FIVE-YEAR REVIEW REPORTHealth is now known as Wyeth. The PRP, Wyeth, continues to sample groundwater monitoring wells onsite and conducts surface water sampling upstream and downstream

Five-Year Review Report

for

LaBounty Superfund Site

Charles City, Iowa

September 2005

Prepared by:

Region VIIUnited States Environmental Protection Agency

Kansas City, Kansas

Approved by: Date:

feciliaJPapiH-ector

Su> ivision40222974

SUPERFUND RECORDS

Table of Contents

PageList of Acronyms iiiExecutive Summary ivFive-Year Review Summary Form v

I. Introduction 1

II. Site Chronology 2

III. Background 2

Physical Characteristics 2Land and Resource Use 3History of Contamination 3Initial Response 3Basis for Taking Action 4

IV. Remedial Actions 5

Remedy Selection. 5Remedy Implementation 6System Operation/Operation and Maintenance 6

V. Progress Since the Last Five-Year Review 8

VI. Five-Year Review Process 11

Administrative Components/Community Involvement 11Document Review 11Data Review 12Site Inspection 13

VII. Technical Assessment 14

VIII. Issues 15

IX. Recommendations and Follow-up Actions 15

X. Protectiveness Statement •. 15

XI. Next Review 16

Table 1. Chronology of Site Events 2

Attachments

Attachment 1. Documents Reviewed 18Attachment 2. Site Tables and Figure 19Attachment 3. Inspection Reports 20

11

List of Acronyms

AMSL Above Mean Sea LevelARARs Applicable or Relevant and Appropriate RequirementsCERCLA Comprehensive Environmental Response, Compensation, and Liability

ActCFR Code of Federal RegulationsCfs Cubic feet per secondHASP Health and Safety PlanIDNR Iowa Department of Natural ResourcesMCL Maximum Contaminant LevelMG/KG Milligrams per kilogramMG/L Milligrams per literMSL Mean Sea LevelNCP National Oil and Hazardous Substances Pollution Contingency PlanNPL National Priorities ListO&M Operation arid MaintenanceOS WER Office of Solid Waste and Emergency ResponsePPB Parts per billionPPM Parts per millionPRP Potentially Responsible PartyQAPP Quality Assurance Project PlanQA/QC Quality Assurance/Quality ControlRA Remedial ActionRCRA Resource Conservation and Recovery ActRD Remedial DesignRI/FS Remedial Investigation/Feasibility StudyROD Record of DecisionSAL State Action LevelUG/KG Micrograms per kilogramUG/L Micrograms per literUST Underground Storage TankVOC Volatile Organic Compound

in

Executive Summary

The five-year review of the LaBounty Superfund site located in Charles City,Iowa, has been completed, including a site inspection conducted on April 5, 2005.During the years 1953 to 1977, Salsbury Laboratories, Inc. (later known as SolvayAnimal Health, Inc.), a manufacturer of veterinary pharmaceuticals, disposed of sludgecontaining various compounds and metals on the site. This disposal resulted in thecontamination of a shallow groundwater aquifer that connects to the Cedar River.Investigations by the Environmental Protection Agency (EPA) and the Iowa Departmentof Natural Resources (IDNR) in 1977 and 1978 revealed that waste components werebeing leached and transported from the disposal site by groundwater to the Cedar River.In 1977, IDNR issued an Administrative Order that required the owner, SalsburyLaboratories, Inc., to prevent runoff, cease operations, and submit a plan for theremediation of the site. Salsbury Laboratories, Inc. installed a groundwater monitoringsystem in 1979 consisting of 24 groundwater monitoring wells. In 1980, SalsburyLaboratories Inc. also constructed a cover comprised of clay and gravel and vegetationover the chemical fill. The capping of the chemical fill reduced the leaching of wasteslocated above the water table. However, the cover over the waste was not effective inreducing pollutant leaching where wastes were placed below the water table. In 1983, thesite was placed on the National Priorities List (NPL). The EPA and the potentiallyresponsible party (PRP), Salsbury Laboratories, Inc., entered into an AdministrativeOrder on Consent in 1985 to further address remediation of the waste onsite. Between1985 and 1986 under EPA oversight, Salsbury Laboratories, Inc. installed a subsurfacegroundwater diversion wall upgradient of the chemical fill. The purpose of thesubsurface diversion wall was to provide a barrier between the clean groundwater and thechemical waste fill and to allow the groundwater to flow around the chemical fill materialwith uncontaminated groundwater flowing into the Cedar River. In 1989, SalsburyLaboratories, Inc. merged with Solvay Veterinary, Inc. to form Solvay Animal Health,Inc. This PRP company, Solvay Animal Health, Inc., later became known as Fort DodgeAnimal Health, a division of American Home Products Corporation. Fort Dodge AnimalHealth is now known as Wyeth. The PRP, Wyeth, continues to sample groundwatermonitoring wells onsite and conducts surface water sampling upstream and downstreamof the site in the Cedar River. Five-year reviews were conducted on this site in 1992 and2000; and in each review, the site was determined to be protective of human health andthe environment. The LaBounty site was deleted from the NPL in 1993.

IV

Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN): LaBounty Site

EPA ID (from WasteLAN): IAD980631063

Region: VII State:IA City/County: Charles City/Floyd

SITE STATUS

NPL status: D Final DX Deleted D Other (specify)

Remediation status (choose all that apply): D Under Construction D Operating DX Complete

Multiple OUs? DYES GXNO Construction completion date: _10/15_/1988

Has site been put into reuse? DX YES D NO

REVIEW STATUS

Reviewing agency: DX EPA D State D Tribe D Other Federal Agency

Author name: Catherine Barrett

Author title: Remedial ProjectManager

Author affiliation: EPA Region VII

Review period: _03 / 05 to _09 / 05_

Date(s) of site inspection: _04 / 05_ / 05_

Type of review: Dx StatutoryD Policy (D Post-SARA D Pre-SARA D N PL-Removal only

D Non-NPL Remedial Action Site D NPL State/Tribe-leadD Regional Discretion)

Review number: D 1 (first) D 2 (second) DX 3 (third) D Other (specify)

Triggering action:D RA Onsite constructionD Construction CompletionD Other (specify)

U KA StartDX Previous Five-Year Review Report

Triggering action date (from WasteLAN): 09_/27 / 2000

Due date (five years after triggering action date): 09_ / 27_ / 2005_

Five-Year Review Summary

Recommendations and Follow-up Actions:

The LaBounty site operation and maintenance and groundwater monitoringshould continue to be addressed by Wyeth, the PRP, in accordance with theAdministrative Order on Consent.

Protectiveness Statements:

All immediate threats at the site have been addressed, and the remedy for the sitewill be protective of human health and the environment.

Long-term protectiveness of the remedial action continues to be evaluated andmonitored with groundwater sampling and maintenance inspections of the site.

VI

I. Introduction

The Environmental Protection Agency (EPA), in cooperation with the IowaDepartment of Natural Resources (IDNR), has conducted a five-year review of theSuperfund remedial action implemented at the LaBounty site in the city of Charles City,in Floyd County, Iowa.

The five-year review report is completed pursuant to Section 121 (c) of theComprehensive Environmental Response, Compensation, and Liability Act of 1980(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986(SARA); to Section 300.430 (f) (4) (ii) of the National Oil and Hazardous SubstancesContingency Plan (NCP); and pursuant to EPA, Office of Solid Waste and EmergencyResponse (OSWER) Directive 9355.7 - 03B - P, Comprehensive Five-Year ReviewGuidance (June 2001). • .

The purpose of the five-year review is to ensure that the remedy at the siteremains protective of human health and the environment. The five-year review reportidentifies any deficiencies found and provides recommendations.

This five-year review is required by statute and is implemented consistent withthe CERCLA and the NCP. 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 President shallreview such remedial action no less often than each five years after the initiationof such remedial action to assure that human health and the environment arebeing protected by the remedial action being implemented.

The NCP Part 300.430 (f) (4) (ii) of the Code of Federal Regulations (CFR) states:

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

For sites with multiple operable units (OUs), one five-year review is conductedfor the combined OUs. The first five-year review for the site is conducted five yearsfrom the initiation of the first remedial action. This is the third five-year review for theLaBounty site. The triggering action for this review was the second five-year reviewconducted in the year 2000.

