in this mostly agricultural area, the available groundwater has beenpumped out for irrigation purposes. Shallow groundwater levels have dropped; however,groundwater in the area of the site remains abundant. This has caused a cone of depressionwithin the City of Fresno, including the landfill area. To the west of the landfill, the pondsassociated with the Fresno Regional Wastewater Facilities have created a water table high orrecharge mound. Regional hydraulic conductivity has been calculated from 1 to 3 feet perday (CDM 1994).

3.3 History of ContaminationThe FSL, owned and operated by the City of Fresno from 1935 to 1987, was the “oldestcompartmentalized landfill in the Western United States” (USEPA 1993a). The state ofCalifornia designated the FSL as a Class III landfill (a municipal landfill that acceptsnon-hazardous solid waste) (California Code of Regulations [CCR] Title 27, Division 2,Subdivision 1, Chapter 3, Subchapter 2, Article 3, Section 20260). The unlined landfill wasfilled with municipal trash and some liquid waste (USEPA 1993a). The landfill was initiallyonly located north of Annadale Avenue. In 1945, it was expanded south of Annadale Avenue.

An average of 16,500 tons of solid waste was disposed of at the FSL per month. The totalamount of waste has been calculated to be about 4.7 million tons or 7.9 million cubic yards.In addition to municipal solid waste, 1,600-gallon tanker trucks disposed of battery acid into the FSL twice a week from the late 1950s to the mid-1960s (CDM 1994).

In 1984, nearby residents wrote complaint letters to the California Department of HealthServices (DOHS), now the California Department of Toxic Substances Control (DTSC). InJune 1984, the DOHS conducted a preliminary inspection of the site in response to thoseletters (USEPA 1993a).

Numerous studies, described in Section 3.4, characterized the contamination. The studiesshowed that the highest volatile organic compound (VOC) concentrations in groundwaterwere downgradient (west side) of the landfill. The VOC concentrations were higher in theshallow (less than 70 feet bgs) and intermediate wells (70 to 110 feet bgs) than in the deepwells (greater than 110 feet bgs). VOCs, including vinyl chloride, trichloroethene (TCE),tetrachloroethene (PCE), 1,1-dichloroethene (DCE), 1,1-dichloroethane (DCA),



dichloropropane, dichloropropene, trichlorofluoromethane (Freon-11), and methylenechloride, were all detected in the groundwater. Purgeable aromatic compounds, includingbenzene, chlorobenzene, 1,2-dichlorobenzene (DCB), and 1,4-DCB, were also detected.Nitrate was the only inorganic compound detected above maximum contaminant levels(MCLs). Previous investigations attributed the high nitrate to the nitrogen-based fertilizersused for agriculture. No polychlorinated biphenyl (PCB) compounds or pesticides weredetected in the groundwater (CDM 1994).

3.4 Initial ResponseThe City hired consultants to conduct numerous studies to further understand the physicalcharacteristics of the site and the extent of the contaminant plume between 1983 and thestartup of remedial actions at OU-2 in 2001. In 1983, the City initiated an assessment ofgroundwater contamination and landfill gas (LFG) migration. These results, along withadditional testing that determined that hazardous constituents were disposed of in thelandfill, were reported in 1986. The next year, additional sampling led to the conclusion thatcontamination had moved vertically downward beneath the landfill to as deep as 100 to150 feet bgs. This vertical contamination occurred because the A-Aquifer is relatively thickand the first aquitard is not encountered until an approximate depth of 95 feet bgs.According to Section 3.2.1, there is an aquitard beneath the A-Aquifer at a depth of about95 feet and is about 15 feet thick since the B-Aquifer starts at about 110 feet. The studies alsoshow that LFG extended 150 feet laterally from the landfill edge.

The City discontinued accepting waste at the landfill in 1987. In preparation for the closure,an Air Quality Solid Waste Assessment Test report was prepared in 1988. The Solid WasteAssessment Test findings were that ambient air contained benzene, methylene chloride,PCE, carbon tetrachloride, trichloroethane (TCA), and TCE. The concentrations rangedfrom.07 to 2.6 parts per billion volume (ppbv). TCA, TCE, and PCE were also detected in thesurface air of the landfill (2 to 3 inches above the landfill) (CDM 1994). The study also foundVOCs above the detection limit in interior gas wells.

Also in 1988, the City installed two methane barriers to protect residences to the north andthe south. The barriers were constructed by digging 26-foot deep trenches. The trencheswere backfilled with gravel and a membrane liner on the landfill side of the barrier. Thetrenches had two perforated horizontal collection pipes at 12 and 19 feet bgs. Theseperforated pipes were tied into vertical pipes to allow for passive venting of landfill gases tothe surface (USEPA 1993a). The City also retained Laidlaw Gas Recovery Systems to designa landfill gas extraction and recovery system. In 1990, a soil-gas survey found elevatedmethane and vinyl chloride just outside the methane gas barriers. Therefore, it was believedthat the methane gas was migrating below or around the methane gas barriers. The Citybegan removal of migrating landfill gas (VOCs) by placing a vacuum on an existing gasmigration barrier. It was found that the vacuum was not effective in stopping the landfillgases from migrating past the barriers because the methane barriers were not designed for avacuum extraction system (USEPA 1996).

The understanding of the lateral and vertical extent of groundwater contamination wasexpanded in 1989. An environmental impact report for landfill closure, a grading anddrainage plan report, and a closure and post-closure maintenance plan were completed, and



a feasibility study was conducted. In October 1989, USEPA placed the landfill on theNational Priorities List.

The remedial investigation showed that the groundwater was contaminated largely byVOCs. The highest concentrations of which were trans-1,2-DCE, methylene chloride, TCE,PCE, and vinyl chloride.

In the early 1990s, the City began providing bottled drinking water and installing andmaintaining wellhead treatment systems for some nearby residences. In 1992, the City wasproviding bottled water and wellhead treatment systems to 15 nearby residences on NorthAvenue, West Avenue, and Jensen Avenue. One resident elected to only receive the City’sbottled water. Five residences either refused or did not request bottled water or filtration(City of Fresno 1992). The City also purchased four homes along the southwest boundary ofthe site (Slater 2005). The City currently provides purified water to seven residences andfiltration to seven residences.

The City was proactive in conducting an Early Action for groundwater cleanup. The EarlyAction was under the oversight of USEPA but not required in the Consent Decree. Thestartup began in May of 1999. It included pumping and treating groundwater. The objectiveof the Early Action was to get an immediate start on controlling and reducing the offsitecontaminant plume. The data that the Early Action provided were also valuable in refiningthe design of the Phase 1 groundwater system for OU-2 (CDM 2000). The Early Actionsystem included the installation and operation of three extraction wells (PW-1A, PW-2A,and PW-3A). In addition, the City continued monitoring 45 existing wells and installed sixadditional monitoring wells. The Early Action treatment unit included two modularhydraulic venturi air strippers. The north stripper treated groundwater from PW-1A andPW-2A. The south stripper treated groundwater from PW-3A. The treated effluent wasconveyed to the South Detention Basin via newly-constructed transmission piping(CDM 1999).

3.5 Basis for Taking ActionThe USEPA and the City signed an Administrative Consent Order in September of 1990,where the City agreed to conduct a remedial investigation/feasibility study.

The remedial investigation focused on the contamination of PCE, TCE, and vinyl chloridebecause the USEPA had stated, in a verbal disclosure, that those chemicals were the sitepreliminary constituents of concern (COCs). Groundwater and soil gas were found to beimpacted by the COCs. It was determined that the ambient air and soil were notsignificantly contaminated. Based on the investigation, it appears the liquid wastes thatwere disposed were more of a contributor to the groundwater contamination than theleachate generated from percolation of water through the landfill waste.

VOC contamination of groundwater (above MCLs) existed downgradient of the landfill. FiveCOCs had a maximum detection exceeding 10 times their federal MCL value: PCE, TCE,trans-1,2-DCE, vinyl chloride, and methylene chloride. Benzene, 1,1-DCA, and 1,2-DCA allexceeded their federal MCLs as well. 1,2-DCA exceeded the California MCL (CDM 1994).Nitrate was the only inorganic constituent detected above MCLs. The presence of nitrate hasbeen attributed to the nitrogen-based fertilizers used for agricultural purposes. Irrigation well



pumping in the vicinity of the site is thought to be the cause of downward vertical migrationof constituents from the A-Aquifer into the B-Aquifer. Trans-1,2-DCE, cis-1,2-DCE, and vinylchloride are likely the anaerobic biodegradation compounds of PCE and TCE.

The remedial investigation showed the soil-gas was contaminated around 1,000 feet fromthe perimeter of the landfill. Methane was found around 500 feet from the perimeter. Therewere no consistent trends of the vertical distribution of the VOCs and methane in soil gas.PCE, TCE, vinyl chloride, TCA, Freon-12, and methane were the only VOCs that wereconsistently found in soil-gas (CDM 1994).

The human health risk assessment (ICF 1994) found that, at the time of the report, therewere no receptors present at the site. It was assumed that in the future: (1) the perimeter ofthe area would be fenced off, (2) access to the site would be controlled, (3) the site would becapped, (4) nothing would be built directly on top of the landfill because of potentialsubsidence, and (5) a worker would be present for 8 hours per day on the site afterremediation. Therefore, potential receptors were determined to be adult and child offsiteresidents, offsite workers, onsite workers, and onsite trespassers. The mechanisms by whichthese receptors could be exposed include direct contact with contaminated soil,volatilization into the ambient air, fugitive dust generation via wind erosion, leaching bycompression and percolation to groundwater supplies, and volatilization into soil-gas withsubsequent transport through soil.

The constituents of potential concern were based on the most recent data available at thetime. The risk assessment concluded that the constituents in indoor and outdoor air maypose potential carcinogenic risks to current residents in the Fresno area. For future risks,constituents in indoor air and groundwater may pose a potential carcinogenic risk toresidents in the Fresno area. It was also concluded that residential receptors may experienceadverse non-carcinogenic effects under the 1994 land-use conditions and future conditions(ICF 1994). Because of the determination that these potential risks existed, USEPAdetermined that remedial action was necessary.


SECTION 4.0

Remedial Actions

The following section summarizes the remedial actions selected and implemented at theFSL, as well as the operations and maintenance of the remedies. The RODs for the FSL weresigned in 1993 and 1996. They address OU-1 (the source control operable unit) and OU-2(the groundwater operable unit).

4.1 Remedial Action Selection and ImplementationBecause the contamination at the FSL is complex and varied, USEPA organized the workinto two operable units. The first of two RODs was signed on September 30, 1993 andpertains to OU-1, including the landfill cover, stormwater, and gas monitoring. The secondROD was signed on September 30, 1996 and pertains to OU-2, which includes agroundwater monitoring system, a landfill perimeter groundwater containment system, aplume perimeter containment system, and an aquifer restoration system.

An Administrative Consent Order was signed in 1990 and amended in 1993. Theamendment to the Consent Order, signed December 1993, pertains to OU-1 and includes thescope of work, as well as a list of the reports that the City must submit to USEPA. A ConsentDecree was recorded in official records on August 6, 1998. This Consent Decree outlines themost up-to-date requirements for OU-1 and OU-2, including producing monthly progressreports. Based on an approval from USEPA (letter dated April 16, 2004), the project updatereport submittals are now required on a quarterly basis rather than a monthly basis(Nyznyk 2005). The Consent Decree is a legal document that binds the City of Fresno, itsassigns, and the United States. The City must give a copy of the Consent Decree to eachcontractor it hires to perform the work in the Consent Decree.

4.1.1 OU-1 Selection and Implementation

4.1.1.1 SelectionThe primary objective for OU-1, outlined in the 1993 ROD, is to contain the contaminationwithin the landfill. This involves minimizing the volume of leachate formed due tostormwater infiltration, as well as collection and offsite treatment of any generated leachate.It also includes controlling releases through the surface and subsurface and collection andtreatment of the LFG. Managing stormwater, controlling oxygen intrusion into the landfill,and controlling erosion and offsite transport of contaminated soils are the other requiredremedial activities.

To obtain these objectives, a number of components were to be implemented at the FSL.Collectively, these components make up OU-1 and include:

A landfill cover with a series of functional layers (including a synthetic membrane) thatminimize the infiltration of water into the underlying refuse, provide erosion control,

SECTION 4.0: REMEDIAL ACTIONS


and provide a barrier to fugitive surface emissions and to ambient air entering the wastepile under vacuum conditions.

A LFG migration monitoring system consisting of monitoring probes along the landfillperimeter.

A LFG collection and conveyance system that includes interior gas extraction wells,perimeter gas extraction wells, a blower system, and a piping system to move the gas tothe treatment system.

A LFG treatment system that is a flare to combust LFG onsite.

A gas condensate collection system to manage any condensate that would form duringthe conveyance of the gas.

A contingency leachate collection system that includes liquid extraction pumps at thebottoms of the gas extraction wells and a network of piping to move the leachate to alocation where it would then be trucked offsite for treatment. This would only beinstalled if the leachate liquid found in the gas wells was determined to be a threat togroundwater.

Stormwater management, which includes perimeter drains, retention basins, and otherassociated structures.

4.1.1.2 ImplementationConstruction of OU-1 components occurred between June 2000 and September 2001, withconstruction quality assurance monitoring by GeoSyntec, the City of Fresno, and BSKconstruction quality assurance personnel. The final cover included the installation of thefoundation layer, the LFG collection system, the LFG treatment system, the high-densitypolyethylene (HDPE) geomembrane, drainage geocomposite, filter and cushion geotextile,vegetative soil layer, and the landfill access road.

To construct the foundation layer, the landfill surface was cleared, grubbed, and stripped,and some wastes were excavated and relocated. The soil cover was from onsite borrow(previously piled when the sports complex was formed) and from biosolids from theFresno/Clovis wastewater treatment plant. The cover was placed, compacted, and graded.

The LFG extraction wells were installed to the bottom of the waste after the foundation layerwas complete. The treatment system was constructed, and the startup of the flare andcondensate pumping system was monitored. The final cover system including the 60-mil(1.5 mm)-thick, double-sided textured and single-sided textured HDPE geomembrane wasalso installed and tested with seam testing. The double-sided and single-sided geocompositefor the final liner system was then installed and tested. The vegetative soil layer was placedand compacted to a minimum thickness of 33 inches (840 mm) (GeoSyntec 2001). Thecomponents of OU-1 were constructed in a manner consistent with standard constructionindustry practice. (Kleinfelder/Geosyntec 2003a).

A few minor design modifications occurred during construction, which were documentedas construction memoranda and included in the remedial action completion report preparedby GeoSyntec Consultants in September 2001. These include the following:



The landfill top surface settled from the initial topography (1994) to the time ofconstruction (2000). Therefore, the final elevation was lower than originally designed.

The grading of the north access road was modified.

The slope of the perimeter road was reduced from 4 percent to 2 percent toward thetrapezoidal ditch.

Instead of the continuous layer of granular drainage material, a PVC-lined, V-shapedconduit was filled with gravel, and discharge laterals extended from it every 100 feet.

The perimeter road alignment had to be altered because irrigation structures obstructedthe path. These were supposed to be removed before the construction but were notremoved until after. The perimeter road location was not changed after the irrigationstructures were removed.

The grades of the south- and west-side discharge system would not allow gravity tocarry the flow. Therefore, a subdrain piping network to carry the flow was designed andconstructed.

Additional borrow material was necessary for the construction of the cover. Therefore,the East Pond was lengthened and deepened. Because, the East Pond was now larger,the stormwater from the northeast area was rerouted to the East Pond, and a30-inch-diameter pipeline to the South Pond was eliminated.

A 12-inch irrigation line obstructed the path for stormwater to flow in the pipeline fromthe trapezoidal ditch to the perimeter outside the cover to the ponds. Therefore, theirrigation line was modified to route water over the stormwater pipeline.

The perimeter fence was needed to accommodate the park corporation yard area northof the landfill. Therefore, modifications were made in gate access locations.

The existing gas monitoring wells were repaired.

A vapor injection manifold was installed; the control panel was redesigned to allowcommunication with the packed tower aerator (PTA); a shut-off valve on the 12-inch PTAline was installed; and the stack was extended by 5 feet to provide additional residence time.

Sump CS-1 was outside of the waste footprint. Therefore, it was modified to be adouble-walled unit. (GeoSyntec 2001).

Also, the 1993 ROD called for a leachate collection system, if necessary. A leachate collectionsystem was not designed or constructed because of the small quantity of leachate reportedin the 1994 remedial investigation report (CDM 1994). Borings drilled through the refuse atthe FSL showed no signs of saturated waste. Refuse leachate was not found, and thedistribution of inorganic water quality parameters in the groundwater suggested thatmunicipal refuse leachate was not a significant source of groundwater contamination at thesite. The groundwater table is at least 25 feet below the base of the landfill (approximately50 feet bgs) (CDM 1994).

The most recent progress report does not note any issues with OU-1 (City of Fresno 2005).



4.1.1.3 Reporting DeliverablesPer the 1998 Consent Decree, the remedial action report for OU-1, construction completionreport for the entire site, yearly status reports, and monthly progress reports are the requireddeliverables for OU-1. A Scope of Work (SOW) for OU-1 was included in the amendment toAdministrative Consent Order U.S. Docket No. 90-22 (December 1993). This was then revisedand included as an attachment to the 1998 Consent Decree. This showed the specific reportingrequirements for construction planning, construction, compliance testing, and O&M. The Cityof Fresno hired Kleinfelder and GeoSyntec to help meet these reporting requirements andoversee OU-1. Based on an approval from USEPA (letter dated April 16, 2004), the projectupdate report submittals are now required on a quarterly basis rather than a monthly basis(Nyznyk 2005).

4.1.2 OU-2 Selection and Implementation

4.1.2.1 SelectionThe objective of OU-2 is to restore the aquifer to beneficial use in a timely and cost-effectivemanner. Beneficial use is defined here as when levels are at or below MCLs. The 1994remedial investigation had only identified PCE, TCE, and vinyl chloride as COCs, but the1996 ROD identified 16 COCs. These are: PCE, TCE, vinyl chloride, 1,1-DCE, 1,2-DCA, trans-1,2 DCE, cis-1,2 DCE, 1,2-dichloropropane, 1,2-DCB, 1,4-DCB, benzene, chlorobenzene,chloroform, 1,1-DCA, trichlorofluoromethane, and toluene.

To obtain these objectives, a number of components were to be implemented at the FSL.Collectively, these components make up OU-2 and include:

Phased installation of the groundwater extraction system.

Installation and operation of Phase 1 groundwater extraction wells (landfill perimetercontainment).

Installation and operation of Phase 2 groundwater extraction wells (plume containment).

Installation and operation of Phase 3 groundwater extraction wells (aquifer restoration).

Analysis of each phase of the groundwater remedy.

Treatment system for the extracted groundwater and all necessary piping.

A groundwater monitoring system.

Decommission certain wells, specifically agricultural wells affecting area water levelelevations.

Institutional control during remediation.

The remedy was to be implemented in three phases to optimize the design elementsincluding the number of wells, location of wells, and pumping rates.

4.1.2.2 ImplementationThe Phase 1 (landfill perimeter containment) groundwater remediation activities arecurrently ongoing. Thirty-four A-Aquifer monitoring wells, 24 B-Aquifer monitoring wells,



and 13 C-Aquifer monitoring wells (CDM 2000) were installed from 1986 to 2001(CDM 2005a). Five extraction wells were installed along the western downgradient edge ofthe landfill (wells PW-1 through PW-5). Figure 4-1 shows the locations of the extractionwells and other groundwater remedial action components. Table 4-1 shows the extractionwell information.

TABLE 4-1Extraction Well InformationFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

ExtractionWell Aquifer

Date ofInstallation

Total Depthof Boring(feet bgs)

PVC ScreenInterval

(feet bgs)

WellDiameter(inches)

Top of CasingElevation

(feet above msl)

PW-1A A 11/26/97 89 57-87 6 266.32

PW-2A A 12/16/98 89 57-87 8 267.36

PW-3A A 12/11/98 89 56 ½ - 86 ½ 8 263.31

PW-4A A 12/7/99 93 1/2 58-88 8 264.55

PW-5A* A 6/15/01 86 54-84 8 259.69

Source: CDM 2000.* CDM 2003a.

The extracted groundwater travels via the underground conveyance pipes to the groundwatertreatment PTA. The anti-scalent and oxidant are added to the water stream. The contaminatedwater enters the tower from the top and runs down due to gravity flow. The water runs over amedium that converts the stream into tiny droplets (thereby increasing the surface area of thewater). The PTA blower forces air past the water. The VOCs, which prefer to be in air overwater, transfer to the air. The air is then sent to the LFG flare for combustion. The treated waterends up in the junction box, which then distributes the water for irrigation of the park complex.It is either sent to the South Detention Basin for infiltration or the lake to be used as irrigationwater, depending on the lake level. Figure 4-2 shows the steps of the treatment plant process.

Some design changes did occur. These included changes during the bidding period andduring construction. During the bidding period, changes were minor, including alternativelining for piping, additional valves or other ancillary equipment, and concrete-encasedburied steel piping in the groundwater treatment plant yard. The changes made duringconstruction that required engineering analysis are described below.

Change Order 1 – Electrical modifications associated with the addition of twogroundwater extraction wells.

Change Order 2 – Modification to the instrumentation control loop tying together thegroundwater treatment plant and the flare station operation.

Change Order 3 – Modifications to the structural supports for the equipment yardcanopy.

Change Order 4 – Installation of intrinsic safety barriers for instruments location in theextraction well vaults.



Change Order 5 – Revised electrical control schematics for the sump pump operation.

Change Order 6 – Installation of a chemical feed system to provide hypochlorite to theinfluent to the PTA (CDM 2001a).

The Phase 1 groundwater remediation activities are currently ongoing. In early 2006, aPhase 1 evaluation report will be completed which will assess the effectiveness of thePhase 1 groundwater remedial action relative to the objectives of each phase of groundwaterremediation (including Phases 2 and 3). Based on the results of the evaluation, a decisionwill be made either to proceed to Phase 2 or to refine and continue with Phase 1 remedialactions.

At the time of the remedial action completion report, three private agriculture wells (I-3, I-4,and I-5) located to the west still required decommissioning. A well decommissioning reportwas released by the City in June 2005. Beginning in October of 2004, the City begandecommissioning the wells. This included pulling the well pumps and performing down-hole video and geophysical logging. The well casing for I-3, I-4, and I-5 were perforated andI-4 and I-5 were grouted. The agricultural well decommissioning was completed in April2005. A technical report documenting the decommissioning was submitted in April 2005(City of Fresno 2005).

The main institutional controls identified include prohibiting the use of nearby wells andpreventing the installation of new wells in the area to ensure that their hydrologic effect willnot adversely impact the goal of containing the contaminant plume during operations. TheCity has worked with neighbors to decommission the agricultural wells. Figure 4-3 showsthe locations of the decommissioned agricultural wells and their replacements. (CDM2003a). Institutional control activities are discussed in more detail in Section 4.1.3.

Reporting DeliverablesPer the 1998 Consent Decree, the remedial action/design report for each phase, a constructioncompletion report for the entire site, evaluations of each phase, and yearly status reports arethe required deliverables for OU-2. An SOW for OU-2 was included as an attachment to the1998 Consent Decree. It included specific reporting requirements for design planning, design,evaluation, construction, and O&M of OU-2. The City of Fresno hired CDM to help meet thesereporting requirements and oversee OU-2. OU-2 is currently in Phase 1.

4.1.3 Institutional ControlsInstitutional controls are non-engineering methods by which access to contaminatedenvironmental media is restricted. In order to comply with the requirements relating toinstitutional controls, as outlined in the 1996 Final ROD, the City of Fresno prepared theFinal Fresno Sanitary Landfill Technical Memorandum – institutional controls (CDM 2003c)outlining the proposed approach to implementation. The institutional controls anticipatedfor FSL in the ROD were restriction of installation of water supply wells in the impactedaquifer and limiting site access. In addition, controls on the use of the groundwater pumpedfrom existing wells in the contaminated aquifer were to be considered. The ROD states thatimplementation of these controls can be enforced by the county governmental agency or byzoning and deed restrictions.



According to the technical memorandum, two capture zones were identified on theperimeter of the site where well usage could cause adverse impacts on the treatment systemand have the potential for exposing well users to constituents. The delineated zonespresented in the 2003 memo applied only for Phase 1 operation of the FSL groundwaterremediation system. The memo stated that “the presented evaluation of institutionalcontrols no longer applied if the remediation system were expanded to include Phase 2extraction wells.”

A well’s impact on the remediation system was defined as a function of its pumping rate,completion depth, and location. Therefore, the City determined that new water supply wellinstallation should be restricted in these areas, and existing wells should be evaluated forimpact on the treatment system.

The City of Fresno’s approach for implementing the institutional controls addressed wellconstruction and water supply well use in the vicinity of the FSL. The City selectedrestrictions or denial of well permits and evaluation of existing production wells by theFresno County Health Services Agency (the enforcing agency) in the two identified capturezones on the perimeter of the FSL. The prescribed restrictions or denial and evaluation ofexisting wells were selected based on the results of technical studies using Phase 1 data fromthe pump-and-treat system.

The first zone, referred to as the Well Prohibition Zone, includes the landfill footprint andthe areal extent of the offsite VOC plume that exceeds USEPA action levels. The Citydetermined that any wells located in this area have a significant likelihood for exposingwells users to constituents and for compromising the effectiveness of the remediationsystem. Therefore, the City proposed no new water supply wells be allowed in this zone. Atthe time the institutional controls technical memorandum was issued, existing wells locatedin this zone had either been decommissioned or were in the process of beingdecommissioned.

The second zone is referred to as the Well Assessment Zone. It delineates an area wherewells could have an adverse effect on the groundwater plume and remediation system. Theinstitutional controls would require that all well permit applications for new or modifiedwells located in this zone be evaluated for potential impacts on the plume and theremediation system prior to approval of the well permit. The well evaluation would resultin the approval of the well permit or would offer conditions for approval that would revisethe well location, completion depth, or pumping rate.

The evaluation process for existing water supply wells presented in the 2003 memo calls forthe identification and evaluation of existing wells within the Well Assessment Zone. Thepurpose of the evaluation is to identify if the potential exists for their operation to adverselyimpact the groundwater treatment system. Evaluation of the well impacts will be performedthrough modeling. Consistent with the present well decommissioning program, wellpermits could be rescinded and the wells could be decommissioned and replaced with wellsthat would not result in adverse impacts.

The technical memorandum also recommended that the following institutional controls beimplemented to further restrict access:



Install perimeter fencing around the landfill footprint with signs indicating that the siteis a closed solid waste disposal facility.

Attach a deed notification to the 145-acre landfill parcel. Restrictions on the deed shouldinclude prohibitions on excavations and construction.

As part of this Five-Year Review, a determination of the status of the institutional controlswas made. An outstanding issue remains relating to the institutional controls:

No deed notification with restrictive covenants has been attached to the landfill parcel title.The USEPA recommends that an Explanation of Significant Difference (ESD) be created thatwill instruct the City to execute and record a restrictive covenant for the property thatwould bind current and future owners and restrict certain uses of the site itself, includingresidential use, and prohibit use of the groundwater underneath the site.

4.2 Operation and Maintenance

4.2.1 OU-1The three aspects of O&M for OU-1 are landfill closure inspection and maintenance, LFGcollection and treatment system operations, and the Compliance Testing Program.

The final O&M plan includes details about inspecting, maintaining, and operating thelandfill final cover systems, the LFG collection and treatment, and surface watermanagement. The O&M manuals for LFG control systems are in a separate volume. TheO&M for the irrigation system were not submitted as of June 2003 and were not requireduntil the 2-year landscaping establishment period. This would have been due in late 2003.These documents were not available for review.

