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SAMPLING AND ANALYSIS WORK PLAN

Prepared For: EXIDE TECHNOLOGIES FRISCO RECYCLING CENTER 7471 SOUTH FIFTH STREET FRISCO, COLLIN COUNTY, TEXAS

EPA ID NO. TXD006451090 DOCKET NO. RCRA-06-2011-0966

DISCLAIMER:
SOME FORMATTING CHANGES MAY HAVE OCCURRED WHEN THE ORIGINAL DOCUMENT WAS PRINTED TO PDF; HOWEVER, THE ORIGINAL CONTENT REMAINS UNCHANGED.

Prepared by: Conestoga-Rovers & Associates


2270 Springlake Road, Suite 800 Dallas, Texas 75234

REVISED NOVEMBER 2011 REF. NO. 029796-02 (1)

Office: (972) 331-8500 Fax: (972) 331-8501 web: http:\\www.CRAworld.com

Worldwide Engineering, Environmental, Construction, and IT Services

TABLE OF CONTENTS Page 1.0. 2.0 INTRODUCTION ...................................................................................................................1 1.1 WORK PLAN OBJECTIVES...............................................................................1 SITE HISTORY ........................................................................................................................2 2.1 SITE DESCRIPTION AND FACILITY HISTORY ...........................................2 2.2 PREVIOUS INVESTIGATIONS ........................................................................2 PRELIMINARY CONCEPTUAL SITE MODEL .................................................................5 3.1 FACILITY PROFILE............................................................................................5 3.1.1 GENERAL OPERATIONS .................................................................................6 3.1.2 FACILITY STRUCTURES...................................................................................6 3.1.2.1 THE RAW MATERIALS STORAGE BUILDING............................................6 3.1.2.2 BATTERY RECEIVING AND STORAGE BUILDING...................................7 3.1.2.3 OXIDE BUILDING ..............................................................................................7 3.1.2.4 BATTERY BREAKER BUILDING .....................................................................7 3.1.2.5 BLAST FURNACE BUILDING..........................................................................8 3.1.2.6 SLAG TREATMENT TANK BUILDING .........................................................8 3.1.2.7 WASTEWATER TREATMENT PLANT ..........................................................8 3.1.3 PROCESS AREAS................................................................................................9 3.1.3.1 RECEIVING SCALES AND TRUCK STAGING AREA ................................9 3.1.3.2 THE RAW MATERIALS STORAGE BUILDING............................................9 3.1.3.3 BATTERY RECEIVING AND STORAGE BUILDING.................................10 3.1.3.4 BATTERY BREAKER BUILDING ...................................................................10 3.1.3.5 THE BALE STABILIZATION AREA..............................................................10 3.1.3.6 REVERBERATORY (REVERB) FURNACE ...................................................11 3.1.3.7 BLAST FURNACE.............................................................................................11 3.1.3.8 SLAG TREATMENT TANK BUILDING OR SLAG FIXATION TANK BUILDING .............................................................................................12 3.1.3.9 THE REVERB AND BLAST FURNACE SCRUBBER...................................12 3.1.3.10 LANDFILL .........................................................................................................12 3.1.3.11 WASTEWATER TREATMENT PLANT ........................................................13 3.1.3.12 CRYSTALLIZER ................................................................................................13 3.1.3.13 THE STORMWATER COLLECTION AND RETENTION POND SYSTEM.........................................................................13 3.1.3.14 BONE YARD ......................................................................................................14 3.1.4 SOLID WASTE MANAGEMENT UNITS (SWMUS) AND WASTE MANAGEMENT AREAS..................................................................14 3.1.5 PROPERTY BOUNDARIES .............................................................................14 3.2 LAND USE AND EXPOSURE PROFILE .......................................................14 3.2.1 LAND USE ON THE FACILITY AND ADJACENT PROPERTIES ...............................................................................15

3.0

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3.2.2 3.2.3 3.2.4 3.2.4.1 3.2.4.2 3.2.4.3 3.2.4.4 3.2.4.5 3.2.5 3.2.5.1 3.2.5.2 3.2.5.3 3.2.5.4 3.3 3.3.1 3.3.2 3.3.3 3.3.4 3.3.5 3.3.6 3.4 3.4.1. 3.4.2 3.4.3 3.4.4 3.5 3.5.1 3.5.1.1 3.5.1.2 3.5.1.3 3.5.1.4 3.5.1.5 3.5.1.6 3.5.1.7 3.5.1.8 3.5.1.9 3.5.1.10 3.5.1.11 3.6 3.6.1

BENEFICIAL RESOURCE DETERMINATION AND LOCATIONS............................................................................................15 SENSITIVE RECEPTORS .................................................................................15 APPLICABLE EXPOSURE SCENARIOS .......................................................16 ON-SITE OUTDOOR WORKER .....................................................................16 ON-SITE INDOOR WORKER .........................................................................16 ON-SITE CONSTRUCTION WORKER .........................................................16 OFF-SITE RECREATIONAL VISITOR...........................................................17 OFF-SITE RESIDENTIAL OCCUPANT.........................................................17 APPLICABLE EXPOSURE PATHWAYS.......................................................17 POTENTIAL SOURCES ...................................................................................17 EXPOSURE MEDIA ..........................................................................................17 ROUTES OF EXPOSURE..................................................................................18 POTENTIALLY-COMPLETE EXPOSURE PATHWAYS ............................18 PHYSICAL PROFILE ........................................................................................20 REGIONAL GEOLOGY ...................................................................................20 REGIONAL HYDROGEOLOGY.....................................................................21 SITE GEOLOGY AND HYDROGEOLOGY ..................................................22 SURFACE FEATURES ......................................................................................23 SOIL.....................................................................................................................24 SURFACE WATER HYDROLOGY.................................................................25 ECOLOGICAL PROFILE .................................................................................25 LAND FEATURES ............................................................................................26 DESCRIPTION OF SITE RECEPTORS IN RELATION TO HABITAT TYPE ..........................................................................................27 THREATENED/ENDANGERED SPECIES ..................................................27 DESCRIPTION OF RELATIONSHIP OF RELEASES TO POTENTIAL HABITAT AREAS .....................................................................29 RELEASE PROFILE...........................................................................................29 FATE AND TRANSPORT MECHANISMS...................................................30 LEAD BIOGEOCHEMICAL CYCLES ............................................................30 LEAD TRANSPORT BETWEEN POTENTIALLY AFFECTED MEDIA ..........................................................................................30 LEAD TRANSPORT IN SEDIMENT ..............................................................31 LEAD TRANSPORT IN AIR/ATMOSPHERE..............................................31 TRANSPORT OF LEAD IN SURFACE WATER ..........................................31 TRANSPORT OF LEAD IN SOIL....................................................................32 LEAD TRANSPORT IN THE SOIL TO GROUNDWATER PATHWAY.......................................................................32 LEAD TRANSPORT IN THE SOIL TO AIR PATHWAY ............................32 LEAD TRANSPORT IN THE SOIL TO SURFACE WATER RUNOFF PATHWAY........................................................................33 TRANSPORT OF LEAD IN GROUNDWATER...........................................33 LEAD UPTAKE BY PLANTS...........................................................................33 RISK MANAGEMENT PROFILE ...................................................................33 RISK MANAGEMENT .....................................................................................33

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3.7 4.0

DATA GAPS ......................................................................................................34

CHARACTERIZATION AND FIELD ACTIVITIES ........................................................35 4.1 SOIL SAMPLING ..............................................................................................35 4.1.1 SAMPLING PROCEDURES ............................................................................35 4.1.2 BACKGROUND SOIL SAMPLING................................................................37 4.1.3 SWMU SOIL SAMPLING ................................................................................37 4.1.3.1 RFI UNITS ..........................................................................................................38 4.1.3.1.1 NORTH DISPOSAL AREA ..............................................................................38 4.1.3.1.2 SLAG LANDFILL..............................................................................................39 4.1.4.1.3 RAW MATERIAL STORAGE AREA..............................................................40 4.1.4.1.4 SOUTH DISPOSAL AREA...............................................................................41 4.1.4.2 NON-RFI UNITS ...............................................................................................41 4.1.4.2.1 BONEYARD .......................................................................................................41 4.1.4.2.2 BAIL STABILIZATION AREA ........................................................................42 4.1.4.2.3 CRYSTALLIZATION UNIT FRAC TANK ....................................................42 4.1.4.2.4 STEWART CREEK FLOOD WALL ................................................................43 4.1.4.2.5 FORMER SHOOTING RANGE.......................................................................44 4.2 SURFACE WATER AND SEDIMENT SAMPLING STEWART CREEK ............................................................................................44 4.2.1 SURFACE WATER SAMPLES ........................................................................44 4.2.2 SEDIMENT SAMPLES......................................................................................45 4.3 GROUNDWATER IINVESTIGATIONS ........................................................46 4.3.1 GROUNDWATER CLASSIFICATION AND FLOW DIRECTION ..........................................................................................46 4.3.2 BACKGROUND GROUNDWATER QUALITY ...........................................47 4.3.3 GROUNDWATER SAMPLING ......................................................................49 4.4 ABANDONMENT OF BOREHOLES .............................................................50 4.5 INVESTIGATION-DERIVED MATERIAL ....................................................50 4.6 MODIFICATIONS TO FIELD CHARACTERIZATION ACTIVITIES........................................................................................................51 DATA EVALUATION .........................................................................................................52 QUALITY ASSURANCE/QUALITY CONTROL............................................................53 6.1 PROPOSED ANALYTICAL LABORATORIES.............................................53 HEALTH AND SAFETY......................................................................................................55 7.1 MINIMUM QUALIFICATIONS FOR PERSONNEL ...................................55 7.2 ACCESS BY USEPA ..........................................................................................55 PRELIMINARY SCHEDULE AND REPORTING............................................................56 CERTIFICATION ..................................................................................................................57