II. Site Chronology

Chronology of Site Events for the Labounty Site

Date Event

1976

1977

1982

1983

1985

1985

1985

1986

1988

1992

1993

2000

III. Background

Physical Characteristics

The LaBounty Superfund site is located on the western edge of the Cedar River inthe city of Charles City, in the SW/4, Section 7, T95N, R15W, Floyd County, Iowa. Thesite includes about eight acres which is within or near the area of the 100-year floodplainof the Cedar River. The city of Charles City recorded a 2000 year census population of7,812. The site is bounded by the Cedar River to the east and south. The city of CharlesCity owns property to the north, and several commercial businesses to the west provideeasements to the LaBounty site.

The geohydrology beneath the LaBounty site includes the Cedar Valley aquiferwhich is subdivided into two parts, the Upper and Lower Cedar Valley aquifers. TheUpper Cedar Valley aquifer is made up of hydrologically interconnected alluvial deposits

Preliminary Assessment

Administrative Order - IDNR

Proposal to NPL

Final Listing on NPL

EPA Consent Order

Feasibility Study

Remedial Design

Remedial Action

Close Out Report

First Five-Year Review

NPL Deletion

Second Five-Year Review

and bedrock. The Upper Cedar Valley aquifer is separated from the Lower Cedar Valleyaquifer by a sequence of low permeability rock including a shale member. The LowerCedar Valley aquifer is the Cedar Valley formation immediately below the Rapid Shale.The Upper Cedar Valley aquifer has been locally affected by leaching from the LaBountysite. The potential for regional contamination of the Cedar Valley aquifer was assessedin a 1980 report by the Iowa Geological Survey, "Evaluation of the Extent of HazardousWaste Contamination in the Charles City Area." The report concluded that the CedarValley aquifer was not at that time in danger of regional contamination from theLaBounty site because the site is located in the discharge zone of an active groundwaterflow system. Discharge from that system is to the Cedar River.

Land and Resource Use

Before the 1950s, the site was operated as a farm and as a borrow operation,selling sand and fill soil excavated from the alluvial overburden. Between 1953 and1977, pharmaceutical wastes were deposited on the site. The Cedar River borders the siteto the east and south, with the city of Charles City property to the north and commercialbusinesses to the west. The Linked States Geological Survey (USGS) monitors the waterlevel of the Cedar River at stations upgradient and downgradient of the site.

History of Contamination

The use of the site for disposal of solid wastes from Solvay Animal Health, Inc.(formerly Salsbury Laboratories, Inc. and currently Wyeth) began in 1953. From 1953 to1977, it was estimated that approximately 237,000 cubic yards of pharmaceutical wasteswere deposited at the site. As many as 15 discrete waste streams were generated asindicated in an evaluation in 1977. A great volume of waste arose from operation of theliquid waste treatment plant and production of byproduct sludges. The major solid wastewas gypsum sludge produced during the neutralization of sulfuric acid. Arsenic wasteswere primarily calcium arsenite and calcium arsenate sludges produced during limeprecipitation of arsenic-containing wastewaters. These sludges were hauled by truck inbulk form and deposited at the site. Smaller volume liquid waste materials included1,1,2-trichloroethane (1,1,2-TCA), orthonitroaniline (ONA), phenol, and nitrobenzene.Analytical results indicated that leachate from the landfill was contaminated with 36chemicals, including some metals and heavy metals. The leaching of contaminants fromthe landfill resulted in contamination of the groundwater in the alluvium and UpperCedar Valley aquifer which discharges to the Cedar River. The contaminants of concernand indicator parameters for the site have been established as arsenic, 1,1,2-TCA, andONA. Disposal at the LaBounty site ceased in December 1977 following the discoveryof ONA in shallow alluvial wells in Waterloo, Iowa.

Initial Response

Several response actions have been implemented at the site as part of a phasedplan for remedial action. The first response action was taken in 1977 when the IDNR(formerly Iowa Department of Environmental Quality) requested and approved plans for

construction of a dike around the disposal area at the site. The dike was constructed andmaintained until 1979. It was determined in 1979 that the downgradient portion wasresponsible for the impoundment of precipitation, thereby increasing infiltration. Thedike was removed in 1979.

The EPA and IDNR outlined a phased remedial action program for the site in1979. Phase I of the program which was implemented in October 1979 included theinstallation and sampling of 24 groundwater monitoring wells and the sampling of theCedar River. The monitoring well locations that monitor the alluvium (designatedby -A) and the Upper Cedar Valley aquifer (designated by -R) are shown in Figure 1-1.All wells have the year of installation in their identification number. Well MO279-A wasremoved during the diversion wall construction and replaced with well MO286-A (in1986), which was installed after the diversion wall construction. Monthly water levelmeasurements and water samples were taken from the groundwater monitoring wells andthe Cedar River stations beginning in October 1979 with the exception of times whenwells were dry or frozen or when flooding prevented sampling at river stations. Thewater samples were analyzed for arsenic, 1,1,2-TCA, and ONA.

Phase II of the remedial action program was initiated in 1980 and includedsurface water diversion, capping, and rerouting of a storm sewer. The cap was designedas a two-foot compacted clay cover placed over the contoured fill area. A six-inch claycap was employed for the parking lot area around the buildings west of the site. Rip-raperosion controls were installed at the edge of the cap. An existing storm sewer throughthe site was abandoned and a new one installed around the west and south ends of thelandfill area.

Basis For Taking Action

At the time the Phase II program was initiated, an impact assessment was madeindicating the cap should reduce arsenic loadings into the Cedar River to acceptablelevels by reducing surface infiltration through the wastes. Three subsequent reportsindicate that this, however, was not the case. In a January 1981 report, Hickok andAssociates concluded that the available monitoring data indicated that the responseactions had not been effective in attenuating the generation and transportation of leachatefrom the wastes.

The EPA National Enforcement Investigations Center (NEIC) published a reportin October 1982 evaluating arsenic, 1,1,2-TCA, and ONA monitoring data from the 24wells and river stations. Based on a statistical analysis of results before and after capplacement, EPA concluded that while capping had been effective where wastes werelocated above the water table, it had not been effective in reducing contaminant leachingwhere wastes were located below the water table.

The LaBounty site was listed on the NPL in September 1983.

IV. Remedial Actions

Remedy Selection

In January 1985, a focused feasibility study prepared for EPA by CH2M-HH1suggested that additional remedial response alternatives should be considered to addresswastes located below the groundwater table. This report concluded that the preferredalternatives for remedial action would be control of the groundwater upgradient of thewaste area through construction of an upgradient diversion wall or dewatering thesubmerged wastes through diversion pumping.

In 1985, EPA and Solvay reached an agreement on further response actions to beundertaken at the site. Additional response actions were implemented pursuant to aCERCLA Section 106/Resource Conservation and Recovery Act (RCRA) Section 3013Consent Order issued on July 3, 1985. These actions included construction of anupgradient groundwater diversion wall, installation of three Lower Cedar Valley aquifermonitoring wells, and installation of three pairs of wells to monitor the effectiveness ofthe diversion wall. The Consent Order also required that water levels and chemicalanalyses for the contaminants of concern be taken monthly in the monitoring wells andCedar River for no less that 24 months after completion of the diversion wallconstruction.

As a result of the Upgradient Cutoff Wall Evaluation Report prepared in April1988 for EPA by the REM IV team, a new monitoring well nest (M1289-A and M1289-R) was installed in 1989 to monitor background concentrations in the groundwaterupgradient of the diversion wall.

Based on the study of the arsenic-loading characteristics to the Cedar River, it wasconcluded by EPA that the major portion of the contaminant loading was resulting fromleaching of contaminants from those wastes that remained saturated beneath thegroundwater table. To reduce the level and volume of groundwater flow through thewastes, a groundwater diversion wall with a groundwater collection system wasconstructed upgradient of the site at the location shown on Figure 1-1. The location anddepth of the wall was based on monitoring well data and boring log information includedin the January 1985 Conestoga-Rovers & Associates Limited report, Upgradient CutoffWall-Data Base. Design Criteria. The wall is located west of the landfill wastes, orientednorth-northwest to south-southeast with a total length of approximately 600 feet.Operating in conjunction with the previously constructed clay cap covering the landfillwastes, the diversion wall was designed to reduce groundwater flowing through theUpper Cedar Valley Formation and diminish the hydraulic gradient upgradient of thewaste material. This would reduce the hydraulic gradient and total volume of waterpassing through the wastes resulting in reduced leachate production.