The final O&M plan was developed according to the SOW included in the Consent Decree.The landfill control systems that are to receive post-closure care and frequency of this careare included in Table 4-2.

TABLE 4-2OU-1 Operations and Maintenance ActivitiesFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

System Sub-system Activity Type Frequency

Final LandfillCover

Vegetation Visual inspection for bare spots andpoorly performing vegetation. Re-seedand mulch as necessary. See Section02970 of Specifications.

Visual inspection for unwanted deeprooted plants, weeds or saplings.Remove as necessary.

Trimming/mowing of vegetation duringfall and spring (or as necessary).

Semi-annually

Semi-annually

Semi-annually





Topsoil Visual inspection for erosion or surfacecracking. Replace topsoil, reseed andmulch as necessary. See Sections02970 and 02930 of Specifications.Monitor areas with significant erosion orlarge cracks for additional erosion ormovement of cover materials.

Visual inspection for settlement orsubsidence. Monitor settlement todetermine if repair is required.

Visual inspection for burrowing animals.Remove/trap animals and fill in holes.Use fine sand to fill holes. Mark andmonitor holes for settling of sand.

Semi-annually

Semi-annually

Quarterly

Fence Visual inspection of entire perimeter forbreaches or damage. Repair or replacefence sections as necessary

Visual inspection of entire perimeter forunder fence erosion. Repair erosion orextend fence as necessary.

Semi-annually

Semi-annually

Gates Check for tampering/damage to locks.Repair or replace as necessary.

Check for proper gate lock function.Repair or replace as necessary.

Semi-annually

Semi-annually

Site SecurityFence

Warning Signs Check for presence of warning signs.Repair or replace as necessary

Check for damage to warning signs.Repair or replace as necessary.

Semi-annually

Semi-annually

Sideslopes Visual inspection for erosion damage orcleaning. Repair erosion damage(replace topsoil, reseed and mulch perAppendix A). Maintain slopes (removeexcess soil, weeds, etc.) as necessary.

Semi-annually or after100-year rainfall event

Culverts/LetdownStructures

Visual inspection for erosion damage orcleaning. Repair erosion damage(maintain riprap aprons). Maintainletdown structures (remove weeds andother debris or clogging materials) asnecessary.


Surface WaterManagementSystem

Riprap Visual inspection for erosion damage orcleaning. Replace or clean out riprap asnecessary.






Cover Swales Visual inspection for erosion damage orcleaning. Repair erosion damage(replace riprap, separator geotextile,etc.). Maintain drainage ways (removeexcess soil, weeds, etc.) as necessary.


Perimeter drainageditch

Visual inspection for erosion damage orcleaning. Repair erosion damage(replace riprap, ditch liner, etc.).Maintain drainage ways (remove excesssoil, weeds, etc.) as necessary.


Detention basins Visual inspection for erosion damage orcleaning. Repair erosion damage(replace or clean out riprap and reseedand mulch per Appendix A). Removesediment from basin bottom andstockpile in appropriate areas. Maintainembankment (remove weeds) asnecessary.


Gas Extractionwells

Visual inspection for damage. Monitorfor gas constituents, flow rate, wellpressure and adjust as necessary.

Weekly

Gas header Visual inspection for damage and lowspot formation.

Monthly

Condensateheader

Visual inspection for damage, low spotformation and wet areas indicating abreak in the condensate force mainpiping.

Monthly

Condensatesumps

Visual inspection for damage. Adjust airpressure as necessary. Check liquidlevels to ensure the pump is operating.

Monthly

Blower Check for proper lubrication, v-belttension, inlet and outlet valveadjustments, and operating amperage.

Weekly

Flare Station Check for proper flare temperature,automatic control sequences foroperation, system shutdowns, propanelevels, chart recorder paper/pens, andair compressor operation.

Weekly

Gas Control,Treatment andMonitoringSystems

Monitoring Wells Sampling for presence of landfill gas.

Sounding and/or visual inspection forpresence of leachate in well.

Quarterly

Quarterly

Seep Monitoringand CollectionSystem

Discolored Liquid Visual inspection of the aerial extentand location of all seeps. Record thestatus of the seep (continual flow,relatively dry, etc.) and photograph.

Collect liquid samples from the leachate

Quarterly

As necessary





seeps, for laboratory analysis.

Ponding Visual inspection for water ponding;repair as necessary.

Semi-annually

Vegetation Visual inspection for vegetative growth;removal as necessary.

Semi-annually

Access Roads

Aggregate Visual inspection for erosion, ruts orwashed-out areas; addition of newaggregate to fill as necessary.

Semi-annually

Sprinklers Visual inspection for damage ormalfunction; repair as necessary.

Bi-monthly

Pumps Visual inspection for damage ormalfunction; repair as necessary.

Bi-monthly

SatelliteControllers

Visual inspection for damage ormalfunction; repair as necessary.

Monthly

Irrigation System

Central Control System test and diagnostic; repair asnecessary.

Quarterly

Source: Kleinfelder/GeoSyntec 2003b.

During the site inspection, a potential issue was identified. The lids on the soil-gasmonitoring wells are about 200 pounds each. These are too heavy to be lifted by one personand are left open. As a replacement for the existing heavy lids, the City has chosen to place aplywood lid with a hinged opening on each of the monitoring well vaults.

The compliance testing plan adequately outlines requirements for compliance testing basedon San Joaquin Valley Air Pollution Control District (SJVAPCD) Rule 4642. However, thePTA should be considered in the final compliance testing plan, especially as it is acontributor to the mass inlet emission rate of VOCs (GeoSyntec 2002, 2003).

4.2.2 OU-2The four primary components of the groundwater remediation system are the groundwaterextraction and monitoring, groundwater treatment (PTA), chemical addition (an anti-scalentbuildup prevention precipitates and sodium hypochlorite for bacterial growth preventionwithin the PTA), and off-gas treatment (LFG flare station). Operation and maintenance isnecessary to ensure all the components are functioning properly.

There are currently five extraction wells located on the western side of the landfill tointercept the VOC-contaminated groundwater as it flows in the westerly direction. Theseare the perimeter extraction wells that pump from both the A- and B-Aquifers. The wellpumps have a hands-off remote switch for remote operation, as well as local and centralalarms. There are numerous monitoring wells located around the site to measure the extentof movement of the downgradient edge of the VOC plume, the groundwater gradient, and



the extent that the groundwater is being intercepted at the landfill boundary. There isquarterly monitoring of a select number of these wells (CDM 2003d).

The PTA blower is operated automatically from the control system. The air-to-water ratio ismaintained by the photoionization detector algorithm. Alarms enable automatic completetreatment plant shutdown for numerous unsafe conditions, such as low water level in a PTAreservoir.

The chemical system components of the groundwater treatment include chemical storagetanks, metering pumps, piping and valving, and mounted electrical and instrumentationand control components. The pump speeds are set manually on the local pump speedcontroller.

Quarterly monitoring of the influent and effluent from the treatment plant occurs todetermine if the design treatment goal is reached. The goal is for the treated effluent to haveVOC concentrations below one-half of the MCLs (CDM 2003d).

The off-gas from the top of the PTA is sent to the LFG flare. The condensate is collected in asump and routed back to the PTA for treatment. When the flare is offline, the extractionsystem and treatment system will shut down. If the flare needs to be shut down for 1 to3 days for maintenance, the system can resume without loss of hydraulic control. If thesystem is shut down long term because of low supply of LFG, propane gas can be used tokeep the flare operating. Also, a granular-activated carbon system can be purchased and putonline to treat the off-gas from the groundwater treatment system if the flare is shut downlong term.

Currently, there is an onsite manager of the FSL. A daily printout of O&M activitiesprovides a schedule of activities. Table 4-3 describes the routine O&M activities on OU-2.





Packed TowerAerator

Routine inspection including:

Inspection of packing to determine theextent of fouling.

Removal and clean packing of PTA withchemical acid baths, high-pressurehosing, or combination of bothprocedures, as required.

Every 6 months

Packed TowerAerator Blower

Routine fan maintenance Including:

Check fan wheel for wear and corrosion

Check fan wheel for buildup of materialleading to unbalancing. Clean asrequired.

Check the V-belt drive for properalignment and tension.

Check all setscrews and bolts fortightness.

Fan-bearing Lubrication

Motor-bearing Lubrication

Every 3 months

Every 2 to 4 months

Every 3 months

GroundwaterTreatmentSystem

BlowerSilencer/Muffler

Routine maintenance including:

Check the inlet screens for blockage.

Check the air paths between acousticbaffles for obstructions.

Check the perforated acoustic baffles forclogging.

Clean with cloth dampened in mildcleaning solution not containing any acidor caustic base.

Every 6 months

Hypochloritefeed system

Chemical FeedPump


Tighten leaking fittings.

Check pump oil level using sight glass onthe back side of the gearbox.

Torque lead bolts.

Check motor/pump flexible coupling.

Change gearbox oil.

Wetted end disassembly, inspect, andreplace if needed.

Check pump capacity via calibration run.

Disassemble/inspect motor/pump flexiblecoupling.

Weekly

First 100-200 hours ofoperation

Every 5,000 hours orevery 12 months





Anti-ScalentFeed System

Chemical FeedPump

Routine tune-up Including:

Replace the check valves, diaphragm,and relief valve poppets.

Oil change:

Drain oil in the main housing andreplace. Schedule oil changes tocorrespond with summer and winterseasons to allow for appropriate lubricantgrade.

Every 12 months

Every 6 months

Treatment AreaDrainage Sump


Check the oil level in the seal cavity.

Check the motor lubrication level whenthe pressure relief valve is activated.

Lubrication schedule:

Replace the oil.

Every month

Every 12 months

Sump Pumps

Off-gasCondensate Pump


Check oil level with dip stick. The levelshould be 3/4 –inch below the top of themotor housing.

Lubrication schedule:

Replace the oil.

Every month

Every 12 months

Source: CDM 2003d.

The quarterly progress reports document any issues regarding O&M. The most recent issuesare documented in the first quarter 2005 report. The low-flow conditions have had anegative effect on the flow meters in that the flows are too low to be measured. New flowmeters are to be installed within the next six months.

Recently, the City prepared a letter to USEPA requesting modifications to the groundwatermonitoring program including reducing sampling frequency for certain wells. The USEPAresponded by requesting more information to support these changes. In addition, the EPAhas approved the City’s request to use the City’s wastewater analytical laboratory forperforming inorganic analysis of groundwater samples. Also, EPA approved the City’srequest to continue groundwater treatment program operations while the landfill gas flareis not operating for maintenance purposes. (City of Fresno 2005).

Other current issues were identified during the site inspection and interviews. The throttlevalves on the extraction wells were not optimally designed. The City plans to replace themwith a better design, although they have not specified when this will occur. Higherfrequency of well rehabilitation activities has been necessary lately because the performanceof the extraction wells has decreased. Extraction well rehabilitation activities may becomesemi-annual or annual. The perimeter road also gets muddy during the rainy season;graveling or paving the road could be a good improvement.



An O&M issue in the past includes the unacceptable destruction efficiency on the flares, asidentified during compliance testing. Also, the Supervisory Control and Data Acquisition(SCADA) system had small issues, and the City improved the computer system.

Optimization of O&M has occurred in numerous ways. The computerized O&M scheduleproduces work orders to help ensure efficient and thorough maintenance. The overall costof O&M has been optimized, as the City took over groundwater sampling but retains CampDresser and McKee (CDM) for quality assurance oversight. The City has also developed amore efficient groundwater sampling route in that they have modified the sequence inwhich they sample the wells. The City was granted its request to perform its own analysis ofinorganics and perform a reduced amount of sampling for organics (CDM 2005).

4.2.3 Operations and Maintenance CostsTable 4-4 presents both the ROD-estimated costs and the actual dollars spent for thesystems. The information for Kleinfelder was obtained from Table 8-1 in the Final RAReport (Kleinfelder/GeoSyntec 2003a). During the site inspection, George Slater, ProjectCoordinator for the City of Fresno, provided the City’s annual O&M expenses. All of theannual O&M costs are well below the ROD-projected costs. This is mostly attributed to thefact that a leachate system was not needed due to an insignificant volume of leachate andthe landfill gas condensate is disposed to the sanitary sewer (Kleinfelder/GeoSyntec 2003a).The budget for O&M in 2005-2006 is significantly higher than previous years because theCity is preparing for potential additional costs associated with actions that will be takenaccording to the recommendations from the Phase 1 Evaluation Report. There do not appearto be any unusually high O&M costs.


TABLE 4-4OU-1 and OU-2 Operations and Maintenance CostsFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Annual O&M Cost

UO $$ Capital Cost 99’- ‘00 ‘00 – ‘01 ‘01 – ‘02 ‘02 – ‘03 ‘03 – ‘04 ‘04 – ‘05 ‘05 – ‘06

OU-1(Kleinfelder)

Spent $13,160,000d $212,600a

ROD Estimate $15,569,000d $432,700

% DifferenceBetween RODEstimate andSpent

- 15.5 % - 50.9 %

OU-2 (CDM) Spent $338,708e

ROD Estimate $3,714,000b

(Phase 1)

$6,375,000b

(Phase 2)

$7,948,000b

(Phase 3)

$453,000b

(Phase 1)

$598,000b

(Phase 2)

$624,000b

(Phase 3)

Total (City) Spent $220,400 $188,625 $126,450 $337,600 $551,308 $787,100c O&M:1,075,200c

Phase 2:$660,000c

Estimate

Notes:a Estimated for that year.b Estimates in 1996 dollars.c Budgeted for that year.d Estimates in 2003 dollars.e Total O&M for City minus O&M for OU-1.

north

Feet

0 1000

Regional Park &Sports Complex

Boundary

.evA se

hg

uH

. evA tse

W

North Ave.

Jensen Ave.

.evA skra

M

PW1A

PW2A

PW5A

PW4A

PW3A

SouthDetention

Basin

Treated WaterDischarge

Park Lake

GroundwaterExtraction Well

Raw WaterInfluent

GroundwaterTreatment Plant

Yard

East BasinAgriculturalIrrigation Wells

I-3

I-4

I-5

Source: CDM, 2004.

324131.FR.01_Fig 4-1 Groundwater Remedial Action Components _7/25/05_ez_sfo

FIGURE 4-1GROUNDWATER REMEDIAL ACTION COMPONENTS (OU-2)FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CA

Source: CDM, 2000.

324131.FR.01_Fig 4-2 Groundwater Treatment System Process Flow Diagram _7/26/05_ez_sfo

FIGURE 4-2 GROUNDWATER TREATMENT SYSTEM PROCESS FLOW DIAGRAM FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CA

north

Feet

0 1000

Regional Park &Sports Complex

Boundary

.evA se

hg

uH

. evA tse

W

North Ave.

Jensen Ave.

.evA skra

M

GroundwaterTreatment Plant

AgriculturalIrrigation WellsDecommissioned

ReplacementIrrigation Wells

I-3

I-4

I-5

Source: CDM, 2005.

324131.FR.01_Fig 4-3 Locations of Agricultural Irrigation Wells _7/26/05_ez_sfo

FIGURE 4-3 LOCATIONS OF AGRICULTURAL IRRIGATION WELLSFRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CA


SECTION 5.0

Five-Year Review Findings

The following section discusses findings from the Five-Year Review.

5.1 Five-Year Review ProcessLisa Hanusiak, USEPA Remedial Project Manager (RPM), led the FSL Five-Year Review.CH2M HILL provided technical support to the USEPA. Activities to involve the communityin the Five-Year Review included preparation and distribution of a fact sheet in March 2005.The Five-Year Review consisted of a review of relevant documents (see Appendix A), aregulatory review, a site inspection, and interviews with FSL onsite staff and theirconsultants, former USEPA RPMs, DTSC oversight staff, and the California Regional WaterQuality Control Board (RWQCB) oversight staff.

Following the release of this document, USEPA will produce and distribute a fact sheet tothe community near the site.

5.2 Community Notification and InvolvementUSEPA distributed a fact sheet in March 2005 and placed a notice in the paper announcingthe start of the Five-Year Review. The fact sheet outlined the process associated withconducting a Five-Year Review and invited community involvement.

Copies of the fact sheet and newspaper ad are included in an Appendix B. A second factsheet explaining the conclusions of the review and announcing the availability of the Five-Year Review Report and how to access a copy will be issued following the release of thisdocument.

5.3 Documents ReviewAs a part of the Five-Year Review process, CH2M HILL conducted a brief review ofnumerous documents related to site activities. The documents chosen for review ranged inpublication date from 1991 to 2005. Appendix A provides a list of the documents reviewedas part of this report.

5.4 Data ReviewedThe following sections describe the periodic reporting and/or monitoring at the treatmentfacility for the FSL.

SECTION 5.0: FIVE-YEAR REVIEW FINDINGS


5.4.1 GroundwaterThe City of Fresno is responsible for submitting semi-annual reports to USEPA that estimatethe lateral and vertical capture of VOC-impacted groundwater along the downgradientedge of the FSL, assess the VOC concentration trends at the monitoring wells influenced bygroundwater extraction, and verify that treatment goals are being met prior to surfacedischarge. The reports also document the operational summary of the extraction wellpumping rates, depth to groundwater in the extraction wells, groundwater treatment plantinfluent flow rates, PTA differential pressure, PTA blower flow rates, and off-gas dischargepressure.

Groundwater level measurements are collected quarterly in all wells. Groundwatersampling and analysis is performed on a mixed quarterly, semi-annual, and annual basis.These efforts have been conducted since 1993. From 1992 to 1993, the remedial investigationincluded quarterly groundwater levels and sample analysis of all available site wells. Theearly groundwater remediation action started in May 1999. This consisted of full-timeoperation of extraction wells PW-1A, PW-2A, and PW-3A. PW-4A was brought online inFebruary 2000. In September 2001, the Phase 1 groundwater extraction and treatment at theFSL began, and the monitoring expanded to follow the performance monitoring programplan. In May 2002, PW-5A was brought on-line (CDM 2005a).

The performance monitoring program plan for OU-2 provides a detailed description of theplan. Table 2-1 of that report (shown as Table 5-1 below) describes the sampling schedulefor the wells during Early Action monitoring and Phase 1 monitoring, as well as adescription of the purpose for the specific sampling.

TABLE 5-1Groundwater Monitoring for OU-2 (as Required by the 2000 Performance Monitoring Program Plan)First Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Early ActionMonitoring Phase I Monitoring Phase I Sampling Purpose

Well IDWaterLevels

WaterQuality

WaterLevels

WaterQuality

SourceControl

PlumeMigration

TI WaiverEvaluation

Monitoring Wells

CDM-1A/B/C Q A Q A X

CDM-2A/B/C Q A Q A X

CDM-3A/B Q S Q S X X

CDM-4A/B Q Q Q Q X X X

CDM-4C Q S Q S X X


CDM-5C Q S Q S X X

CDM-6A Q S Q S X X

CDM-7A/C Q Q X


CDM-8C Q Q Q S X X





Well IDWaterLevels

WaterQuality

WaterLevels

WaterQuality

SourceControl

PlumeMigration

TI WaiverEvaluation

CDM-12A Q Q Q A X

CDM-12B Q Q Q S X X X

CDM-13A Q Q Q A X

CDM-13B Q Q Q S X X X

CDM-13C Q Q Q S X X

CDM-15AB Q Q Q Q X X X

CDM-15C Q S Q S X

CDM-16A/B/C Q Q Q S X

CDM-17AB/C Q Q Q S X

CDM-18A/B/C Q Q Q S X

DW-1A Q Q X

DW-1 B/C Q S Q S X X X

DW-2A Q Q X

DW-2B/C Q S Q S X X X

MW-1 Q S Q S X X X

PZ-3B Q Q X

MW-2 Q A Q A X

PZ-4B Q S Q S X X X

PZ-4C Q 0 Q A X

MW-3 Q Q X

MW-4 Q S Q S X

PZ-1A Q Q X

PZ-2A/B Q Q Q Q X X X

PZ-5A Q A Q A X

PZ-5B Q S Q S X X X

PZ-5C Q Q Q A X X

UW-1A/B/C Q A Q A X

UW-2A/B/C Q Q X

W-1 R Q A Q A X

W-2/W-3 Q Q X

W-4 Q S Q S X





Well IDWaterLevels

WaterQuality

WaterLevels

WaterQuality

SourceControl

PlumeMigration

TI WaiverEvaluation

W-5 Q S Q S X

W-6 Q Q Q Q X X

Residential Wells

1770 North Ave A A

2045 North Ave S S

2429 North Ave S S

1304 Jensen Ave A A

1346 Jensen Ave A A

1642 Jensen Ave A A

1650 Jensen Ave S A

1912 Jensen Ave A A

2121 Jensen Ave A A

GroundwaterExtraction Wells

Residential Wells

Notes:

A Annual sampling

S Semi-annual sampling

Q Quarterly Sampling

Source: CDM 2000.

This monitoring program has been approved by USEPA and revised in recent years.Table 3-2 in the Fall 2004 Semi-Annual Performance Monitoring Program Report (CDM 2005a)provides a description of the current monitoring. This is included below as Table 5-2. In2004, sampling of six wells, all in the A-Aquifer, was not possible because insufficient waterin the well casing made it impossible to sample with the bladder pump or a bailer. The Cityperformed well rehabilitation activities, including a downhole video log, brushing the wellscreen with a wire brush to remove biological growth, and swabbing. Information about theflow since the well rehabilitation activities was not available at the time of this report.

Quarterly water level measurements are currently taken from the five extraction wells,31 A-Aquifer monitoring wells, 27 B-Aquifer monitoring wells, and 13 C-Aquifermonitoring wells. VOC analysis and inorganic analysis are conducted on numerous A, B,and C wells, including the extraction wells and nine residential wells. Figure 5-1 shows allthe locations of the monitoring and extraction wells.



TABLE 5-2Fall 2004 Groundwater MonitoringFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Groundwater Sampling

Well July 2004October

2004January

2005 April 2005

Water LevelMeasurements

Quarterly

A-Aquifer Extraction Wells

PW-1A V/I X

PW-2A VA X

PW-3A V/I X

PW-4A V/I X

PW-5A V/I V/I V/I V/I X

A-Aquifer Monitoring Wells

CDM1A V/1 X

CDM2A V/I X

CDM3A V V/I X

CDM4A V V V VA X

CDMSA V V/I V VA X

CDM6A V/I VA X

CDM7A V/I X

CDMSA V V/I V VA X

CDM12A V V/I V V/1 X

CDM13A V V V V/I X

CDM15A V V V VA X

CDM16A V/I VA V/I V/I X

CDM17A VII V/I V/I V/I X

CDM18A V/I VA V/I VA X

DW1A X

DW2A X

MW1 NS VA X

MW2 V/I X

MW3 X

MW4 NS VA X

PZ1A X

PZ2A NS NS V V/I X

PZSA VA X

UW1A VII X

UW2A X

W1R V/I X

W2 X






2004January

2005 April 2005


Quarterly

W3 X

W4 NS V/I X

W5 NS V/I X

W6 V NS V VA X

Aquifer Monitoring Wells

CDM1 B VII X

CDM2B V/1 X

CDM3B V VA X

CDM4B V VA V VA X

CDM5B V VA V VA X

CDMBB V VA V VA X

CDM12B V V V V/I X

CDM13B V VA V VA X

CDM13B2 V/I V/I V/I V/I X

CDM15B V V V V/I X

CDM15B2 V/I V/I V/I V/I X

CDM16B V/I V/I V/I V/I X

CDM17B V/I V/I V/I VII X

CDM18B V/I V/I V/I V/I X

DW1B V V/I X

DW1C V/I V/1 X

DW2B V V/I X

DW2C V/1 x

PZ2B V V V V/I X

PZ3B X

PZ4B V V/I X

PZ513 V/1 VII X

PZ5132 V/I V/I V/I V/I X

UW1B V/1 x

UW1C V/I X

UW2B X

UW2C X






2004January

2005 April 2005


Quarterly

C-Aquifer Monitoring Wells

CDM1C V/I X

CDMSC V/1 X

CDM4C V V/I X

CDMSC V V/I X

CDM7C VII X

CDMSC V/I V/I V/I V/I X

CDM13C V V V/I X

CDM15C V/I V/I X

CDM16C V/1 V/I V/I V/I X

CDM17C V/I V/ V/I V/I X

CDM18C V/I V/I V/I V/I X

PZ4C V/I V/1 X

PZ5C V/I VII V/I V/I X

Residential Wells

1770 North Avenue V/1

2045 North Avenue V/I V/1

2429 North Avenue V/I V/1

1304 Jensen Avenue V/I




1912 Jensen Avenue VII

2121 Jensen Avenue V/1

Notes:

V = Well to be sampled for VOCs only.

V/I = Well to be sampled for VOCs and inorganic constituents.

NS = Well not sampled.

Source: CDM 2005a.



approximately 50 to 95 feet bgs, the B-Aquifer from approximately 110 to 150 feet bgs, andthe C-Aquifer from approximately 200 to 240 feet bgs.

Groundwater elevation has been decreasing in the FSL area since 2001. The elevation wasdecreasing until about 1993 and then began increasing until 2001 in all wells. Since 2001, thewater has decreased 10 feet, back to 1993 water levels (around 200 feet) (CDM 2005b). This isconsistent with a continuing decline in the regional water table.

The groundwater contours from April 2000 and June 2004 are shown on Figures 5-2a, 5-2b,5-3a, 5-3b, 5-4a, and 5-4b. The decrease in groundwater from 2000 to 2004 is evident in thesecontours, as is the southwest groundwater flow direction.

Groundwater elevation across the site currently ranges from approximately 199.5 feet abovemean sea level in the northeast to approximately 195 feet above mean sea level in thesouthwest of the landfill. Measurements from April (wet season) are about 0.5 foot higherthan in November (dry season). Cones of depression form around the five groundwaterextraction wells to the west of the landfill. Because the groundwater elevation hasdecreased, it is not possible to obtain water levels from numerous A-Aquifer wells.Groundwater flow is predominantly to the west. West of the landfill, the groundwater flowspredominantly to the south.

In the B-Aquifer, groundwater elevations are also decreasing. The groundwater flows are tothe southwest, similar to those in the A-Aquifer. The extraction wells in the A-Aquiferappear to have an influence on groundwater flow in the B-Aquifer, as shown in thedeflection of contour lines. Groundwater elevation contours in the C-Aquifer are alsodecreasing. Flow is generally to the southwest (CDM 2005a).

5.4.1.2 A-AquiferThe five extraction wells operate in this shallow aquifer. There are 31 A-Aquifer monitoringwells that are currently sampled and analyzed for VOCs and/or inorganics. Concentrationsof VOCs are highest in the A-Aquifer as compared to B- and C-Aquifers. Constituentsdetected above MCLs in the A-Aquifer include PCE, TCE, vinyl chloride, and cis-1,2-DCE.Other VOCs that were detected but are below MCLs include 1,1-DCA, 1,1-DCE, 1,2-DCB,1,2-DCA,1,2-dichloropropane,1,4-DCB, benzene, chlorobenzene, dichlorodifluoromethane,and trans-1,2-DCE.

TCE, PCE, Vinyl Chloride, and cis-1,2-DCE. Table 5-3 shows the maximum concentrations ofTCE, PCE, vinyl chloride, and cis-1,2-DCE each year with available data. These are analyzedbecause they are above the MCL in numerous wells. Interestingly, the concentrationsgenerally increased from 1995 to 1999. In 1999, Early Action began. The 2004 data showsthat the maximum concentrations for all constituents have decreased below their 1999maximum concentrations. PZ-5A is located in the southwestern corner of the landfillrecorded numerous maximum concentrations. This well is located in the plumedowngradient of the landfill and was installed in 1998. CDM-12A is located just northwestof PZ-5A. CDM-15A, which recorded the maximum cis-1,2-DCE concentration in 2003, isactually located in the northwest corner.