5.0 6.0 7.0

8.0 9.0

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LIST OF FIGURES (Following Text) FIGURE 1 FIGURE 2 FIGURE 3 FIGURE 4 FIGURE 5 FIGURE 6 FIGURE 7 FIGURE 8 FIGURE 9 FIGURE 10 FIGURE 11 FIGURE 12 FIGURE 13 FIGURE 14 FIGURE 15 SITE LOCATION MAP SITE MAP PRELIMINARY CONCEPTUAL SITE MODEL PROPOSED SOIL SAMPLE LOCATIONS NORTH DISPOSAL AREA PROPOSED SOIL SAMPLE LOCATIONS SLAG LANDFILL PROPOSED SOIL SAMPLE LOCATIONS RAW MATERIAL STORAGE AREA PROPOSED SOIL SAMPLE LOCATIONS SOUTH DISPOSAL AREA PROPOSED SOIL SAMPLE LOCATIONS - BONEYARD PROPOSED SOIL SAMPLE LOCATIONS BAIL STABILIZATION AREA PROPOSED SOIL SAMPLE LOCATIONS CRYSTALLIZATION UNIT FRAC TANK PROPOSED SOIL SAMPLE LOCATIONS STEWART CREEK FLOOD WALL PROPOSED SURFACE WATER AND SEDIMENT SAMPLE LOCATIONS EXISTING GROUNDWATER MONITORING NETWORK AND PROPOSED BACKGROUND MONITOR WELL LOCATIONS TYPICAL MONITOR WELL INSTALLATION ECOLOGICAL RECEPTORS MAP WITHIN 1,000-FOOT RADIUS OF FACILITY BOUNDARIES

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LIST OF APPENDICES APPENDIX A APPENDIX B APPENDIX C APPENDIX D QUALITY ASSURANCE PROJECT PLAN HISTORICAL GROUNDWATER GRADIENT MAP MONITOR WELL CONSTRUCTION DETAILS ECOLOGICAL ASSESSMENT CHECKLIST AND ECOLOGICAL EXCLUSION CRITERIA WORKSHEET FACILITY DRAWINGS OF UNDERGROUND UTILITIES

APPENDIX E

LIST OF EXHIBITS EXHIBIT 1 PRELIMINARY SCHEDULE

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1.0.

INTRODUCTION Exide Technologies (Exide) Frisco Recycling Center (the permitted facility is hereinafter referred to as facility or Site) submits this Sampling and Analysis Work Plan (Work Plan) in response to Section VI of the Administrative Order (Order) issued to Exide by the United States Environmental Protection Agency (USEPA) in Docket No. Resource Conservation and Rehabilitation Act (RCRA)-06-2011-0966, on August 1, 2011.

1.1

WORK PLAN OBJECTIVES

This Work Plan, once implemented, is designed to define the nature, location, extent, and movement of hazardous wastes and/or hazardous constituents, which are present at or have been released from the Site, through monitoring, testing, analysis, and reporting. The Work Plan is intended to accomplish the following (per specific language specified in the Order): a. Characterize the potential pathways of migration of hazardous waste and/or hazardous constituents at the Site b. Characterize the sources of hazardous waste and/or hazardous constituents in the various environmental media at the Site c. Define the degree and extent of hazardous waste and/or hazardous constituent concentrations in various media at the Site above applicable regulatory standards d. Identify actual or potential receptors e. Identify potential further actions

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2.0

SITE HISTORY This section presents a description of the Site history and information regarding previous investigations performed at the Site.

2.1

SITE DESCRIPTION AND FACILITY HISTORY

The Site is a secondary lead smelter, lead metal recycling facility that has been in operation in Frisco, Texas, since approximately 1964. The location of the Site is shown on the Site Location Map presented on Figure 1. The extent of the surrounding property owned by Exide is also shown on Figure 1. The facility recycles spent lead-acid batteries and other lead-bearing scrap materials. The scrap lead is smelted and refined to produce lead, lead alloys, and lead oxide. The Site consists of a Battery Receiving/Storage Building, battery breaker operations, raw materials storage, a laboratory, a blast furnace, a reverbatory furnace, an oxide production facility, refining operations, one active non-hazardous waste landfill, several closed landfills, a wastewater treatment plant, and a stormwater retention pond. A Site map is presented on Figure 2. Wastewater generated at the Site is treated on-Site and recycled to the process. Stormwater runoff is collected in a stormwater retention pond, treated as necessary, then recycled to the process. The Site is permitted by the Texas Commission on Environmental Quality (TCEQ) to discharge wastewater to Stewart Creek, although this has not occurred since approximately 2009.

2.2

PREVIOUS INVESTIGATIONS

Several investigations have been conducted to characterize the Site and assess the nature and extent of constituent of concern concentrations in the various environmental media at the Site. Dames and Moore conducted a hydrogeologic investigation at the Site, which included the installation of eight groundwater monitor wells. The investigation is described in the August 1983 report. The investigation identified the uppermost water-bearing zone to consist of unconsolidated materials, shallow limestone, and shale bedrock. According to the Dames and Moore report, the groundwater contained in the uppermost water-

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bearing zone is separated from the deeper aquifer by the relatively impermeable Eagle Ford shale, which acts as an aquitard. In 1987, Southwestern Laboratories, Inc., performed a soil sampling program during the closure of the former drum storage area and installed two monitor wells for evaluation of groundwater. Details of the Southwestern Laboratories investigation are presented in the Phase I Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) report. The hazardous waste operating permit issued for the Site in 1989 identified nine Solid Waste Management Units (SWMUs) for investigation as part of the Corrective Action Program: 1. Battery Storage Area 2. Raw Material Storage Area 3. Slag Landfill 4. North Disposal Area 5. South Disposal Area 6. Stewart Creek 7. Old Drum Storage Area 8. Stewart Creek Sediment Dredging Waste Pile, and 9. Product Waste Pile These SWMUs were identified by the Texas Water Commission (TWC) in their RCRA Facility Assessment (RFA), dated November 16, 1987. The Battery Storage Area, Old Drum Storage Area, Stewart Creek Sediment Dredging Waste Pile (placement of the waste pile on a portion of the North Disposal Area for use as intermediate cover was approved by the Texas Natural Resource Conservation Commission [TNRCC], presently known as the TCEQ), and Product Waste Pile have been certified as closed and the closure was approved by the TNRCC. The North Disposal Area was capped and closed in 1978, prior to RCRA. The South Disposal Area was closed and capped in 1974, prior to RCRA. The Slag Landfill has been closed since 1996. A tenth SWMU, residue from an earlier release from a diesel tank (Former Diesel Fuel Tank), was discovered in the spring of 1988 during construction of the retention wall along Stewart Creek and was subsequently remediated.

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During the RFI, the SWMUs referenced in the 1989 permit were consolidated into four waste management areas (WMA1 through 4) as provided at that time in 30 Texas Administrative Code (TAC) 335.163(2) for the purpose of designing a groundwater monitoring system. WMA1 consisted of a portion of the Slag Landfill, the closed North Disposal Area, and the closed Stewart Creek Sediment Dredging Waste Pile. WMA2 included the Raw Material Storage Area, the Old Drum Storage Area, the Closed Product Waste Pile, the Battery Receiving/Storage Building, and the Former Diesel Fuel Tank leak area. WMA3 included a portion of the South Disposal Area and MWA4 was Stewart Creek. The Phase I RFI was conducted in 1990/1991 and consisted of a soil and groundwater investigation of WMAs 1, 2, and 3, an investigation of WMA4, a hydrogeological investigation, and delineation of the landfill areas. The limits of the North and South Disposal Areas were delineated during the Phase I RFI by borings around the perimeter and through the units. The Phase I Report, dated May 8, 1991, and the Addendum to the Phase I RFI Report, dated December 10, 1993, identified lead as the primary constituent of concern at the Site, and soil as the primary environmental media of concern. Cadmium is also present in soils, but at very low concentrations. The TNRCC approved the Phase I RFI Report and Addendum in correspondence dated June 3, 1994, and requested a Phase II RFI of selected areas of the Site. A Phase II RFI was conducted in June 1998, pursuant to a work plan approved, with modifications, by the TNRCC. The Phase II RFI addressed the areas referenced in the TNRCCs June 3, 1994, correspondence and included soil sampling at the truck staging area, the railroad spur, and the area adjacent to monitor well B7R, as well as further delineation of the lateral extent of soil constituent of concern concentrations above applicable regulatory standards at the South Disposal Area and development of a Corrective Measures Study for the South Disposal Area. The Phase II RFI field activities and findings were documented in an August 28, 1998, report submitted to TNRCC. Stewart Creek was addressed as a separate project (baseline risk assessment). The Human Health and Ecological Risk Assessment and Corrective Measures Study for Stewart Creek (Stewart Creek CMS) was submitted to the TNRCC on August 5, 1998. As a result of the Stewart Creek CMS, an approximate 2,800-foot stretch of the creek sediments was remediated to standards for lead and cadmium approved by the TNRCC (91 milligrams per kilogram [mg/kg] for lead and 4.23 mg/kg for cadmium). The details of the remediation are presented in the Stewart Creek Corrective Measures Implementation Report dated July 13, 2000.

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3.0

PRELIMINARY CONCEPTUAL SITE MODEL A Conceptual Site Model (CSM) is a three-dimensional picture of site conditions at a discrete point in time (a snapshot) that conveys what is known or suspected about a facility, releases, release mechanisms, contaminant fate and transport, exposure pathways, potential receptors, and risks. Preliminary Conceptual Site Model (CSM) for the Site is presented on Figure 3. The CSM was prepared using the November 2008 EPA Region VI Corrective Action Strategy guidance for developing a conceptual site model (http://www.epa.gov/region6/6pd/rcra_c/pd-o/cas_final08.pdf). The preliminary CSM for the Site is based on the existing information and is developed prior to additional field activities. The preliminary CSM will be used to identify data gaps in current Site knowledge and focus future investigative activities on filling those gaps. The CSM is dynamic and will be refined from the initial stages of the investigation phase as additional information becomes available. As per EPA guidance, the following profiles are included in the preliminary CSM for the Site: 1. Facility profile 2. Land use and exposure profile 3. Physical profile 4. Release profile 5. Ecological profile, and 6. Risk management profile

3.1

FACILITY PROFILE

This facility profile provides information on buildings or process structures that may affect remedy implementation. The locations of facility structures, process areas, and property boundaries can be important to land use determinations and site-specific risk assessment. The facility profile information in this section is from the EPA Region 6 Multi-Media Inspection Report, dated September 13, 2010, and from the Texas Commission on Environmental Quality Investigation Report, conducted May 6, 2011 June 29, 2011.