Remedy Implementation

The upgradient diversion wall and groundwater collection system was constructedaccording to the specific criteria described in the Remedial Work and MonitoringSystems Construction Report prepared by Conestoga-Rovers & Associates for the PRP,Solvay, in June 1986. Construction of the diversion wall consisted of excavation throughthe overburden into the Upper Cedar Valley Formation to an elevation of 965 feet abovemean sea level (AMSL) and backfilling with a low permeability clay to within six inchesof the groundwater collection system pipe at an elevation of 976 AMSL. A high-densitypolyethylene membrane was installed from the top of the clay material to an elevation of980 feet AMSL. A groundwater collection system was installed west and upgradient ofthe diversion wall along the alignment of the diversion wall and consisted of perforatedpipe, two manholes, and a wet well equipped with a pumping system. The groundwatercollection system excavation was backfilled with permeable material. The water fromthe groundwater collection system is pumped to a Charles City storm sewer, whichdischarges to the Cedar River downstream of the site.

System Operation/Operation and Maintenance

The effectiveness of the cap and the upgradient diversion wall and groundwatercollection system in mitigating the migration of contaminants into the Cedar River arediscussed in two reports, The Effects of Capping on Leachate Production at the LaBountvSite, Charles City. Iowa, prepared by NEIC, October 1982 and Upgradient Cutoff WallEvaluation Report, LaBountv Landfill Site, Charles City, Iowa, prepared by the REM FVteam for EPA, April 1988. In the report, Effects of Capping on Leachate Production, theNEIC concluded that the cap is effective where wastes are above the groundwater table,but not effective where wastes are below the groundwater table. This conclusion wasbased on a statistical analysis of analytical results before and after cap installation. Basedon a statistical analysis of data collected from 1985 to 1987, the Upgradient Cutoff WallEvaluation Report recommended that: (1) a new background well nest be installedupgradient to verify background contaminant levels in the alluvium and Upper CedarValley Formation and to evaluate whether contaminants were leaving the site to the westbecause of the construction of the diversion wall; and (2) monthly monitoring of the threeriver stations and periodic monitoring of the groundwater wells should continue to furtherverify apparent decreasing irends in concentration and loading of arsenic and ONA in theCedar River.

Groundwater modeling was performed using MODFLOW and MODPATH todetermine the contaminated groundwater flow paths from the LaBounty site in 1991. Themodeling concluded that some of the contaminated groundwater from the LaBounty siteflows beneath the Cedar River to the Shaw Avenue site, where it can be detected in someof the monitoring wells closest to the river, before ultimately discharging into the CedarRiver upstream of river monitoring station 12.

Groundwater and surface water monitoring was first implemented under Phase Iof the remedial action progjam in 1979. Groundwater and surface water samples andwater level measurements from the wells and river stations were collected on a monthlybasis until 1988 when the monitoring program was revised to include quarterlymonitoring of some wells. Water samples were analyzed for arsenic, 1,1,2-TCA, andONA.

The 1985 Consent Order required bimonthly inspection and maintenance of thesite and monthly surface water and groundwater monitoring by the PRP for the first 24months following the completion of the diversion wall construction. Site monitoring andmaintenance has continued in accordance with the 1989 Monitoring and MaintenancePlan, LaBounty Landfill, prepared by Conestoga-Rovers & Associates for the PRP. Thegroundwater pumped from the groundwater collection system has been monitored weeklyfor volume and arsenic concentration. Daily local precipitation and Cedar River meanflows are monitored and collected monthly. Site maintenance requires the performanceof inspections of the site remedial measures, including the cap, drainage ditches, securityfence, vegetative ground cover, diversion wall wet well, and the groundwater monitoringsystem on a bimonthly schedule. Inspection and monitoring reports are submitted to EPAby the PRP.

Monitoring data, including arsenic, ONA, and 1,1,2-TCA analytical data,precipitation data, and water level data are tabulated by the PRP. These data were plottedversus time in the past and compared to identify cause and affect relationships betweenthe various parameters. A statistical comparison of the combined data collected beforethe completion of the diversion wall construction, 1981 through 1985, to the datacollected after the diversion wall construction completion, 1986 through 1991, was madefor all the parameters. Precipitation data were plotted against time and used as areference for comparison to variations in groundwater and surface water levels andcontaminant concentrations.

First Five-Year Review

The EPA conducted the first five-year review of the remedial action implementedat the site in 1992. The 1992 five-year review included review of historical informationand statistical analyses of the groundwater, surface water, precipitation, diversion wall,and river stage monitoring data. Since the installation of the diversion wall and capthrough 1991, ONA, 1,1,2-TCA, and arsenic concentrations showed statisticallysignificant decreases in the alluvial and bedrock aquifers with the exception of 1,1,2-TCAconcentrations in wells M0979-A and M0979-R which have shown a statisticallysignificant increase. However, a statistically significant decrease in 1,1,2-TCA wasshown in well nest M0879, which is located downgradient of well nest M0979 andbetween M0979 and the Cedar River. In addition, the concentrations of 1,1,2-TCA wereconsistently lower in wells M0879-A and M0879-R than in wells M0979-A and M0979-R. Also, ONA and arsenic concentrations in well nest M0979 showed statisticallysignificant decreases during the same period that 1,1,2-TCA concentrations showed astatistically significant increase in these wells.

Surface water samples collected at station 11, which is located on the Cedar Riverapproximately 0.4 mile upstream of the LaBounty site, represent background contaminantconcentrations. Station 12 and the McDonnell station are both downstream of the site.ONA and arsenic concentrations at station 11 showed no statistically significant changein the years following the installation of the diversion wall (1986 through 1991). The1,1,2-TCA concentrations from station 11 were below detection limits. In the CedarRiver at station 12, downstream of the LaBounty site, statistically significant decreases inarsenic, ONA, and 1,1,2-TCA concentrations were identified in 1991. No analytical datafor 1,1,2-TCA or ONA are available before installation of the diversion wall at theMcDonnell station. Arsenic concentrations at the McDonnell station showed astatistically significant decrease in 1991 compared to before installation of the diversionwall.

Second Five-Year Review

The data collected from 1992 through 1999 showed statistically significantdecreases in contaminant concentrations in the alluvial and bedrock wells whencompared to the pre-diversion wall (1981 to 1985) data with the exception of 1,1,2-TCAconcentrations in M0879-R which have exhibited an increase. The localized area of high1,1,2-TCA concentration moved downgradient since the previous five-year review.When compared to 1986 to 1991 data, the bedrock wells showed decreases or nosignificant change in contaminant concentrations, with the exception of the 1,1,2-TCAconcentrations in M0879-R which showed an increase. The alluvial wells showedincreases in ONA and 1,1,2-TCA concentrations in wells M0479-A, M0679-AD,M0779AS, and M0879-A. ONA concentrations were higher in well M0979-A. Arsenicconcentrations were higher in wells M0779-AS and M1079-A. However, there were noincreases in concentrations in the Cedar River. At station 12 downstream of the site,ONA and arsenic concentrations decreased compared to the 1981-1985 data and the1986-1991 data. The 1,1,2-TCA concentrations from 1992-1999 were below detectionlimits.

V. Progress Since the Last Five-Year Review

In July 2004, the PRP, Fort Dodge Animal Health, a division of Wyeth, submitteda proposal for a revised Monitoring and Maintenance Plan for the site. The revisedMonitoring and Maintenance Plan consisted of changes in groundwater water levelmeasurements, frequency of measurements of groundwater parameters measured atalluvial and bedrock groundwater monitoring wells, upgradient bedrock groundwatercollection system, the Cedar River, the site inspections, and the reporting of results.O-nitroaniline was proposed for elimination as a site parameter for groundwatermonitoring and Cedar River monitoring. O-nitroaniline was originally designated as asite monitoring parameter based on its presence in the site waste material, and it wasmeasured in an aqueous matrix at a very low limit of detection level of 0.015 parts perbillion (ppb). This parameter came to be considered as a tracer compound and has noestablished Maximum Contaminant Level (MCL) or water quality standard. Cedar River

monitoring was proposed to continue. Quarterly sampling (composite) and streamgauging will continue at stations 11 and 12, along with grab sampling at the downstreamMcDonnell station.

The revised Monitoring and Maintenance Plan includes the following.