TABLE 5-3A-Aquifer Maximum Groundwater Concentrations of PCE, TCE, Vinyl Chloride, and cis-1,2-DCEFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

YearPCE

(µg/L)TCE

(µg/L)Vinyl Chloride

(µg/L)cis-1,2-DCE

(µg/L)

1995 58 (MW-1) 32 (MW-1) 21 (W-5) 120 (MW-1)

1996 49 (MW-1) 37 (MW-4) 180 (MW-4) 240 (MW-4)

1997 28 (MW-4) 39 (MW-4) 170 (MW-4) 210 (MW-4)

1998 29 (MW-1) 42 (MW-4) 130 (MW-4) 140 (MW-4)

1999 57 (PZ-5A) 100 (MW-4) 130 (MW-4) 420 (PZ-5A)

2000 190 (PZ-5A) 99 (PZ-5A) 190 (W-4) 240 (CDM-12A)

2001 130 (PZ-5A) 74 (PZ-5A) 77 (CDM-12A) 250 (CDM-12A)

2002 140 (PZ-5A) 80 (PZ-5A) 61 (CDM-12A) 260 (CDM-12A)

2003 92 (PZ-5A) 64 (PZ-5A) 52 (CDM-12A) 190 (CDM-15A)

2004a 23 (CDM-12A)a 19 (CDM-12A)* 46 (CDM-12A)a 170 (CDM-12A)a

Source: CDM 2005c.* CDM 2005a.

µg/L micrograms per liter

The Fall 2004 Semi-Annual Performance Monitoring Program Report (CDM 2005) includesconcentration trends for PCE, TCE, vinyl chloride, and cis-1,2,-DCE at selected wells. Thegraphs indicate a decreasing or stable concentration trend in most wells for these VOCs,with a few exceptions. PCE shows a slight increase (2 to 3.7 micrograms per liter [µg/L]) inwell CDM-6A but still remains below the MCL in that well. cis,1-2,DCE is increasing inextraction well PW-2A and monitoring wells CDM-12A, MW-1, and CDM-15A.

The constituents plumes for TCE, PCE, and vinyl chloride were compared from April 2000and April 2004 and are included as Figures 5-5a to 5-7b. The TCE plume has shrunk in sizesince 2000. The western boundary of the plume is now closer to the landfill. The PCE plumehas also shrunk closer to the landfill. The southern plume has dramatically decreased from amaximum concentration of 190 µg/L to 1.4 µg/L. The center of the western plume hasslightly increased to 15 µg/L from 2.1 µg/L. The northern section of the plume hasdecreased in concentration from a maximum of 20 µg/L to 9.8 µg/L. The southern section ofthe vinyl chloride plume has decreased from a maximum of 190 µg/L to 39 µg/L. The entiresouthern plume has decreased slightly in size but more so in concentration. The northernpart of the plume has also decreased in concentration from 76 µg/L to 5 µg/L.

There are no plume maps available for cis-1,2-DCE.

Inorganic Constituents: Nitrate and Total Dissolved Solids. Many of the A-Aquifer monitoringwells have concentrations of nitrate and total dissolved solids (TDS) above their respectiveMCLs. Nitrate has recently been found at concentrations of up to 42 milligrams per liter(mg/L) at well CDM-16A. The MCL for nitrate is 10 mg/L. TDS concentrations are as highas 1,166 mg/L at well CDM-12A. The MCL for TDS is 500 mg/L.



5.4.1.3 B-AquiferThe constituents detected at concentrations above the MCL in the B-Aquifer are the same asin the A-Aquifer: PCE, TCE, cis-1,2-DCE, and vinyl chloride. Other VOCs detected belowthe MCL include 1,1-DCA, 1,2-dichoropropane, 1,4-DCB, cis-1,2-DCE,dichlorodifluoromethane, trans-1,2-DCE, and trichlorofluoromethane.

TCE, PCE, Vinyl Chloride, and cis-1,2,-DCE. Table 5-4 presents the maximum concentrationsof TCE, PCE, vinyl chloride, and cis-1,2-DCE each year with available data. Interestingly, theconcentrations generally increased from 1995 to 1999. These constituents follow a similartrend in the B-Aquifer as in the A-Aquifer. The maximum generally increases until1999/2000 and has decreased in recent years. DW-1B is located southwest of landfill. It wasinstalled in 1986. CDM-4B is actually on the western side of the park. CDM-12B is located onthe southwestern area of the landfill just east of the park.

TABLE 5-4B-Aquifer Maximum Groundwater Concentrations of PCE, TCE, Vinyl Chloride, and cis-1,2-DCEFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Year PCE (µg/L) TCE (µg/L) Vinyl Chloride (µg/L) cis-1,2-DCE (µg/L)

1995 39 (DW-1B) 26 (DW-1B) 8.4 (CDM-8B) 33 (DW-1B)

1996 43 (DW-1B) 37 (DW-1B) 10 (CDM-8B) 48 (DW-1B)

1997 62 (DW-1B) 62 (DW-1B) 23 (DW-1B) 100 (DW-1B)

1998 51 (DW-1B) 52 (DW-1B) 18 (DW-1B) 80 (DW-1B)

1999 110 (PZ-5B) 59 (DW-1B) 21 (PZ-5B) 100 (DW-1B)

2000 54 (PZ-5B) 50 (CDM-12B) 23 (CDM-12B) 150 (CDM-12B)

2001 43 (CDM-4B) 29 (CDM-12B) 24 (CDM-12B) 69 (CDM-12B)

2002 55 (CDM-4B) 29 (CDM-4B) 19 (CDM-12B) 66 (CDM-12B)

2003 54 (PZ-5B) 20 (CDM-4B) 12 (CDM-12B) 38 (CDM-12B)

2004* 55 (CDM-4B) 25 (CDM-4B) 7.3 (CDM-13B) 22 (CDM-12B)


VOC concentrations at CDM-4B have been increasing ever since the onset of the EarlyAction groundwater extraction. PCE concentrations have increased from approximately 25µg/L to approximately 50 µg/L in 2004. CDM-5B has had a slight increase since the onset ofthe Early Action groundwater extraction for PCE, cis-1,2-DCE, and TCE, but is stable forvinyl chloride. VOC concentrations at CDM-15B and DW-1B have remained stable since theonset of Early Action. VOC concentrations at CDM-8B remained steady during the onset ofthe Early Action but have been decreasing ever since startup of Phase 1.

Figures 5-8a, 5-8b, 5-9a, and 5-9b show the TCE and PCE plumes from April 2000 andApril 2004 in the B-Aquifer. The TCE and PCE plumes appear to be similar in concentration,size, and shape in April 2000 and April 2004. The vinyl chloride plume appears slightly



closer to the landfill, with slightly lower concentrations in 2004 than in 2000 (Figures 5-10aand 5-10b).

Inorganic Constituents: Nitrate and TDS. Nitrate and TDS concentrations exceed the MCLs inthe B-Aquifer. Concentrations of nitrate in July 2004 were as high as 43.9 mg/L as N in wellCDM-18B. TDS was as high as 1,239 mg/L in October of 2004 in CDM-18B as well.CDM-18B is located next to an active dairy pond (CDM 2005a). Exceedances also occurred atwells CDM-16B and CDM-17B for nitrate, as well as eight others for TDS, but theconcentrations were much lower.

5.4.1.4 C-AquiferPCE is the only constituent that was detected above the MCL in C-Aquifer in 2004. It wasdetected at 6.3 ug/L in CDM-15C and 5.4 µg/L in PZ-5C. The MCL for PCE is 5 µg/L. Thiswas the first exceedance of the MCL for PCE in well PZ-5C. Other VOCs detected below theMCL include cis-1,2-DCE, dichlorodifluoromethane, TCE, and trichlorofluoromethane, all invery low concentrations. No trend graphs were provided for the C-Aquifer in the Fall 2004Semi-Annual Performance Monitoring Report (CDM 2005a).

Table 5-5 shows the maximum concentrations of PCE, TCE, vinyl chloride, and cis-1,2-DCEsince 1995. PCE and TCE have been increasing, with maximums found in the southwestcorner in wells PZ-5C and CDM-13C. Vinyl chloride and cis-1,2-DCE were not detecteduntil 2003 and 2002, respectively.

TABLE 5-5C-Aquifer Maximum Groundwater Concentration of PCE, TCE, Vinyl Chloride, and cis-1,2-DCEFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Year PCE (µg/L) TCE (µg/L)Vinyl Chloride

(µg/L) cis-1,2-DCE (µg/L)

1995 ND ND ND ND

1996 ND ND ND ND

1997 1.3 (CDM-5C) ND ND ND

1998 .6 (CDM-4C) ND ND ND

1999 .89 (CDM-15C) ND ND ND

2000 1.4 (PZ-5C) ND ND ND

2001 4.5 (PZ-5C) 1 (PZ-5C) ND ND

2002 3.5 (PZ-5C) .74 (PZ-5C) ND .58 (CDM-8C)

2003 7.6 (CDM-13C) 4.4 (CDM-13C) 7.8 (CDM-13C) 3.3 (CDM-13C)

2004* 6.3 (CDM-15C) .66 (PZ-5C) ND .58 (CDM-13C)


Plume maps were not created in April 2000 for the C-Aquifer because only three wells weresampled. All VOCs were non-detect for two of the wells, but CDM-4C had concentrations ofdichlorodifluoromethane at 5.9 µg/L (Nyznyk 2005) and PCE at 0.8 µg/L (CDM 2005c). In



April 2004, there was no detection of vinyl chloride in the C-Aquifer in any wells, includingCDM-13C. Figures 5-11, 5-12, and 5-13 show the PCE, TCE, and vinyl chloride plumes forApril 2004. TCE was detected at .72 µg/L and .65 µg/L at two locations directly next to thelandfill. PCE was detected as high as 4.6 µg/L in CDM-15C, whereas it was not detected atall in CDM-15C in April of 2000. In the April of 2004, dichlorodifluormethane was found atwell CDM-4C at 11 µg/L and at a maximum of 22 µg/L in well CDM-8C (CDM 2004).

Inorganic Constituents: Nitrate and TDS. Nitrate and TDS concentrations exceeded the MCLsin three wells in the C-Aquifer. CDM-18C had the highest exceedances of nitrate at19.3 mg/L and TDS (762 mg/L) in July 2004.

5.4.1.5 Vertical GradientThree additional monitoring wells, CDM-13B2, CDM-15B2, and PZ-5B2 were installed deepinto the B-Aquifer in the summer of 2001 to evaluate vertical migration of constituents.Three C-Aquifer wells have seen stable to decreasing concentrations of constituentsregardless of the trends in the A- and B-Aquifers. PZ-5C, PZ-5B, and PZ-5B2 have shownstable to slightly increasing trends in PCE, while the concentration in the PZ-5A aquifer hasdecreased. Table 3-4 of the CDM report (2005a) shows the head differentials at well clusters.In July 2004, a downward gradient of .03 foot existed between PZ-5A and PZ-5B. Adownward gradient of .18 foot existed between PZ-5B and PZ-5C. A downward gradient of.21 foot existed between PZ-5A and PZ-5C.

5.4.1.6 Residential WellsWater quality measurements have been taken for residential areas. Concentrations of PCEhave remained steady and below MCL (5 µg/L) since 1995. Cis-1,2-DCE was measured forthe first time in a well on Jensen Avenue in 2003 at .84 µg/L, just above the detection limit of0.5 µg/L.

TABLE 5-6Residential Wells Maximum Groundwater Concentration of PCE, TCE, Vinyl Chloride, and cis-1,2-DCEFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

ResidentialWells

PCE(µg/L)

TCE(µg/L)

Vinyl Chloride(µg/L)

cis-1,2-DCE(µg/L)

1995 2.3 (North St.) ND ND ND








2003 1.4 (North St.) ND ND 0.84 (Jensen Ave.)




5.4.1.7 Extraction WellsExtraction well PW-4A has been consistently drawing in water with the highestconcentrations of PCE, TCE, vinyl chloride, and cis-1,2-DCE. The concentrations haveremained consistent since pumping began in 1999.

TABLE 5-7Extraction Wells Maximum Groundwater Concentration of PCE, TCE, Vinyl Chloride and cis-1,2-DCEFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Extraction WellsPCE

(µg/L)TCE

(µg/L)Vinyl Chloride

(µg/L)cis-1,2-DCE

(µg/L)

1999 54 (PW-3A) 25 (PW-3A) 10 (PW-2A) 130 (PW-1A)

2000 49 (PW-4A) 47 (PW-4A) 67 (PW-4A) 230 (PW-4A)

2001 46 (PW-4A) 32 (PW-4A) 21 (PW-4A) 120 (PW-4A)

2002 41 (PW-4A) 34 (PW-4A) 16 (PW-4A) 120 (PW-4A)

2003 52 (PW-4A) 39 (PW-4A) 17 (PW-4A) 110 (PW-4A)

Influent/Effluent. The Fall 2004 Semi-Annual Performance Monitoring Report includes a tablethat shows the influent concentrations for two sampling events in 2004. This is included inTable 5-8 below. TCE, PCE, vinyl chloride, and cis-1,2-DCE were present in the influentabove the MCLs. Other VOCs were detected but were under their MCLs. The effluent mustbe treated to the level of non-detect for COCs. No COCs were detected in the effluent. Twotrihalomethanes (THMs), bromoform and dibromochloromethane, were detected in theeffluent at .97 and .63 µg/L, respectively. The THMs were not present in the influent. TheTHMs are formed during the treatment process. Sodium hypochlorite reacts with the rawgroundwater, leaving residual chlorine. The residual chlorine then is oxidized tohypochlorous acid. The hypochlorous acid reacts with organics in the water to form THMs.The drinking water regulations place a limit of 80 µg/L on total THMs. The combination ofbromoform and dibromochloromethane is 1.6 µg/L, well below the drinking-levelregulation (CDM 2005a).

TABLE 5-8Phase 1 Groundwater Treatment Plant Influent and Effluent Concentrations of Select ConstituentsFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Results (µg/L)

Sample 357120/2004

Sample 3611/1/2004

Contaminant of Concern(PQL - µg/L)

TreatmentStandards Influent Effluent Influent Effluent

Trichloroethene (0.5) ND 9.8 — 9.1 —

Tetrachloroethene (0.5) ND 22 — 18 —

Vinyl Chloride (0.5) ND 2.6 — 2.1 —

1,1-dichloroethene (0.5) ND — — — —

1,2-dichloroethane (0.5) ND — — — —



TABLE 5-8Phase 1 Groundwater Treatment Plant Influent and Effluent Concentrations of Select ConstituentsFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Results (µg/L)

Sample 357120/2004

Sample 3611/1/2004

Contaminant of Concern(PQL - µg/L)

TreatmentStandards Influent Effluent Influent Effluent

Trans-1,2-dichloroethene (0.5) ND 1.5 - 1.2 —

CIS-1,2-dichloroethene (0.5) ND 32 - 33 —

1,2-dichloropropane (0.5) ND 0.60 — 0.57 —

1,2-dichlorobenzene (0.5) ND — — — —

1,4-dichlorobenzene (0.5) ND 1.7 — 0.88 —

Benzene (0.5) ND — — — —

Chlorobenzene (0.5) ND — — — —

Chloroform (0.5) ND — — — —

1,1-dichloroethane (0.5) ND 1.7 — 1.9 —

Trichlorofluoromethane (0.5) ND 1.0 — 1.2 —

Toluene (0.5) ND — — — —

Other Constituents

Bromodichloromethane (0.5) NS — — — —

Bromoform (0.5) NS — 0.97 — 1.5

Dibromochloromethane (0.5) NS — 0.63 — —

Dichlorodifluoromethane (0.5) NS 11 — 11 —

Notes:

VOC analysis – USEPA Method 8260B.

PQL = Practical Quantitation Limit.

Treatment Standards are defined in the Clean Water Act, Title 33, Code of Federal Regulations, Parts 301 and 302.

ND = Non-detect.

NS = Not Specified.

— = Compound not detected.

Source: CDM 2005a.

The treatment of the influent groundwater has resulted in the removal of 238 kilograms ofVOCs since 1999. Table 5-9 shows the amount removed each quarter. This includes165 kilograms that were removed during the Early Action system and 72.7 kilograms thathave been removed during Phase 1 treatment thus far.



TABLE 5-9VOC Mass RemovalFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

QuarterPumping

Period (days)

Average VOCConcentrationa

(µg/L)

Average Flow Rate(Meter-Based)

(gpd)VOC Removal

(kg)

Phase 1 GTP

4th Quarter 2001 107 77.4 302,540b 9.5

1st Quarter 2002 90 136.5 124,792b 5.8

2nd Quarter 2002 91 89.5 113,745 b 3.5

3rd Quarter 2002 92 72.1 101,922 b 2.6

4th Quarter 2002 92 80 d 74,339c 2.1

1st Quarter 2003 90 87.9 236,117 c 7.1

2nd Quarter 2003 91 65.4 272,744 c 6.1

3rd Quarter 2003 90 86.7 205,618 c 6.1

4th Quarter 2003 91 97.5 214,121c 7.2

1st Quarter 2004 91 79.9 249,846 c 6.9

2nd Quarter 2004 91 73.3 182,967 c 4.6

3rd Quarter 2004 92 83.9 184,680 c 5.4

4th Quarter 2004 92 79 212,451 c 5.8

Subtotal 72.7

Early Action System

May 1999 -Sept. 2001 165

Total 237.7

Notes:a Non-detects assumed to be at a concentration of zero for the purpose of estimating the total VOC concentration.b Average based on the total PTA influent flow divided by the number of days in the quarter.c Average based on the sum of the flows from the individual extraction wells divided by the number of days in thequarter.

d Influent and effluent samples were not collected 4 th Quarter 2002. The VOC concentration represents an average ofthe VOC concentration in 3rd Quarter 2002 and 1st Quarter 2003.

Source: CDM 2005a.

5.4.1.8 Emerging Constituents of ConcernEmerging constituents include unknown constituents at the time of the ROD, constituentsfor which a MCL is not established, or constituents for which the treatment system cannotremediate as currently constructed.

The emerging COCs for FSL are 1,4-dioxane, 1,2,3-trichloropropane, perchlorate, cyanide,and N-nitrosodimethylamine. The City collected treatment plant influent and effluent andtested the samples for all five of these COCs in the April/May 2005 monitoring round. The



results of the emerging COC analysis were presented in the Spring 2005 Semi-annualPerformance Monitoring Program Report, dated July 29, 2005. The COCs were non-detect in allsamples collected from the influent and effluent of the groundwater treatment plant(CDM 2005d).

5.4.2 AirThe Consent Decree specified testing and limits for some aspects of air quality at the FSL.Areas of interest were the LFG surface emissions, the landfill perimeter probe gases, and theLFG flare emissions. The compliance testing activities, submitted in the First ComplianceTesting Report (Kleinfelder 2004) were conducted according to the Final Testing Plan(GeoSyntec 2003).

5.4.2.1 Landfill Surface EmissionsThe regulatory instantaneous threshold limit for landfill surface emissions is set at1,000 ppmv above the background levels as described in the Consent Decree. The surface isto be monitored quarterly. Quarterly measurements were not available for this review butmeasurements for the compliance testing report were reviewed. Kleinfelder monitored thelandfill surface for VOCs on March 17 and 18, 2004 with a Foxboro model OVA108TM

portable organic vapor analyzer. Measurements were recorded approximately every 120 feetfrom the north to the south of the landfill. This resulted in 14 north south traverses(approximately 90 feet apart) with 33 to 36 measurements at each traverse. The VOCconcentrations ranged from 3 to 14 ppmv, well under the 1,000 ppmv threshold limit.

5.4.2.2 Landfill Gas MonitoringThe FSL has clusters of monitoring probes that were required under CCR Title 27 to assessthe potential subsurface migration of landfill gases from the disposal area. The probeclusters at the FSL consist of three separate gas monitoring probes that extend to depths of5, 25, and 45 feet below grade. The three gas monitoring probes have color-coded PVCcasings that are contained in one larger casing. The probes are analyzed for methane, carbondioxide, oxygen, and balance (nitrogen) using a GES Landtec Model GEM 2000 portablelandfill gas monitoring device. For compliance testing, measurements were taken at13 probe clusters along the perimeter of the landfill on April 19 and 20, 2004. The firstcompliance testing report indicates that some of the monitoring wells needed maintenance.Many of the caps were missing from the ends of the LFG monitoring probe sampling tubingand should be replaced. Debris and/or water were inside the tubing at two landfill locations(MMW4 at depths of 5 feet, 25 feet, and 45 feet and MMW3 at 5 feet), shown on Figure 5-14.Two of the vault lids were partially buried by surface soil (GMW-1 and GMW-3). Thelocation of CMW-7 did not correspond with its location on the map.

CCR Title 2720921 allows 5 percent methane by volume at the facility property line.Methane was detected in three of the 13 clusters. In the 45-foot deep probes, methane wasdetected at 1.5 percent (probe MMW2) and.7 percent (probe MMW3), well below therequirement. Methane was detected at probe MMW5 below the 5 percent limit at the 5-footand 45-foot depths. Methane was recorded above the limit at MMW5 at the 25-foot depth at13.4 percent by volume. MMW5 is located close to the waste and not near the property line.Kleinfelder recommends that the monitoring probe location be re-measured to provideongoing methane levels in that area. If the levels do not decrease, the City may need to



install an additional well between MMW5 and the property line along Jensen Avenue.Carbon dioxide was detected at a range of 0 to 18 percent. Neither typical ranges nor limitsfor carbon dioxide are presented in the report, but Kleinfelder states that the levels areconsistent with the methane detected. Oxygen was detected ranging from 7.6 percent to21.3 percent at the monitoring probes. Acceptable or optimal concentrations were notpresented in the report.

5.4.2.3 Landfill Gas TreatmentThe performance standards for the LFG flare identified in the 1993 ROD are twofold. Thefirst standard is that the remedy must meet the reactive organic destruction efficiencyrequirements of the SJVUAPCD Rule 4642. This rule states that the flare must achieve aVOC destruction efficiency of 98 percent by weight, or the VOC concentration must beunder 20 ppmv (measured as methane) corrected to 3 percent oxygen. The second standardis that the emissions shall not exceed a level, as determined by the USEPA, which wouldcause a 10-6 excess cancer risk as determined pursuant to the California Air PollutionControl Officers’ Association Air Toxics “Hot spots” Program Risk Assessment Guidelines,January 1991.

Three sampling events were conducted in February 2004. Field measurements of the intakeair ranged from 20.4 percent to 36.5 percent methane concentrations, and the dischargegases ranged from 0.0 percent to 0.01 percent methane. The LFG flare did not achieve98 percent destruction efficiency for VOCs. The concentration of VOCs was 20.2 ppmv, justabove the 20 ppmv requirement. The effluent gas temperature was apparently 1,363 °F,which has reportedly been increased to approximately 1,450 °F since the testing. Thesampling location was also identified as a potential cause for the non-compliance. Theoxygen content apparently is increased with the current location at the sampling portslocated between the collection system blowers and the flare. Kleinfelder recommendsmoving it to just upstream of the lower system for the second round of compliance. Also, nosamples were collected from the PTA exhaust air. This is the second source of VOCs and,while it is a much lower concentration than the LFG itself, the destruction efficiency iscalculated lower than reality. Therefore, Kleinfelder recommends that they test the influentstream from the PTA for VOCs and add that into the calculation for destruction efficiency(Kleinfelder 2004). The second round of testing was performed in April 2005. Whileconducting the second compliance test, samples of the effluent air emissions at the PTAwere collected to determine the concentration of VOCs in the exhaust air from thegroundwater treatment packed tower aerator (PTA). The laboratory analytical results fromthese samples will be included in the 2nd Compliance Testing Report and will be used toverify that this potential source emits very low VOC concentrations. At the time of this Five-Year Review, the second compliance testing report was still in preparation by Kleinfelderand therefore results were not available for review. A recommendation will be made toevaluate the performance of the flare in a follow-up to the Five-Year Review.

The City has requested that the groundwater treatment plant remain online while the flareis taken offline for routine maintenance. The flare normally receives influent air from thePTA and the LFG. It is required to meet 98 percent destruction efficiency. USEPAconditionally approved the City’s request in a letter to the project coordinator for the City ofFresno, dated April 7, 2005. The conditions that the City must examine include compliancewith local air discharge limits and sustained compliance with air discharge. The two criteria



to be met, according to the SJVAPCD, are that the flare must emit less than 2 pounds perday of any of the five criteria pollutants and must not be a hazardous air pollutant emissionssource that will cause a significant health risk. If the PTA does not meet these requirements,it would need to meet substantive air permit requirements. The community must benotified, and clarification of the proposed 14-day downtime and operating procedure thatthe flare will be manually disconnected and reconnected to the PTA must be documented.

The potential need for dioxin testing of the flare has been an issue raised in the past. De novodioxin formation is a potential concern under certain operating conditions. These conditionsare related to incinerator design and gas residence time in the temperature window favoringdioxin formation. This issue is addressed in Section 7.0 and recommendations are provided.

5.4.3 StormwaterThe City of Fresno submits an annual report to the RWQCB every year by July 1. This isrequired by the Regional Board Industrial Storm Water Permit. For this Five-Year Review,annual stormwater reports from 1999 to 2004 were reviewed.

The City is required to collect and analyze samples from two storm events in accordancewith sections B.12 or 15 of the General Permit. In 2003 and 2004, the City met thisrequirement. The samples were collected from the three stormwater discharge locations: thewest side, the south side, and the east side during the first hour of discharge after at leastthree working days without a stormwater discharge. In 2002 and 2003, the City collectedsamples from only one storm but did not state the reason. In 2000, 2001 and 2002, the Citydid not collect any samples during a storm because the site was under closure constructionas required by the USEPA and there was reportedly no runoff. In 1999 and 2000, the Citycollected one sample from one discharge location. An exception form was filled outindicating that significant stormwater discharges occurred at times other than scheduledfacility operating hours or within 2 hours, following scheduled operating hours, hence onlyone storm event was captured.

Visual observations were made of all drainage areas to detect the presence of unauthorizednon-stormwater discharges and their sources, as required by Section B.3.a of the GeneralPermit. No unauthorized non-stormwater discharges were detected in any year.Monthly visual observations of stormwater discharges occurred at all locations during thewet season, as required in Section B.4.a of the General Permit. The wet season months areOctober through May. In 2003 and 2004, all observations were made. In April 2004, nostorms occurred, and in May 2004 no discharge occurred. In 1999 and 2000, 2000 and 2001,and 2001 and 2002, the reports were filled out, indicating that the observations were notmade at all locations, but the attached Form 4 shows that the observations were made at onelocation on West Avenue and that no pollutants were observed.

An Annual Comprehensive Site Compliance Evaluation, as required by Section A.9 of theGeneral Permit, was conducted each year according to the stormwater reports. The potentialpollutant source/industrial activity area was not applicable to the Fresno Sanitary Landfill.