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3.1.1

GENERAL OPERATIONS

The facility is a secondary lead smelter and refinery. The facility manufactures lead ingots (soft lead), alloyed lead ingots (hard lead), and lead oxide. The facility also manufactures sodium sulfate as a byproduct of their wastewater treatment system. The facility reclaims and recycles lead containing materials in their furnaces. The feed to the facilitys furnaces includes spent batteries, floor sweep, potentially lead-impacted material generated on-Site, battery scrap, and lead scrap. Sources of the lead-containing material received at the facility include scrap metal recyclers, automotive industries, and the military. The main waste that the facility produces is blast furnace slag. The facility produces approximately 400 tons per day of finished product and is limited to 72,000 tons of finished goods per year by one of its air permits. The facility is limited to 58,300 tons of finished lead oxide per year by another of its air permits.

3.1.2

FACILITY STRUCTURES

The buildings that are used in the lead process at the facility are described here. Their locations are shown on Figure 2.

3.1.2.1

THE RAW MATERIALS STORAGE BUILDING

The Raw Materials Storage Building is a centrally located building permitted to store lead-containing materials. The building is completely enclosed. A one foot thick reinforced concrete wall extends up from the floor 10-feet on the inside perimeter of the building. A 3/6 inch steel plate extends an additional 40 inches above the top of the concrete wall. The inside of the walls and the exposed side of the steel plate are sealed with a high solids industrial epoxy coating. The building has a structural steel frame and roof joist system with a sheet metal skin. The floor is constructed of reinforced concrete and its thickness varies from 24-inches near the load bearing foundation walls, to 12-inches toward the center of the building. The building has a rated bearing capacity of 4,150 tons. The wastes stored in this building have passed a paint filter test (no free liquids). Since there are no free liquids (with the exception of dust suppression liquid which is allowed), this building is not subject to leak detection and secondary containment requirements.

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The Raw Materials Storage area is part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.2.2

BATTERY RECEIVING AND STORAGE BUILDING

The Battery Receiving and Storage Building is on the western side of the facility and is permitted to store lead-acid batteries. It is approximately 18,150 square feet. The building has a steel-reinforced concrete foundation and an 8-inch thick reinforced concrete floor. The building has an unloading dock with space for two trailers. The batteries stored in this building contain sulfuric acid; therefore, the building is constructed of reinforced concrete floors and curbs that are designed to contain any leaks or spills that may occur. The concrete curbing (1.3 feet high minimum) also prevents liquids (rain water, facility sweeping water, etc) from flowing to adjacent areas of the facility. The floor is sloped to drain to one of two stainless steel sumps designed to capture accumulated liquids. One sump has a storage capacity of approximately 22,333 gallons and the second sump has a storage capacity of approximately 4,875 gallons. The sumps are connected by a 6-inch PVC pipe, which drains the liquids to a 15,000 gallon storage tank in the on-Site Wastewater Treatment Plant. The Battery Receiving and Storage Building is part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.2.3

OXIDE BUILDING

The Oxide building is on the east side of the facility and is west of the Truck Staging Area. The Oxide plant uses Soft lead to produce lead oxide. The Oxide Building is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.2.4

BATTERY BREAKER BUILDING

The Battery Breaker Building is centrally located in the facility. Batteries are delivered on pallets to this building. The Battery Breaker Building contains a Hammer Mill that crushes batteries and a Screw Conveyor that transports crushed battery components.

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The Battery Breaker Building is part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.2.5

BLAST FURNACE BUILDING

The Blast Furnace is in the northern end of the building and the Reverberatory Furnace in the southern end of the building. The Blast Furnace Building is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.2.6

SLAG TREATMENT TANK BUILDING

The Slag Treatment Building is adjacent to the Wastewater Treatment Plant and south of the Battery Breaker Building. It has a contained capacity of 500 cubic yards and is designed to hold 750 tons of blast furnace slag. The floor is sloped towards the center of the building so that wash down water can drain into a sump. The above grade structure consists of a prefabricated steel building. The floor of the doorway is ramped both to the interior and exterior to provide a sill height of 18 inches above floor level. The containment walls around the slag storage area are 12 inches thick and designed for an overturning load of 1920 lb/cubic feet. The floor slab and walls are designed to support slag piled to an approximate height of 10 feet. The Front End Loader can dump through an open wall that is partially protected by plastic curtains. The Slag Treatment tank Building is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.2.7

WASTEWATER TREATMENT PLANT

The Wastewater Treatment Plant is south of the Battery Receiving and Storage Building. Wastewaters are routed via hard pipe to the wastewater treatment system. The wastewater passes through a plate frame filter process and then through a chemical co-precipitation process. The wastewater is then clarified, filtered, and media polished before being sent to the Crystallizer. The wastewater treatment process also generates a lead-bearing sludge which is returned to the Reverberatory Furnace to be used as feed.

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The Wastewater Treatment Plant is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3

PROCESS AREAS

The buildings and areas of the facility that are used in lead processing, and the process itself, are summarized in this section.

3.1.3.1

RECEIVING SCALES AND TRUCK STAGING AREA

The Truck Staging Area is located along the eastern edge of the facility. Incoming loads of spent lead acid batteries and other lead-containing materials are inspected at the Receiving Scales where either the load is accepted or rejected. Scrap lead receives a radiation scan with a scanning meter. Trucks carrying accepted loads of batteries are directed to the Battery Receiving and Storage Building. Lead scrap is delivered to the Raw Material Storage Building. The Receiving Scales and Truck Staging Area is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3.2

THE RAW MATERIALS STORAGE BUILDING

The Raw Materials Storage Building is centrally located and is permitted to store lead-containing materials from crushed lead acid batteries, emission control dust, lead-bearing drosses and slags, lead parts from other industries, sump muds, wastewater treatment sludge containing lead, scrap materials from battery manufacturing, flue dust characteristic for cadmium, coke (fuel for the blast furnace), steel (fluxing agent for the reverberatory furnace), and other waste generated by secondary lead smelting. Mixing and drying equipment prepare the feed, which is then conveyed to the Reverberatory Furnace. The Raw Materials Storage area is part of the preliminary CSM for the Site as defined by the scope of the current investigation.

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3.1.3.3

BATTERY RECEIVING AND STORAGE BUILDING

The Battery Receiving and Storage Building is on the western side of the facility and is permitted to store lead-acid batteries. The batteries are off-loaded via forklift, unwrapped, and transported to the Battery Breaker Building for processing. Due to the high volume of incoming loads, many of the batteries are temporarily stored in the Battery Receiving and Storage Building until they can be processed. Only whole undamaged spent lead acid batteries are stored. Damaged batteries are taken directly to the Battery Breaker Building for immediate processing. After the batteries are unloaded the trucks go to one of two Truck Washing Stations for cleaning. The Truck Washing Stations discharge to the Acid Receiving Tank in the on-site Wastewater Treatment Plant. The Battery Receiving and Storage area is part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3.4

BATTERY BREAKER BUILDING

The Battery Breaker Building is centrally located in the facility. Batteries are delivered on pallets separated by cardboard and wrapped in shrink wrap or in drums. The Battery Breaker Building contains a Hammer Mill. Batteries are carried up by a Screw Conveyor, dropped into the Hammer Mill, and crushed to a size of one inch or less. The crushed batteries are separated by density in a Water Bath. The pulverized lead is transferred to the Overflow Densifying Dewatering Unit (ODDU) and then to the Covered Raw Materials Storage Area, where it is staged in piles until it is transported to the Raw Materials Storage Building by a front end loader. The Battery Breaker Building is part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3.5

THE BALE STABILIZATION AREA

The Bale Stabilization Area is a lot covered with soil and gravel in close proximity to the eastern boundary of the North Disposal Area, and immediately west of the Truck Staging Area. The area was used in the past to treat cardboard and shrink wrap bails in roll-off boxes prior to off-Site disposal.

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The Bale Stabilization area is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3.6

REVERBERATORY (REVERB) FURNACE

The Reverb Furnace is a natural gas fired oxidizing furnace. The main feed to the Reverb Furnace is battery breaker mud (fine grained lead containing material). In addition, the Reverb Furnace takes any small lead-impacted or potentially leadimpacted debris generated on Site, such as wastewater treatment sludge and baghouse dust. Off-gas from the Reverb Furnace passes through a Blast Baghouse to a Scrubber. Scrubber water blows down (approximately 30 gallons per minute) to the Wastewater Treatment Unit. Baghouse dust is fed back to the Reverb Furnace. The Reverb Furnace produces a slag which is 45 to 65% lead. For every two tons of lead that is produced, one ton of slag is produced. The slag is fed to the Blast Furnace. The Reverb Furnace is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3.7

BLAST FURNACE

The Blast Furnace is a reducing furnace that uses metallurgical coke for fuel. The feed for the Blast Furnace is Reverb slag, battery plates, drosses, large lead containing solids (like emptied baghouse bags), and any potentially lead-impacted debris from the Site (with the exception of cardboard and shrink wrap). Off gas from the Blast Furnace goes to an Afterburner (to destroy residual Volatile Organic Compounds) and then to the Blast Baghouse, and then to the Scrubber (the Reverb and Blast Furnaces share a Scrubber). Baghouse dust from the Blast Furnace is used as feed for the Reverb Furnace. For every three tons of hard lead produced in the Blast Furnace, one ton of blast furnace slag is produced. Molten slag is drained from the bottom of the Blast Furnace into cast iron crucibles. The waste slag is broken up and transported by front end loader to the Slag Treatment Building. The Blast Furnace is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