Groundwater- Groundwater levels will be measured on all 13 alluvial monitoring wellsand all 13 Upper Cedar Valley Aquifer monitoring wells on a semi-annualschedule. A spring/fall schedule will be separated by an approximate six-month interval.- Groundwater levels will be measured on the three Lower Cedar ValleyAquifer monitoring wells on a quarterly schedule. A continuous waterlevel recorder installed in Lower Cedar Valley Aquifer monitoring wellM15R and in Upper Cedar Valley Aquifer monitoring well M03R (thesewells are nested together) will provide measurement of positive upwardhydraulic head differential existing between the two aquifers.- Alluvial monitoring well locations (six total downgradient) M04, M05,M06 (2 wells), M07 (2 wells), M08, and M09 will be sampled annually.- Alluvial monitoring well locations M01, M02, M03, and M12,upgradient of the upgradient bedrock groundwater collection system, willno longer be sampled. Downgradient alluvial monitoring well locationM10 will no longer be sampled.- Upper Cedar Valley Aquifer monitoring well locations (six totaldowngradient) M04, M05, M06 (two wells), M07, M08, and M09 will besampled annually. Upgradient Upper Cedar Valley Aquifer monitoringwell locations M01, M02, and M03 will be sampled biennially.Downgradient Upper Cedar Valley Aquifer monitoring well locationsM10 and Ml 1 will be sampled biennially. Upgradient Upper CedarValley Aquifer monitoring well location Ml2 will no longer be sampled.- Lower Cedar Valley Aquifer monitoring wells Ml3, Ml4, and Ml5 willbe sampled quarterly.- Total arsenic and 1,1,2-TCA will continue as groundwater monitoringparameters. ONA will no longer be a monitoring parameter.

Cedar River- Composite sampling and stream gauging of the Cedar River upgradientstation 11 and downgradient station 12 will be performed quarterly. Thedowngradient McDonnell station, grab sampled along with the currentstation 11 and 12 monthly composite sampling events, will continue to besampled monthly, with four of these sampling events to be conductedalong with the proposed quarterly sampling events at station 11 and 12.- A low flow condition of 93 cubic feet per second (cfs) in the CedarRiver, as recorded by the USGS gage station located at station 11, requiresweekly composite sampling and stream gauging until the Cedar River flowcondition exceeds 93 cfs. Under the revised Monitoring and Maintenance

Plan, this composite sampling and stream gauging will be performedmonthly at station 11 and 12, with a weekly grab sampling to beperformed at the McDonnell station.- If the McDonnell station grab sampling results reveal an arsenicconcentration of 50 ppb or greater, composite sampling and streamgauging at stations 11 and 12 will be temporarily performed monthly for aminimum period of three consecutive calendar months, inclusive ifpossible, of the date on which the arsenic concentration was firstmeasured.- Total arsenic and 1,1,2-TCA will continue as the Cedar River monitoringparameters. O-nitroaniline will no longer be a monitoring parameter.

Site InspectionThe inspection schedule is revised to a quarterly frequency.

Reporting Results- The results reporting to the EPA and IDNR will be revised to a semi-annual schedule.

In September 2004, EPA and IDNR approved the revised Monitoring andMaintenance Plan. The sampling frequency beginning in October 2004 reflects therevised Monitoring and Maintenance Plan. A summary of the results of the groundwatermonitoring and Cedar River monitoring for arsenic, 1,1,2-TCA, and ONA and thegroundwater elevations levels is shown in tables in Attachment 2.

The sampling results since the last five-year review show similar trends as datafrom the previous two five-year reviews. In the last five years, 2000-2004, the highestconcentrations of arsenic in groundwater were in alluvial groundwater monitoring wellswhich are downgradient of the chemical fill area. During the sampling conducted in2004, arsenic concentrations were greatest in alluvial groundwater monitoring wellM0879-A (149 parts per million [ppm] in January 2004) as well as M0979-A (208 ppmin January 2004) as shown in the summary table of results in Attachment 2. The highestconcentrations of 1,1,2-TCA in 2004 were in alluvial groundwater monitoring wellsM0879-A (21.5 ppm in April 2004), M0779-AD (19.7 ppm in July 2004), M0679-AS(20.1 ppm in April 2004), and M0679-AD (20.1 ppm in April 2004). In past years, ONAwas found in well M0879-A; however, as of October 2004 with the implementation ofthe revised Monitoring and Maintenance Plan, ONA sampling is no longer required.

In the Cedar River, concentrations of arsenic and 1,1,2-TCA were greatest forriver stations 11 and 12 and the McDonnell station when the 2004 river flow was at itshighest level (693 million gallons per day [mgd]) in June 2004. The Cedar Riverdowngradient station 12 arsenic loading was 56.64 Ibs./day and the arsenic concentrationwas 9.8 ppb in June 2004 when the flow rate was 693 mgd. In comparison, theupgradient station 11 arsenic loading was 9.25 Ibs./day and the arsenic concentration was1.60 ppb in June 2004. The 1,1,2-TCA loading for station 12 was 8.49 Ibs./day, and the1,1,2-TCA concentration was 1.47 ppb in June 2004. Local precipitation was measured

10

and recorded with the Cedar Raver flow rates increasing the month following increases inprecipitation.

Site inspections of the landfill and surrounding areas of the site were conductedand summarized in quarterly reports completed by the PRP, Wyeth, for the previous fiveyears, 2000 through 2004. The inspection reports for the site completed by the PRP forthe year 2004 are attached to this report as Attachment 3. The inspection reports indicatethat the site has been maintained appropriately. The landfill cover and surrounding areashave been routinely inspected and maintained. Rip-rapped areas along the perimeter ofthe cap between the Cedar River and the cap, which could be subject to erosion andflooding by the river, have been maintained and kept free of debris and weeds by thePRP. Fencing has been inspected and repaired as needed.

VI. Five-Year Review Process

Administrative Components/Community Involvement

The LaBounty site five-year review has included the following team members:Catherine Barrett, EPA Remedial Project Manager; Bob Drustrup, IDNR ProjectManager; Neil Leipzig, Conestoga-Rovers & Associates, PRP contractor; DonaldLorsung, City Administrator, Charles City, Iowa; Tracy Meise, Planning and ProjectCoordinator, Charles City, Iowa; and the EPA Community Involvement Coordinator.

This five-year review consisted of the following activities: (1) a review ofrelevant documents (Attachment 1); (2) discussions among representatives of the EPA,the IDNR, the city of Charles City, Iowa, and the PRP contractor, Conestoga-Rovers &Associates; and, (3) a site inspection on April 5, 2005, conducted by Catherine Barrett,EPA, Bob Drustrup, IDNR, Neil Leipzig, Conestoga-Rovers & Associates, and DonaldLorsung and Tracy Meise, city of Charles City, Iowa.

A notice regarding the initiation of the five-year review was placed in the CharlesCity Press on March 31, 2005, and at the end of the five-year review, a newspaper noticewill indicate the availability of the five-year review report for the public. The completedfive-year review report will be available: in the site information repository, the CharlesCity Public Library, 106 Milwaukee, Charles City, Iowa 50616; in the EPA SuperfundDivision Records Center, 901 North 5th Street, Kansas City, Kansas 66101; and in theIDNR Offices, Wallace Building, 502 East 9th Street, Des Moines, Iowa 50319.

Document Review

Section 121 (d) of CERCLA, as amended by SARA, requires that remedialactions comply with applicable, or relevant and appropriate requirements or standards(ARARs) under federal or state environmental statutes or regulations. Several chemical-specific ARARs have been considered for this site.

11

The chemical-specific ARARs are: (1) Federal MCLs for compounds in drinkingwater supplies, 40 CFR Part 141, as defined in the Safe Drinking Water Act of 1974, asamended in 1986, 42 U.S.C., Section 300 et. seq.: (2) the Federal Ambient Water QualityStandards, 40 CFR Part 131, as defined by the Clean Water Act of 1977, as amended bythe Water Quality Act of 1987, 33 U.S.C., Section 1251 et. seq.. and the state of Iowa,Chapter 61, water quality standards.

The MCL for 1,1,2-TCA is 5 micrograms per liter (ug/L). There are no federal orstate drinking water or surface water standards for ONA. The MCL for arsenic waslowered to .010 milligrams per liter (mg/L) since the last five-year review. A standard of100 ppb for arsenic in the Cedar River was set in the July 1985 Consent Order. Iowawater quality standards (Chapter 61) include 50 ppb for arsenic in the Cedar River forprotection of human health from fish consumption. The state of Iowa has set ambientsurface water quality criteria for arsenic in the Cedar River at 360 ppb (acute) and 200ppb (chronic) for protection of aquatic life. Federal surface water quality standards forarsenic for protection of aquatic life are 360 ppb (acute) and 190 ppb (chronic). TheCedar River adjacent to the site is designated a Class B (WW) stream which is to beprotected for wildlife, fish, aquatic and semi-aquatic life, and secondary body contactuses.