The samples were analyzed for pH, TSS, total organic carbon, specific conductance, and oiland grease. Reporting limits were not provided in the reports, but the laboratory resultsfrom the stormwater analysis were reviewed. pH ranged from 7.9 to 8.1 in 2003 and 2004,6.7 to 7.4 in 2002 and 2003, and was 6.93 in 1999 and 2000. TSS ranged from 15 to 180 mg/L



in 2003 and 2004, 180 to 600 mg/L in 2002 and 2003, and was 820 mg/L in 1999 and 2000.Total organic carbon ranged from 6.6 to 15 mg/L in 2003 and 2004, 5.3 to 7.4 mg/L in2002 and 2003, and was not tested for in 1999 and 2000. Specific conductance ranged from170 to 450 µmho/cm in 2003 and 2004, was not tested for in 2002 and 2003, and was200 µmho/cm in 1999 and 2000. Oil and grease has not been detected in any of thestormwater discharge analyzed (City of Fresno 2000, 2001, 2002, 2003, 2004).

5.4.4 Landfill Gas CondensateSix sumps (five at the toe of the landfill slopes and one adjacent to the landfill gas flare) areconnected via a common piping system. The condensate from the landfill gas collectionsystem is conveyed via piping to a sewer manhole located in the intersection of North andWest Avenues. It is then conveyed approximately 4 miles west to the Fresno-ClovisRegional Wastewater Treatment Facility. The sumps each have float sensors that triggerautomatic pumping to the manhole when the condensate level reaches a designated height.The City is looking into installing a gauge to obtain a numeric value for the condensatevolume discharged to the publicly-owned treatment works (POTW).

The Consent Decree does not specify gas condensate limits but general discharge criteriawere obtained from the Fresno-Clovis Regional Wastewater Treatment Plant. The originalintent, as specified in the Consent Decree was to sample from the manhole. Because themanhole is located in the middle of the intersection, the sumps are instead sampled atcondensate sump CS-1, next to the LFG flare area. The condensate from CS-1 is actuallyfrom the LFG from the entire site. Therefore, Kleinfelder states that it is actually a morerepresentative sample than the manhole sample would have been. According to GeorgeSlater, Project Coordinator for the City of Fresno, the condensate samples for the secondround of flare testing were taken from CS-1, located adjacent to the LFG flare; CS-2, locatedalong the southwest edge of the landfill; and CS-6, located along the southeast edge of thelandfill. This change was approved by the EPA and the Regional Water Quality ControlBoard because of the difficulty of sampling from the manhole in the intersection of WestAve and North Ave. This change was discussed in the 2nd Compliance Testing Reportwhich was not available at the time of this Five-Year Review.

Kleinfelder collected samples of the LFG condensate from CS-1 on March 9, 2004. NumerousVOCs, semivolatile organic compounds, metals, and other characteristics were detected inthe condensate. Those that exceeded the discharge limits include arsenic, cyanide, and pH.Arsenic at.349 mg/L was above its discharge limit of.32 mg/L. Cyanide, at 28.2 mg/L, waswell over its.77 mg/L discharge limit. The pH, at 4.87, was outside of its limit of 6 to 12.4.Discharge limits for many of the detected VOCs do not exist. Kleinfelder recommended thatthe Fresno-Clovis Regional Wastewater Treatment Facility staff be informed of thecharacteristics of the condensate discharge.

5.4.5 Operations and Maintenance Activities, 1998 to 2003The total flow, the average flow rate, and the percent well operation are presented inTable 5-10 for the five extraction wells. The extraction wells were all consistently operating ataround 80 to 95 percent of the time in 2004. From October 2000 through June 2002, PW-1A,PW-2A, PW-3A, and PW-4A were operating at lower percentages of time than their usualpercent well operation. The Early Action treatment system was operating during the first part



of this time frame (until September 2001). The downtime was largely attributed to constructionactivities, power outages, and the changeover to the Phase 1 treatment system. Pumps wereremoved from PW-1A, PW-3A, and PW-4A from June 5 to June 20, 2001 in order to redevelopthe wells and install new subsurface vaults. The North Treatment Unit was down for a week inthe beginning of August 2001 while a broken pressure manhole on an irrigation line wasreplaced. Activities to connect PW-1A, PW-2A, PW-3A, and PW-4A to the Phase 1 treatmentsystem resulted in a 25 percent operation time from August 9 to September 25, 2001. The Phase1 treatment system, online in September of 2001, experienced downtime due totroubleshooting, well pump replacement, and anti-scalent system problems (CDM 2001a).

Average flow rates have also decreased at all of the wells except PW-5A. PW1A has had adecrease in average flow rate from 96 gallons per minute (gpm) in 1999 to 43 gpm in thefourth quarter 2004. PW-2A has had a decrease in average flow rate from 105 to 32 gpm,PW3A from 175 to 39 gpm, and PW-4A from 26 to 13 gpm during that similar time period.The extraction well flow rates have been adjusted because of lowered groundwaterconditions (CDM 2005a). PW-5A was placed online in the summer of 2002 and has remainedconsistent in its average flow rate and its percent operation time.

TABLE 5-10Groundwater Extraction Rates and Percent OperationFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, CaliforniaExtraction

Well Date Total Flow (gallons)Average Flow

Rate (gpm)% Well

Operation

1999Oct 19 - Dec 30

9,705,961 meter-based10,200,679 calculated

96 95

2000Dec 30 ‘99 – Apr 24 ‘00


87 100

2000Apr 24 – Oct 27


84 81

2000 – 2001Oct 27 ‘00 – May 31 ‘01


79 65

2001May 31 – Dec 31


75 37

2002Jan 1 – June 30


92 53

2002July 1 – Dec 31

7,960,717 meter-based 44 68

2003 Q1 7,439,000 meter-based9,553,338 calculated

68 78

2003 Q2 5,099,000 meter-based 51 82

2003 Q3 5,182,000 meter-based 44 90

2003 Q4 Data notavailable

2004 Q1 5,990,000 meter-based 52 89

2004 Q2 4,567,000 meter-based 45 77

PW-1A

2004 Q3 4,913,000 meter-based 43 81





Rate (gpm)% Well

Operation

2004 Q4 5,349,000 meter-based 43 98

1999Oct 19 – Dec 30


105 96

1999Dec 30 ‘99 – April 24 ‘00


115 100

2000Apr 24 – Oct 27


138 83

2000 – 2001Oct 27 ‘00 – May 31 ‘01


131 66

2001May 31 – Dec 31


95 49

2002Jan 1 – June 30


107 49

2002July 1 – Dec 31

10,506,637 meter-based 49.1 81

2003 Q1 10,584,885 calculated7,995,000 meter-based

76 76

2003 Q2 4,966,000 meter-based 49 85

2003 Q3 2,597,000 meter-based 22 90


2004 Q1 5,038,000 meter-based 43 89

2004 Q2 3,609,000 meter-based 35 78

2004 Q3 3,156,000 calculated 26 91

PW-2A

2004 Q4 4,069,000 calculated 32 97

1999Oct 19 – Dec 30


175 90

1999Dec 30 ‘99 – April 24 ‘00


177 98

2000Apr 24 – Oct 27


174 79

2000 – 2001Oct 27 ‘00 – May 31 ‘01


181 68

2001May 31 – Dec 31


82 29

2002Jan 1 – June 30

Unknown meter-based21,405,060 calculated

82 unknown

PW-3A

2002July 1 – Dec 31

7,729,627 35 83





Rate (gpm)% Well

Operation


51 58

2003 Q2 5,558,731 meter-based 53 87

2003 Q3 5,522,000 meter-based 51 82


2004 Q1 6,568,000 meter-based 60 83

2004 Q2 4,006,000 meter-based 41 75

2004 Q3 3,775,000 calculated 35 81

2004 Q4 4,599,000 calculated 39 90

1999Oct 19 – Dec 30

Not InstalledUntil 12/7/99

1999Dec 30 ‘99 – Apr 24 ‘00


26 85

2000Apr 24 – Oct 27 00


29 91

2000 – 2001Oct 27 ‘00 – May 31 ‘01


33 77

2001May 31 – Dec 31


25 24

2002Jan 1 – June 30th

Unknown meter-based11,865,636 calculated

46 unknown

2002July 1 – Dec 31

2,972,756 meter-based 11.6 97


17 48

2003 Q2 1,909,763 meter-based 17 92

2003 Q3 1,622,000 meter-based 13 92


2004 Q1 1,388,000 meter-based 12 86

2004 Q2 1,021,000 meter-based 10 82

2004 Q3 1,466,000 calculated 13 85

PW-4A

2004 Q4 1,680,000 calculated 13 98





Rate (gpm)% Well

Operation

1999 Not InstalledUntil 6/15/01

2000 Not InstalledUntil 6/15/01

2001s Not InstalledUntil 6/15/01

2002Jan 1– June 30

Not InstalledUntil 6/15/01

2002July 1 – Dec 31

3,085,994 meter-based 12.0 97

2003 Q1 4,722,142 calculated3,879,000 meter-based

34 82

2003 Q2 3,400,000 meter-based 30 92

2003 Q3 3,750,000 meter-based 30 93


2004 Q1 3,752,000 meter-based 32 89

2004 Q2 3,447,000 meter-based 32 82

2004 Q3 3,485,000 meter-based 28 95

PW-5A

2004 Q4 3,140,000 meter-based 25 99

5.5 Regulatory ReviewA review of applicable or relevant and appropriate requirements (ARARs) and otherstandards to be considered (TBCs) was conducted for the selected remedy at the FSLSuperfund Site. The review was conducted to determine if changes to standards and TBCshave occurred since the RODs were issued in 1993 and 1996 that might affect currentprotectiveness of the selected remedies.

The specific documents that were reviewed for any changes, additions, or deletions are asfollows:

ROD signed on September 30, 1993 for OU 01.

ROD signed on September 30, 1996 for OU 02.

City of Fresno Department of Public Utilities, “November 17, 1997 meeting re 40 CFR 51et seq.,” Letter, December 1997.

Consent Decree signed in August 1998.



SJVUAPC, “Air Pollution Requirements for Fresno Landfill Remediation Project,”Letter, 1998.

The following general requirements were identified as ARARs in the 1993 source controloperable unit ROD:

Central Valley RWQCB Standards – Selected sections from CCR, Title 23, Chapter 15,which pertains to landfill closure, including cover design and construction standards, aswell as ancillary facilities.

California Integrated Waste Management Board Standards – Selected sections fromCCR, Title 14, which requires establishment of monitoring and control during closureand post-closure of a landfill.

In addition, performance criteria relating to constituent emissions into ambient air wereestablished.

Ambient air concentrations from both the landfill gas treatment system and the landfillitself can not exceed a level (determined by USEPA) that would cause a 10-6 excesscancer risk. The determination of the cancer risk was to be based on the California AirPollution Control Officers Association Air Toxics “Hot Spots” Program Risk AssessmentGuidelines (January 1991).

The treatment system was required to meet the Solid Waste Disposal Sites – Draft Rule46-42, which established a reactive organic destructive efficiency of 98 percent for anyreactive organic except methane, any flares designed as part of the LFG control systembe enclosed in a shroud, and the maximum concentration of organic compoundsmeasured as methane, measured at any point on the surface of the landfill shall notexceed 1,000 ppm.

The gas extraction system will be operated until the LFG production has declined to theextent that the compliance points monitoring requirements can be met withoutcontinued gas extraction.

The flares shall be operated as long as the LFG extraction system is in operation.

The following general requirements were identified as ARARs in the 1996 groundwateroperable unit ROD:

Safe Drinking Water Act – Sections relating to maximum contaminant MCLs andunderground injection.

Clean Water Act – Sections relating to effluent limitations for point source pollutiondischarges and establishment of pretreatment standards for the control of pollutants toPOTWs.

Clean Air Act – Relates to emission standards for specific chemicals and requires thegroundwater treatment facility to meet all substantive conditions stipulated in theSJVUAPCD rules.

Central Valley RWQCB Standards – Selected sections from CCR, Title 23, relating toassurances that implementation of a remedial action is meeting objectives.



Central Valley RWQCB Standards – Selected sections from CCR, Title 22, relating tohazardous waste storage in containers and design and management standards for tanks.

California Health and Safety Code – Prohibits the discharge or release to water or toland of chemical known to the State of California to cause cancer or reproduce toxicitywhen the chemical will probably pass through a source of drinking water.

Tables 5-11 and 5-12 provide an evaluation of ARARs using the regulations and requirementslisted in the RODs as a basis. No location-specific ARARs were identified in either of the RODs.The evaluation includes a determination of whether the regulation is currently an ARAR or TBCand whether the requirements have been met. Most of the listed ARARs remain applicable orrelevant and appropriate to the site and most are being complied with. A summary of changesto existing ARARs can be found in Section 6.2.

5.6 Site InspectionRepresentatives of USEPA, FSL, and CH2M HILL performed a site inspection onMarch 9 and 10, 2005 to observe the current status of operations. The inspection includedthe components of OU-1 and OU-2, as well as a driving tour of the surrounding areaincluding the agricultural wells. A summary of the inspection findings is presented below.The site inspection checklist and photos are provided in Appendices C and D, respectively.Conditions during the inspection were favorable, sunny, with temperatures of 75 to 80 °F.There were numerous birds at the site. According to the tour guides, coyotes, groundsquirrels, and foxes all visit the site. The entire landfill has a perimeter fence around it,which is well maintained and locked.

The tour of OU-1 included a drive around the landfill with numerous stops to inspectdifferent components. Overall, the landfill appeared to be in good condition with noapparent settlement. The vegetation was dense and healthy. The gravel roads on the landfillwere also in good condition. There are 1,200 sprinkler heads on the landfill to ensure thevegetative cover is a success. Bait dispensers are placed around the landfill to preventsquirrels from damaging the liner.

There are 115 gas collection wells connected to a 12-inch loop system. On the day of the visit,approximately 80 percent of the gas extraction wells were in operation. The wells wereoperating at around 750 to 800 cubic feet per minute. The gate valves on the wells allow formanual operation. The ideal conditions (<5 percent oxygen, 25 percent nitrogen, 40 percentmethane, low temperature) can be achieved manually. Kleinfelder, the City’s subcontractor forlandfill O&M, is asked to visit the site to modify extraction as necessary. Appendix D contains aphoto of an example LFG well. The lids on the LFG wells were left open for easier access formaintenance because they weigh 200 pounds each. The City budgeted money to replace theheavy lids with plywood lids. There was a dead squirrel in one of the boxes. The LFG wells areapproximately 45 to 50 feet bgs. The wells are analyzed every 2 weeks for methane, carbondioxide, oxygen, and temperature. The results are not reported but are used to modify gas flowas needed. There are three ports for the Gym200 gas analyzer. There is no leak detection systemfor the LFG, but an elevated oxygen reading reflects a leak.



TABLE 5-11Chemical-specific ARARsFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Source Citation Description Findings and Comments

Safe Drinking WaterAct (SDWA) NationalPrimary DrinkingWater Standards

40 CFR Part 141.61 Chemical-specific drinking water standardMCLs have been promulgated under theSDWA.

Applicable or relevant and appropriate

Several VOCs (including TCE, cis-1,2-DCE, vinyl chloride, andPCE), nitrates and TDS exceeded MCLs in groundwatersamples collected during the fall 2004 event. The 1996 RODrequires that the ultimate objective is to obtain aquiferrestoration, in other words, all constituents at or below MCLs.

Clean Air Act NationalEmission Standardsfor Hazardous AirPollutants

40 CFR 61 Identifies and establishes emission standardsfor specific chemicals.

Applicable or relevant and appropriate.

List of amendments:

§ 61.12 Compliance with standards and maintenancerequirements. [50 FR 46292, Nov. 7, 1985, as amended 62 FR8328, Feb. 24, 1997]

§ 61.18 Incorporations by reference.[48 FR 3740, Jan. 27, 1983,as amended at 48 FR 55266, Dec. 9, 1983; 49 FR 23520, June6, 1984; 51 FR 34914, Sept. 30, 1986; 54 FR 38073, Sept. 14,1989; 54 FR 51704, Dec. 15, 1989; 55 FR 8341, Mar. 7, 1990;55 FR 18331, May 2, 1990; 55 FR 22027, May 31, 1990; 55 FR32914, Aug. 13, 1990; 65 FR 62150, Oct. 17, 2000; 65 FR78280, Dec. 14, 2000; 67 FR 57166, Sept. 9, 2002; 69 FR18803, Apr. 9, 2004]

Porter-Cologne WaterQuality Control ActPlan (Basin Plan) forthe RWQCB, CCR(Tulare Lake BasinPlan)

Water Quality Control Plan(Basin Plan) for theRWQCB, CCR (TulareLake Basin Plan)

Water quality objectives

Establishes water quality objectives, includingnarrative and numerical standards thatprotect the beneficial uses and water qualityobjectives of surface and ground waters inthe region.


The Basin Plan has been updated in August 1995 and January2004.

California Code ofRegulations

Title 22, CCR, Division 4,Chapter 15, Articles 4, 5.5,and 8

Requirements for public water systems.Includes MCLs.




TABLE 5-11Chemical-specific ARARsFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California


GroundwaterProtection

Title 22, CCR, Division 4.5,Chapter 14, Article 6§66264.90-66264.101

Creates broad groundwater monitoring andcompliance standards. Includesconcentrations standards, monitoringrequirements and corrective actionrequirements.


There have been no significant changes.

Health and SafetyCode

Title 22, CCR, Division 2,Subdivision 1, Chapter 3;§25249.5 of the Health andSafety Code

Prohibits the discharge or release to water orto land of a significant amount of anychemical known to the State of California tocause cancer or reproduce toxicity when thechemical will probably pass through a sourceof drinking water.



State WaterResources ControlBoard

Resolution No. 88-63(“Sources of DrinkingWater Policy”) (ascontained in the RWQCB’sWater Quality Control Plan)

Specifies that, with certain exceptions, allground and surface waters have thebeneficial use of municipal or domestic watersupply.





TABLE 5-12Action-specific ARARsFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California


Porter-Cologne WaterQuality Control Act Plan(California Water Code13240)

Title 23, CCR, Chapter15, Sections 2510 (a),2510(c), and 2510 (d).

Applies to applicability of Chapter 15 and toengineered alternative to the prescriptive standardfor final cover at a waste management unit.

The measurements remain applicable or relevant andappropriate and have been complied with.

Section 2510: Amendment of subsections (a) and (d)-(h),repealer of subsection (i) and amendment of Note filed 6-18-97; operative 7-18-97 (Register 97, No. 25).

Title 23, CCR, Chapter15, Sections 2580 and2581.

Applies to general closure requirements andlandfill closure requirements.


Section 2581 - Repealer filed 6-18-97; operative 7-18-97(Register 97, No. 25).

Title 23, CCR, Chapter15, Sections 2540, 2541,2546, 2547, and 2596.

These sections apply to:

Design and construction standards forcontainment structures.

Design, construction, and maintenance ofdrainage, collection and holding facilities for wastemanagement units.

Design and construction of landfill structures towithstand seismic events.

Requirements in the design reports andoperations plans for containment structures,precipitation and drainage control facilities andancillary facilities.


2540 - Amendment of article heading and subsections (a)-(d) filed 6-18-97; operative 7-18-97 (Register 97, No. 25).

2541 - Amendment of subsections (d) and (e), Table 4.1and Figure 4.1, and repealer of figure 4.2 filed 6-18-97;operative 7-18-97 (Register 97, No. 25).

2546 - Amendment of subsections (a)-(d) and (f) filed 6-18-97; operative 7-18-97 (Register 97, No. 25).

2547 - Amendment filed 6-18-97; operative 7-18-97(Register 97, No. 25).

2596 - Amendment of subsections (a)(2), (a)(3) and(a)(3)(B)7.-8. filed 6-18-97; operative 7-18-97 (Register 97,No. 25).






Title 23, Division 3,Chapter 15, Article 1CCR 2510 (g)

Applies to the development and implementation ofa monitoring program for closed, abandoned, orinactive waste management units in accordanceto Article 5 of Chapter 15.


Section 2510: Amendment of subsections (a) and (d)-(h),repealer of subsection (i) and amendment of Note filed 6-18-97; operative 7-18-97 (Register 97, No. 25).


Title 23, CCR, §2550.6,§2550.7, §2550.9, and§2550.10

Requires monitoring for compliance with remedialaction objectives for three years from the date ofachieving cleanup levels. Requires general soil,surface water, and groundwater monitoring.Requires an assessment of the nature and extentof the release, including a determination of thespatial distribution and concentration of eachconstituent. Requires implementation of correctiveaction measures.


2550.6- Amendment of subsection (a) filed 6-18-97;operative 7-18-97 (Register 97, No. 25).

2550.9 - Amendment of subsection (e)(6) filed 6-18-97;operative 7-18-97 (Register 97, No. 25).

Closure and PostClosure

Title 22, CCR, Division4.5, Chapter 14, Article7, §66264.117

States that monitoring, maintenance and reportingrequirements must continue for 30 years pastclosure.



Containers Title 22, CCR, Division4.5, Article 9,§66264.170-66264.178

Requirements for facilities that store containers ofhazardous waste.

The measurements remain relevant and appropriate.

Section §66264.175 added new subsections (d)-(e) on07/24/97

Tanks Title 22, CCR, Division4.5, Chapter 14, Article10, §66264.190-66264.200

Outlines design and management standards fortanks.

The measurements remain relevant and appropriate.

Changes in the following subparts have no regulatoryeffect: 66264.192; 66264.193; and 66264.200





State Water ResourcesControl Board

Resolution No. 92-49 IIIG. (As amended April21, 1994)

Establishes requirements for investigation andcleanup and abatement of discharges that impactor threaten water quality. Discharges must cleanup and abate the effects of discharges in amanner that promotes the attainment of eitherbackground water quality or the best water qualitythat is reasonable if background is not technicallyand economically feasible.


Amended on October 7, 1996. To include provisions for acontainment zone policy.

These policies and procedures apply to all investigations,and cleanup and abatement activities, for all types ofdischarges subject to Section 13304 of the WChttp://www.epa.gov/ost/standards/wqslibrary/ca/ca_9_92_49.htm.

CAPCOA California Air PollutionControl OfficersAssociation (CAPCOA)Air Toxics “Hot Spots”Program RiskAssessment Guidelines(January 1991)

Ambient air concentrations of landfill gascontaminants or landfill gas treatment facilitycontaminant emissions shall not exceed a level,as determined by USEPA, which would cause a10-6 excess cancer risk as determined pursuant toCAPCOA.

Additional Requirements - Performance

The guidance document has been updated in 1996 and1997 subsequently, and is due for an update in 2005. The1996 and 1997 amendments include an emission inventoryplan amendment and a high risk facilities reportingrequirements.

The proposed 2005 amendment will include changes in therisk assessment methodology, as well as provisions fordiesel engines.

Solid Waste DisposalSites – Draft Rule 46-42

At a threshold minimum, the remedy must meetthe requirements of:

Establishes a reactive organic destructionefficiency of 98% for any reactive organicexcept methane.

Requires that flares designed as part of thelandfill gas control system be enclosed in ashroud.

Requires that the maximum concentration oforganic compounds measured as methane,measured at any point on the surface of thelandfill, shall not exceed 1,000 ppm.






Safe Drinking Water ActUnderground Injection

40 CFR Part 144 Provides requirements for underground injectionprogram.

No longer applicable or relevant and appropriate.

It has been amended in 1999 and 2002. The amendmentapplies to owners and operators of Class V well that is nota large-capacity cesspool or a motor vehicle wastedisposal well, as described in the December 7, 1999 ClassV Rule (64 FR 68546) at 40 CFR 144.81 (2) and 144.81(16), respectively.

Clean Water Act-EffluentLimitations

33 USC Chapter 26,Subchapter III, § 1311-1312as derived fromClean Water ActSections 301 and 302

Note: These ARARswere cited incorrectly inthe 1996 ROD as 33CFR Parts 301 and 302

Requires establishment of technology-baseddischarge limits for point sources of pollution.


Clean Water Act Toxicand PretreatmentStandards

33 USC Chapter 26,Subchapter III, § 1317derived from CleanWater Act Section 307

Note: This ARAR wascited incorrectly in the1996 ROD as 33 CFRPart 307

Requires the establishment of pretreatmentstandards for the control of pollutants to POTW.



Title 23, Division 3,Chapter 15, Article1CCR2511(d)

Exemptions to actions taken by or at the directionof public agencies to clean up or abate conditionsof pollution or nuisance resulting fromunintentional or unauthorized releases of waste orpollutants to the environment.


Amendment of first paragraph and subsections (a), (b)(1)-(2), (c), (d), (e)(1)-(3), (g)(1) and (h), and amendment ofNote filed 6-18-97; operative 7-18-97 (Register 97, No. 25).





California Code ofRegulation Title 14

Title 14, CCR Sections17776

Applies to final grading. The measurements remain applicable or relevant andappropriate and have been complied with.

California Code of Regulations Title 14 and Title 27 Combined

Title 27, CCR Section20324


Applies to construction quality assurance. Applicable or relevant and appropriate.

Title 27, CCR Sections:20932 and 20933

Title 14, CCR Sections17783, 17783.9, and17783.11.

Applies to gas monitoring and control duringclosure and post-closure; monitored parameters,and monitoring frequency.




Applies to final cover. Applicable or relevant and appropriate.



Applies to final site face. Applicable or relevant and appropriate.



Applies to final drainage. Applicable or relevant and appropriate.



Applies to slope protection and erosion control. Applicable or relevant and appropriate.


Title 14, CCR Sections17778.5

Applies to perimeter monitoring network. Applicable or relevant and appropriate.


Title 14, CCR Sections17783.7 and 17783.15

Applies structure monitoring and gas control. Applicable or relevant and appropriate.



Applies to post-closure maintenance. Applicable or relevant and appropriate.



Applies to change of ownership during closureand post-closure maintenance.




Applies to post-closure land use. Applicable or relevant and appropriate.



Georges Lake lies west of the landfill. It is a man-made lake where some of the treatedgroundwater is discharged. The lake water is used for irrigation. The South Basin is used fortreated groundwater when the lake water level is high. Stormwater sampling, required bythe RWQCB, is performed twice a year at the three culverts. The three culverts are locatednear the three basins – Georges Lake, South Basin, and the East Basin. The culverts aregravel and go under the road to one of the three detention ponds. Georges Lake is the onlylined pond. The data are sent to the Department of Water Resources in an annual report.

The tour of OU-2 included the extraction wells, monitoring wells, and treatment area,including the flare and PTA, and the office, including the SCADA system. All five extractionwells were operating at the time of the site inspection. The extraction wells are outfittedwith Grundfos pumps. Transducers are placed in all extraction wells and electronicallytransmit data to SCADA (in the office). The groundwater extraction wells are located invault boxes that do not lock but are very heavy and have control panel locks. If the vault boxis opened, it sends a warning to the SCADA system. There was no leaking around theinspected extraction well. The extraction wells are inspected weekly and sampled at leastonce per year.

The decrease in water elevation levels has created a dramatic decrease in the extractionrates. For example, PW-3 first started extracting groundwater at approximately 200 gpm.Over the past years, this has decreased to about 20 gpm. The flow meters are currentlygoing to be replaced for lower-purge range magnetic pumps. The flow meters have not beenworking for the past 18 months. The flow is therefore currently calculated based on a pumptest that the City performs periodically at CDM’s request. CDM obtains groundwatereffluent and influent records. There have also been issues with the throttle valves.Replacement of the valves may resolve the need to frequently adjust the flow rate in theextraction wells. Plant shutdown would be required to replace the valves. The totalizer isalso not operating (it is off by about 20 gpm). Well rehabilitation has also been conducted.Monitoring wells CDM-5A, 5B, and 5C were observed during the site inspection. Thesewells were all locked and have dedicated bladder pumps. A-, B-, and C-Aquifer wells atlocations CDM-2, CDM-13, CDM-16, and CDM-17 were all observed while driving by.