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3.1.3.8

SLAG TREATMENT TANK BUILDING OR SLAG FIXATION TANK BUILDING

The Slag Treatment Building is adjacent to the Water Treatment Plant and south of the Battery Breaker Building. Slag from the Blast Furnace and spent furnace brick are treated in this building. Cooled slag is brought to the building in a Front End Loader. The Front End Loader can dump through an open wall that is partially protected by plastic curtains. Slag is crushed, sized, and accumulated in a Storage Bin. The material is mixed with Free Flow 100, water, and Portland cement. After treatment, the material is disposed of in an On-Site Landfill as non-hazardous waste. The Slag Treatment Building is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3.9

THE REVERB AND BLAST FURNACE SCRUBBER

The Reverb and Blast Furnaces share a Wet Scrubber. The Scrubber uses water from the Stormwater Pond or Condensate from the Crystallizer as makeup water, and has a 30 gallon per minute (gpm) blow down to Wastewater Treatment. The Scrubber has a counterflow of soda ash and water. The Scrubber is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3.10

LANDFILL

The landfill is in the northeastern portion of the Site. It is a Class 2 Industrial NonHazardous Landfill for treated slag. The active portion of the landfill is approximately 84,000 square feet. The landfill is constructed of 3 feet of compacted clay, a 60 mil liner, and one foot layer of soil. The landfill consists of nine cells, six of which are already closed. When cells are full, they are covered with compacted clay, a 40 mil liner, soil, and seeded to grow grass. Exide has not dispose of slag off-site since 1992. The landfill is equipped with two leachate collection sumps at the bottom of the landfill. Each sump utilizes 4-inch Grundfos stainless steel pumps connected to underground lines conveying the leachate to a single collection point enclosed in a small building. The leachate is hard-piped from the building into the polypropylene 2,000-gallon capacity leachate tank located on the north side of the solar evaporation pond inside a concrete secondary containment system. Landfill leachate and surface water runoff is pumped to

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the solar evaporation pond, which has a high-density polyethylene liner and a capacity of approximately 900,000 gallons. The evaporation Pond has one aerator to assist evaporation and prevent the pond from becoming anaerobic. Sediments that accumulate in the solar evaporation pond are recycled in the Reverberatory Furnace or disposed of at DFW Recycling and Disposal in Lewisville, Texas. The Landfill is part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3.11

WASTEWATER TREATMENT PLANT

The Wastewater Treatment Plant is south of the Battery Receiving and Storage Building. The facility treats wastewater on Site prior to discharge to the Crystallizer. Wastewaters are routed via hard pipe to the wastewater treatment system. The wastewater passes through a plate frame filter process and then through a chemical co-precipitation process. The wastewater is then clarified, filtered, and media-polished before being sent to the Crystallizer, which is the Sodium Sulfate Production Unit. The Wastewater Treatment Plant is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3.12

CRYSTALLIZER

The Crystallizer is located on the western portion of the Site to the west of the creek. Water from the Wastewater Treatment Plant is processed in the Crystallizer. The Crystallizer removes salt (sodium sulfate) from the wastewater. The Crystallizer is part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3.13

THE STORMWATER COLLECTION AND RETENTION POND SYSTEM

The stormwater collection and retention system consists of a barrier wall at the south and southwest sides of the plant, a double-lined earthen pond, and a storm sewer line. Stormwater run-off from the manufacturing area of the facility is collected by gravity sheet flow to a low point between the Battery Receiving and Storage Building and the Wastewater Treatment Plant. From this point, stormwater flows through the storm sewer line to the stormwater retention pond (capacity = 249,000 cubic feet) via gravity

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and/or a sump pump. The stormwater collection pond is located on the west side of the facility and northwest of the Crystallizer. The Stormwater System is not part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.3.14

BONE YARD

This is an area on the south/southwest side of the slag landfill where various pieces of currently unused equipment are managed. The Boneyard is part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.4

SOLID WASTE MANAGEMENT UNITS (SWMUS) AND WASTE MANAGEMENT AREAS

Solid Waste Management Units and Waste Management Areas are described in Section 2.2. The Waste Management Areas are shown on Figure 2. The Waste Management Areas are part of the preliminary CSM for the Site as defined by the scope of the current investigation.

3.1.5

PROPERTY BOUNDARIES

The facility is located at 7471 S. 5th St., Frisco, Texas (Collin County). The facility occupies 59.10 acres of land within a 264 acre parcel also owned by Exide Technologies. Facility boundaries are shown on Figure 1.

3.2

LAND USE AND EXPOSURE PROFILE

This land use and exposure profile identifies the beneficial resources and the physical receptor locations (such as surface water bodies, water wells, and residences) that could potentially be affected by releases from the Site. These inert receptors have the potential to be conduits for exposing humans to Site constituents.

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Human land use patterns (industrial, residential, etc.) surrounding the Site are identified in this section, and are used to develop exposure assumptions.

3.2.1

LAND USE ON THE FACILITY AND ADJACENT PROPERTIES

Land use within the Facility boundary is limited to industrial activities associated with lead smelting and recycling, and the useful byproducts associated with these activities. Property owned by Exide outside of the Facility boundary has been primarily undeveloped. Developed land within a 1,000-foot radius of the Site potentially includes residential, industrial and commercial properties. Land use within a 1,000-foot radius of the Site is shown on Figure 15.

3.2.2

BENEFICIAL RESOURCE DETERMINATION AND LOCATIONS

A search of beneficial resources and their locations within a 1,000-foot radius of the Site boundary will be performed to update the CSM. Tentatively identified beneficial resources are shown on Figure 15. A water well survey will be performed to establish the locations and groundwater quality of wells in the vicinity of the Site. A preliminary search of the Texas Water Well Information System indicated no water wells within a 1000 foot radius of the Site. A search of surface water bodies in addition to Stewart Creek and their primary uses will be performed. A search of parks within a 1,000-foot radius of the Site will be performed. An initial search identified Grand Park to the west of the Site, Oakbrook Park to the east of the Site, and First Street Park to the north of the Site.

3.2.3

SENSITIVE RECEPTORS

A review will be performed to determine if there are populations of people in close proximity to the Site that are more sensitive than the general population to Site constituents. Sensitive sub-populations may be found in schools, hospitals, daycare centers, and nursing homes. Sensitive populations are generally the very young, the

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very old and those with existing health conditions that exacerbate the affects of exposure to Site constituents. Sensitive receptors will be identified in the CSM. An initial search within a 1000 foot radius of the Site identified two schools to the north of the Site. It should be noted, however, at this time, it is believed that there have been no releases at the SWMUs that would potentially affect sensitive receptors.

3.2.4

APPLICABLE EXPOSURE SCENARIOS

Humans potentially affected by Site constituents can be categorized by how frequently they encounter Site constituents and by what activities they engage in. Sections 3.2.4.1 through 3.2.4.5 identify human activities on and off site that can be considered for inclusion in the CSM.

3.2.4.1

ON-SITE OUTDOOR WORKER

The outdoor worker is an adult working mostly on the exterior of the Site buildings. It is expected that the outdoor worker would be exposed mostly to outdoor air and soils.

3.2.4.2

ON-SITE INDOOR WORKER

The indoor worker is assumed to spend most of the time inside of a building. The indoor worker is assumed to be exposed to indoor air and outdoor air.

3.2.4.3

ON-SITE CONSTRUCTION WORKER

The construction/utility worker receptor is assumed to be an adult conducting ground intrusive activity (such as the construction of building foundations and/or installation or maintenance of a subsurface utility). The construction/utility worker could potentially be exposed to Site surface and subsurface soils through contact with exposed skin on the head, hands, and forearms. The construction worker is assumed to be exposed to outdoor air.

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3.2.4.4

OFF-SITE RECREATIONAL VISITOR

The off-Site recreational visitor exposure scenario is developed to reflect the infrequent and occasional exposure patterns typical of an adolescent who could potentially visit Stewart Creek, for example, during part of the year (e.g., late spring to early fall) for recreational purposes (i.e., wading, crossing, birding). The recreational visitor could be exposed to outdoor air, surface waters, and sediments of Stewart Creek

3.2.4.5

OFF-SITE RESIDENTIAL OCCUPANT

The off-Site residential occupant may potentially be exposed to fugitive dust in outdoor air that has been emitted from soils in the SWMUs.

3.2.5

APPLICABLE EXPOSURE PATHWAYS

An exposure pathway describes the means by which an individual may be exposed to contaminants present in impacted environmental media.

3.2.5.1

POTENTIAL SOURCES

Releases from the identified SWMUs may have impacted various media at the Site, and some of these media may serve as on-going sources or even secondary sources of contamination based on transport and partitioning to a different media. The investigation contained in this Work Plan will confirm the presence of source areas and the magnitude of these impacts. This section of the CSM will be updated once these data are available.

3.2.5.2

EXPOSURE MEDIA

The following is a list of media at the Site that may be impacted. As new data are collected and analyzed, the list of media to be assessed will be refined and the conceptual site model will be updated. Sediments in Stewart Creek Surface soil Subsurface soil
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Outdoor air Indoor air Surface water, and Groundwater

3.2.5.3

ROUTES OF EXPOSURE

Contaminants can affect human health by entering the body through specific routes of exposure. The following are considered potential routes of exposure for human receptors at the Site: Inhalation of outdoor air: lead can sorb to particulates and be inhaled as dust and fumes Ingestion of dust or dirt that contains lead via accidental hand-to-mouth contact after exposure to lead-containing soil or dust Ingestion of airborne dusts that settle onto food, water, clothing, and other objects, and are subsequently transferred to the mouth, and Dermal (skin) contact with dust and dirt containing lead. absorbed through the skin Lead is poorly

3.2.5.4

POTENTIALLY-COMPLETE EXPOSURE PATHWAYS

An exposure pathway describes the means by which an individual may be exposed to contaminants present in impacted environmental media. An exposure pathway is complete (i.e., it could result in a receptor contacting a contaminant in impacted media) if the following elements are present: 1. A source or a release from a source 2. A probable environmental migration route 3. An exposure point where a receptor may come in contact with a contaminant 4. A route by which a contaminant may enter a potential receptor's body 5. A receptor population which is potentially exposed

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The preliminary conceptual exposure model (CEM) shown on Figure 3 presents a summary of the exposure pathways identifying the sources, release and migration mechanisms, exposure media, exposure routes, and receptors. The exposure pathways that are potentially complete, based on the media of potential concern listed in Section 3.2.5.2 for the various SWMUs listed by receptor are: On-site industrial outdoor worker exposed to site-related COPCs via incidental ingestion of and dermal contact with surface soil, and inhalation of fugitive dust emissions from surface soil On-site construction worker exposed to site-related COPCs via incidental ingestion of and dermal contact with surface and subsurface soil, and inhalation of fugitive dust emissions from surface and subsurface soil during excavation activities Off-site recreational receptor at Stewart Creek exposed to outdoor air via inhalation, sediment and surface water via incidental ingestion of both media, and dermal contact with surface water and sediment Off-site residential receptor possibly exposed via inhalation to fugitive dust emissions from surface soil

Currently there is not a complete exposure pathway for groundwater since shallow groundwater at the Site is not being used and is not believed to be impacting surface water or deeper groundwater. Groundwater will be investigated, however, as part of this investigation to get a better understanding of potential impacts. If it is determined during this investigation that there is a reasonable likelihood that a receptor could contact impacted groundwater at the Site the CSM will be revised accordingly. Utilities map is presented in Appendix E to aid in determination of potential preferential conduits for constituent migration. Currently, there is no indication that the underground utility lines serve as preferential migration pathways. These scenarios and exposure pathways may be revised once additional information about the SWMUs, potential releases and potentially complete pathways is available.