Data Review

The groundwater monitoring and surface water monitoring continue to beimplemented by the PRP, Wyeth, in accordance with the EPA and IDNR orders and therevised Monitoring and Maintenance Plan. The sampling frequency beginning inOctober 2004 reflects the revised Monitoring and Maintenance Plan. Sampling ofmonitoring wells 01 A, 02A, 03A, 10A, 12A, and 12R has been discontinued. As ofOctober 2004, ONA sampling is no longer required. The alluvial wells downgradient04, 05, 06, 07, 08, and 09 will be sampled annually. Upper Cedar Valley downgradientwells 04, 05, 06, 07, 08, and 09 will be sampled annually. Upper Cedar Valleyupgradient wells and Upper Cedar Valley downgradient wells 10 and 11 will be sampledbiennially in even numbered years (i.e., 2006). Lower Cedar Valley wells 13, 14, and 15will be sampled quarterly. The Cedar River stations 11 and 12 will be sampled quarterlyand the McDonnell station monthly.

The groundwater flow patterns of the Cedar Valley Aquifers have remainedconsistent with historical data. Groundwater is flowing east toward the Cedar River.Water levels have increased and decreased in aquifers reflective of precipitation andsnow melt upstream. Low water levels typically occur in fall, and high water levelstypically occur in spring.

The water levels and trends in groundwater concentrations for monitoring wells inthe aquifers and the surface water monitoring trends are shown in tables in Attachment 2of this report. Concentrations of contaminants in monitoring wells and surface watermonitoring trends are similar to monitoring data collected during previous five-yearreviews. In 2004, arsenic concentrations were greatest in alluvial monitoring wells

12

M0879-A and M0979-A. The highest concentrations of 1,1,2-TCA in 2004 were inmonitoring wells M0879-A, M0779-AD, M0679-AS, and M0679-AD. In the CedarRiver, concentrations of arsenic and 1,1,2-TCA were greatest for river stations 11 and 12and the McDonnell station when the 2004 river flow was at its highest level in June 2004.

Site Inspection

On April 5, 2005, a site inspection was conducted by Catherine Barrett, RemedialProject Manager, EPA, Bob Drustrup, State Project Manager, IDNR, Neil Leipzig, SiteEngineer, Conestoga Rovers & Associates, the PRP contractor, Donald Lorsung, CityAdministrator, Charles City, and Tracy Meise, Planning and Project Coordinator, CharlesCity. The purpose of the inspection was to assess the protectiveness of the remedy,including the maintenance of the site, the monitoring wells, the fence surrounding thesite, and the institutional controls.

The site inspection began with driving on Highway 218/South Grand Avenue pastthe Grand Avenue USGS gauging station on the Cedar River to the location of sitegroundwater monitoring wells and the location of the underground diversion wall whichwas installed in order to divert groundwater around the chemical fill area to the CedarRiver. The site inspection was led by Donald Lorsung and Neil Leipzig who havehistorical knowledge of the site and the past remedial work which has been completed bythe PRP. After viewing the area of the underground diversion wall, the group then droveto the landfill area of the site. The chemical fill is partially beneath the asphalt parkingarea of a construction company on Grand Avenue. The easement which is in effect doesnot allow the owner of the parking area to penetrate the chemical fill area. The groupthen walked to the landfill area to the east of the asphalt parking area. The landfill capappeared well maintained with a thick vegetated grass cover. Rip-rap between thelandfill and the Cedar River was in good condition. Maintenance of the rip-rap includesapplication of herbicides to inhibit growth of weeds and volunteer trees. The group thenleft the landfill area and drove around to the northeast side of the-landfill cap to observethe groundwater monitoring wells and property between the landfill and the Cedar River.The landfill fence extended around the landfill cap at the north and east sides. The gatewas opened and allowed entrance of the vehicles to drive between the landfill cap and theCedar River. Evidence of flooding of the Cedar River floodplain in the past was seen.Debris was located at high elevations in trees. In the floodplain area, tracks of wildturkey and deer were evident in muddy areas. As the group was leaving the site, a herdof 10-12 deer was seen running across the lower northeastern edge of the cap toward theCedar River. The group continued to drive along the access road and exited through thegate which was then closed.

The site is inspected twice each year, and it is evident that the site has been wellmaintained. The cap over the chemical fill has a thick growth of short grass and the rip-rap between the landfill and the river is in good condition with no evidence of erosion.The fence surrounding the capped area was intact and locked. No significant issues havebeen identified during the site inspection or during the five-year review regarding the siteconditions.

13

There has been no change in the land use surrounding the site since the last five-year review was completed in 2000. Commercial development surrounds some portionof the western edge of the landfill including overlap of the landfill by an asphalt parkingarea. Easements along the edge of the landfill govern the area and prevent penetration ofthe cover in this area. The eastern and southern edge of the landfill between the landfilland the Cedar River includes a rip-rap area which provides protection of the landfill fromerosion by the river.

The recent PRP site inspection reports submitted by the PRP contractor,Conestoga-Rovers & Associates, are included in this report in Attachment 3.

VII. Technical Assessment

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

- Implementation of Institutional Controls and Other Measures - The PRP,Wyeth, continues to be responsible for the site; and there are no current or plannedchanges in land use at the site. The original PRP, Salsbury, obtained perpetual easementsfrom all owners of property affected by either the LaBounty site or required remedialactivities. The required easements were filed in the Office of County Recorder onOctober 22, 1980. Salsbury also obtained a restrictive covenant from Duane L. LaBountyand Alice O. LaBounty prohibiting them from tampering with the LaBounty site. Thesite is listed on the State Registry of Hazardous Substances or Hazardous Waste DisposalSites pursuant to Iowa Code 455B.426. The state registry listing, which is filed with thecounty recorder, prohibits sale or significant change in use of the property without theapproval of the Director of the IDNR.

- Remedial Action Performance - The review of documents, ARARs, the sitegroundwater and surface water monitoring data, and the results of the site inspectionconducted April 5, 2005, indicate that the remedy of capping the chemical fill materialalong with providing rip-rap and the construction of the diversion wall to directgroundwater flow around the chemical fill material has achieved success in controllingcontamination migration.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, andremedial action objectives used at the time of remedy selection still valid?

- Changes in Standards and "To Be Considered" Requirements - The arsenicMCL was lowered to 0.010 mg/1 since the last five-year review in 2000.

- Changes in Exposure Pathways - No changes in the site conditions that affectexposure pathways were identified as part of this five-year review. There are no currentor planned changes in land use. No new contaminants, sources, or routes of exposurewere identified as part of this five-year review. There is no indication that hydrologic orgeologic conditions are not adequately characterized.

14

- Changes in Toxicity and Other Contaminant Characteristics - There have beenno changes in toxicity or other contaminant characteristics.

- Changes in Risk Assessment Methodologies - There are no changes in riskassessment methodologies which call into question the protectiveness of the remedy.

- Remedial Action Objectives - Remedial action objectives used at the time of theremedy selection are still valid.

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

- No other information has come to light that could call into question theprotectiveness of the remedy.

Technical Assessment Summary

The remedy of capping the chemical fill material and the construction of thediversion wall to control ground water flow around the contamination and into the CedarRiver has been successful. The PRP has continued to conduct groundwater monitoring ofonsite groundwater monitoring wells and surface water monitoring at upstream anddownstream stations of the Cedar River and to conduct site inspections of the site.

VIII. Issues

There were no deficiencies discovered during the site inspection of the LaBountysite property conducted on April 5, 2005, or in conducting the five-year review of thissite, including the review of the recent groundwater monitoring and surface watermonitoring data for this site.

IX. Recommendations and Follow-up Actions

No deficiencies were discovered during this five-year review. It is recommendedthat groundwater monitoring of onsite monitoring wells and surface water monitoring ofthe Cedar River and onsite inspections continue to be conducted by the PRP, Wyeth.

X. Protectiveness Statement

The results of the five-year review indicate that the remedy has been shown to beeffective with the capping of the chemical fill material, protective rip-rap between thecontamination and the Cedar River, and the construction of the diversion wall to controlgroundwater flow around the chemical fill material and into the river. The PRP, Wyeth,continues to conduct groundwater monitoring of site monitoring wells and surface watermonitoring of upstream and downstream stations of the adjacent Cedar River and to

15

conduct site inspections of the property. The site is surrounded by a fence in areas ofgeneral access. No vandalism or unauthorized entry has occurred at this site.Institutional controls have included perpetual easements obtained by the PRP, Salsbury,from all owners of property affected by either the LaBounty site or required remedialactivities. Easements were filed in the Office of County Recorder on October 22, 1980.Salsbury also obtained a restrictive covenant from Duane L. LaBounty and Alice 0.LaBounty prohibiting them from tampering with the LaBounty site. The LaBounty sitehas met remedial action objectives and is protective of human health and theenvironment.