The treatment system area has a well maintained fence and gate around it. The gate is closedin the evenings and contains a security system. The PTA, flare, propane tanks, chemicals,and office are all contained in the fenced in area. The interim groundwater treatmentequipment is left unused in this gated area. It should be removed. In general, all themachinery is well-maintained and labeled.

Power failure is the biggest problem in terms of interrupted operations. The system isoperating 98 percent of the time. The groundwater treatment system has been in operationfor the past 4 years. Shutdown occurs when the packing media requires cleaning or the flareshuts down.

Dead bees are abundant on the ground around the flare. The bees fly over the flare and arekilled by the heat. There were no dead birds around the flare during the inspection, but theoperators report that occasionally dead birds can be found around the flare. There iscorrosion around the flare caused by the heat, and the City is preparing to paint the flare.There are louvers around the base of the stack to control oxygen and, therefore, thetemperature at which the flare operates. All the records are available for the flare but are not



reported except during compliance testing. A blower creates a vacuum on the system. Thereis a 2-inch vacuum line. A safety shut-off valve is present on the blower manifold by thecompressed air. If there is a loss of air pressure or power, the system will shut down. Thereis no long-term sampling planned for the flare. The City has coordinated with SJVAPCD onan as-needed basis to ensure compliance with SJVAPCD requirements.

The flow rate for LFG into the flare is recorded. There are no data for the volume of VOCemissions that are burned by the flare. The moisture is separated from the gas beforeentering the flare, and the condensate flows into the groundwater treatment sump. Thecondensate is only sampled during compliance testing. One 300-gallon propane tank isonsite to light the flare, if necessary.

The PTA consists of the air stripper and blower. It is operated at 95 to 98 °F. The anti-scalentused is GE Flogard POT 807. It is stored in one 1,000-gallon tank onsite. The hypochlorite isstored in a separate area that is well-maintained. All the health and safety precautions are inplace. The influent sampling ports are in good condition. They are sampled every 3 months.The solvent gas is not tested regularly—it is sent to the flare. Any fluid in the sumps is sentto the PTA for treatment prior to discharge. The treated water is sampled every 3 months.The VOCs from the PTA are sent to the flare, where they are burned off.

The SCADA system that controls and relays information regarding the groundwatertreatment system is located in the office. The alarm was on because during the inspectionthe extraction well vault box was opened. The SCADA system shows the flow of the wells.Well PW-5A was operating at 14 gpm, Well PW-4A at 20 gpm, and the totalizer read137 gpm. There are five methane sensors in the office all reading 0 percent methane. This isa building requirement because it is within 300 feet of a landfill. Two fire extinguishers arein the office, as well as the main circuit breakers. The sampling equipment is stored in theoffice. The equipment is clean and well-maintained.

The area is currently zoned for agricultural use, and there has been no development in thearea for several years. There are vineyards to the east and west of the landfill and a dairyfarm further to the west. The community master plan called for a park in southwest Fresno.The City decided to use the land around the landfill to build a park to fund the long-termmaintenance of the FSL. The park cost $9 million. Soil that was piled up while the park wasbuilt was then used to cap the landfill. The Parks Department will take over themaintenance of the landscaping on the landfill by the end of 2005. The sports complex is apart of a 72-acre purchase by the City. Land to the east of the landfill was purchased becausethe vineyard was affected by the LFG. As the east pond was dug; the soil that was removedwas used to create part of the landfill cap. There are greenhouses east of the landfill. Theowner previously claimed loss against the City. The unlined irrigation canal runs along theeast side of the landfill. This is often filled with water after mid-March. There are currentlyno deed restrictions.

The tour also included a look at the agricultural wells that were to be decommissioned. Thenew replacement agricultural irrigation wells are screened at 250 to 500 feet bgs. Oneirrigation well was installed in January of 2005 but is not in service yet. Another agriculturalwell was installed in October 2004. The well pump is connected, but there is no generator.Eventually, a permanent power supply will be installed.



Four homes were purchased by the City along the southwest boundary of the site. The Cityprovides bottled water to seven residences and businesses to the north and south of the site.The water has been provided since the early 1990s. This began as a “good neighbor”activity, as the City was not aware of the contamination at the time except at a home to thesouth of the landfill. The City tests their water regularly.

5.7 InterviewsInterview summary forms are provided in Appendix C. Interviews were conducted with thefollowing City of Fresno staff, their consultants (Kleinfelder and CDM), former USEPARPMs, DTSC, and the RWQCB:

George Slater/City of Fresno/City Project Manager and Coordinator/March 10, 2005/Onsite

Jeff Garner/City of Fresno/Groundwater Treatment Plant Operator/March 10, 2005/Onsite

John (Yash) Nyznyk/CDM/CDM Project Manager/March 28, 2005/Telephone

Wayne Pickus/CDM/CDM Project Director/March 22, 2005/Telephone

Jeff Dunn/Kleinfelder/Kleinfelder Project Manager/March 28, 2005/Telephone

Lynn Suer/USEPA/Former RPM/April 12, 2005/Telephone

Cynthia Wetmore/USEPA/Former RPM/April 8, 2005/Telephone

Bret Moxley/USEPA/Former RPM/May 4, 2005/Telephone

Pete Phillips/URS/Technical Oversight for USEPA/April 6, 2005/In Person

Bruce Myers/RWQCB/RWQCB Project Manager/ March 10, 2005/RWQCB Office

Emmanuel Mensah/DTSC/DTSC Project Manager/March 22, 2005/telephone

All interviewees noted that the FSL is well run, with a great amount of open communicationbetween all involved parties. As issues arise, they are discussed openly and resolutions arequickly sought.

A main concern of the interviewees dealing with the implementation of institutionalcontrols has been the nearby agricultural wells. Lynn Suer, former RPM for USEPA, spokeof how the preliminary Phase 1 report did not provide enough information because of theagricultural well influence. Decommissioning the nearby agricultural wells was a longprocess filled with negotiations, according to George Slater, Project Coordinator for the Cityof Fresno. Yash Nyznyk, Project Manager for CDM, spoke of how the delay in acquiring theagricultural wells on private property had recently been solved, as the wells were acquiredin October 2004. Yash Nyznyk and Wayne Pickus, Project Director for CDM, spoke of howthis was an important step because of the agricultural wells effect on vertical migration.According to Jeff Garner, Groundwater Treatment Plant Operator for the City of Fresno,new irrigation wells for neighboring properties are currently being constructed. BruceMyers, Project Manager for RWQCB, spoke of how the model will be corrected following 1



year of sampling after the destruction of the agricultural wells because of the wells’influence on vertical plume movement and decreasing the water table, leading to a less-than-full capture of the plume during Phase 1. The decommissioning of the agriculturalwells will change site conditions; therefore, monitoring wells near the decommissionedagricultural wells may need to be sampled to establish a baseline. Also, Bruce noted thatthere are no site monitoring wells as deep as the new agricultural replacement wells (CDM2003c).

Wayne Pickus noted that CDM has developed an institutional control plan to regulate theinstallation of new wells. The status is discussed earlier in this report.

A problem that occurred during construction of the remedy was when the City’s consultant,the IT Corporation, went bankrupt. George Slater and Jeff Dunn spoke about the delay onOU-1 due to IT’s bankruptcy but that the remedy has been functioning well since itsconstruction.

A current issue with systems operations is decreased groundwater levels; therefore, the flowmeters cannot read the low levels of flow. The flow meter issue was mentioned by GeorgeSlater, Jeff Garner, Yash Nyznyk, and Wayne Pickus. New flow meters are scheduled to beinstalled this year. The extraction wells also needed to be cleaned more often than originallyplanned, according to George Slater and Yash Nyznyk.

Lynn Suer and George Slater both noted that during the first compliance testing, the flaredid not meet its goal of 98 percent destruction efficiency. Jeff Dunn, Project Manager forKleinfelder, noted that the flare was not operating at a high enough temperature when itwas sampled. There was no evidence of gas leakage, determined by a surface sweep.Emanuel Mensah, Project Manager for DTSC, spoke of the improved performance of theflare after increasing its operating temperature since the first performance test failure.

There have also been successes in operations and maintenance. For example, George Slatermentioned the strides in efficiency due to computerized O&M schedule, the decreasedO&M costs since the City’s takeover of groundwater sampling, and the City’s proposal touse the City’s wastewater treatment lab for analyses of some compounds.

George Slater, Project Coordinator for the City of Fresno, was interviewed onsite on March10, 2005. George is onsite regularly and thinks that the overall operations are conductedvery well. George would like to see the FSL eventually delisted from the National PrioritiesList because the community places a negative association with Superfund sites.

Jeff Garner, Treatment Plant Operator for the City of Fresno, was also interviewed on site onMarch 10, 2005. Jeff diligently runs daily operations. Jeff spoke of the poor design of thethrottle valves on the extraction wells and the heavy vault lids on the gas monitoring wellsthat remain open. These issues are all in the process of being resolved. The City hasbudgeted $15,000 for new lids and will replace the throttle valves during plant shutdown. Asampling trailer will soon be built to increase sampling efficiency. Jeff’s suggestions for thesite include gravel or pavement on the often muddy perimeter road, removing the old airstrippers that are no longer used, and looking into the option of using the extracted gas forpower generation either onsite or at the wastewater treatment plant. Jeff does not think thatbaiting for squirrels is a problem for the wildlife around the landfill because of the safemanner in which it is done.



Yash Nyznyk, Project Manager for CDM, was interviewed by phone on March 28, 2005.Yash has been impressed with the collaborative effort in addressing issues at the site as wellas the City’s proactive implementation of the early groundwater remedial action. It is thefirst time USEPA incorporated phased-implementation of remedial action into a ROD. Someissues with the SCADA system were resolved by improving the computer system andadding a protective box for the hard drive to address dust problems. Yash doesn’t believethat vapor intrusion is an issue any more because of the operation of the gas collectionsystem. The City recently collected treatment plant influent and effluent sample for analysisof cyanide, 1,4-dioxane, perchlorate, and 1,2,3-trichloropropane.

Jeff Dunn, Project Manager for Kleinfelder, was interviewed by phone on March 28, 2005.OU-1 is functioning well and consistent with land use. Jeff mentioned the LFG condensate ispumped to the sanitary sewer line and, even though it does not meet the City’s dischargerequirements, the POTW allows it because of the low-flow volume (a few hundredgallons/day). The LFG condensate is discharged to the POTW rather than being retainedand treated onsite in the PTA because OU-1 was constructed before OU-2. Therefore, theLFG condensate has been discharged to the POTW before OU-2 was constructed.

Mr. Wayne Pickus, Project Director for CDM, was interviewed on March 22, 2005 by phone.The early groundwater action system initiated cleanup of the plume and provided usefuldata for the effective design of the Phase 1 remedial action. Wayne thinks that the Phase 1evaluation will provide an indication for the need for any improvements to OU-2. Waynealso noted the local retention ponds influence on the groundwater near the site.

Emanuel Mensah, Project Manager for DTSC, was interviewed by phone on March 22, 2005.He mentioned that there were minor concerns from neighbors regarding their wells and siteconstituents.

Bruce Myers, Project Manager for RWQCB, was interviewed in person on March 10, 2005.His overall impression of the work at the site and communication is favorable and stressesthe continued need to evaluate the site based on new data collected. Because the Citydischarges treated water to onsite ponds, Waste Discharge Requirements will be necessaryalong with monthly reporting. The first round of baseline sampling for the Waste DischargeRequirements was reported in the Fall 2004 monitoring report. As far as emerging COCs,perchlorate could be present from the Chilean nitrate fertilizer.

Pete Phillips, URS Technical Oversight for USEPA, was interviewed in person on April 6,2005. He commented on the ability of the potentially-responsible party to complete theelements of the remedial design under difficult conditions and the cooperative environmentthat the consultants and regulatory members work in. There were typical startup-typeshakedown adjustments and modifications made.

Lynn Suer, RPM for USEPA in 2003 and 2004, was interviewed by phone on April 12, 2005.Lynn commented on the open communication. While the LFG was not reported, it wasmonitored and believes that records are kept by the City. There was concern raised byanother consultant that the electrical panel was placed in a hazardous place on the soccerfield. Lynn suggested that the Air and Water Boards should be involved in ensuringcompliance. The Air Board requirements were not detailed in the Consent Decree, RODs,nor compliance testing plan. Sampling for dioxins from the flare was an issue raised during



Lynn’s time as RPM. There are numerous issues regarding when and where to collectsamples. The cost is around $150,000 per sampling event. USEPA is currently conductingmore research on this issue. Also, the groundwater effluent is cleaned up to MCLs and notRWQCB cleanup standards (NPDES effluent discharge limits) because there was concernthat these standards could not be met.

Cynthia Wetmore was the USEPA RPM in the mid-1990s. The cap had not yet beenconstructed during her work on the site. There was not a lot of public participation in apublic meeting that focused on groundwater. Leachate investigation/recovery wasdetermined not to be technically and economically feasible.

Bret Moxley was the USEPA RPM until 1993. The FSL was in its early stages of treatment. Amethane barrier was not properly installed at that time. There was little public concern forthe site except for a few comments about effects on vegetation, property value, and health.

I-3

I-4

I-5

Feet

0 1000

.evA skra

M

Jensen Ave.

.evA se

hg

uH

. evA tse

W

North Ave.

UW1A,B,C

W2

CDM1A,B,C

UW2A,B,C

W3

W6

CDM2A,B,C

CDM3A,B

CDM4A,B,C

CDM8A,B

CDM5A,B,C

CDM6A

CDM7A,C

CDM16A,B,C

CDM17A,B,C

CDM18A,B,C

CDM15A,B,B2,C

PZ3B

PZ1A

PZ2A,B

PZ4B,C

CDM8C

CDM13A,B,B2,C

CDM12A,B

PZ5A,B,B2,C

MW1

DW2A,B,CW1R

MW2

MW3

W5

W4

MW4

DW1A,B,C

PW1A

PW2A

PW5A

PW4A

PW3A

Landfill Perimeter Fence

Pre-Remedial Action Monitoring Wells

Monitoring Wells Installed DuringPhase 1 Remedial Action

Extraction Wells Installed DuringPhase 1 Remedial Action

Agricultural Water Supply

Legend

Source: CDM, 2005.

FIGURE 5-1 EXTRACTION AND MONITORING WELL LOCATIONS FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-1 Extraction and Monitoring Well Locations _7/26/05_ez_sfo

FIGURE 5-2A A-AQUIFER GROUNDWATER ELEVATION CONTOURSAPRIL 2000 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-2a A-Aquifer Groundwater Elevation Contours; April 2000 _ez_sfo

Source: CDM, 2000.

FIGURE 5-2B A-AQUIFER GROUNDWATER ELEVATION CONTOURSJUNE 2004 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-2b A-Aquifer Groundwater Elevation Contours; June 2004 _7/26/05_ez_sfo

Source: CDM, 2004.

FIGURE 5-3A B-AQUIFER GROUNDWATER ELEVATION CONTOURSAPRIL 2000 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-3a B-Aquifer Groundwater Elevation Contours; April 2000 _7/26/05_ez_sfo

Source: CDM, 2000.

FIGURE 5-3B B-AQUIFER GROUNDWATER ELEVATION CONTOURSJUNE 2004 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_5-3b B-Aquifer Groundwater Elevation Contours; June 2004_7/26/05_ez_sfo

Source: CDM, 2004.

FIGURE 5-4A C-AQUIFER GROUNDWATER ELEVATION CONTOURSAPRIL 2000 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-4a C-Aquifer Groundwater Elevation Contours; April 2000_7/26/05_ez_sfo

Source: CDM, 2000.

FIGURE 5-4B C-AQUIFER GROUNDWATER ELEVATION CONTOURSJUNE 2004 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-4b C-Aquifer Groundwater Elevation Contours, June 2004 _7/26/05_ez_sfo

Source: CDM, 2004.

FIGURE 5-5A PCE CONCENTRATIONS IN A-AQUIFERAPRIL 2000 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_5-5a PCE Concentrations in A-Aquifer; April 2000_7/26/05_ez_sfo

Source: CDM, 2000.

FIGURE 5-5B PCE CONCENTRATION IN A-AQUIFERAPRIL 2004FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-5b PCE Concentration in A-Aquifer; April 2004_7/26/05_ez_sfo

Source: CDM, 2004.

FIGURE 5-6A TCE CONCENTRATION IN A-AQUIFERAPRIL 2000FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-6a TCE Concentration in A-Aquifer; April 2000_7/26/05_ez_sfo

Source: CDM, 2000.

FIGURE 5-6B TCE CONCENTRATION IN A-AQUIFERAPRIL 2004 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-6b TCE Concentration in A-Aquifer; April 2004_7/26/05_ez_sfo

Source: CDM, 2004.

FIGURE 5-7A VC CONCENTRATION IN A-AQUIFERAPRIL 2000 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-7a VC Concentration in A-Aquifer; April 2000_7/26/05_ez_sfo

Source: CDM, 2000.

FIGURE 5-7B VC CONCENTRATION IN A-AQUIFERAPRIL 2004 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-7b VC Concentration in A-Aquifer; April 2004_7/26/05_ez_sfo

Source: CDM, 2004.

FIGURE 5-8A PCE CONCENTRATION IN B-AQUIFERAPRIL 2000 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-8a PCE Concentration in B-Aquifer; April 2000_7/26/05_ez_sfo

Source: CDM, 2000.

FIGURE 5-8B PCE CONCENTRATION IN B-AQUIFERAPRIL 2004FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-8b PCE Concentration in B-Aquifer; April 2004_ez_sfo

Source: CDM, 2004.

FIGURE 5-9A TCE CONCENTRATION IN B-AQUIFERAPRIL 2000 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-9a TCE Concentration in B-Aquifer; April 2000_ez_sfo

Source: CDM, 2000.

FIGURE 5-9B TCE CONCENTRATION IN B-AQUIFERAPRIL 2004 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-9b TCE Concentration in B-Aquifer; April 2004_ez_sfo

Source: CDM, 2004.

FIGURE 5-10A VC CONCENTRATION IN B-AQUIFERAPRIL 2000 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-10a VC Concentration in B-Aquifer; April 2000 _ez_sfo

Source: CDM, 2000.

FIGURE 5-10B VC CONCENTRATION IN B-AQUIFERAPRIL 2004 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-10b VC Concentration in B-Aquifer; April 2004_ez_sfo

Source: CDM, 2004.

FIGURE 5-11 PCE CONCENTRATION IN C-AQUIFERAPRIL 2004FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-11 PCE Concentration in C-Aquifer; April 2004_ez_sfo

Source: CDM, 2004.

FIGURE 5-12 TCE CONCENTRATION IN C-AQUIFERAPRIL 2004FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-12 TCE Concentration in C-Aquifer; April 2004_ez_sfo

Source: CDM, 2004.

FIGURE 5-13 VC CONCENTRATION IN C-AQUIFERAPRIL 2004 FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-13 VC Concentration in C-Aquifer; April 2004 _ez_sfo

Source: CDM, 2004.

Landfill Gas Flare

CS-2

CS-1

CS-6

CS-1 = Condensate Sump designation and location.MMW-1 = Landfill Gas Monitoring Probe Cluster designation and location.

CMW-7

MMW-3

MMW-2

GMW-1

GMW-2

GMW-3

CMW-1

MMW-4

MMW-5 MMW-6

MMW-7

CMW-5

CMW-6 eunevA tse

W

North Avenue

parks department yard

Jensen Avenue

N

FIGURE 5-14 LANDFILL GAS FLARE, CONDENSATE SUMP,AND PERIMETER PROBE LOCATIONS FRESNO SANITARY LANDFILLFIRST FIVE-YEAR REVIEW REPORTFRESNO, CALIFORNIA

324131.FR.01_Fig 5-14 Landfill Gas Flare, Condensate Sump, and Perimeter Probe Locations_08/29/05_ez_sfo

Source: Kleinfelder, 2005.


SECTION 6.0

Technical Assessment

This section evaluates the functioning of the remedy as intended, the current status ofassumptions, and new information affecting the remedy.

6.1 Functioning of the Remedy as Intended by DecisionDocumentsIs the remedy functioning as intended by the decision documents?

6.1.1 OU-1This section discusses how OU-1 is operating and functioning in relationship to its intendedobjectives, O&M implementation, optimization opportunities, any early indicators ofpotential issues, and access controls and institutional control implementation.

6.1.1.1 Obtaining ObjectivesThe objective of OU-1 is to address onsite control of constituents by confinement of the trashprism and extraction and treatment of LFG, LFG condensate, and leachate. Currently, theintegrity of the landfill is intact. From the site tour, there did not appear to be any settling ofthe landfill, exposed membranes, or other disrepair. The vegetation was thick and healthy.The monitoring wells are in good condition.

Evaluation of plume containment was not possible at the time of this Five-Year Review. ThePhase I evaluation report scheduled for completion in early 2006 will evaluate plumecontainment. The concentrations of VOCs are low in the sampled stormwater. While OU-1 issuccessful in transporting the LFG from the landfill to the flare, the operation of the flare isnot currently meeting the performance requirement of a destruction efficiency of 98 percentfor any reactive organic other than methane. The second round of testing was performed inApril 2005. At the time of this Five-Year Review, the second compliance testing report wasstill in preparation by Kleinfelder and therefore results were not available for review.

6.1.1.2 System OperationThe onsite City of Fresno operator conducts preventative maintenance on the flare and gasmonitoring wells.

The O&M costs for OU-1 for 2003 and 2004 (available data) are lower than estimated. TheROD-estimated costs were $432,700; actual costs were $212,600. The lower actual costs aredue, in part, to the fact that the contingency leachate collection system was never installedbecause very little leachate is generated.

The City is proactively in looking for optimization opportunities. Currently, the percentoxygen, methane, and carbon dioxide is adjusted at the LFG monitoring wells manually.This optimizes the performance of the flare.

SECTION 6.0: TECHNICAL ASSESSMENT


6.1.1.3 Potential IssuesIssues include the flare’s performance, dioxin testing of the flare, lack of an ecological riskassessment, and maintenance of the gas monitoring wells.

A secure fence around the entire complex is well-maintained. The public does have access tothe landfill during the day, however. People could hurt themselves or vandalize the LFGcollection system.

The park is located adjacent to the landfill. EPA evaluated health risks using a workerscenario. This method is conservative and therefore the remedy is also protective forrecreational users. The treated groundwater is used for irrigation for the park. This is not ahealth risk because the effluent is tested and has consistently met the requirements for non-detect for the COCs. The soil is not considered contaminated and, therefore, is not anexposure route.

6.1.2 OU-2This section discusses how OU-2 is operating and functioning in relationship to its intendedobjectives, O&M implementation, optimization opportunities, any early indicators ofpotential issues, and access controls and institutional control implementation.

6.1.2.1 Obtaining ObjectivesThe objective of OU-2 is to restore the aquifer to beneficial use in a timely and cost-effectivemanner. Beneficial use is defined here as when levels are at or below MCLs. The ROD listed16 COCs.

OU-2 is currently in Phase 1 operations. The Phase 1 objective is plume containment aroundthe landfill. The plume size has decreased in the years that the treatment system has beenoperating, but the low extraction rates have inhibited complete containment. A secondassessment of Phase 1 will be reported later this year. It will include a capture-zone analysisand a newly-calibrated version of the groundwater model (Phillips 2005). The firstassessment was not able to completely evaluate the effectiveness because the agriculturalwells were still in operation and creating drawdown.

The effluent standards are defined in the Clean Water Act, Title 33, Code of FederalRegulations, Parts 301 and 302. The PTA is treating the influent to those standards—non-detect for COCs.

6.1.2.2 System OperationAn employee for the City of Fresno is onsite during workday hours maintaining the system.The Project Manager/Coordinator for the City is also frequently onsite. Preventativemaintenance is performed daily to ensure a properly-functioning system. Daily printoutsprovide information about maintenance to be performed for the day. The maintenance islogged and kept electronically in an Excel spreadsheet, which includes the scheduled startdate, completion date, equipment description, task number, and other relevant information.

The extraction wells have not been pumping at the rate for which they were designed. Aknown cause for the low flow is the decrease in groundwater levels. The City cleanedextraction wells PW-2A and PW-3A to see if biofouling was also part of the cause of the low



flow. In 2004, all of the extraction wells were operating between 81 and 99 percent of thetime. Reasons for extraction well downtime include well rehabilitation activities andadjustment of flow rates to compensate for the low water levels.

The treatment plant, including the flare, was down for routine maintenance because of localpower failures and upgrades and repair of the SCADA system. According to the Fall 2004Semi-Annual Monitoring Report (CDM 2005a), there were numerous weekend shutdownswhile staff were not present. The system was not started up again until Monday when staffreturned. The O&M plan states that the plant will remain offline until a manual shutdownRESET is invoked in the main plant central computer monitor. This does not appear to be alarge problem because operation of the extraction wells has been consistently over80 percent in recent years (CDM 2003d).

Actual O&M costs for 2003 and 2004 were approximately $100,000 less than the anticipatedO&M costs. Potential optimization in the process could be responsible for the reduced costs.Detailed information about the costs was not reviewed and therefore specific reasons for thelower costs are not described here.

The City is currently in the process of requesting a decrease in sampling for inorganics.Possible opportunities exist to use the LFG for the treatment plant’s electricity needs. Thiswas examined in the past and was, for the time, deemed impractical. Documentationregarding potential LFG usage was not available.

6.1.2.3 Potential IssuesThe flow meters are to be replaced within the next 6 months. Low flows could indicate apotential problem as far as the ability to contain the contamination. Also, vertical migrationof constituents appears to be increasing the concentration of PCE in the C-Aquifer.

The implementation of institutional controls as required by the ROD is still being discussedbetween the City and Fresno County. Fresno County would be responsible for enforcing theproposed controls, which include denying permit approval for installation of wells into theWell Prohibition Zone, as defined in the 2003 technical memorandum. According to currentlimited information, two wells were installed within the well assessment zone. The City istrying to obtain the well installation data in order to determine if these wells might have anadverse effect on the groundwater plume and remediation system. In addition, the City willcontinue their discussions with the County to work out an agreement as it relates to theseinstitutional controls.

6.2 Current Validity of Assumptions Used During RemedySelectionAre the exposure assumptions, toxicity data, cleanup levels, and remediation objectivesused at the time the remedy selection still valid?

The exposure assumptions, toxicity data, cleanup levels, and remedial action objectives usedat the time of remedy selection are generally unchanged. The following section describesany changes that have been made.



The post-closure groundwater monitoring indicates the presence of constituents atconcentrations exceeding the respective MCLs and confirms the need to continuemonitoring the extent of contamination. Thus, the Title 22 Groundwater Protectionrequirements are relevant and appropriate (CCR, Div 4.5, Chap 14, Art 6). In 1993, theprimary state statutory provisions governing solid waste management under CaliforniaIntegrated Waste Management Board (CIWMB) and the State Water Resources ControlBoard were combined under Title 27, Division 2, Subdivision 1 entitled “ConsolidatedRegulations for Treatment, Storage, Processing or Disposal of Solid Waste” (27 CCR §20164).Title 14 provisions identified in the 1993 FSL OU-1 ROD can now be found under Title 27,Division 2. There were no known significant changes noted in these regulations that wouldaffect the FSL site current remedy.