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3.3

PHYSICAL PROFILE

This physical profile describes the factors that may affect releases, fate and transport, and receptors. The physical profile describes the environmental setting in the absence of a release.

3.3.1

REGIONAL GEOLOGY

The Site is located in southwest Collin County, Texas. The exposed bedrock in Collin County is of late Cretaceous age and includes the Taylor Group (marl), Austin Group (chalk), and Eagle Ford Group (shale) (Barnes, 1988, Geologic Atlas of Texas, Dallas Sheet, Bureau of Economic Geology of Texas, Austin, Texas). The Eagle Ford Shale crops out in western Collin County. Moving eastward, the Austin Chalk and Taylor Marl formations are exposed. In this area of Texas, regional dip is to the east and southeast so that older rock formations are present at the surface west of the Site and progressively younger formations lie to the east. Undivided surficial deposits of Quaternary age comprise the uppermost geologic horizon in the region. Underlying these surface deposits is the Taylor Marl, Austin Chalk, and Eagle Ford Shale followed by the Woodbine Group, Washita Group, Fredericksburg Group, and Trinity Group. These Cretaceous units unconformably overlie undifferentiated Paleozoic rocks. The Taylor Marl crops out in eastern Collin County (east of the Site). It consists of clay, marl, mudstone, chalk, and sand and includes Wolfe City Sand and Ozan Formation. Below the Ozan Formation lies the Austin Chalk that forms isolated outcrops in the Site vicinity. This formation consists of chalk, fossiliferous limestone, marl, and sand. The Austin Chalk is relatively resistant to weathering compared to the overlying Ozan and underlying Eagle Ford Shale. As a result, it tends to form escarpments in the region. The Eagle Ford Group, which forms the surface geological unit in the Site vicinity, consists of marine shale with some sandstone and limestone. The shale is typically dark gray. Installation of soil borings and monitor wells at the Site confirmed the presence of the Eagle Ford Shale at a depth of approximately 20 feet below ground surface (ft bgs). The shale was dark gray to black, hard, and fissile. Thickness of the Eagle Ford Shale in Collin County ranges from 550 to 600 feet.

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The Woodbine Group consists primarily of sandstone with some clay and shale. The upper and middle parts of the formation are mostly fine gravel and well-sorted sandstone. The lower part is mostly interbedded fine-grained sandstone and clay with some beds of ironstone and ironstone conglomerate. Thickness of the Woodbine Group in Collin County ranges from 250 to 300 feet. Below the Woodbine Group is the Washita Group, which consists of limestone, marl, and clay. The Trinity Group is comprised of the Paluxy and Twin Mountains Formations. In north-central Texas, these two formations are separated by the Glen Rose Formation, which is characterized by limestone, marl, shale, and anhydrite. The Paluxy Formation consists of fine sand, sandy shale, and shale. In the region, the top of the Paluxy lies at a depth of approximately 1,500 feet below the surface. The thickness is approximately 250 feet. The Twin Mountains Formation consists primarily of claystone in the upper part, sandstone in the middle, and sandstone with some claystone and conglomerate in the lower part. The Twin Mountains Formation overlies older Mesozoic rock and is approximately 450 feet thick.

3.3.2

REGIONAL HYDROGEOLOGY

Groundwater quality in Texas can be classified on the basis of several factors, with quality and yield being the two primary factors. Groundwater quality is determined by total dissolved solid (TDS) content. Groundwater is differentiated by the concentration of TDS on the following basis: Freshwater TDS of 0 to 1,000 milligrams per liter (mg/L) Slightly saline TDS of 1,000 to 3,000 mg/L Moderately saline TDS of 3,000 to 10,000 mg/L Saltwater or brine TDS in excess of 10,000 mg/L

Although wells were once a primary source of drinking water in the Dallas/Fort Worth area, surface waters from reservoirs along the Trinity River are now utilized. Groundwater is still utilized in the region by industrial and residential users. The majority of water wells in the Dallas/Fort Worth area produce from aquifers screened in the Twin Mountains and Paluxy Formations, and to a lesser extent, the Woodbine Formation. The Twin Mountains Formation is the most important source of groundwater in the north-central Texas region. This formation yields moderate to large

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quantities of fresh to slightly saline water to municipal and industrial wells. In the region, the top of the formation lies at a depth of approximately 1,800 ft bgs. The Paluxy and Woodbine Formations are also important aquifers. Wells tapping these aquifers yield small to moderate quantities of fresh to slightly saline water to wells. The primary source of groundwater recharge to these aquifers is precipitation on the outcrop. Other minor sources include recharge from streams flowing across the outcrop and surface water seepage from lakes. The outcrop of the Woodbine Formation is at least 12 miles west of the Site. Groundwater quality of the Paluxy and Twin Mountains aquifers is generally best near the outcrop area west of Fort Worth (TDS of less than 500 mg/L), and quality decreases to the east. Water from the outcrop area generally flows basinward to the east and southeast. Discharge occurs in areas of pumpage or through natural spring flow. The formations that are exposed in the Collin County area include the Taylor Marl, Austin Chalk, and Eagle Ford Shale. The Taylor, Eagle Ford, and Austin Formations can yield small quantities of water to shallow wells in localized areas. However, these units are not classified as major or minor aquifers in Texas.

3.3.3

SITE GEOLOGY AND HYDROGEOLOGY

The Site is located in a relatively flat section between two tributaries. The southern tributary is mapped as Stewart Creek; the northern tributary is unnamed. In this Work Plan, the northern tributary will be designated the north tributary. The north tributary was diverted and rechannelized slightly north of its original location. The current and former alignments of the north tributary are shown on Figure 2. The Stewart Creek confluence of these tributaries is located west of the Site buildings and north of the stormwater retention pond. Stewart Creek is the only natural surface water body at the Site. The topography of the Site is relatively flat with the exception of the tributaries and bluff formed by the Austin Chalk outcrop. Steeper slopes and bluffs resulting from outcrops of the resistant Austin Chalk Formation are present south of Stewart Creek. The headwaters of Stewart Creek and the north tributary initiate in the topographically higher areas of the Austin Chalk bluffs. The highest elevation at the Site is the crest of a resistant ridge approximately 700 feet above mean sea level (ft amsl) near the southeastern boundary of the Site. From this location, the topography slopes northwest to an elevation of approximately 620 ft amsl at the western boundary of the Site near the

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railroad easement. The surface water run-off from certain operational areas of the Site is collected in a stormwater retention pond. The majority of the Site is underlain by the Eagle Ford Shale. The Austin Chalk underlies the bluffs south of the Site. The Austin Chalk unconformably overlies the Eagle Ford Shale, from which is derived the soil covering most of the property. A water well penetrating the Eagle Ford Shale and older rocks was drilled approximately 1.5 miles northeast of the Site in 1976 (Nordstrom, 1982, Occurrence, Availability, and Chemical Quality of Groundwater in the Cretaceous Aquifers of North-Central Texas, Texas Department of Water Resources, Report 269, vol. 1). In this well (DT-18-50-805), the drilled thickness of the Eagle Ford was approximately 580 ft bgs. The top of the Woodbine Formation was encountered at approximately 600 ft bgs. The top of the Washita Group was found at a depth of approximately 850 ft bgs. The top of the Paluxy Formation was encountered at a depth of approximately 1,450 ft bgs. The top of the Twin Mountains Formation was encountered at a depth of approximately 1,900 feet. The well was screened in the Twin Mountains Formation. The uppermost groundwater bearing unit (GWBU) at the Site is the saturated portion of the soil above the Eagle Ford Shale bedrock and appears unconfined. The clay soil is typically 15 to 20 feet thick at the Site, based on boring logs in the May 1991 RFI report. The clay soil is typically saturated in the lower 10 feet. Groundwater flow is primarily towards the east across the facility with a hydraulic gradient of approximately 0.016 (ft/ft) and may be oriented to the southeast towards Stewart Creek in the eastern portion of the Site, based on a groundwater contour map in the May 1991 RFI report. The shallow GWBU has been determined to be Class III groundwater on the property immediately west of the Site, but the on-Site classification will be verified with the proposed scope of work

3.3.4

SURFACE FEATURES

The Site is located just southwest of the City of Frisco, Texas. Stewart Creek traverses the Site from East to Northwest. Site topography, as determined from the United States Geological Survey (USGS) topographic map (Frisco Quadrangle), slopes to Stewart Creek from the south and east. The Site stretches north to south from Eubanks Street to approximately 1,500 feet south of Stewart Creek and east to west from approximately 1,000 feet east of Fifth Street to the railroad track. The Site production area is located

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along Fifth Street and Stewart Creek. The area around the Site consists of open fields with several trees around the perimeters of the fields and along the streams.