XI. Next Review

This is a statutory five-year review. The first five-year review was conducted in1992, and the second five-year review was conducted in 2000. The next five-year reviewwill be conducted in the year 2010.

16

ATTACHMENTS

17

ATTACHMENT 1

Documents Reviewed

Consent Order between Salsbury Laboratories, Inc. and EPA, Docket No. 85-F-0013,July 1985

"Focused Feasibility Study, LaBounty Site, Charles City, Iowa", by the RemedialPlanning Field Investigation Team (REM FIT), CH2M-HH1, for EPA, January 30, 1985

"Five-Year Review Report", prepared by PRC Environmental Management, Inc., B&VWaste Science & Technology Corp. for EPA, August 1992

"Five-Year Review Report", prepared by Black & Veatch Special Projects Corp. forEPA, September 2000

"Tables, Results Summary, 2000-2003", by Conestoga-Rovers & Associates

"Tables, Results Summary, 2004", by Conestoga-Rovers & Associates

"Site Inspection Reports, 2000-2004", by Conestoga-Rovers & Associates

"Revised Site Monitoring and Maintenance Plan", by Conestoga-Rovers & Associates,July 12, 2004

18

ATTACHMENT 2

Site Tables and Figures

19

LABOUNTY DISPOSAL SITECHARLES CITY, IOWA

SITE FIGURE

0602 Submlttal Index CONESTOGA-ROVERS & ASSOCIATES

OSTATION 11 LOCATED UPSTREAM LEGEND

CW5-85 I CW6-85

M.H.-B

LIMIT OF DISPOSED WASTEAS IDENTIFIED BY BORINGSAND SALSBURY PERSONNEL

ALIGNMENT OF UPGRADIENTCUT OFF WALL AND GROUNDWATER

M.H.-B COLLECTION SYSTEM

FENCE

NESTED MONITORING WELL

LOWER CEDAR VALLEY AQUIFERMONITORING WELL

CEDAR RIVER MONITORING STATION

CUT OFF WALL MONITORING WELL

figure 1ION 12 LOCATED DOWNSTREAM 3

MONITORING WELL LOCATIONS1-APPROX. 3.3 MILES DOWNSTREAM LaBOUntyDlSpOSdlSite6 MCDONNELL STATION

10884-00(PRES008)GN-WA009 JUL 12/2004


TABLESRESULTS SUMMARY 2004

• GROUNDWATER MONITORING• GROUNDWATER ELEVATIONS

' UPGRADIENT DIVERSION WALL GROUNDWATER DISCHARGE• CEDAR RIVER MONITORING

0602 Submlttal Index CONESTOGA-ROVERS & ASSOCIATES

Date Sampled

WELL ID

Quarterly Schedule*M1385-RM1485-RM1585-R

Annual Schedule*M0479-AM0479-RM0579-AM0579-RM0679-ADM0679-ASM0679-RSM0679-RDM0779-ASM0779-ADM0779-RM0879-AM0879-RM0979-AM0979-R

Biennial Schedule*M0179-RM0279-RM0379-RM1079-RM1179-R

Jan-041

ND2ND2ND2

74166566

169002660053313

82300896004510

2080003670014900016700

12ND2ND2

435

TABLESUMMARY OF RESULTS

GROUNDWATER MONITORINGLABOUNTY DISPOSAL SITE

CHARLES CITY, IOWA

Arsenic (ppb)

Page 1 of 1

Feb-04* Mar-041 Apr-041 May-041 Jun-042 Jul-042 Aug-043 Sept-043 Oct-044

ND2ND2ND2

ND2ND2ND2

ND2ND2ND2

ND2ND2ND2

ND1ND1ND1

ND1ND1ND1

ND1ND1/ND1

ND1

693-6-----

—-

——

—13600011400

703

—5-----

—-

——-

14000012900

69268247

28600249004996

792008800048701980002960012000013100

674

—3

—----

—-

—--

11500015500

646

—5.3

—---------

11000013000

160006504.58.539000280005667.87200074000122016000027000

100700/10870012000

668

—3.4----------

9800016000

621

—3.8--------- '

—10000015000

5ND2ND2

3212

6.9ND17.63

256.3/259.6

Notes:

* Indicates sampling frequency beginning October 2004, per revised Site M&M Plan. Biennial sampling to occur in even-numbered years (i.e., 2006). Sampling of Wells -01 A, -02A, -03A, -10A, -12A, -12R discontinued.

1 - All results from FDAH laboratory.

2 - Arsenic and 112-TCA results from Test America-Cedar Falls. ONA/s-ONA results from FDAH laboratory.

3 - Arsenic, 112-TCA, and ONA results from Test America-Cedar Falls. s-ONA results from FDAH laboratory.

4 - From this sampling event forward Arsenic and 112-TCA results from Test America-Cedar Falls. ONA and s-ONA no longer required per revised Site M&M Plan.

NDxx - The compound was not detected at detection limit xx.

/ - Denotes analysis of duplicate sample completed by TA laboratory.

CRA 0602 -Sumimcy of Reiulb



CHARLES CITY, IOWA

1,1,2-Trichloroethane (ppb)

Page 1 of 1

Date Sampled /an-041

WELL ID

Quarterly Schedule*M1385-R ND5M1485-R ND5M1585-R ND5

Feb-041 Mar-041 Apr-041 May-041 Jun-042 Jul-042 Aug-043 Sept-043 Oct-044

ND5ND5ND5

ND5ND5ND5

ND5ND5ND5

ND5ND5ND5

ND1ND1ND1

ND1ND1ND1

ND1ND1ND1

ND1ND1ND1

ND1ND1/ND1

ND1

Annual Schedule*M0479-A 463M0479-R 2530M0579-A 54.6M0579-R 39.9M0679-AD 8490M0679-AS 14200M0679-RS 9.6M0679-RD ND5M0779-AS 11600M0779-AD 14700M0779-R 1140M0879-A 14700M0879-R 3640M0979-A 6900M0979-R 533

Biennial Schedule*M0179-R ND5M0279-R ND5M0379-R ND5M1079-R ND5M1179-R ND5

529

66.5

619

84.6

9600704

10300402

554225042.973.8

2010020100ND5ND51350017100114021500407059501030

ND5ND5ND5ND5ND5

545

—38.4-

—-----

———5820921

352

—32.7-

—

—----

—-

—55101020

185158021.085.61470018700ND1ND1922019700421169004560

4850/5070920

261

—19-

—-----

—-

—6500929 .

275

—19.6----------

56001030

ND1ND1ND1ND1

ND1/ND1

Notes:








CRA 0602-Sumnvry of fesulb



CHARLES CITY, IOWA

ONA (ppb)

Page 1 of 1

Date Sampled

WELL ID

Quarterly Schedule*M1385-RM1485-RM1585-R

Annual Schedule*M0479-AM0479-RM0579-AM0579-RM0679-ADM0679-ASM0679-RSM0679-RDM0779-ASM0779-ADM0779-RM0879-AM0879-RM0979-AM0979-R

Biennial Schedule*M0179-RM0279-RM0379-RM1079-RM1179-R

Jait-041

ND0.015ND0.015ND0.015

1.29J76.410.412.51541800ND5ND5173096615

3470063.12680669

ND0.015ND0.015

ND5ND5ND5

Feb-041

ND0.015ND0.015ND0.015

1.52J-

11.7----------

2390742

-----

Mar-041

ND0.015ND0.015ND0.015

1.57J

—15.7

—-

———————-

22501160

———— '

-

Apr-041

ND0.015ND0.015ND0.015

Z&2J706.4

19.82322280ND5ND51260507NR

3130099

2040703

0.017ND0.015

ND5ND5ND5

May-041

ND0.015ND0.015ND0.015

1.49J-

5.6

——--

—— •-

—--

2080331

-----

Jun-042

ND0.015ND0.015ND0.015

1.38J-

7.1

—---

—-----

2144599

-----

Jul-042

ND0.015ND0.015ND0.015

1.18J32

ND2.2519.33241910ND5ND577985

NDZ25259001471710229

ND0.015ND0.015

.ND5NDZ25

ND2.25/ND2.25

Aug-043

ND0.015ND0.015ND0.015

NDZ25-

NDZ25

—--------

'1850373

-----

Sept-043 Oct-044

ND0.015ND0.015ND0.015

NBZ25- -

NDZ25- -- -- -

-- -

--

- ---

1830529

_ _

-_

- -

-








CRA 0602-Summery of Retulls

GROUNDWATER ELEVATION DATA SUMMARYLABOUNTY DISPOSAL SITE

CHARLES CITY, IOWA

Groundiuater Elevation (ft. AMSL)2004

Well No.