The groundwater cleanup goals were based on MCLs promulgated under the Safe DrinkingWater Act, which is an ARAR. The cleanup goals for the COCs in the aquifer were listed inthe ROD. Whenever the state MCL was more stringent than the federal MCL, the state MCLwas used, with the exception of trans-1,2-DCE. The state MCL for trans-1,2-DCE has been 10µg/L since September 1994, prior to the ROD; yet, the higher federal MCL of 100 µg/L wasused. The more stringent of the two standards for the trans-1,2-DCE should be considered forremediation cleanup goal for complete aquifer restoration. Based on review of recentgroundwater monitoring reports prepared under Phase 1, it appears that the MCL of 10 µg/Lfor trans-1,2-DCE is being used. The actual trans-1,2-DCE concentration levels were slightlyabove the MCL in one well in the A-Aquifer in 2004. That well, CDM-12A had a maximumconcentration of 1,2-DCE of13 µg/L.The concentrations of trans-1,2-DCE are below the MCLin the B- and C-Aquifers. The correct MCL of 10 µg/L for trans-1,2-DCE will be cited in theESD that the USEPA has recommended be prepared for the Site.

It was noted, while conducting the ARARs review, that there were two incorrect citationsmade in the 1996 OU-2 ROD. These related to the Clean Water Act, Title 33. The citationsmade in the ROD indicated that the regulations for these would be found in 33 CFR, Parts301, 302 and 307. The actual citations should have been 33 USC §1311, 1312, and 1317, whichwere derived from the Clean Water Act Sections 301, 302, and 307. The performance of theremedy has not been compromised based on this finding, since the general intent has beencomplied with. These incorrect citations will be corrected in the ESD that the USEPA hasrecommended be prepared for the site.

During this Five-Year Review, the assumptions concerning COC exposure and toxicity dataand changes in remedial action objectives were evaluated. No current or potential changeshave been identified during this Five-Year Review process.

The land use of the site changed with the development of the regional park/sports complexon the western portion of the site in 2002. No documentation on the health risk exposurepathways to citizens using the park was available for review, but it is assumed that theexposure pathways are similar to those used in the risk assessment conducted in 1994. Therisk assessment was conducted with the analysis that a worker would be spending 8 hoursper day working at the site.



6.3 Recent Information Affecting the RemedyHas any other information surfaced that could call into question the protectiveness of theremedy?

No other information has surfaced that could call into question the protectiveness of theremedy. An ecological risk assessment has not been conducted at the Site. USEPA has askedthe City to conduct a screening-level ecological risk assessment. There have not been anynatural disasters, such as weather-related or seismic incidents in recent years that wouldaffect or compromise the protectiveness of the remedy.


SECTION 7.0

Issues and Recommendations

This section describes the issues and recommendations for the site as a whole, OU-1, andOU-2. Table 7-1 summarizes the issues and recommendations as well as presents the partyresponsible, oversight agency, and the effect that it has on the protectiveness of theenvironment and human health currently and in the future.

7.1 Issues Related to OU-1 and OU-2

IssueAn institutional control needs to be in place to prohibit well installation and construction inthe area around the FSL that could cause contamination of that well or adversely affect thecontainment of the plume by the extraction wells. An institutional control also needs to beput in place to restrict certain uses of the site itself and protect the landfill cap.

RecommendationUSEPA recommends that an ESD be prepared for the site. The ESD will include thefollowing recommendations with regard to institutional controls for the site. The OU-1 RODrelied on the State Water Resources Control Board and Integrated Waste ManagementBoard regulations for closure and post-closure maintenance requirements to ensure integrityof the landfill cap and protect public health and safety by preventing public contact with thewaste. However, the State Water Resources Control Board and the Integrated WasteManagement Board regulations cited in the Landfill ROD (Title 22, Chapter 15 and Title 14,Division 7, respectively) have been superseded and replaced by Title 27. Thus, the ESD willcite to the Title 27 regulations that pertain to closure and post-closure maintenancerequirements. The ESD will also recommend that the City execute and record a restrictivecovenant for the property that would bind current and future owners and restrict certainuses of the site itself, including residential use, and prohibit use of the groundwaterunderneath the site.

7.2 Issues Related to the Landfill (OU-1)Issues related to the landfill include the flare’s compliance with the SJVAPCD requirements,the dioxin testing of the flare, lack of an ecological risk assessment, and maintenance on thegas monitoring wells.

SECTION 7.0: ISSUES AND RECOMMENDATIONS


IssueDuring the first compliance testing, the flare did not achieve 98 percent destructionefficiency. The second compliance testing occurred in April 2005, but the report will not beavailable for this Five-Year Review.

RecommendationThe second compliance testing report will not be available for this Five-Year Review.Therefore, the second compliance testing report will include how to address any problemsidentified with the performance of the flare. Additionally, resolutions will be identified forall outstanding recommendations included in the First Compliance Testing Report FresnoSanitary Landfill Jensen Avenue Fresno California (July 2004).

This includes evaluating data collected as part of the second compliance testing todetermine the mass of VOCs in the exhaust air from the groundwater treatment packedtower aerator (PTA) to account for all VOC sources. Because of the correlation between theVOC concentrations in groundwater and the potential VOC emissions in the exhaust airfrom the PTA, future scheduled compliance tests should include review and discussion ofthe total VOC influent groundwater concentrations. This review should include verificationthat no significant increases in total VOCs have occurred over time. Only if significantchanges are found, would retesting the PTA exhaust air emissions be necessary.

IssueThe absence of dioxin testing of the flare has been an issue raised in the past.

Recommendation1. Perform modeling to evaluate what dioxin emissions level from the flare stack would

result in a 10-6 excess cancer risk to the maximally-exposed individual (probably aworker at the adjacent sports complex or a neighbor). If the level of emissions necessaryfor a 10-6 increase in cancer risk is much higher than we would expect from the landfillflare, then dioxin testing may not be called for at this time.

2. Consider reviewing data (when they are available) from a similar landfill site wheredioxin testing has been performed recently. These data may assist in drawing furtherconclusions about the potential need for testing at FSL.

3. Perform sampling if analysis above indicates flare stack emissions level may exceedhealth protective standards (10-6 excess cancer risk or 200 pg/m-3).

Additional recommendation: In evaluating the performance of the flare, considerationshould be given to modifying the stack so that dioxin testing could be easily accomplishedin the future, particularly if system reengineering already will be necessary to bring the flareinto compliance.

IssueThere has not been an ecological risk assessment conducted at the site. A review ofecological reports for the site found that a screening-level ecological risk assessment shouldhave been conducted (USEPA 2003). The squirrel bait that is currently dispensed around the



landfill and the heat of the flare that kills birds and bees could both be a threat toendangered species in the area.

RecommendationConduct a screening-level ecological risk assessment or an acceptable alternative assessmentthat evaluates the protectiveness of the remedy (i.e., ensure there are no exposure pathwaysconnecting landfill constituents and ecological receptors) and identifies any current adverseimpacts of the remedy on the environment.

IssueDebris and water were found in some of the gas monitoring wells (MMW4 at depths of5 feet, 25 feet, and 45 feet and MMW3 at 5 feet). Also, one of the wells, MMW5 at 25 feetdeep, detected methane at 13.4 percent by volume.

RecommendationMaintenance should be conducted on the gas monitoring wells. MMW5 is located close to thewaste and not near the property line. If the methane levels do not decrease, the City may needto install an additional well between MMW5 and the property line along Jensen Avenue.

7.3 Issues Related to the Groundwater (OU-2)Issues identified during the Five-Year Review process relate to groundwater movementconcerns and flow meter issues.

IssueThe vertical migration of constituents appears to be increasing the concentration of PCE inthe C-Aquifer.

Recommendation Continue to monitor the concentration changes in well clusters.

Use the groundwater model to predict how vertical migration of constituents of concerncan be reduced, and consider the results of this analysis in evaluating the effectiveness ofthe Phase 1 remedial action for groundwater cleanup as appropriate.

IssueThe extraction wells have been operating at lower flow rates than designed. This leads toissues such as incomplete containment of the plume and non-functioning flow meters.

Recommendation Replace flow meters.

Review flow rate data after the extraction well rehabilitation activities. Semi-annual orannual well rehabilitation activities may be necessary if these activities are found toresult in improved flow rates.



Review groundwater elevation data since the decommissioning of the agricultural wells.

The Phase 1 evaluation should assess the implications of the low extraction rates.



TABLE 7-1Summary Table- Issues, Recommendations, and Follow-up ActionsFirst Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

AffectsProtectiveness

(Y/N)

Issue Recommendations and Follow-up ActionsParty

Responsible

Over-sight

AgencyMilestone

Date* Current Future

Sitewide Institutional controls needto be in place.

a) An ESD will be produced for the site including comprehensiveinstitutional controls including a restrictive covenant.

USEPA ——- 2007 N Y

The flare did not achieve 98%destruction efficiency.

a) The second compliance testing report will include how to addressany problems identified with the performance of the flare.Additionally, resolutions will be identified for all outstandingrecommendations included in the First Compliance Testing ReportFresno Sanitary Landfill Jensen Avenue Fresno California (July2004).

This includes evaluating data collected as part of the secondcompliance testing to determine the mass of VOCs in the exhaustair from the groundwater treatment packed tower aerator (PTA) toaccount for all VOC sources. Because of the correlation betweenthe VOC concentrations in groundwater and the potential VOCemissions in the exhaust air from the PTA, future scheduledcompliance tests should include review and discussion of the totalVOC influent groundwater concentrations. This review shouldinclude verification that no significant increases in total VOCs haveoccurred over time. Only if significant changes are found, wouldretesting the PTA exhaust air emissions be necessary.

City ofFresno

USEPA 2005 Y Y





(Y/N)


Responsible

Over-sight

AgencyMilestone


Absence of dioxin testing of theflare has been an issue raised inthe past.

a) Perform modeling to evaluate what dioxin emissions level from theflare stack would result in a 10-6 excess cancer risk to themaximally-exposed individual (probably a worker at the adjacentsports complex or a neighbor). If the level of emissions necessaryfor a 10-6 increase in cancer risk is much higher than we wouldexpect from the landfill flare, then dioxin testing may not be calledfor at this time.

b) Consider reviewing data (when available) from a similar landfill sitewhere dioxin testing has been performed recently. These data mayassist in drawing further conclusions about the potential need fortesting at FSL.

c) Perform sampling if analysis above indicates flare stack emissionslevel may exceed health protective standards (10-6 excess cancerrisk or 200 pg/m3)

Additional recommendation: In evaluating the performance of the flare,consideration should be given to modifying the stack so that dioxintesting could be easily accomplished in the future, particularly ifsystem reengineering already will be necessary to bring the flareinto compliance.

City ofFresno

USEPA April 2006 N Y

There has not been an ecologicalrisk assessment conducted at thesite.

The squirrel bait and heat of theflare are potential threats toendangered species in the area.

a) Conduct a screening-level ecological risk assessment or anacceptable alternative assessment that evaluates theprotectiveness of the remedy (i.e., ensure there are no exposurepathways connecting landfill constituents and ecological receptors)and identifies any current adverse impacts of the remedy on theenvironment.

City ofFresno

USEPA April 2006 N N





(Y/N)


Responsible

Over-sight

AgencyMilestone


Debris and water were found insome of the gas monitoring wells.Also, one of the wells, MMW5 at 25ft. deep, detected methane at13.4% by volume.

a) Conduct maintenance on the gas monitoring wells.

b) Continue to monitor methane levels.

c) If the methane levels do not decrease, the City may need to installan additional well between MMW5 and the property line alongJensen Avenue.

City ofFresno

USEPA April 2006 N Y

The vertical migration ofconstituents appears to beincreasing the concentration ofPCE in the C-Aquifer.

a) Continue to monitor the concentration changes in well clusters.

b) Use the groundwater model to predict how vertical migration ofconstituents of concern can be reduced, and consider the results ofthis analysis in evaluating the effectiveness of the Phase 1remedial action for groundwater cleanup as appropriate.

City ofFresno

USEPA Early2006

Y Y

The extraction wells have beenoperating at lower flow rates thandesigned. This leads to issues suchas incomplete containment of theplume and non-functioning flowmeters.

a) Replace flow meters.

b) Review flow rate data after extraction well rehabilitation activities.Semi-annual or annual well rehabilitation activities may benecessary if these activities are found to result in improved flowrates.

c) Review groundwater elevation data since the decommissioning ofthe agricultural wells.

d) The Phase 1 evaluation should assess the implications of the lowextraction rates.

City ofFresno

USEPA Early2006

Y Y

* Per the protectiveness statement.


SECTION 8.0

Protectiveness Statement

A protectiveness determination of the remedies for both OU-1 and OU-2 cannot be made atthis time until further information is obtained and actions are completed. The informationand actions required for OU-1 includes demonstration that the flare performs adequately toprevent/eliminate emission levels that are unsafe, resolution of the potential dioxinemissions issue (i.e., perform modeling or sampling, and/or review data from similarlandfill site), and completion of a screening-level ecological risk assessment. It is expectedthat these actions will take no more than 6 months to complete.

The information and actions required for OU-2 includes demonstration of adequate captureand migration control of the contamination plume through capture-zone analysis. ThePhase I evaluation will assess the overall efficacy and protectiveness of the remedy. Thisevaluation will provide recommendations for any further modifications and is anticipatedto be completed in early 2006.

The action required for both operable units relates to institutional controls. For the remedyto be protective in the long-term, institutional controls such as execution and recordation ofa restrictive covenant for the property that would bind current and future owners andrestrict certain uses of the site itself, including residential use, and prohibit use of thegroundwater underneath the site, need to be implemented. It is anticipated that this actionwould be completed by 2007.

As the required information is obtained and actions are completed at each of the operableunits, the protectiveness determination will be made at that time.


SECTION 9.0

Next Five-Year Review

The next Five-Year Review for the Fresno Sanitary Landfill will be performed in 2010.


SECTION 10.0

References

Camp Dresser & McKee (CDM). 1994. Fresno Sanitary Landfill: Remedial Investigation Report;Final. May.

__________. 1999. Fresno Sanitary Landfill: Early Groundwater Remedial Action ConstructionCompletion Report. November.

__________. 2000. Fresno Sanitary Landfill: Performance Monitoring Program Plan OperableUnit 2. November.

__________. 2001a. Fresno Sanitary Landfill: Operable Unit No. 2 Construction CompletionReport. September.

__________. 2001b. City of Fresno: Revised Plume Boundary Monitoring Well Siting. January.

__________. 2002. Fresno Sanitary Landfill: Fall 2001 Semi-Annual Performance MonitoringProgram Report. January.

__________. 2003a. Fresno Sanitary Landfill: Fall 2003 Semi-Annual Performance Monitoring andPhase 1 Groundwater Remedial Action Evaluation Report. December.

__________. 2003b. Fresno Sanitary Landfill: Spring 2003 Semi-Annual Performance MonitoringProgram Report. July.

__________. 2003c. Final Fresno Sanitary Landfill Technical Memorandum – InstitutionalControls. January.

__________. 2003d. Fresno Sanitary Landfill Operations and Maintenance Plan OU-2Groundwater Remediation System. May.

__________. 2003e. Interim Remedial Action Report. May.

__________. 2004. Fresno Sanitary Landfill: Spring 2004 Semi-Annual Performance MonitoringProgram Report. July

__________. 2005a. Sanitary Landfill: Fall 2004 Semi-Annual Performance Monitoring ProgramReport (Compact Disc). January.

__________. 2005b. Raw Data in Excel Sheet: TREND PLOTS and waterlevel2.xls May.

__________. 2005c. Raw Data in Excel Sheet: July 2003 voc trends v02.xls May.

__________. 2005d. Fresno Sanitary Landfill: Emerging Compounds Analytical Results. August 1.

City of Fresno. 1992. Letter from Jay Adams, Management Analyst Solid Waste Division, to GeorgeSlater, Project Coordinator for the City of Fresno. Status: Residents in Proximity to CityLandfill Receiving Bottled/Filtered Water. January.

SECTION 10.0: REFERENCES


City of Fresno. 2000. 1999-2000 Annual Report for Storm Water Discharges Associated withIndustrial Activities. Submitted to: State of California – State Water Resources ControlBoard. July.

__________. 2001. 2000-2001 Annual Report for Storm Water Discharges Associated withIndustrial Activities. Submitted to: State of California – State Water Resources ControlBoard. July.




__________. 2005. Fresno Sanitary Landfill: Progress Report – 1st Quarter 2005. April.

GeoSyntec Consultants, Inc. 2001. Draft Construction Completion Report Closure ConstructionActivities for Operable Unit 1; Fresno Sanitary Landfill; Volume 1 of 3. September.

__________. 2002. Prefinal Compliance Testing Plan; Fresno Sanitary Landfill. September.

__________. 2003. Final Compliance Testing Plan; Fresno Sanitary Landfill. February.

ICF Technology, Inc. 1994. Final Human Health Risk Assessment for the Fresno Sanitary LandfillSuperfund Site Fresno, California. September.

Kleinfelder. 20B04. First Compliance Testing Report Fresno Sanitary Landfill Jensen AvenueFresno, California. July.

Kleinfelder and GeoSyntec Consultants. 2003a. Final Remedial Action Report for Operable Unit1; Fresno Sanitary Landfill. June.

__________. 2003b. Final Post-Closure Operations and Maintenance Plan for the Source ControlOperable Unit (SCOU); Fresno Sanitary Landfill. June. (Appendix E of FinalRemediation Action Report for OU1)

Nyznyk, Yash, Project Manager for CDM. 2005. Email correspondence to Debbie Seibold,CH2M HILL: May 17th. C-Aquifer April 2000 Water Quality Results. May.

Phillips, Pete, URS Technical Oversight for USEPA. 2005. Email correspondence to DebbieSeibold, CH2M HILL: April 11, 2005 Tech Mtg. for FSL. May.

Slater, George. 2005. Conversation during Site Inspection. March.

United States Department of the Interior (USDOI) 1991. Fish and Wildlife Enhancement; SpeciesList for the Proposed Fresno Sanitary Landfill Site, Southwest of Fresno, Fresno County,California. December.

SECTION 10.0: REFERENCES


United States Environmental Protection Agency (USEPA). 1993a. Record of Decision – FresnoSanitary Landfill. September.

__________. 1993b. Amendment to Administrative Consent Order U.S. Docket No. 90-22.December.

__________. 1996. Record of Decision – Fresno Sanitary Landfill. September.

__________. 2001. Comprehensive Five-Year Review Guidance, EPA 540-R-01-007. June.

__________. 2003. Letter to George Slater, Project Coordinator for the City of Fresno. Comments forthe Operable Unit No. 2 Construction Completion Report and Operations and MaintenancePlan OU-2 Groundwater Remediation System; Fresno Sanitary Landfill November 2002.January.

__________. 2003. Summary of Ecological Information on Fresno Sanitary Landfill Site.

__________. 2004. Letter to George Slater, Project Coordinator for the City of Fresno. New RemedialProject Manager (RPM), Five-Year Review, Dioxin/Furan Sampling. August.

__________. 2005. E-mail from Dan Stralka/USEPA to Lisa Hanusiak/USEPA. August 17.

APPENDIX A

Documents Reviewed

E092005004SAC/324131/052550001 (5YEARREVIEWREPORT_FINAL.DOC) A-1

APPENDIX A

Documents Reviewed

Camp Dresser & McKee. 1992. Technical Memorandum; Fresno Sanitary Landfill LeachateInvestigation. May.

__________. 1994. Fresno Sanitary Landfill: Remedial Investigation Report. Final. May 20.

__________. 1996. Fresno Sanitary Landfill: Revised Final Feasibility Study Report. July.

__________. 1997. Fresno Sanitary Landfill: September 1997 Semiannual Groundwater MonitoringReport. November.

__________. 1998. Fresno Sanitary Landfill: April 1998 Semiannual Groundwater MonitoringReport. June.

__________. 1999. Fresno Sanitary Landfill: Technical Memorandum; Early Groundwater RemedialAction. January.

__________. Final (100 percent) Groundwater Remedial Design Submittal. Volume 1: DesignReport. July.

__________. 1999. Fresno Sanitary Landfill: Early Groundwater Remedial Action ConstructionCompletion Report. November.

__________. 2000. Fresno Sanitary Landfill: Performance Monitoring Program Plan Operable Unit2. November.


__________. 2001. Fresno Sanitary Landfill: Revised Plume Boundary Monitoring Well Siting.January.

__________. 2001. Fresno Sanitary Landfill: Operable Unit No. 2 Construction Completion Report.September.

__________. 2001. Fresno Sanitary Landfill: Operable Unit No. 1 Construction Completion Report.September.


__________. 2002. Fresno Sanitary Landfill: Spring 2002 Semi-Annual Performance MonitoringProgram Report. July.

__________. 2003. Final Fresno Sanitary Landfill Technical Memorandum – Institutional Controls.January.

APPENDIX A: DOCUMENTS REVIEWED



__________. 2003. Fresno Sanitary Landfill: Operations and Maintenance Plan OU-2 GroundwaterRemediation System. May.

__________. 2003. Interim Remedial Action Report. May.

__________. 2003. Fresno Sanitary Landfill: Spring 2003 Semi-Annual Performance MonitoringProgram Report. July.

__________. 2003. Fresno Sanitary Landfill: Fall 2003 Semi-Annual Performance Monitoring andPhase 1 Groundwater Remedial Action Evaluation Report. December.

__________. 2004. Fresno Sanitary Landfill: Spring 2004 Semi-Annual Performance MonitoringProgram Report. July

__________. 2005. Letter to Ms. Lisa Hanusiak U.S. Environmental Protection Agency; FresnoSanitary Landfill- Operable Unit 2 Proposed Modification of the Phase 1 PerformanceMonitoring Program. January.

__________. 2005. Fresno Sanitary Landfill: Fall 2004 Semi-Annual Performance MonitoringProgram Report. January. (Compact Disc)

__________. 2005. Fresno Sanitary Landfill: Emerging Compounds Analytical Results. August 1.

City of Fresno. 1992. Letter from Jay Adams, Management Analyst Solid Waste Division, to GeorgeSlater, Project Coordinator for the City of Fresno. Status: Residents in Proximity to CityLandfill Receiving Bottled/Filtered Water. January.






__________. 2005. Fresno Sanitary Landfill: Progress Report – 1st Quarter 2005. April.

__________. 2005. Fresno Sanitary Landfill: Progress Report – 4th Quarter 2004. January.

APPENDIX A: DOCUMENT S REVIEWED


Department of the Interior (United States) 1991. Fish and Wildlife Enhancement; Species List forthe Proposed Fresno Sanitary Landfill Site, Southwest of Fresno, Fresno County, California.December.

Eastern District Court. 1998. Consent Decree. CIV FR -98-5195 REC SMS. February.

GeoSyntec Consultants 2001. Draft Construction Completion Report Closure ConstructionActivities for Operable Unit 1; Fresno Sanitary; Volume 1 of 3. September.

__________. 2002. Prefinal Compliance Testing Plan; Fresno Sanitary Landfill. September.

__________. 2003. Final Compliance Testing Plan; Fresno Sanitary Landfill. February.

ICF Technology, Inc. 1994. Final Human Health Risk Assessment for the Fresno Sanitary LandfillSuperfund Site Fresno, California. September.

Kleinfelder. 2004. First Compliance Testing Report; Fresno Sanitary Landfill. July.

Kleinfelder and GeoSyntec Consultants. 2003. Final Remedial Action Report for Operable Unit 1Fresno Sanitary Landfill Fresno, California. June.

Kleinfelder and GeoSyntec Consultants. 2003. Final Post-Closure Operations and MaintenancePlan for the Source Control Operable Unit (SCOU); Fresno Sanitary Landfill. June.(Appendix E of Final Remediation Action Report for OU1).

San Joaquin Valley Unified Air Pollution Control District. 1998. Re: Air Pollution ControlRequirements for Fresno Landfill Remediation Project. September.

State Water Resources Control Board. 1996. Letter to Ms. Thelma Estrada Office of RegionalCounsel United States Environmental Protection Agency, Region 9 City of Fresno SanitaryLandfill ARARS. January.

USEPA. 1993. Record of Decision – Fresno Sanitary Landfill. September.

__________. 1993. Amendment to Administrative Consent Order U.S. Docket No. 90-22. December.

__________. 1996. Letter for the public: USEPA Issues Proposed Plan to Clean Up Groundwater. July.

__________. 1996.Record of Decision – Fresno Sanitary Landfill. September.

__________. 2001. Comprehensive Five-Year Review Guidance, EPA 540-R-01-007. June.

__________. 2003. Letter to George Slater, Project Coordinator for the City of Fresno. Comments forthe Operable Unit No. 2 Construction Completion Report and Operations and MaintenancePlan OU-2 Groundwater Remediation System; Fresno Sanitary Landfill November 2002.January.

__________. 2003. Summary of Ecological Information on Fresno Sanitary Landfill Site.

__________. 2004. Letter to George Slater, , Project Coordinator for the City of Fresno. NewRemedial Project Manager (RPM), Five-Year Review, Dioxin/Furan Sampling. August.

__________. 2005. Letter to George Slater, Project Coordinator for the City of Fresno. RE: Request forOperational Modification for Phase 1 Groundwater Remedial Action, Fresno Sanitary Landfill .April.

APPENDIX A: DOCUMENTS REVIEWED


__________. 2005. Fact Sheet: USEPA begins Five-Year Review of Cleanup at Site: Fresno SanitaryLandfill Superfund Site. March.

__________. 2005. Newspaper Ad: USEPA begins Five-Year Review of Cleanup at Fresno SanitaryLandfill Superfund Site.

APPENDIX B

Community Notification

��

��

��

��

��

��

North

C h u r c hC

herr

y A

ve.

Elm

Ave

.

Fig

Ave

.

Wal

nut A

ve.

Wes

t Ave

.

Fru

it A

ve.

Ma

rks

Av

e.

Ave.Ave.

A v e.

A v e.

Three miles west ofHighway 99

Fresno Sanitary Landfill Superfund Site

A v e.

99F R E S N O

N

J e n s e n

A n n a d a l e

�� !��"��"�

��

�� !�"��#��

�� "��

� ��"��#��$��

��

��

�� !��"�� #�� "�� $�� %��

��

#��&'#��(�� !�� )�� *�� !�� #��&'#�� (��

�� +��'�� ,�� #�� -��.��/��/��

��

��&'#�� 0� ��1��*��1��2��/��'�� 3�� 455!�$6"�6578�� .�� &'#)��9::��:�;:��:�� -��3�� 1��

��

#�� "�� "��#��

�� $��%&'�� (�� $��)*�� +��,��

��-� ��.��#�� #��

� �� "�� #�� %/01��

�� %/2/�� 3 �� !��

� � �� +��%//0!��4�� 5��

��

�� 6�%��+�� !��

�� #�� 7**%��

�� 8�� +��%//)!��4�� 5�� 9��

�� 6�7��+!��9�� :�� !

�� $� �� 9

�� !��++�� ;�� $� ��

�� +++��

�� 8��

�� +!��"�� 3 �� "��.�� %///��

�� 8��

��+�� 7**%�� !��

��

ADMINISTRATIVE RECORDS

WO

RKPL

ANS

��

��

4�� :�� !��59190

1'�<��

�� !�"��/&%*'

�&%'��/1790%'7

��

7&7*��

� ��!�"�

�7*/��&2290%''

��

/'�<��

�� !�"��/&%*'

�&%'��'0)97***

��

"��+��590�

1'�<��

�� !�"��/&%*'

�&%'��/179070)

��

��

��

��

��

��

�� !

"��#�$�%��&��'��(

��)�� !*+,�

��-��.��/0��&��)��1,�(

��

� ��

��&'#�� #��/� ��

��

U.S. EPA BEGINS FIVE YEAR REVIEW OF CLEANUP AT THE FRESNO MUNICIPAL SANITARY LANDFILL

SUPERFUND SITEThe United States Environmental Protection Agency (U.S. EPA) has begun the process of reviewing thecleanup remedies at the Fresno Municipal Sanitary Landfill Superfund site (Site) in Fresno, CA. Thereview process will evaluate the effectiveness of the landfill cover and groundwater remediation systemsinstalled by the City of Fresno (City).