3.3.5

SOIL

According to the Soil Conservation Service (SCS) Soil Survey for Collin County, the predominant soils at the Site are the Houston Black clay (1 to 3 percent slopes) and the Trinity clay, frequently flooding. Some small areas of Austin silty clay (3 to 5 percent slopes) also exist at the Site. The Houston Black clay is characterized by deep, calcareous, clayey soils that formed in calcareous clay or chalky marl. The soil has a high shrink/swell potential due to the presence of montmorillinitic clay. The permeability rate of the soil is very slow (less than 0.063 inches/hour). A typical profile of this soil consists of 0 to 22 inches of very dark gray clay which is calcareous and moderately alkaline (A horizon). The A horizon is underlain by the AC horizon (44 to 60 inches), which consists of light gray clay with mottles and cemented concretions of calcium carbonate. This soil is moderately alkaline throughout (7.4 to 8.4). The C horizon (below the AC horizon) consists of light gray clay with yellowish-brown mottles and cemented concretions of calcium carbonate. The soil is calcareous and moderately alkaline. The Trinity clay is characterized by deep, calcareous, clayey soils. These soils are located on flood plains along major streams and their tributaries. The soil also has a high shrink/swell potential due to the presence of montmorillinitic clay. The permeability rate of this soil is very slow (less than 0.063 inches/hour). A typical profile of the Trinity series is as follows: Ap (0 to 5 inches) very dark gray clay; calcareous; moderately alkaline; very hard when dry; and very sticky when wet A1 (5 to 14 inches) dark gray clay; very hard when dry; very sticky when wet; calcareous; and moderately alkaline C (14 to 56 inches) dark gray clay; very hard when dry; very sticky when wet; calcareous; and moderately alkaline

In some places, the C horizon of the Trinity clay is stratified with thin layers and lenses of clay loam or silt loam. Beds of gravel underlie the C horizon at a depth of 6 to 10 ft bgs.

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The Austin series consists of deep, calcareous, clayey soils that are gently sloping. These soils formed in clayey marls or chalky limestone on uplands. In a typical profile of the Austin silty clay, the surface layer is approximately 16 inches thick and consists of dark grayish-brown, calcareous silty clay. The subsoil is calcareous silty clay that is light brownish-gray in the upper part and pale brown in the lower part and has a thickness of approximately 14 inches. The substratum consists of very pale brown silty clay and lime that makes up approximately 40 percent of the layer (by volume). At a depth of approximately 42 inches, alternating beds of chalky limestone and clayey marl are present that exhibit a moderately slow permeability. The depth of the R horizon (regolith unconsolidated materials above bedrock) ranges from 30 to 60 inches.

3.3.6

SURFACE WATER HYDROLOGY

Surface water hydrology at the Site is primarily controlled by topography. Review of the surface elevation contours from the USGS topographic map and survey information in the Phase I RFI indicates that the Site gently slopes to the west from Fifth Street and more steeply to the north from the bluff south of Stewart Creek. Drainage at the Site is toward Stewart Creek. Stewart Creek flows through the Site in a westerly direction, then downstream (off-Site) turns southwesterly and empties into Lewisville Lake approximately five miles downstream (due Southwest) from the Site. The rechannelized north tributary now discharges approximately 400 feet upstream (northwest) of its original location. Surface water runoff during rain events will flow to Stewart Creek and the north tributary. Stormwater flows from the process area are controlled by the stormwater structures that exist at the Site. Water from rainfall events flows into the stormwater retention pond, treated as necessary, then recycled to the process. As mentioned previously, the Site is permitted by the TCEQ to discharge wastewater to Stewart Creek, although this has not occurred since approximately 2009.

3.4

ECOLOGICAL PROFILE

The ecological profile consists of information concerning the physical relationship between the developed and undeveloped portions of the Site, the use and level of disturbance of the undeveloped property, and the type of ecological receptors present in relation to completed exposure pathways.

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3.4.1.

LAND FEATURES

This section describes the land features present within Exides property boundaries. Structures, buildings, process areas, and waste management units are described in Section 3.1 through Section 3.1.4 of this Sampling and Analysis Work Plan. Text below provides additional details on other features at the Site. Stewart Creek runs through the Site, south of the main process area. There is an area with tree cover in the southeastern corner of the Site. There are grassy areas on the western edge of the Site and adjacent to the area with trees in the southeast corner of the Site. Trees cover approximately 10% of the Site and grassy areas cover about 20% of the Site. There is a stormwater collection and retention system that consists of a barrier wall at the south and southwest sides of the plant, a double lined earthen pond, and a storm sewer line. Stormwater run off from the manufacturing area of the facility is collected by gravity sheet flow to a low point between the Battery Receiving and Storage Building and the Wastewater Treatment Plant. From this point, stormwater flows through the storm sewer line to the stormwater retention pond (capacity = 249,000 cubic feet) via gravity and/or a sump pump. The stormwater collection pond is located on the west side of the facility and northwest of the Crystallizer. The collected water is filtered and used as make up water in the Scrubber. There is a landfill is in the northeastern portion of the Site. It is a Class 2 Industrial NonHazardous Landfill for treated slag. The active portion of the land fill is approximately 84,000 square feet. The landfill is constructed of 3 feet of compacted clay, a 60 mil liner, and one foot layer of soil. The landfill consists of nine cells, six of which are already closed. When cells are full, they are covered with compacted clay, a 40 mil liner, soil, and seeded to grow grass. The landfill is equipped with two leachate collection sumps at the bottom of the landfill. Each sump utilizes 4-inch Grundfos stainless steel pumps connected to underground lines conveying the leachate to a single collection point enclosed in a small building. The leachate is hard-piped from the building into the polypropylene 2,000-gallon capacity leachate tank located on the north side of the solar evaporation pond inside a concrete secondary containment system. The leachate collected in the tank is removed by vacuum truck and processed in the Wastewater Treatment Plant. Landfill leachate and surface water runoff is pumped to the solar evaporation pond, which has a high-density polyethylene liner and a capacity of approximately 900,000 gallons. The evaporation Pond has one aerator to assist

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evaporation and prevent the pond from becoming anaerobic. accumulate in the solar evaporation

Sediments that

3.4.2

DESCRIPTION OF SITE RECEPTORS IN RELATION TO HABITAT TYPE

Ecological receptors on Site are limited, as it is an industrial facility, and is not a preferred habitat for natural species. Potential ecological receptors will be identified as the CSM is refined. The Ecological Assessment Checklist and the Ecological Exclusion Criteria Worksheet (from EPA Region VI Corrective Action Strategy, November 2008) presented in Appendix D will be completed and evaluated to identify ecological receptors. A review of the threatened and endangered species for Denton and Collin counties is included here, and will be assessed for relevance beyond this preliminary CSM.

3.4.3

THREATENED/ENDANGERED SPECIES

According to the United States Fish and Wildlife Service, there are currently two federally listed species for Collin County, the bald eagle and whooping crane. There are four federally listed species for Denton County, the bald eagle, interior least tern, piping plover (Charadrius medodus), and whooping crane. The following table lists the state and federal threatened (T) and endangered (E) species indigenous to Denton and Collin Counties, Texas. The federally listed species in Denton and Collin Counties are all avian species and considered migratory. An initial review finds no suitable habitat present on Site for the listed species.

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FEDERAL AND STATE LISTED THREATENED/ENDANGERED SPECIES OF DENTON AND COLLIN COUNTIES, TEXAS
Species Birds American Peregrine Falcon Falco peregrinus anatum Nests in tall cliff eyries; migrates through Texas; winters along coast range of habitats during migration including urban, concentrations along coast and barrier islands; low altitude migrant, stopovers at leading landscape edges such as lake shores, coastlines, and barrier islands. Migrant throughout state from far northern breeding range, winters along coast and farther south. Occupies wide range of habitats during migration including urban, concentrations along coast and barrier islands; low altitude migrant, stopovers at leading landscape edges such as lake shores, coastlines, and barrier islands. Found primarily near rivers and large lakes; nests in tall trees or on cliffs near water; communally roosts, especially in winter; hunts live prey, scavengers, and pirates food from other birds. Nests along sand and gravel bars within braided streams and rivers; also known to nest on manmade structures. Subspecies (F.p. tundrius) potential migrant through most of state, winters along coast; subspecies (F.p. anatum) resident, nests in west Texas. Because the subspecies level. See subspecies for habitat. Wintering migrant along the Texas Gulf Coast; beaches and bayside mud or salt flats. Prefers freshwater marshes, sloughs, and irrigated rice fields, but will attend brackish and saltwater habitats; nests in marshes, in low trees, on the ground in bulrushes or reeds, or on floating mats. Potential migrant via plains throughout most of state to coast. Winters in coastal marshes of Aransas, Calhoun, and Refugio countries. Forages in prairie ponds, flooded pastures or fields, ditches, and other shallow standing water, including salt-water, usually roosts communally in tall snags, inhabits mud flats and other wetlands. Extirpated; formerly known throughout eastern half of Texas in brushy and forested areas, as well as coastal prairies. Federal Status State Status Description of Suitable Habitat Habitat Assessed?

No

Arctic Peregrine Falcon Falco peregrinus tundrius

No

Bald Eagle Haliaeetus leucocephalus *Interior Least Tern Sterna anitllarum athalassos Peregrine Falcon Falco peregrinus *Piping Plover Charadrius melodus White-faced Ibis Plegadis Chihi

AD,T

No

No

E,T

No

E,T

No

No

Whooping Crane Grus americana Wood Stork Myceria americana Mammals Red Wolf Canis rufus

No

No

No

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Reptiles Perennial water bodies; deep water of rivers, canals, lakes, and oxbows; also swamps, bayous, and ponds near deep running water; sometimes enters brackish coastal waters; usually in water with mud bottom and abundant aquatic vegetation; may migrate several miles along rivers; active March-October; breeds AprilOctober. Open, arid and semi-arid regions with sparse vegetation, including grass, cactus, scattered brush or scrubby trees; sandy to rocky soil. Swamps, floodplains, upland woodlands, riparian zones, abandoned farmland; prefers dense ground cover, i.e. grapevines or palmetto.