M0179AM0286AM0379AM0479AM0579AM0679ASM0679ADM0779ASM0779ADM0879AM0979AM1079AM1289AM0179RM0279RM0379RM0479RM0579RM0679RSM0679RDM0779RM0879RM0979RM1079RM1179RM1289RM1385RM1485RM1585RIGS3DeepIGS3 ShallowCW-1-85CW-2-85CW-3-85CW-4-85CW-5-85CW-6-85

Notefs):

7-Jan

Dry990.791002.16974.39974.24973.47973.99973.45973.35973.34973.56973.92

Dry977.86977.92977.66974.53974.45973.86974.54974.0197338973.65974.31977.75997.78986.18986.05986.76987.66988.51977.95977.%977.99979.56977.91978.93

10-Feb

Dry990.621001.95974.59974.43973.88974.38973.75973.64973.74973.86974.16Dry

977.48977.61977.43974.5797444975.02974.76974.32973.74973.98974.45977.00997.35986.35986.05985.65986.70975.29977.69977.63975.16977.72977.52978.57

1-MarDry

990.551004.299746897442973.8197435973.71973.59973.8997404976.23

Dry980.46979.25978.539748697466974219748397431973.8897407976.76981.35999.64987.26987.22987.61986.39975.29979.31979.29980.22979.54980.51978.49

5-AprDry

991.531004.12975.1497470974029745597405973.939741197463976.85Dry

9844198Z8898Z80975.08975.029744397497974599741797478977.17983.771002.43993.59993.13987.63988.34978.15983.3398Z7797490984.26984.44979.80

t-MayDry

992.201003.83974.63974.29973.70974.06973.63973.52973.76973.98975.49Dry

981.61981.15981.26974.79974.60974.10974.52974.20973.78974.12975.75980.771000.65991.09990.%991.58990.68977.70981.52981.43973.82981.68981.64980.62

7-Jun

Dry994.57100431978.43976.65975.60978.97975.77975.65975.79976.32978.17Dry

986.55986.76987.80977.41977.00976.05976.81976.36975.84976.52978.68985.301006.471000.681000.221000.08

**

97Z56987.29987.07986.68986.95986.5898Z50

22-Jul

Dry993.82100413976.91976.43975.72976.07975.63975.49975.81975.84977.66Dry

984.75984.6398477976.83976.55976.16976.64976.25975.78976.03978.07984.02100Z09997.68997.22977.71

**

981.41984.73984.62984.77984.85983.78983.90

10-Aug

Dry993.111003.93976.14975.88975.31975.67975.20975.06975.33975.32976.93

Dry98Z6798Z5698Z43976.11976.17975.71976.09975.77975.31975.47977.2098Z101000.50

NANA

996.05**

980.1098Z6098Z5498Z7498Z8798Z72983.79

27-Sep

Dry99Z021003.27978.15977.37976.38976.75976.55976.70976.59977.07977.72

Dry98Z8798Z8398Z80978.07977.65976.80.977.45977.06976.60977.21977.9798Z47999.59

NANA

99Z62993.0299Z6298Z9398Z8598Z95983.2898Z92983.17

2005

26-Ocf

Dry991.70100Z59975.22974.87974.28974.62974.23974.10974.38974.54975.35

Dry979.82979.66979.53975.17975.1597464975.0397475974.34974.67975.58979.30998.80

NANA

990.09993.10978.56979.79979.74979.88979.98979.8698Z47

ft AMSL - feet above mean sea levelPer the revised Site M&M Plan, beginning in October 2004 groundwater level measurement frequency is quarterly for Wells M1385R, M1485R, M1585R and semi-annually for all other wells.NA = Not Available** Measured water level exceeds reference elevation.

CRA 0602-Water Levets_PrecipitflHon Pagel

TABLE Page 1 of 1SUMMARY OF RESULTS

QUARTERLY NPDES MONITORINGUPGRADIENT GROUNDWATER DIVERTED FROM FLOWING THROUGH THE LABOUNTY SITE


Arsenic Concentrations (tngflVArsenic Loadings (Ibs per day)QuarterDate Sampled

LBTD

Jan-Mar 04 'VL6/2004

Cone. Mass

0.204 0.002

Apr-Jun 04 *6/14/1004:

Cone. Mass

0.047 0.005

July-Sept 04 'W6/2004

Cone. Mass

0.113 0.008

Oct-Dec042

10/4/2004Cone. Mass

0.205 0.012

Notes:

1 - Arsenic analysis performed by FDAH laboratory.

2 - From this sampling event forward arsenic analysis performed by Test America-Cedar Falls.



NR- No Report

CRA 0601-Summaiy of Result)


CEDAR RIVER MONITORINGLABOUNTY DISPOSAL SITE

CHARLES CITY, IOWA

Page 1 of 2

Date SampledFlowrate

S-Jan-'Ot1

113 mgdCone. Loading

2-Feb-Oi1 29-Mar-04'87 mgd 406 mgd

Cone. Loading Cone. Loading

8-Apr-O*1


e-Affly-041


29-/HM-042


Arsenic Concentrations (ppb)/Arsenic Landings (Ibs per dai/)CEDAR RIVER IDMonthly Schedule*CR McDonnell

Quarterly Schedule*CR Station 11CR Station 12Calc. LaBounty

12

ND210-

11.30

ND1.889.42

7.18-9.06

MR 15

ND2 ND1.45 ND29 6.53 15

4.89-6.34

50.79

NT)6.7750.79

43.91-50.68

22

NTJ222-

31.19

1ND2.8431.19

28.18-31.02

13

ND213-

20.93

ND3.2220.93

16.74-19.96

10.5

1.609.8-

60.69

9.2556.6446.61

112TCA Concentrations (vpb)/112TCA Loadings (Ws per day)CEDAR RIVER IDMonthly Schedule*CR McDonnell


ND5

ND5ND5-

ND4.71

ND4.71ND4.71-

ND5

ND5 ND3.63 ND5ND5 ND3.63 ND5_

ND16.93

ND16.93ND16.93

-

ND5

ND5ND5-

ND7.09

ND7.09ND7.09

-

ND5

ND5ND5-

ND8.05

ND8.05ND8.05

-

1.25

ND11.47-

7.23

ND5.788.49-

Naln:* Indicates sampling frequency beginning October 2004, per revised Site M&M Plan. Grab sampling performed at the McDonnell Station and

stream gaging-composite sampling performed at Stations 11 and 12 for arsenic and 112-TCA.1 - All results from FDAH laboratory.


3 - Arsenic, 112-TCA, and ONA results from Test America-Cedar Falls. S-ONA results from FDAH laboratory.

4- From this sampling event forward Arsenic and 112-TCA results from Test America-Cedar Falls. ONA and s-ONA no longer required per revised Site M&M Plan.



" - No stream gaging & composite sampling - River discharge above 750 cfs all month.

NR- No Report

MGD - Cedar River flowrate in million gallons per day

CRA 0602-Sumiruiy of Result*


CEDAR RIVER MONITORINGLABOUNTY DISPOSAL SITE

CHARLES CITY, IOWA

Page 2of 2

Date SampledFloivrate

Jul-042 18-Aug-Ot3

422 mgdCone. Loading Cone. Loading

7-Sept-043


26-Oct-044 12-Nov.-04 2-Dec.-04251 mgd

Cone. Loading Cone. Loading Cone. LoadingArsenic Concentrations (ppb)/Arsenic Loadings (Ibs per day)

CEDAR RIVER IDMonthly Schedule*CR McDonnell


4.1 14.43

** NT>1 ND3.524.5 15.84

11.61-15.13

9.1

1.87.8-

20.95

4.1417.9612.68

7.7

—--

16.12 4.8 3.9

ND15.1

-1 12TCA Concentrations (ppb)/112TCA Loadings (Ibs per day)

CEDAR RIVER IDMonthly Schedule*CR McDonnell ND1 ND3.52 ND1 ND2.30 ND1 ND2.10 ND1 ND1


ND1 ND3.52ND1 ND3.52

ND1 ND2.30ND1 ND2.30

ND1ND1

Holes:

* Indicates sampling frequency beginning October 2004, per revised Site M&M Plan. Grab sampling performed at the McDonnell Station and

stream gaging-composite sampling performed at Stations 11 and 12 for arsenic and 112-TCA.