THE ISSUE AND THE SOLUTION IMPLEMENTED

The primary objective of the review is to assure that the cleanup activities undertaken by the City areprotective of both human health and the environment. Cleanup goals established for the Site includestopping the migration of contaminated groundwater from leaving the Site and cleaning up contaminatedgroundwater that has already moved off the Site to drinking water standards established by the federalgovernment and the State of California. Contaminants that are currently being cleaned up at the Siteinclude chemicals contained in the gas that is emitted to the atmosphere from the landfill and volatileorganic chemical compounds in groundwater. To better manage the cleanup activities, the Site wasdivided into two components called operable units (OUs). Operable Unit 1 included the installation of alandfill cover, a landfill gas collection system and a surface water management system. All the componentsof OU 1 help collect gas and leachate currently released by the landfill. Operable Unit 2 included theinstallation of a groundwater extraction and treatment system to cleanup chemical contaminants and agroundwater monitoring well network to measure the effectiveness of the groundwater treatment system.

THE REVIEW PROCESS

The Superfund law requires the U.S. EPA to evaluate the effectiveness and protectiveness of remedialsystems every five years until the cleanup is complete. This first, Five-Year review of the Site willaddress the operation of the OUs and the Site’s institutional controls. Upon completion, a copy of thefinal report will be placed in the local information repository listed below. Additionally, a notice,announcing the completion of the Five-Year Review Report will be placed in the local paper.

INFORMATION REPOSITORIES: Fresno County Central Library.2420 Mariposa Street, Fresno, CA.(209) 488-3155.

CONTACT INFORMATION: Jackie Lane, Community Involvement Specialist (SFD-3)(415) 972-3236or toll-free 800 231-3075. You can obtain further site information from the U.S. EPA’s web site athttp://yosemite.epa.gov/r9/sfund/overview.nsf

3.75x4.5FresnoLandfillSuperfund.qxd

APPENDIX C

Five-Year Review Site Inspection Checklist andInterview Summary Forms

E092005004SAC/324131/052550001 (5YEARREVIEWREPORT_FINAL.DOC) C-1

APPENDIX C

Five-Year Review Site Inspection Checklist andInterview Summary Forms

TABLE C-1Site Inspection Team RosterSite Inspection- March 9-10, 2005First Five-Year Review Report for Fresno Municipal Sanitary Landfill Superfund Site, Fresno County, California

Name Title Affiliation

Lisa Hanusiak Remedial Project Manager United States Environmental ProtectionAgency Region 9

George Slater Project Manager/Coordinator for the City City of Fresno

Jeff Garner Groundwater Treatment Plant Operator City of Fresno

Debbie Seibold Task Manager CH2M HILLOakland Office

Tina Girard Task Manager CH2M HILLOakland Office

1

Five-Year Review Site Inspection ChecklistFresno Municipal Sanitary Landfill Superfund Site

I. SITE INFORMATION Applicable

Site name:Fresno Municipal Sanitary Landfill

Date of inspection:Wednesday, March 9, 2005

Location and Region:Fresno, CA, Region IX

EPA ID:CAD980636914

Agency, office, or company leading the five-yearreview:EPA Region IX

Weather/temperature:Sunny, 75-80˚

Remedy Includes: (Check all that apply) Landfill cover/containment

Access controls Institutional controls Groundwater pump and treatment

Surface water collection and treatmentOther

Attachments: Inspection team roster attached Site map attached [in report]

II. INTERVIEWS (Check all that apply) Applicable

1. O&M site manager George Slater Project Coordinator- City of Fresno 3/9/05Name Title Date

Interviewed: 3/10/05 Phone No: (559) 960-8049 CellProblems; suggestions: See Attached interview summary form

NOTE: All referenced attachments can be found in Five-Year Review Report.

2. O&M staff Jeff Garner Water Systems Operator 3/9/05Name Title Date

Interviewed: 3/10/05 Phone No.: (559) 498-1426 OfficeProblems; suggestions: See attached interview summary form

2

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

Agency California RWQCB Central Valley Region

Contact: Bruce Myers Associate Engineering Geologist 3/10/05 (559) 488-4397Name Title Date Phone No.

Problems; suggestions: See attached interview summary form

Agency

ContactName Title Date Phone No.

Problems; suggestions:

4. Other interviews (optional)

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

1. O&M DocumentsO&M manual Readily available Up to dateAs-built drawings Readily available Up to dateMaintenance logs Readily available Up to date

Remarks

2. Site-Specific Health and Safety Plan Readily available Up to dateContingency plan/emergency Readily available Up to date

response planRemarks

3. O&M and OSHA Training RecordsReadily available ~Up to date N/A

Remarks Jeff will be trained next month – or at the first available in-town class.

4. Permits and Service AgreementsAir discharge permit Readily available Up to date N/AEffluent discharge Readily available Up to date N/AWaste disposal, POTW Readily available Up to date N/AOther permits Storm Water Permit Readily available Up to date N/A

Remarks

3

5. Gas Generation Records Readily available Up to date N/A

Remarks

6. Settlement Monument Records Readily available Up to date N/A

Remarks There are no settlement monuments at the landfill.

7. Groundwater Monitoring Records Readily available Up to date N/A

Remarks

8. Leachate Extraction Records Readily available Up to date N/A

Remarks Leachate collection not performed.

9. Discharge Compliance RecordsAir – See below Readily available Up to date N/AWater (effluent) Readily available Up to date N/A

Remarks Air – 2 rounds of start up performance monitoring; next round scheduled May.

10. Daily Access/Security Logs Readily available Up to date

Remarks None________________________________________________________________

IV. O&M COSTS Applicable

1. O&M OrganizationState in-house Contractor for StatePRP in-house Contractor for PRPOther City in-house

2. O&M Cost RecordsReadily available Up to dateFunding mechanism/agreement in place NAOriginal O&M cost estimate Breakdown attached

Total annual cost by year for review period if available

Date Date Total cost

From 2004 To 2005 $787,100 (estimate) Breakdown attachedDate Date Total cost

From 2003 To 2004 $551,308 Breakdown attachedDate Date Total cost

See Section 4.2.3 in the Five-Year Review for more information.

4

3. Unanticipated or Unusually High O&M Costs During Review PeriodDescribe costs and reasons:

Minor: Higher frequency of well cleaning.

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable

A. Fencing

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

Remarks Good condition. Public has access to all areas during daylight. At dusk, gate is secured.

B. Other Access Restrictions

1. Signs and other security measures Location shown on site map N/A

Remarks No smoking signs and hazardous materials/MSDS posted at the facility (office & treatmentsystem)

C. Institutional Controls1. Implementation and enforcement

Site conditions imply ICs not properly implemented Yes NoSite conditions imply ICs not being fully enforced Yes No

Type of monitoring (e.g., self-reporting, drive by)FrequencyResponsible party/agency

ContactName Title Date Phone No.

Reporting is up-to-date Yes No N/AReports are verified by the lead agency Yes No N/A

Specific requirements in deed or decision documents havebeen met Yes No N/AViolations have been reported Yes No N/AOther problems or suggestions: Report attached

Comments:

The implementation of institutional controls as required by the ROD is still being discussed between the City andFresno County. Fresno County would be responsible for enforcing the proposed controls which include denyingpermit approval for installation of wells into the Well Prohibition Zone, as defined in the 2003 TechnicalMemorandum. According to current limited information, two wells were installed within the well assessmentzone. The City is trying to obtain the well installation data in order to determine if these wells might have anadverse effect on the groundwater plume and remediation system. In addition, the City will continue theirdiscussions with the County to work out an agreement as it relates to these institutional controls. An ESD wasrecommended for this site which will include a thorough list of institutional controls necessary for the Site.

5

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

Remarks See the Five-Year Review for a more complete discussion of additional ICs necessary forthe Site.

D. General

1. Vandalism/trespassing Location shown on site map No vandalism evidentRemarks

2. Land use changes onsite

RemarksRedeveloped to regional park/sports complex

3. Land use changes offsite

RemarksPurchased land to the east and constructed pond. Purchased land to west for sports complex.Purchased home and land to north now not occupied. Purchased land to south for pond.

VI. GENERAL SITE CONDITIONS Applicable

A. Roads Applicable

1. Roads Location shown on site map Roads adequate N/A

RemarksGood condition

B. Other Site Conditions

RemarksVery good vegetation coverage; no erosion present; Stormwater collection system in goodcondition. General housekeeping needed around treatment compound; specifically the removalof former temporary groundwater treatment unit antiscalent containers.

VII. LANDFILL COVERS Applicable

A. Landfill Surface

1. Settlement (Low spots) Location shown on site map Settlement not evidentAreal extent Depth

Remarks

2. Cracks Location shown on site map Cracking not evidentLengths Widths Depth

Remarks

6

3. Erosion Location shown on site map Erosion not evidentAreal extent DepthRemarks

4. Holes Location shown on site map Holes not evidentAreal extent Depth

Remarks Squirrel holes only

5. Vegetative Cover Grass Cover properly established No signs of stressTrees/Shrubs (indicate size and locations on a diagram)Remarks Grass and wild flowers in abundance ~80% coverage

6. Alternative Cover (armored rock, concrete, etc.) N/ARemarks

7. Bulges Location shown on site map Bulges not evidentAreal extent HeightRemarks

8. Wet Area/Water Damage Wet areas/water damage not evidentWet areas Location shown on site map Areal extentPonding Location shown on site map Areal extentSeeps Location shown on site map Areal extentSoft subgrade Location shown on site map Areal extentRemarks

9. Slope Instability Slides Location shown on site map No evidence of slope instabilityAreal extentRemarks

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

1. Flows Bypass Bench Location shown on site map N/A or okayRemarks

2. Bench Breached Location shown on site map N/A or okayRemarks

7

3. Bench Overtopped Location shown on site map N/A or okayRemarks

C. Letdown Channels Applicable N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep sideslope of the cover and will allow the runoff water collected by the benches to move off of the landfillcover without creating erosion gullies.)

1. Settlement Location shown on site map No evidence of settlementAreal extent DepthRemarks

2. Material Degradation Location shown on site map No evidence of degradationMaterial type Areal extentRemarks

3. Erosion Location shown on site map No evidence of erosionAreal extent DepthRemarks

4. Undercutting Location shown on site map No evidence of undercuttingAreal extent DepthRemarks

5. Obstruction Type No obstructionLocation shown on site map Areal extentSizeRemarks

6. Excessive Vegetative Growth TypeNo evidence of excessive growthVegetation in channels does not obstruct flowLocation shown on site map Areal extent

Remarks

D. Cover Penetrations Applicable N/A

1. Gas Vents NARemarks

8

2. Gas Monitoring ProbesProperly secured/located Functioning Routinely sampled Good conditionEvidence of leakage at penetration

Remarks Vault box lids should be replaced or repaired as needed.

3. Monitoring Wells (within surface area of landfill) Properly secured/located Functioning Routinely sampled Good conditionEvidence of leakage at penetration

Remarks All fitted with dedicated QED low flow sampling equipment.

4. Leachate Extraction WellsProperly secured/located Functioning Routinely sampled Good conditionEvidence of leakage at penetration Needs O&M N/A

Remarks

5. Settlement Monuments Located Routinely surveyed N/ARemarks

E. Gas Collection and Treatment Applicable N/A

1. Gas Treatment Facilities Flaring Thermal destruction Collection for reuse Good condition Needs O&MRemarks Operating at the time of inspection.

2. Gas Collection Wells, Manifolds and Piping Good condition Needs O&M

Remarks Majority of the structures are underground. All above ground structures appear in goodcondition.

3. Gas Treatment Facilities (e.g., gas monitoring of adjacent homes or buildings)Good condition Needs O&M N/ARemarks

F. Cover Drainage Layer Applicable N/A

1. Outlet Pipes Inspected Functioning N/ARemarks

2. Outlet Rock Inspected Functioning N/ARemarks

G. Detention/Sedimentation Ponds Applicable N/A

9

1. Siltation Areal extent Depth N/ASiltation not evidentRemarks 3 ponds: Georges, South, East used for collection of treated groundwater and

Stormwater runoff. Discharge is at the base of the pond at Georges. South lake – discharge pipewith rocks. Park irrigation system from Georges: South and East – high infiltration.

2. Erosion Areal extent Depth

Remarks Erosion not evident.

3. Outlet Works N/ARemarks

4. Dam N/ARemarks

H. Retaining Walls Applicable N/A1. Deformations Location shown on site map Deformation not evident

Horizontal displacement Vertical displacementRotational displacementRemarks

2. Degradation Location shown on site map Degradation not evidentRemarks

I. Perimeter Ditches/Off-Site Discharge Applicable N/A

1. Siltation Location shown on site map Siltation not evidentAreal extent DepthRemarks

2. Vegetative Growth Location shown on site map N/AVegetation does not impede flow

Areal extent TypeRemarks

3. Erosion Location shown on site map Erosion not evidentAreal extent DepthRemarks

4. Discharge Structure Functioning N/ARemarks

10

VIII. VERTICAL BARRIER WALLS Not Applicable

1. Settlement Location shown on site map Settlement not evidentAreal extent DepthRemarks

2. Performance Monitoring Type of monitoringPerformance not monitoredFrequency Evidence of breachingHead differentialRemarks

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable

A. Groundwater Extraction Wells, Pumps, and Pipelines Applicable

1. Pumps, Wellhead Plumbing, and Electrical Good condition All required wells located Needs O&M N/ARemarks 2 extraction wells inspected. Flow meters will be replaced next week.

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs O&MRemarks Most underground; above ground appeared in good condition.

3. Spare Parts and Equipment Readily available Good condition Requires upgrade Needs to be providedRemarks

B. Surface Water Collection Structures, Pumps, and Pipelines NA

1. Collection Structures, Pumps, and ElectricalRemarks

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other AppurtenancesGood condition Needs O&M NA

Remarks

3. Spare Parts and Equipment

Remarks

11

C. Treatment System Applicable

1. Treatment Train (Check components that apply)Metals removal Oil/water separation Bioremediation Air stripping Carbon adsorbers

Filters Additive (e.g., chelation agent, flocculent) - Chlorine (bleach), antiscalent Good condition Needs O&M Sampling ports properly marked and functional Sampling/maintenance log displayed and up to date - on computer Equipment properly identified

Quantity of groundwater treated annuallyQuantity of surface water treated annually 0

Remarks

2. Electrical Enclosures and Panels (properly rated and functional)N/A Good condition Needs O&M

Remarks

3. Tanks, Vaults, Storage VesselsN/ARemarks Good Condition

4. Discharge Structure and Appurtenances Good condition Needs O&MRemarks

5. Treatment Building(s) – support buildingN/A Good condition (especially roof and doorways) Needs repair Chemicals and equipment properly storedRemarks Very well organized and maintained.

6. Monitoring Wells (pump and treatment remedy) Properly secured/locked Functioning Routinely sampled Good conditionAll required wells located Needs O&M N/A

Remarks 50% wells located.

D. Monitored Natural Attenuation Not Applicable

1. Monitoring Wells (natural attenuation remedy)

Remarks_______________________________________________________________________________

X. OTHER REMEDIES Not Applicable

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

12

XI. OVERALL OBSERVATIONS Applicable

A. Implementation of the Remedy

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

The objective of OU-1 is to address onsite control of constituents by confinement of the trash prism andextraction and treatment of LFG, LFG condensate, and leachate. Currently, the integrity of the landfill isintact. From the site tour, there did not appear to be any settling of the landfill, exposed membranes, orother disrepair. The vegetation was thick and healthy. The monitoring wells are in good condition.

The objective of OU-2 is to restore the aquifer to beneficial use in a timely and cost-effective manner.OU-2 is currently in Phase I operations. The Phase I objective is plume containment around the landfill.The plume size has decreased in the years that the treatment system has been operating, but the lowextraction rates have inhibited complete containment. A second assessment of Phase I will be reportedlater this year. It will include a capture zone analysis and a newly calibrated version of the groundwatermodel. (Phillips 2005) The first assessment was not able to completely evaluate the effectivenessbecause the agricultural wells were still in operation and creating drawdown. From the site tour, OU-2appeared to be operating smoothly.

B. Adequacy of O&M

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

An employee for the City of Fresno is onsite during work-day hours maintaining the system. The ProjectManager/Coordinator for the City is also frequently onsite. Preventative maintenance is performed dailyto ensure a properly-functioning system. Daily print-outs provide information about maintenance to beperformed for the day. The maintenance is logged and kept electronically in an Excel spreadsheet, whichincludes the scheduled start date, completion date, equipment description, task number, and otherrelevant information.

The onsite City of Fresno operator conducts preventative maintenance on the flare and gas monitoringwells. The extraction wells have not been pumping at the rate for which they were designed. A knowncause for the low flow is the decrease in groundwater levels. The City cleaned extraction wells PW-2Aand PW-3A to see if biofouling was also part of the cause of the low flow. In 2004, all of the extractionwells were operating between 81 and 99 percent of the time. Reasons for extraction well downtimeinclude cleaning and adjustment of flow rates to compensate for the low water levels.

The treatment plant, including the flare, was down for routine maintenance because of local powerfailures and upgrades and repair of the SCADA system. According to the Fall 2004 Semi-AnnualMonitoring Report (CDM 2005a), there were numerous weekend shutdowns while staff were not present.The system was not started up again until Monday when staff returned. The Operations and MaintenancePlan states that the plant will remain off-line until a manual shutdown RESET is invoked in the mainplant central computer monitor. This does not appear to be a large problem because operation of theextraction wells has been consistently over 80% in recent years. (CDM 2003d)

The flow meters are to be replaced in early 2005. Low flows could indicate a potential problem as far asthe ability to contain the contamination.

The early action groundwater treatment equipment is still kept onsite in the treatment area. This isunnecessary and should be removed.

13

C. Early Indicators of Potential Remedy Failure

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a highfrequency of unscheduled repairs, that suggest that the protectiveness of the remedy may becompromised in the future.

From the site inspection, no major issues exist that could affect the protectiveness of the remedy.

D. Opportunities for Optimization

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

The City is proactive in looking for optimization opportunities. Currently, the percent oxygen, methane,and carbon dioxide is adjusted at the methane gas monitoring wells manually. This optimizes theperformance of the flare.

The City is currently in the process of requesting a decrease in sampling for inorganics. The City isproactive in looking for opportunities to reduce costs via sampling. Possible opportunities exist to usethe methane gas for the treatment plant’s electricity needs. This was examined in the past and was, forthe time, deemed impractical. Documentation regarding potential methane gas usage was not available.

SLATER_REVISED_FINAL.DOC

1 OF 3 06/05/05

Five-Year Review Interview Record

Interviewee: George Slater

City of Fresno

Site Name

EPA ID No.

Date of Interview

Interview Method via

Fresno Municipal Sanitary Landfill

CAD 98036914

3/10/05

Phone Fax/email In person ⌧

Interview Contacts

Organization

Phone

Email

Address

Lisa Hanusiak

US EPA Region 9

(415)972-3152

[email protected]

75 Hawthorne Street San Francisco, CA 94105

Tina Girard

CH2M HILL / SFO, as rep of EPA

(510) 587-7586

[email protected]

155 Grand Ave, Suite 1000 Oakland, CA 94612

Interview Questions 1. What is your current role as it relates to the site? What is your overall impression of

the work conducted at the site to date? (general sentiment) Response: Project Manager/Coordinator for the City of Fresno Overall impression is that there is very good work conducted at the site. 2. What is the current status of construction? Have any problems or difficulties been

encountered that have impacted construction progress or implementability? Response: OU1: Complete. IT Corporation (contractor) declared bankruptcy during construction causing some delays. OU2: Phase I Complete. Evaluating the need for Phase II. Ability to acquire offsite irrigation wells was a long process (approximately 2 years). Wanted to obtain these wells because of the pumping affects and the potential for cross contamination (screened across multiple zones). Resident was operating irrigation well throughout negotiations.

3. Have there been routine communications or activities (site visits, inspections, reporting activities, etc) conducted by your office regarding the site? If so please give purpose and results.

Response: The City of Fresno Manages the site. George is onsite regularly.


2 OF 3 06/05/05

4. What does the monitoring data show? Are there any trends that show contaminant

levels are decreasing? Have any new or emerging COCs been identified? If so, have they impacted the effectiveness of the remedy?

Response: I have limited knowledge of data trends; overall there are sporadic changes in wells: some decreasing, others fluctuate. In terms of new COCs: there was discussion of dioxin from the flare; however this was never sampled for. Dioxin is developed in the flare it is a by-product of combustion. Never sampled for emergent chemicals such as NDMA, perchlorate, chromium, etc… 5. Is there a continuous on-site O&M presence? If so, please describe staff and

activities. If there is not a continuous on-site presence, describe staff and frequency of site inspections and activities.

Response: Continuous on-site presence weekdays from 7 am to 3:30 pm and there is an auto dialer connected to the treatment compound should any alarms sound. CDM (City’s consultant) is onsite monthly and perform regular site audits. Rosemary (City of Fresno employee) assists Jeff Garner (City of Fresno employee) with groundwater sampling events. 6. Have there been unexpected O&M difficulties or costs at the site in the last five

years? If so, please give details. Response: OU1: Currently there are plans to paint the flare. The heat from the flare has created a need to repaint sooner than expected. OU2: Chemical injection system was not planned for in the original design. The design was updated to incorporate because the temporary groundwater treatment facility was used prior to construction of the current OU2 treatment facility. Higher frequency of well cleaning necessary than anticipated (i.e. algae). The flow meters and totalizer were designed for higher flow. The water levels have decreased across the site resulting in lower flow and therefore the flow meters are ineffective for the lower range. Currently investigating and replacing as needed. 7. Would you say that O&M and/or sampling efforts have been optimized? Please

describe how improved efficiency has or has not occurred. Response: Improved efficiency has occurred through the following: City of Fresno took over groundwater sampling one year ago to decrease costs, however maintained CDM for quality assurance oversight. Recently, proposed using the City’s waste water treatment lab for analyses of certain compounds to reduce long term costs. Computerized the operations and maintenance schedule using the waste water treatment plant system to produce daily work orders.


3 OF 3 06/05/05

Currently, there is a trailer under construction for groundwater sampling to improve efficiency. The City recently requested reduced sampling frequency for organics. EPA is reviewing the request. 8. Are you aware of any institutional controls, site access controls, new ordinances in

place, changes in actual or projected land use, complaints being filed or unusual activities at the site? If so, please describe in detail.

Response: The land (Fresno Landfill) will remain a park for the foreseeable future. There have been no complaints or unusual activities, nor known changes in land use or ordinances. The status of other project related institutional controls is unknown. 9. Have any problems been encountered which required, or will require changes to this

remedial design or ROD? Response: Not thus far, currently the following activities are in progress: OU2: Contingent upon Phase I evaluation report. OU1: Round 1 evaluation of flare did not pass the performance criteria. The temperature of the flare was increased after sampling by altering the louver controls in hopes that Round 2 of sampling will pass the performance criteria. 10. Do you have any comments, suggestions, or recommendations regarding the site? Response: I would like to see Site delisted from NPL. From community stand point, there is negative connotation associated with a Superfund Site.

GARNER_REVISED_FINAL.DOC 1 OF 3 06/05/05


Interviewee: Jeff Garner

City of Fresno

Site Name

EPA ID No.

Date of Interview



CAD 98036914

3/10/05

Phone Fax/email In person ⌧

Interview Contacts

Organization

Phone

Email

Address

Lisa Hanusiak

US EPA Region 9

(415)972-3152

[email protected]


Tina Girard


(510) 587-7586

[email protected]



the work conducted at the site to date? (general sentiment) Response: Groundwater Treatment Plant Operator, primary on-site staff person for the past 2 years. Work conducted at the site is the best job; a very “tight ship”; enjoys the work. 2. What is the current status of construction? Have any problems or difficulties been

encountered that have impacted construction progress or implementability? Response:

OU1: Completed. Maintenance (mowing) will transfer to Parks Dept. this year. OU2: Phase I completed. Currently constructing new irrigation wells for neighboring

roperties. p 3. Have there been routine communications or activities (site visits, inspections,

reporting activities, etc) conducted by your office regarding the site? If so please give purpose and results.

Response: George Slater visits the site every day Supervisor – Waste Management – once a month CDM – once a month




Response: Data fluctuates. Overall the groundwater data is decreasing. The soil gas data is predictable, there is nothing consistently unusual. 5. Is there a continuous on-site O&M presence? If so, please describe staff and


Response: Yes – Jeff performs all O&M operations per O&M manuals and MP2 Program. 6. Have there been unexpected O&M difficulties or costs at the site in the last five

years? If so, please give details. Response: The flow meters were designed for higher flow. There has been a decrease in water level elevation at the site and therefore lower pumping rates. The flow meters are not able to accurately record the lower flow rates. Throttle valves on extraction wells – bad design, plan to replace during plant shutdown with a better design. 7. Would you say that O&M and/or sampling efforts have been optimized? Please

describe how improved efficiency has or has not occurred. Response: Jeff mapped the sampling order (route) more efficiently for periodic groundwater sampling events. Currently a sampling trailer is being fabricated to increase efficiency. Proposed performing inorganic analyses by the City’s waste water management lab to save money. Also MP2 software is used to plan , track & document a preventive maintenance schedule. 8. Are you aware of any institutional controls, site access controls, new ordinances in


Response: May restrict access to landfill in the future – concerned over open vaults. PVC bait dispensers for squirrels are not an issue for coyotes or the public. Vandalism was a concern but has not occurred at the site.


9. Have any problems been encountered which required, or will require changes to this

remedial design or ROD? Response: Flow Meter , Landfill Gas Vault lids & Throttle Valves will be changed. 10. Do you have any comments, suggestions, or recommendations regarding the site? Response: The concrete vault lids on the soil gas monitoring locations are too heavy (approximately 200 pounds) for one person to lift. Currently looking into new vault lids for soil gas monitoring locations – durable (sun damage) and lighter weight. $15,000 budgeted for lids. Suggest using extracted gas for power generation or compressor station and send to wastewater treatment plant. Additionally, place gravel or pavement on the perimeter road (currently muddy). Lastly, dispose of the old air strippers no longer needed for use at the site.

NYZNYK_REVISED_FINAL.DOC 1 OF 4


Interviewee: John (Yash) Nyznyk

CDM (925) 296-8065

Site Name

EPA ID No.

Date of Interview



CAD 98036914

3/28/05

Phone X Fax/email In person

Interview Contacts

Organization

Phone

Email

Address

Lisa Hanusiak

US EPA Region 9

(415)972-3152

[email protected]


Tina Girard


(510) 587-7586

[email protected]



the work conducted at the site to date? (general sentiment) Response: Currently the Project Manager for CDM (contractor for the City) working primarily on OU-2 (groundwater). CDM has been involved since the beginning of the project. CDM performed the RI/FS for both OU-1 and OU-2 and the remedial design for OU-2; Geosyntec was the design engineer for OU-1. Currently serves as the primary contact with EPA on OU-2 issues, preparation of FSL site monthly reports, and management of operation of the groundwater remediation program, including monitoring and reporting. Overall impression is that the project has consisted of addressing a range of issues, resulting in a comprehensive evaluation of conditions and implementation of effective remediation. The OU-2 remedial action was developed in a very collaborative way. This project represents the first time EPA incorporated phased-implementation of remedial action into a ROD. 2. What is the current status of construction? Have any problems or difficulties been


OU-1 is complete, currently carrying out performance testing. OU-2 is near completion, the remaining Phase 1 element is well decommissioning (3 agricultural supply wells in the plume downgradient of landfill). Delays due to acquiring wells on private property, negotiations lasted for approximately 1 year. Acquired wells in October 2004.