Alligator Snapping Turtle Macrochelys temminckii

No

Texas Horned Lizard Phrynosoma cornutum Timer/ Canebrake Rattlesnake Crotalus horridus

No

No

E,T Federally Listed Endangered/Threatened AD Federally Proposed Delisted DL Federally Delisted * - Only Federally listed in Denton County ___ - Not listed
Source: US Fish & Wildlife Service, Texas Parks and Wildlife Department

E,T State Endangered/Thr eatened

3.4.4

DESCRIPTION OF RELATIONSHIP OF RELEASES TO POTENTIAL HABITAT AREAS

The CSM will be updated to include analytical data that characterizes releases, contaminants of concern, and affected media. This data will be used to evaluate potential routes of migration to ecological receptors.

3.5

RELEASE PROFILE

Constituents including TPH and cadmium have been detected at the Site historically, but the potential constituent of concern identified in this preliminary CSM is lead. Analytical data will be collected and used as described in this Work Plan to characterize the effects of potential release to the environment. Analytical data collected in the EPA Multi-Media Inspection occurring December 14-17, 2009, January 28, 2010, and February 2, 2010 and analytical data collected in the TCEQ investigation conducted May through June of 2011 will be used along with Work Plan data to further refine the preliminary CSM as follows: identification of contaminants of concern, potential source locations, source locations where a release has been confirmed, delineation of the areas of contamination, distribution, and magnitude of contaminants of potential concern.

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3.5.1

FATE AND TRANSPORT MECHANISMS

Chemicals move through environmental media such as soil and water based on their chemical and physical characteristics, and this movement is described as transport. The presence of lead in various media of the environment can be predicted by its poor water solubility and its tendency to sorb to organic compounds under more alkaline conditions. The following is a discussion of the fate and transport of lead through environmental media, and the predicted migration routes and mechanisms.

3.5.1.1

LEAD BIOGEOCHEMICAL CYCLES

Lead is cycled naturally between air, soil, water, and sediments by physical and chemical processes such as weathering, precipitation, dry deposition of dust, and stream flow. This is a natural cycle whose balance is influenced by anthropogenic activities. The processes are dynamic in air and water, and less so in soils and sediments, which are the primary sinks, or stores for lead. Lead is extremely persistent in water and soil given that it is an element that cannot be broken down under normal conditions.

3.5.1.2

LEAD TRANSPORT BETWEEN POTENTIALLY AFFECTED MEDIA

Once lead is released to the atmosphere from a source such as a smelting facility, it partitions or binds to particulates in air, soil, and water. The following is a summary of the potential pathways for lead to be transported between media: Lead in air has the potential to remain suspended in the atmosphere or deposit to soil via wet deposition (precipitation) or dry deposition of dust. Lead in air has the potential to be deposited to surface runoff such as to a stormwater ditch, or it can be deposited from the air to other surface water bodies such as streams. Lead in soil tends to remain in soil for long time, but it has the potential to be resuspended into the air (entrainment), or move into the groundwater. Soil containing lead has the potential to be carried by surface runoff into surface water bodies. Lead in surface runoff has the potential to move into surface water bodies.

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Lead in surface water bodies has the potential to be transported to downstream waters. Lead in surface water has the potential to move into sediments. Lead in sediments tends to remain in sediments, and is not highly mobile. However, storm events and turbulence have the potential to resuspend lead into the water column

At the Site, soil is the primary environmental media that is affected by the Site constituents. Potential impacts to sediments and groundwater are being assessed as part of current investigation.

3.5.1.3

LEAD TRANSPORT IN SEDIMENT

In general, lead is relatively stable in sediments with limited mobility, making sediments a sink for lead. Sediments generally contain higher levels of lead than corresponding surface waters. Lead partitions to organic matter in sediments, and can form lead sulfides in anoxic environments. Lead-containing sediment particles can be re-suspended into overlying water, but this fate is generally small compared to sedimentation. Re-suspension of the sediment bed via turbulent storm events or by dissolution from sediment to the water column under acidic conditions.

3.5.1.4

LEAD TRANSPORT IN AIR/ATMOSPHERE

Lead on particles in the air is removed by wet or dry deposition or gravitational settling. Approximately 40 to 70% of the deposition of lead is by wet fallout. Wet deposition is more important than dry deposition for removing lead from the atmosphere.

3.5.1.5

TRANSPORT OF LEAD IN SURFACE WATER

The solubility of lead compounds in water is a function of pH, hardness, salinity, and the presence of organic material. Solubility of lead compounds is highest in soft, acidic water. Lead in water is predominantly found as PbO or PbCO3. At pH >5.4, the solubility of lead is approximately 30 g/L in hard water and approximately 500 g/L in soft water. Sulfate ions, if present in soft water, limit the

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lead concentration in solution through the formation of lead sulfate. Above pH 5.4, the lead carbonates limit the amount of soluble lead. A significant fraction of lead carried by river water is expected to be in an undissolved form, which can consist of colloidal particles or larger undissolved particles of lead carbonate, lead oxide, lead hydroxide, or other lead compounds incorporated in other components of surface particulate matters from runoff. Lead has a tendency to form compounds of low solubility with the major anions found in natural waters. In fresh water, lead may partially exist as the divalent cation (Pb2+) at pHs below 7.5, but complexes with dissolved carbonate to form insoluble PbCO3 under alkaline conditions (Long and Angino 1977). Lead forms strong complexes with humic acid and other organic matter (Denaix et al. 2001; Gao et al. 1999; Guibaud et al. 2003). Hence, the request for TOC in the analysis of sediment samples. Lead-organic matter complexes are stable to a pH of 3 with the affinity increasing with increasing pH, but decreasing with increased water hardness (EPA 1979).

3.5.1.6

TRANSPORT OF LEAD IN SOIL

Lead is relatively immobile in soil, and is therefore a sink for lead.

3.5.1.7

LEAD TRANSPORT IN THE SOIL TO GROUNDWATER PATHWAY

Lead is generally retained in the upper layers of soil and does not leach appreciably into the subsoil and groundwater because it adsorbs to soil organic matter, minerals, clays, silts, and metals. At a neutral pH, lead binds organic carbon and other metals, and this partitioning to soil retards leaching through the soil. Lead is poorly water soluble, so this also slows leaching. The mobility of lead will be increased in acidic conditions, when its solubility is increased. However, most lead is retained strongly in soil, and very little is transported through runoff to surface water or leaching to groundwater except under acidic conditions.

3.5.1.8

LEAD TRANSPORT IN THE SOIL TO AIR PATHWAY

Entrainment or resuspension of soil particles in moving air is route of lead transport back into the air.

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3.5.1.9

LEAD TRANSPORT IN THE SOIL TO SURFACE WATER RUNOFF PATHWAY

Most lead is retained strongly in soil, and very little is transported through runoff to surface water or leaching to groundwater except under acidic conditions.

3.5.1.10

TRANSPORT OF LEAD IN GROUNDWATER

The downward movement of elemental lead and inorganic lead compounds from soil to groundwater by leaching is very slow under most natural conditions except for highly acidic situations.

3.5.1.11

LEAD UPTAKE BY PLANTS

Lead content in plants is largely the result of atmospheric deposition. This is due to the strong retention of particulate matter on plant surfaces. Some plants can uptake lead from soil through their root systems, although this uptake does not appear to be appreciable. Plants and animals may bioconcentrate lead, but lead is not biomagnified in the aquatic or terrestrial food chain.

3.6

RISK MANAGEMENT PROFILE

The risk management profile is used to illustrate the relationship between releases and risks. The profile also illustrates how implementing risk management activities can alter the release-risk relationship. This section is currently limited in scope pending further site assessment activities. It will be expanded once additional information is gathered, assessed, and discussed in context of future risk management strategies.

3.6.1

RISK MANAGEMENT

Site environmental monitoring plans will be incorporated into the CSM once these plans are approved.

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3.7

DATA GAPS

At this stage, identified data gaps include the following: Groundwater classification at the Site Background groundwater concentrations of lead and cadmium Background soil concentrations of lead and cadmium Current groundwater quality at the Site Current surface water quality at the Site Current status of Stewart Creek sediments within Site boundaries and along north tributary of Stewart Creek Lateral extent of constituent of concern concentrations in surface soil at the South Disposal Area Composition of soil pile and status of soils at the former shooting range Constituent of concern concentrations in soil in the vicinity of the Raw Material Storage Area, Boneyard, Bail Stabilization Area, and Crystallization Unit Frac Tank, and along the Stewart Creek Flood Wall

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4.0

CHARACTERIZATION AND FIELD ACTIVITIES The Order requires a plan and timetable for the investigation of the following: North Disposal Area, Slag Landfill Boneyard Bail Stabilization Area Crystallization Unit Frac Tank Stewart Creek Flood Wall Raw Material Storage Area, and South Disposal Area

This section discusses the proposed investigations in these areas and an additional area (Former Shooting Range) adjacent to the South Disposal Area, including sampling and analysis of soil, surface water, sediment, and groundwater. The data collection program will be completed consistent with the USEPA guidance, including the Guidance on Choosing a Sampling Design for Environmental Data Collection (USEPA 2002b), where applicable. The data collection program will be completed consistent with the Quality Assurance Project Plan (QAPP) prepared for this project, included in Appendix A. The development of the data collection program considered the Site history, existing available Site data and previous investigations, the CSM, and USEPA and TCEQ regulations and guidance. A preliminary schedule for field activities and reporting is presented in Exhibit 1.

4.1 4.1.1

SOIL SAMPLING SAMPLING PROCEDURES

Prior to installation of any boreholes to a depth greater than 16 inches using mechanical equipment, Texas One Call service (1-800-DIG-TESS) at least 48 hours in advance of field activities will be alerted per http://www.texas811.org. In addition, boring locations will be checked and cleared of utilities to a depth of approximately 5 ft bgs ground surface using a hand probe.