3 - Arsenic, 112-TCA, and ON A results from Test America-Cedar Falls. S-ONA results from FDAH laboratory.




** - No stream gaging & composite sampling - River discharge above 750 cfs all month.

NR- No Report

MGD - Cedar River (lowratc in million gallons per day

CRA 0602-Sumnury of Rejulu

ATTACHMENT 3

Site Inspection Reports

20

BI-MONTHLY INSPECTION REPORT -- LABOUNTY SITE

DATE:

WEATHER CONDITIONS:

9/28/04 TIME: 1300

Sunnv/64°F

PARKING LOT:

(Design grade andsurface condition)

DITCHES

- North Ditch

- South Ditch

(Design grade and erosion)

a) East of Parking Lot

b) South of Parking Lot

c) Northwest corner of area

FINAL GROUND COVER:

(Erosion, settlement, burrowing,cover gro%vth)

(Growth of trees, brush orlarge weeds over clay area)

FLOOD DAMAGE:

a) Rip rap

b) Flood plain

c) Toe of secure fill

NOTE: Inspect after each significant flood

COMMENTS

OK

OK

OK

OK

OK

OK

OK

OK

OK

OK, some settled area of rock to befurther inspected

OK

OK

-1 -

5.

6.

7.

8.

9.

BI-MONTHLY INSPECTION REPORT (Continued)

MONITORING WELLS:

a) External condition1. Cement collar2. Standpipe3. Cap and Lock

b) Internal condition(Note: Well productivity and depth are checkedannually in conjunction with a sampling event.Document these measurements. A significantincrease or decrease in evacuation rate, adjustedfor seasonal variation or a decrease in welldepth, may indicate an internal defect in thewell.)

ACCESS ROAD

(Condition)

FLOOD PLAIN

a) Grade

b) Access to river

c) Ground cover

FENCE

(Condition)

UPGRADIENT TILE WET WELL

a) Pump/Controls

b) Flowmeter

c) Subdrain tile

MAINTENANCE RECOMMENDATIONS:

Inspection camedout by:

Signature

Dana ShermanPrinted

OKOKOK

OK

OK

OK

OK

OK

Requires repair near gate at CityMaintenance garage, due to recentflooding. River City fencecontacted.

OK

OK

OK

Approved by:

Printed

- 2 -


DATE:

WEATHER CONDITIONS:

7/22/04 TIME: 0900

Partly Cloudv/82°F

PARKING LOT:


DITCHES

- North Ditch

- South Ditch




c) Northwest comer of area

FINAL GROUND COVER:

(Erosion, settlement, burrowing,cover growth)


FLOOD DAMAGE:

a) Riprap

b) Flood plain



COMMENTS

OK

OK

OK

OK

OK

OK

OK

OK

OK


OK

OK

- 1 -


MONITORING WELLS:



6. ACCESS ROAD

(Condition)

7. FLOOD PLAIN

a) Grade

b) Access to river

c) Ground cover

8. FENCE

(Condition)

9. UPGRADIENT TILE WET WELL

a) Pump/Controls

b) Flowmeter

c) Subdraintile


Inspection carrieiout by:

Signature

Dana Sherman

OKOKOK

OK

OK

OK

OK

OK

OK

OK

OK

OK

Approved by:

Printed

Osignature

Neil LeipzigPrinted

- 2 -


DATE:

WEATHER CONDITIONS:

5/6/04 TIME: 1000

Partly Cloudv/73°F

3.

PARKING LOT:


DITCHES

- North Ditch

- South Ditch




c) Northwest corner of area

FINAL GROUND COVER:



FLOOD DAMAGE:

a) Riprap

b) Flood plain



COMMENTS

OK

OK

OK

OK

OK

OK

OK

OK

Requires spraying of rip-rapfor weed control


OK

OK

-1-

5.

6.

7.

8.

9.


MONITORING WELLS:



ACCESS ROAD

(Condition)

FLOOD PLAIN

a) Grade

b) Access to river

c) Ground cover

FENCE

(Condition)

UPGRADIENT TELE WET WELL

a) Pump/Controls

b) Flowmeter

c) Subdrain tile


Inspection carried out by:

Neil LeipzigPrinted

OKOKOK

OK

OK

OK

OK

OK

OK

OK

OK

OK

Resurveyed reference elevation ofM06-AD after standpipe repair

Approved by:

I VJ?

Printed

-2 -


DATE:

WEATHER CONDITIONS:

TIME:

* /=•

COMMENTS1. PARKING LOT:


2. DITCHES

- North Ditch

- South Ditch





3. FINAL GROUND COVER:



4. FLOOD DAMAGE:

a) Riprap

b) Flood plain



C'OIC3

,v. __ ..... •'•"

iL

OK

OK......

OK").

- 1 -

5.

6.

7.

ACCESS ROAD

(Condition)

FLOOD PLAIN

a) Grade -

b) Access to river

c) Ground cover

FENCE

(Condition)

UPGRADIENT TILE WET WELL

a) Pump/Controls

b) Flowmeter

c) Subdraintile


8.

9.

Inspection carried.out by:

Signature

Printed


MONITORING WELLS:


b) Internal condition(Note: Well productivity and depth are checkedannually in conjunction with a sampling event.Document these measurements. A significantincrease or decrease in evacuation rate, adjustedfor seasonal variation or a decrease in well

.. depth, may indicate an internal defect in thewell.)

( OK

OK

OK_.̂-•-••

o:

OK -

Approved by:

f- {"•*-• *-) <y. -VJ.

i > J V A « . s , A .

A ~\ 6

Printed

- 2 -


DATE:

WEATHER CONDITIONS:

2/12/04 TIME: 1100

Cloudv/30°F

PARKING LOT:


DITCHES

- North Ditch

- South Ditch





FINAL GROUND COVER:



FLOOD DAMAGE:

a) Riprap

b) Flood plain



COMMENTS

OK

OK

OK

OK

OK

OK

OK

OK

Requires Fall or Spring sprayingfor weed control

OK

OK

OK - Some settling of rock

5.

6.


MONITORING WELLS:

a) External condition1. Cement collar2. Slandpipe3. Cap and Lock

b) Internal condition(Note: Well productivity <md depth are checkedannually in conjunction with a sampling event.Document these measurements. A significantincrease or decrease in evacuation rate, adjustedfor seasonal variation or a decrease in welldepth, may indicate an internal defect in thewell.)

ACCESS ROAD

(Condition)

7. FLOOD PLAIN

a) Grade

b) Access to river

c) Ground cover

8. FENCE

(Condition)

9. UPGRADIENT TILE WET WELL

a) Pump/Controls

b) Flowmeter

c) Subdrain tile


Inspection carried out by:i

SX

OKOKOK - 15R cracked pipe

OK

OK

OK

OK

OK

OK - Tree on fence, prior to wells

OK

OK

OK

Approved by:

Printed

fiignati

Patrick J. NeuzilPrinted

- 2 -

DAILY LOCAL PRECIPITATIONCHARLES CITY, IOWA

Precipitation (inches)2004

Date12345678910111213141516171819202122232425262728293031TOTAL

Jan.

T

TT

T

0.170.18

T

T

0.290.07

0.05

0.76

Feb.0.300.39

T

0.290.020.06

TTTTT

T

0.29T

0.08

T

1.43

Mar.0.27

0.030.300.490.10

T

0.06T

0.22

0.030.010.050.10

0.010.601.710.700.290.180.06

5.21

Apr.

0.02

0.290.010.32

0.55

T0.410.21

1.81

May

T0.67

0.67

0.22

2.292.180.580.60

0.071.29

8.57

Jun.

0.14

0.250.280.010.480.06T

0.05

T

1.14

0.13

2.54

Jul

1.89T

2.41TT

0.63

0.03

0.010.010.32

T0.49

T0.410.21

0.060.66

7.13

Aug.0.140.320.21

T

0.01TT

TT

0.67

0.340.220.10

2.01

Sept

0.10

0.10

Oct.0.67

0.12

T0.020.01T

T

0.03T

0.08

0.050.430.08

1.49

Nov.0.43

0.04

0.020.080.51T

0.150.21

1.44

Dec.

0.23T(Sn)

0.05T

0.04

T(Sn)T(Sn)

0.06

0.38

2004 TOTAL I 32.87

Note(s):

Total precipitation recorded as inches (water equivalent).Source: National Weather Service Forecast Office, La Crosse, Wisconsin (www.crhjioaa.gov/arx/dimate)T = Trace (<0.01" precipitation)Sn = Snow

CRA 0602 Precipitation Pagel