Operation of the agricultural wells is believed to have caused the vertical migration of contamination. Initially, contamination was confined to the A-aquifer (depth to water approximately 60 feet below ground surface). The A-zone and B-zone aquifers are separated by an A/B aquitard. There appears to be degree of communication between the A- and B-zone aquifers. Attribute the vertical migration to the agricultural wells completed in the B-zone aquifer without conductor casing. These wells were periodically operated at approximately 1,500 gallons per minute when the irrigation canal water was not available. The irrigation canal runs parallel to the eastern perimeter of the FSL, and is conveyed in an underground pipeline on the southern and western perimeters of the landfill. This pipeline is used to transport treated groundwater to the south detention basin. The Phase 1 Evaluation Report will be completed in January 2006, after one full year of Phase 1 operations without the agricultural wells operating. The report will evaluate the effectiveness of the Phase 1 Remedial Action and determine whether to proceed to Phases 2 and 3 are or if modifications to Phase 1 will be sufficient for achieving the overall objectives of the groundwater remedial action. 3. Have there been routine communications or activities (site visits, inspections,


Response: Reports include: Site-wide monthly project reports - now prepared quarterly; Starting in March 2005, project schedule updates are submitted monthly to EPA electronically; Semi-Annual Performance Monitoring Reports (groundwater and groundwater treatment system monitoring) are submitted. Periodic project meetings with all interested parties. CDM performs periodic inspections of the O&M of treatment facility and SCADA system O&M system for the groundwater treatment compound, data summarized in reports). ( 4. What does the monitoring data show? Are there any trends that show contaminant


Response: Monitoring Data: The Fall 2002-3 Groundwater Monitoring Reports show generally decreasing or stable trends, increasing in certain wells; depends upon location. For example, an A-zone extraction well may show decreasing or stable concentration and the B-zone wells are stable with some slightly increasing near agricultural wells and decreasing when proximity is farther from agricultural wells. Within the plume concentrations are variable near some agricultural supply wells. Down-gradient of the site, near the edge of the plume concentrations are generally less than the detection limit for all VOCs except PCE (some wells low concentration but increasing).


COCs: An extensive list of metals was analyzed for during the RI/FS. DTSC has mentioned other COCs; City recently collected treatment plant influent and effluent samples for analysis for perchlorate, 1,4-dioxane, cyanide, and 1,2,3-trichloropropane. 5. Is there a continuous on-site O&M presence? If so, please describe staff and


Response: There is a continuous on-site presence by a City staff member for OU-1 and OU-2 O&M. George Slater makes periodic visits to the site. CDM visits the site periodically to troubleshoot O&M issues. CDM transitioned away from groundwater sampling but continues to provide assistance/QC once a year during the annual sampling event. 6. Have there been unexpected O&M difficulties or costs at the site in the last five

years? If so, please give details. Response: There have been some issues with the SCADA system (instrumentation and controls for the groundwater treatment system) -- reports are automatically generated, improved the computer system, and added a protective box for the hard drive to address dust problems. Flow meters: system was designed for much higher flows; actual flow is at low end of optimum range for current flow meters. The same issue exists for the treatment plant flow totalizer. For reporting, CDM has had to estimate flow 1 well. Currently evaluating the need for rehabilitation (annual or semiannual cleaning) of extraction wells as the well yield has decreased. 7. Would you say that O&M and/or sampling efforts have been optimized? Please

describe how improved efficiency has or has not occurred. Response: Optimization has occurred. Over time, modifications to the program have been proposed. During January 2005, a request was made to reduce the sampling frequency for inorganics at some monitoring wells at the site as there are a lot of historic data. 8. Are you aware of any institutional controls, site access controls, new ordinances in


Response: CDM prepared Institutional Controls technical memo (Jan 21, 2003). This memo addressed offsite pumping and identified well prohibition and assessment zones through groundwater modeling. Phase 1 Remedial Action included decommissioning of the agricultural wells within the well prohibition zone. Additional wells can be installed but a detailed evaluation (i.e., depth, pumping rates) is required prior to approval. The City has met with Fresno County and they are working to incorporate this into the County’s well permitting process.



remedial design or ROD? Response: There have been no significant changes at the site. Closure under OU-1 is a presumptive remedy. The groundwater treatment system is operating as intended, modifications may be necessary based on the Phase 1 evaluation to address capture and the lowered water table to achieve the goal of hydraulic control. 10. Do you have any comments, suggestions, or recommendations regarding the site?

Response: This parties involved in the project have a very good working relationship; issues are identified and collaboratively dealt with. The City proactively implemented the Early Groundwater Remedial Action, which included several of the Phase 1 extraction wells and wellhead treatment systems. Additional Comments -There are a number of residences north and south of landfill purchased by City and the City provides bottled water and/or well head treatment to additional residences. -Vapor intrusion is probably not an issue any more given that the gas collection system is operating, there is perimeter monitoring, and the depth to water (60 ft). In-home gas testing to address vapor intrusion had been performed in homes adjacent to the landfill in the early 1990’s.

PICKUS_OK_FINAL.DOC 1 OF 3


Interviewee: Wayne Pickus CDM (925) 296-8070

Site Name

EPA ID No.

Date of Interview



CAD 98036914

3/22/05


Interview Contacts

Organization

Phone

Email

Address

Lisa Hanusiak

US EPA Region 9

(415)972-3152

[email protected]


Tina Girard


(510) 587-7586

[email protected]



the work conducted at the site to date? (general sentiment) Response: Current role is Project Director. I first started on the project in 1990. My overall impression is high caliber work conducted at site. The City has performed comprehensive work at the site in accordance with CERCLA. 2. What is the current status of construction? Have any problems or difficulties been


OU2: CDM Phase I construction is almost complete (currently decommissioning agricultural wells). There were no delays in construction of the treatment facility. The decreased regional groundwater elevation (15 to 20 feet) has affected the remedy in that the treatment system is not operating at full capacity. Therefore, some pumps, flow meters, and totalizers are not unctioning as intended and must be replaced. f


Response: I regularly attend team meetings. C DM is assisting with O&M oversight for the onsite City Operator (Jeff Garner).




Response: Monitoring data shows generally decreasing or stable concentrations. There are no new COCs identified. 5. Is there a continuous on-site O&M presence? If so, please describe staff and


Response: Initially the design contractor was responsible for startup. There is currently a continuous (business hours) O&M presence onsite. 6. Have there been unexpected O&M difficulties or costs at the site in the last five

years? If so, please give details. Response: The decreased regional water table has decreased the flow rate and created the need for new pumps and flow meters. 7. Would you say that O&M and/or sampling efforts have been optimized? Please

describe how improved efficiency has or has not occurred. Response: In terms of monitoring, the City proposed decreased monitoring in January 2005 in an effort to optimize. Currently awaiting EPA response. 8. Are you aware of any institutional controls, site access controls, new ordinances in

place, and changes in actual or projected land use, complaints being filed or unusual activities at the site? If so, please describe in detail.

Response: CDM developed an Institutional Control (IC) Plan to regulate the installation of new wells. 9. Have any problems been encountered which required, or will require changes to this

remedial design or ROD? Response: No problems have been encountered which would require changes to the ROD. In terms of remedial design, the Phase I evaluation may indicate need for changes/ improvements for OU2.


10. Do you have any comments, suggestions, or recommendations regarding the site? Response: Continue with the Phase I evaluation to determine if the remedial action is meeting the objectives. Additional Notes/Comments: -The model developed during the RI was used at different phases of project i.e. to determine extraction well location, effectiveness, and the Phase I evaluation. The model indicates there is a local influence of retention ponds and agricultural wells in the area of the Site. -CDM identified the main production wells and abandoned accordingly. There may be other that exists farther away, beyond the plume, but there may be no need to abandon. -The early groundwater action system started early cleanup of the plume and provided data to design the Phase I remedial action more effectively.

DUNN_OK_FINAL.DOC 1 OF 3


Interviewee: Jeff Dunn

Kleinfelder (925) 484-1700

Site Name

EPA ID No.

Date of Interview



CAD 98036914

3/28/05


Interview Contacts

Organization

Phone

Email

Address

Lisa Hanusiak

US EPA Region 9

(415)972-3152

[email protected]


Tina Girard


(510) 587-7586

[email protected]



the work conducted at the site to date? (general sentiment) Response: Contractor for the City, Project Manager for OU1 design. Continue to be in direct contact with the City regarding OU1, scope is limited to Compliance Testing. OU1 design was completed in December 1993 and approved in 1997 (when Jeff worked for Geosyntec – contracted by the City). Overall impression is that the remedial construction is good and in compliance with plans. 2. What is the current status of construction? Have any problems or difficulties been


OU1: Construction complete. The biggest issue during construction was contractor-IT Corporation filled for bankruptcy during construction which caused delays. 3. Have there been routine communications or activities (site visits, inspections,


Response: Regularly attend team meetings. The CD for OU1 requires 2 rounds of compliance testing, Kleinfelder is completing the econd round of testing in April 2005. s


4. What does the monitoring data show? Are there any trends that show contaminant levels are decreasing? Have any new or emerging COCs been identified? If so, have they impacted the effectiveness of the remedy?

Response: The Remedy for OU1 seems to be working for the most part. -During performance testing round 1 the flare was not meeting 98% destruction efficiency because when sampled it was not operating at a high enough temperature. -Performed a surface sweep, there was no evidence of leakage (gas). -Evaluated monitoring data from soil gas wells: for the perimeter monitoring points only 1 location showed methane. -Landfill gas condensate is pumped to the sanitary sewer line. There is no specific requirement for sampling. Sampled and did not meet the City’s discharge requirements. The City agency is ok with it because such low volume (few hundred gallons/day) and it is treated by the POTW. -The City monitors landfill gas regularly and adjusts as needed. I do not know if there is a set schedule and reporting timeline. -Unsure of landfill gas data trend, there was a decrease in concentrations after startup. 5. Is there a continuous on-site O&M presence? If so, please describe staff and


Response: The City has a continuous O&M presence (during business hours). 6. Have there been unexpected O&M difficulties or costs at the site in the last five

years? If so, please give details. Response: None 7. Would you say that O&M and/or sampling efforts have been optimized? Please

describe how improved efficiency has or has not occurred. Response: O&M efforts have been optimized by the City. 8. Are you aware of any institutional controls, site access controls, new ordinances in


Response: There are no ICs associated with OU1. In terms of OU2 there are ICs for groundwater uses (well installation) in the area.



remedial design or ROD? Response: In relation to OU1 there have not been any problems encountered which will require changes, the design is working as intended. 10. Do you have any comments, suggestions, or recommendations regarding the site? Response: Overall remedy was implemented successfully despite the construction delayed due to bankruptcy. The remedy is functioning well and consistent with land use. Other Comments/Notes: There are no permits associated with OU1.

SUER_REVISED_FINAL.DOC

1 OF 3 06/05/05


Interviewee: Lynn Suer [email protected] 415-972-3148 EPA: Former Remedial Project Manager

Site Name

EPA ID No.

Date of Interview



CAD 98036914

4/12/05

Phone Fax/email In person

Interview Contacts

Organization

Phone

Email

Address

Lisa Hanusiak

US EPA Region 9

(415)972-3152

[email protected]


Tina Girard


(510) 587-7586

[email protected]


Interview Questions 1. What was your relationship to the site? What was your overall impression of the

work conducted at the site to date? (general sentiment) Response: Remedial Project Manager from July 27, 2003 to approximately September 2004 2. Did you feel well informed about the site’s activities and progress? Response: Y

es. The team was very open and responsive.


Response: Routine communications. Regular meetings, approximately every 3 months depending on

eliverables and issues. d


2 OF 3 06/05/05

4. Is the remedy functioning as expected? How well is the remedy performing? Response: The remedy is not complete. Phase I of OU2 remedy is in progress; there were delays due to gaining access to neighboring properties to abandon irrigation wells, difficult property owner. There was an influence of pumping agricultural wells on the hydraulics of the system and therefore could not interpret success of the groundwater extraction system. Flare was operating during my time as RPM. 5. What does the monitoring data show? Are there any trends that show contaminant


Response: Although landfill gas data was not routinely reported to EPA, landfill gas was monitored and records probably kept by the landfill operator. Groundwater data: reported semi-annually. The Phase I report will evaluate data trends, this is currently in progress. There was a preliminary Phase I report released but this is not a good tool to evaluate conditions given that agricultural wells are still operating. The goal of Phase I is plume containment. Effluent data: not reported. New or emerging COCs: not aware of any sampling performed. 6. Are you aware of any institutional controls, site access controls, new ordinances in


Response: There are access and use restrictions at the site. For example, it is fenced. However, I don't know whether access or use restrictions are formalized in a legally binding document. 7. Would you say that O&M and/or sampling efforts have been optimized? Please

describe how improved efficiency has or has not occurred. Response: When compliance testing was performed, it was realized that the destruction efficiency was not met; the City contracted someone to alter the gas extracted from the wells. Unsure if there was a process in place to ensure O&M was optimized, this maybe a weakness at the Site. 8. Are you aware of any ongoing community concerns regarding the site or its

administration? Response: I am not aware of any concerns from the community. Pete Phillips (URS) raised concern that the electrical panel was placed in a hazardous place on the soccer field.


3 OF 3 06/05/05

9. Do you have any comments, suggestions, or recommendations regarding the site? Response: The Air Board and Water board should be involved and ensuring compliance. The requirements of Air Board are not detailed in compliance testing plan, CD, nor ROD. Groundwater treatment system effluent was cleaned up to MCLs as opposed to water board cleanup standards. Concerned that the treatment system was not able to meet discharge standards. During my time as RPM, an issue was whether or not to sample for dioxins from the landfill gas flare. Dioxane emissions from the type of flare operating are not well documented; however similar flares show no problem. This is a complex issue in terms of how to sample (i.e. sample outside of the stack within emissions air – where/when? sample air or organisms?, etc…). EPA currently does not have enough research to tell the City where/how to sample. The cost would have been approximately $150,000 per sampling event. There is a great possibility of false negative results if sampled in the wrong place.

WETMORE_REVISED_FINAL.DOC 1 OF 1 06/05/05


Interviewee: Cynthia Wetmore US EPA Region 9 415-972-3059

Site Name

EPA ID No.

Date of Interview



CAD 98036914

4/8/2005


Interview Contacts

Organization

Phone

Email

Address

Lisa Hanusiak

US EPA Region 9

(415)972-3152

[email protected]


Tina Girard


(510) 587-7586

[email protected]


Interview Questions 1. What was your relationship to the site? Response: Remedial Project Manager for EPA in the mid 1990’s. 2. What were the major concerns when you were Remedial Project Manager for the

site? Response: -The cap was not yet constructed. -The focus during this time was OU2 (groundwater). There was a public meeting that focused on groundwater during which there was not a lot of public participation. The City provided well head filters to affected residences. -The City wanted to plan to reuse the site (land); -Leachate investigation/recovery was not technically/economically feasible. The landfill was not lined and there were no records of disposal. Interception of groundwater was the primary olution. s

MOXLEY_OK_FINAL.DOC 1 OF 1 06/05/05


Interviewee: Bret Moxley [email protected] Former Remedial Project Manager

Site Name

EPA ID No.

Date of Interview



CAD 98036914

5/4/05


Interview Contacts

Organization

Phone

Email

Address

Lisa Hanusiak

US EPA Region 9

(415)972-3152

[email protected]


Debbie Seibold


(510) 587-7700

[email protected]


Interview Questions 1. What was your relationship to the site? Response: Remedial Project Manager about 12 years ago – left just after the 1993 ROD. 2. What was the status of the site when you were Remedial Project Manager for the

site? What were the major concerns for the site? Response: - There were only a few monitoring wells and the landfill barrier at the time. The landfill barrier was not properly installed - the impermeable membrane was not placed in correctly. - Around six houses were sampled for vinyl chloride. There was little public concern – one resident was concerned about any stress this could cause on his strawberry vegetation. Another resident wanted to sell and was interested in the effect on their property value. Another resident had two small children and therefore was concerned. - A public meeting was held to discuss an aspect of the site – it was either about the indoor air sampling or in advance to the ROD. - There was a fence around the landfill to keep the public off of it. There wasn’t any vandalism or trespassing.

PHILLIPS_OK_FINAL.DOC 1 OF 3 06/05/05


Interviewee: Pete Phillips

URS Corporation 916-679-2259

Site Name

EPA ID No.

Date of Interview



CAD 98036914

4/06/2005


Interview Contacts

Organization

Phone

Email

Address

Lisa Hanusiak

US EPA Region 9

(415)972-3152

[email protected]


Tina Girard


(510) 587-7586

[email protected]



the work conducted at the site to date? (general sentiment) Response: Technical oversight contractor to U.S. EPA. Good to excellent PRP has managed to complete the primary elements of implementing the remedial design under difficult conditions. PRP continues to support the RD/RA activities in a responsible manner. 2. What is the current status of construction? Have any problems or difficulties been


Construction complete, shake-down complete. Some operational difficulties associated with groundwater chemistry have been solved and long term evaluation of the current groundwater extraction strategy is currently being onducted. c


Response: URS continually evaluates operational reports submitted by the PRP. The regulatory remedial project managers meetings are held at the site on a routine basis. Construction complete. Final nspections have all occurred. i




Response: Monitoring data are continually evaluated. Migration of contaminant plume past the toe of the landfill has ceased. Capture zone analysis is currently underway. No new emerging COC’s have been identified. 5. Is there a continuous on-site O&M presence? If so, please describe staff and


Response: Yes, City of Fresno staff operate the groundwater treatment and landfill gas plume components of the treatment facility. The site operates in automatic mode overnight and on weekends. 6. Have there been unexpected O&M difficulties or costs at the site in the last five

years? If so, please give details. Response: No difficulties outside of the typical “start-up” type of shake down adjustments and modifications. 7. Would you say that O&M and/or sampling efforts have been optimized? Please

describe how improved efficiency has or has not occurred. Response: Too early for optimization evaluation of O&M.


8. Are you aware of any institutional controls, site access controls, new ordinances in place, changes in actual or projected land use, complaints being filed or unusual activities at the site? If so, please describe in detail.

Response: Institutional controls regarding construction of new domestic supply and industrial supply wells are currently under review by the PRP legal staff. 9. Have any problems been encountered which required, or will require changes to this

remedial design or ROD? Response: No, however, evaluation of the Phase I remedial strategy is currently under way with possible implementation of the Phase II strategy. 10. Do you have any comments, suggestions, or recommendations regarding the site? Response: Site team including the PRP staff, their consultants and regulatory members work in an excellent cooperative environment.

MYERS_REVISED_FINAL.DOC 1 OF 3 06/09/05


Interviewee: Bruce Myers Regional Water Quality Control Board

Site Name

EPA ID No.

Date of Interview



CAD 98036914

3/10/2005


Interview Contacts

Organization

Phone

Email

Address

Lisa Hanusiak

US EPA Region 9

(415)972-3152

[email protected]


Tina Girard


(510) 587-7586

[email protected]


Interview Questions 1. What is your relationship to the site? What is your overall impression of the work

conducted at the site to date? (general sentiment) Response: Relationship to the site is Project Manager for the Regional Water Quality Control Board (RWQCB) since late 2003. DTSC encouraged RWQCB’s involvement when OU2 remedial action started. Overall, the work conducted at the site has been good. There is a need to continue to evaluate the site based on new data collected. 2. Do you feel well informed about the site’s activities and progress? Response: Yes, well informed. There is always open communication. CDM keeps RWQCB informed of ield activities and other site progress. f


Response: For the RWQCB there is no specific inspection schedule. Once waste discharge requirements are adopted, then there will be regular site inspections, etc. The groundwater treatment system discharges treated water to onsite ponds, therefore NPDES does not apply, but waste discharge requirements (WDRs) will apply. Once WDRs are in place, monthly reporting will be required. The first round of WDR baseline sampling was performed and reported in the ourth quarter 2004 monitoring report. f


4. Is the remedy functioning as expected? How well is the remedy performing? Response: There has been a large decrease in the water table since system design; therefore full capture of the plume at the edge of the landfill is not occurring. The initial plan was for full capture at the edge of the landfill. Phase I, II, and III implementation of remedial actions was accounted for in the ROD. If Phase I is successful this could negate the need for Phase II and Phase III. Because of the decreased water table the Phase I system cannot capture the entire plume; therefore there has been plume movement. Currently, we may not completely understand the hydrogeology of the site. A-zone extraction wells are pulling a lot of water from the B-zone. The groundwater model was not corrected based on initial real world data. The Phase I evaluation will be completed once four quarters of sampling data have been collected following the destruction of the agricultural wells (January 2005?) at which time the model will be corrected. 5. What does the monitoring data show? Are there any trends that show contaminant


Response: There is vertical plume movement between the A and B-zones. Preliminary Phase I assessment concentration plots show: 25% of wells are increasing, 40% steady state, and 35% of wells are decreasing. Looking at paired wells, there is vertical movement in the aquifer. When the pumping at A-zone wells is increased there is a large decrease in concentration in A-zone wells; however the concentration in B-zone wells increased. The agricultural wells influenced plume movement. The general groundwater flow direction is to the south and west. When evaluating the dissolved oxygen data from the field data sheets, the concentration mimics the vinyl chloride data. There is vinyl chloride at the site due to reducing conditions at the landfill. Dissolved oxygen ranged from 0.1 to 6 or 7 mg/L (background concentrations). The model needs to be calibrated to incorporate the affects of agricultural well pumping. Data is not available for the historic pumping rates of the agricultural wells; therefore general assumptions of the agricultural wells pumping rates should be added to the model. Uncertain if emerging COCs have ever been sampled for at the site. There could be perchlorate present from the Chilean nitrate fertilizer. 6. Are you aware of any institutional controls, site access controls, new ordinances in


Response: There is a well prohibition institutional control (IC) program in progress. Within the City of Fresno, an application for a well permit is required prior to installation. The City will implement an IC program to restrict well installation in the site area.


7. Would you say that O&M and/or sampling efforts have been optimized? Please

describe how improved efficiency has or has not occurred. Response: May be able to decrease monitoring frequency given the large history of data but conditions may change now that the agricultural wells have been destroyed. We may need to sample monitoring wells near recently destroyed agricultural wells more frequently until a baseline can be established. 8. Are you aware of any ongoing community concerns regarding the site or its

administration? Response: No 9. Are you aware of any events, incidents, or activities that have occurred at the site,

such as dumping, vandalism, trespassing, or emergency response from local authorities?

Response: None 10. Do you have any comments, suggestions, or recommendations regarding the site? Response: Evaluate the groundwater plume and take action as necessary. Additional comments/information: -There are no site monitoring wells as deep as the new agricultural replacement wells. -A-zone depth to water is approximately 80 feet below ground surface. -Currently, the groundwater extraction system is drawing a substantial amount of water from the B-zone. The aquitard between the A and B-zones is not competent. Even if an extraction well is screened in the A zone it is extracting water from the B-zone. The pumping rate, K, and heads between zones indicate water from other zones is being extracted. -There is a lot of dissolved organic matter coming from the southern portion of the landfill; high concentration and high mass flux. It is imposing locally reducing conditions and forming vinyl chloride from PCE and TCE in groundwater.

MENSAH_OK_FINAL.DOC 1 OF 2


Interviewee: Emanuel Mensah Department of Toxic Substance (DTSCs) Phone: 916-255-3704

Site Name

EPA ID No.

Date of Interview



CAD 98036914

3/22/05


Interview Contacts

Organization

Phone

Email

Address

Lisa Hanusiak

US EPA Region 9

(415)972-3152

[email protected]


Tina Girard


(510) 587-7586

[email protected]


Interview Questions 1. What is your relationship to the site? What is your overall impression of the work

conducted at the site to date? (general sentiment) Response: Relationship is the Project Manager at DTSC for the past 4 years. Overall good work has been conducted at the site. 2. Do you feel well informed about the site’s activities and progress? Response: Yes 3. Have there been routine communications or activities (site visits, inspections,


Response: A

ttend team meetings regularly in person or by conference call.

MENSAH_OK_FINAL.DOC 2 OF 2

4. Is the remedy functioning as expected? How well is the remedy performing? Response: The groundwater treatment system is functioning as expected. The flare system is functioning properly after increasing temperature following the first performance test. 5. What does the monitoring data show? Are there any trends that show contaminant


Response: Overall the concentrations in soil gas and groundwater are decreasing. A comprehensive evaluation of COCs has been performed. 6. Are you aware of any institutional controls, site access controls, new ordinances in


Response: Not aware of any institutional controls; there are site access control in place. 7. Would you say that O&M and/or sampling efforts have been optimized? Please

describe how improved efficiency has or has not occurred. Response: Uncertain 8. Are you aware of any ongoing community concerns regarding the site or its

administration? Response: Minor concerns from neighbors regarding their wells and site contaminants. 9. Are you aware of any events, incidents, or activities that have occurred at the site,

such as dumping, vandalism, trespassing, or emergency response from local authorities?

Response: No emergency responses, etc…. 10. Do you have any comments, suggestions, or recommendations regarding the site? Response: None.

APPENDIX D

Site Inspection Photographs

Description: Aerial View of the Sports Complex/Park Date: 2005

Description: View of Access Road to Top of Landfill Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: View of perimeter fencing around landfill (northern side) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Vegetation on the top of landfill Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: View of sports facility/park west of landfill Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: View of dirt road on landfill Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Gas monitoring well EW55 on top of landfill; heavy lid left open Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: View of neighbors north of landfill (trucking facility and houses) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Storm water drainage on west side of landfill Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Close up of storm water drainage on top of landfill (west side) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Storm water (south drainage trapezoid) There are similar ones for each the east and west basins. Samples are collected from here and analyzed. Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Storm water collection at the base of the landfill (southern side) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: - Sprinkler head surrounded by vegetation (south side of landfill) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Extraction Well PW-4A (outside view) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Extraction well PW-4A Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Up close image of control box for PW-4A Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Offsite groundwater monitoring wells CDM-5 A,B&C Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Offsite ground water monitoring well CDM-5C Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Abandoned irrigation well (west of landfill) (ID: I3) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Up close of abandoned irrigation well (I3) (west of landfill) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Replacement Irrigation Well (Marks Ave.) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: View of groundwater treatment area (flare on left, PTA on right). Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Sump (next to PTA); Condensation from the pipes and groundwater samples are poured down this sump. Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Antiscalant (pot 807 flowguard) storage (next to air stripper) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: PTA Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Flare equipment (condensation knock-out pot) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Flow meter and temperature readings on pipe carrying landfill gas leading to flare. Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Gauge on flare outside view (measures temperature and flowrate) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Data chart gauge on flare PLC (programmable logic control) This records temperature and flowrate. Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Sump (all sumps are connected) This one is the primary condensation drain for solvent air from the PTA. Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Office located in groundwater treatment area Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Old groundwater treatment equipment left outside Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Lisa Hanusiak and Jeff Garner with a GEM2000 gas monitor (analyzes for methane, O2, CO2, balance (nitrogen), temperature, and flowrate) Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Inside the electrical room. Power circuit breakers - main disconnect for groundwater treatment and flare. Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Description: Master SCADA PLC Photographer: Debbie Seibold/CH2M HILL Date: March 9, 2005

Fresno Sanitary Landfill Superfund Site Fresno County, California · 2017-05-12 · Fresno Sanitary...

Documents

Transcript of Fresno Sanitary Landfill Superfund Site Fresno County, California · 2017-05-12 · Fresno Sanitary...