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Soil sampling will be generally based on the procedures described in the American Society for Testing and Materials (ASTM) Standard Guide For Direct Push Soil Sampling For Environmental Site Characterizations. Soil samples will be collected using a Geoprobe Macro-Core MC5 soil sampler, or similar direct push system. Soil samples will be collected continuously on a minimum of two-foot intervals from each boring location to determine the vertical depth of impact. Sampling will continue to 2 ft bgs, or at select locations, to groundwater or refusal. The soil core from the direct push will be recovered in a new, thin-walled, 1.25-inch outer diameter polyvinyl chloride (PVC) liner or similar thin walled core sleeve. The liner will be cut longitudinally to allow access to the soil core. Each soil sample will be described and classified based on the Unified Soil Classification System. A portion of each soil sample will be sealed in a fresh polyethylene bag and allowed to stabilize at ambient air temperature. The headspace in bag will then be analyzed with a portable MiniRae 2000 Photoionization Detector (PID) (or comparable PID instrument) and results noted in a field log book. Prior to use, the PID will be calibrated in accordance with the manufacturer's specifications. PID sampling will be performed where Total Petroleum Hydrocarbon (TPH) and/or Volatile Organic Carbon (VOC) analyses are requested. All sampling equipment that comes into direct contact with samples including hand tools, hand augers, mixing bowls, core samplers, and other sampling equipment, will be thoroughly cleaned using deionized water and Alconox soap (or equivalent) between sample locations. Rinsate water will be changed between sampling locations and disposed off as Investigation Derived Waste (IDW). IDW will be properly labeled and staged in a designated area of the Site. Each location at which a sample is collected will be logged via a Global Positioning System (GPS). Resulting boreholes will be grouted with hydrated bentonite in accordance with the TCEQ guidance. Should a proposed sample location need adjustment in the field due to visual indications of potential impacts, utilities, or other physical barriers/obstructions, safety issues, concurrent approval will be obtained from Exide and USEPA. Any such modifications to sampling locations will be documented in the field log book with annotations regarding the approval details. Samples will be placed in laboratory-supplied containers, sealed, labeled, and placed on ice in an insulated ice chest for subsequent delivery to a selected laboratory.

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Appropriate chain-of-custody documentation, blanks, and seals will accompany the samples as required by the QAPP (Appendix A).

4.1.2

BACKGROUND SOIL SAMPLING

Exide will collect a statistically appropriate number of samples from the 0 to 2 ft bgs soil interval for purposes of establishing background soil concentrations for lead and cadmium. Typically, a minimum sample size of seven is needed to successfully fit a given statistical distribution so that a site-specific background value can be estimated using various computational tools and methods. The background soil samples will be collected at locations mutually agreeable between USEPA and Exide and where Exide can obtain access. Local public spaces such as parks and other similar areas may be an option if access to private properties cannot be obtained. The background sampling locations will be as close to the Site as possible, upgradient and upwind of the Site (prevailing wind direction is to the North-Northeast), located in wooded areas that are least likely affected, and not otherwise influenced by the Site. Because these locations avoid areas where anthropogenic impacts by entities other than Exide may be present (e.g., near roadways), the non-Exide anthropogenic contributions of metals (especially lead) in similar areas in the immediate vicinity of the Site will not be determined Background soil samples will be collected and analyzed consistent with procedures used for Site characterization, as discussed herein. Resulting background soil data will be subjected to a statistical outlier analysis, distribution fitting, and calculation of the appropriate Site-specific background value using the USEPA-approved, ProUCL 4.1.00 (or newer) computational tool.

4.1.3

SWMU SOIL SAMPLING

Exide proposes the following sampling activities for the SWMU listed in the Order,

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4.1.3.1 4.1.3.1.1

RFI UNITS NORTH DISPOSAL AREA

The North Disposal Area was a pre-RCRA landfill that was closed prior to 1978 pursuant to an approved closure plan. The North Disposal Area is bounded by Site buildings to the south, the Slag Landfill to the west, and the Bail Stabilization Area to the east (see proposed sampling of Bail Stabilization Area discussion herein). The lateral and vertical extents of the North Disposal Area were delineated during an extensive investigation as part of the Phase I RFI and are documented in the 1993 Addendum to the Phase I RFI report. In the Phase I RFI Report, Exide requested no further action for the closed North Disposal Area, other than routine maintenance of the cap. The TNRCC approved this portion of the Phase I RFI Report in correspondence dated June 3, 1994. Exide proposes to collect soil samples from three locations to the north of the North Disposal Area. Soil borings will be advanced using direct-push technology (DPT) or other generally-accepted methods. The approximate locations of the proposed soil borings are shown on Figure 4. Per the USEPA request of October 19, 2011, continuous soil samples will be collected from each boring location until groundwater (as indicated by generally saturated soils) is encountered or refusal is reached. Lithological samples will be screened, logged, and selected for laboratory analysis. At minimum, soil samples from 0 to 2 ft bgs, 0 to 2 feet above the generally saturated soils (or refusal depth), and any soil suspected of contamination (based on visual and/or olfactory observations or elevated PID readings), plus a groundwater sample at each boring location (provided the boring is able to yield sufficient groundwater for sample volume requirements within one hour of completion) will be collected and sent to laboratory for analysis of lead and cadmium. Given that the unfiltered water sample will come from an unlined borehole, the resulting lead and cadmium concentrations will not be indicative of representative metal concentrations in groundwater and, as such, will only be used for screening purposes in terms of further investigation. No sampling of the North Disposal Area cap is proposed. This is because Exide is currently scheduling a comprehensive inspection of the North Disposal Area and will repair the North Disposal Area cap where no concrete, buildings, or associated construction activity will be performed in association with the relocation of the slag

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treatment building, as ordered and approved by the TCEQ in Agreed Order No. 20110521-MIS (Agreed Order). The portion of the current access road to the Sites active landfill that crosses the North Disposal Area will be inspected and repaired when it is replaced as part of the work required by the Agreed Order. The Agreed Order requires that the construction activities be completed by March 31, 2012. Upon completion of construction activities, Exide will reinspect the cap and address any remaining cap areas that necessitate repair. The cap will be routinely inspected and maintained pursuant to the Sites Storm Water Pollution Prevention Plan (SWPPP).

4.1.3.1.2

SLAG LANDFILL

Portions of the closed Slag Landfill are located on the northwestern portion of WMA1. The approximate boundaries of the Slag Landfill are apparent in the field. The North Disposal Area is located to the southeast of the Slag Landfill. A boneyard is located on the south/southwest portion of the Slag Landfill (see discussion of proposed sampling at the boneyard herein), and the railroad tracks are located to the west. The Phase I RFI Report requested no further action for the inactive Slag Landfill, other than routine maintenance. The TNRCC approved this portion of the Phase I RFI Report in correspondence dated June 3, 1994. To comply with the Order, Exide proposes to commence one soil boring to the west of the Slag Landfill (between the landfill and the railroad track) and two soil borings to the north of the Slag Landfill. Soil borings will be advanced using DPT or other generallyaccepted methods. The approximate locations of the proposed soil borings are shown on Figure 5. These locations may be adjusted as necessary to allow sufficient access for the DPT equipment. Per the USEPA request of October 19, 2011, continuous soil samples will be collected from each boring location until groundwater (as indicated by generally saturated soils) is encountered or refusal is reached. Lithological samples will be screened, logged, and selected for laboratory analysis. At minimum, soil samples from 0 to 2 ft bgs, 0 to 2 feet above the generally saturated soils (or refusal depth), and any soil suspected of contamination (based on visual and/or olfactory observations or elevated PID readings), plus a groundwater sample at each boring location (provided the boring is able to yield sufficient groundwater for sample volume requirements within one hour of completion) will be collected and sent to laboratory for analysis of lead and cadmium. Given that the unfiltered water sample will come from an unlined borehole, the resulting lead and cadmium concentrations will not be indicative of representative metal concentrations in

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groundwater and, as such, will only be used for screening purposes in terms of further investigation. The Slag Landfill will be routinely inspected and maintained pursuant to the Sites SWPPP. Any deficiencies noted will be addressed pursuant to the SWPPP.

4.1.4.1.3

RAW MATERIAL STORAGE AREA

The Raw Material Storage Area is within the active process area. This SWMU is within an enclosed building erected on a concrete slab floor measuring approximately 100 feet by 160 feet. Furnace charge (lead-bearing raw material) is temporarily stored and mixed in this building prior to feeding into the furnaces. The materials managed in this building are protected from precipitation. Furthermore, the Raw Material Storage Area is within a runoff-controlled area. The Raw Material Storage Area is within WMA2, which was investigated as part of the Phase I RFI. Based on the above considerations, no further action was recommended for this unit in the Phase I RFI Report dated May 1991. The TNRCC concurred with this assessment in correspondence dated June 3, 1994. Historical groundwater monitoring through 2005 confirms no impact to groundwater from the process area. To comply with the Order, Exide proposes to collect soil samples around the Raw Material Storage Area, as access permits. Soil borings will be installed through concrete to an approximate depth of 0 to 2 ft bgs using DPT or other generally-accepted methods. The 0 to 2 ft bgs depth interval will be sampled. If visual staining or other indications of contamination are present, the boring will be advanced until refusal or until the saturated zone is reached. At that point, a groundwater sample will be collected for laboratory analysis of lead and cadmium if the boring is able to yield sufficient groundwater for sample volume requirements within one hour of completion. The approximate locations of the proposed soil borings are shown on Figure 6. Soil pH will be measured in the field. The resulting soil samples will be submitted for laboratory analysis of lead, cadmium, sulfate, and TPH by Method TX1005. If the TX1005 TPH concentration in a sample exceeds the applicable TCEQ regulatory standard, the sample will be analyzed for TPH using Method TX1006.

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4.1.4.1.4

SOUTH DISPOSAL AREA

The South Disposal Area was a pre-RCRA landfill that was closed prior to 1978 pursuant to an approved closure plan. Additional delineation is proposed for the South Disposal Area. During the Phase II RFI activities, lead concentrations in samples collected from several borings (SDA-2, SDA-3, SDA-4, SDA-5, SDA-8, SDA-9-1, and SDA-9-2) exceeded the applicable Risk Reduction Standards and exceed applicable TRPP standards at 0 to 2 ft bgs. The historical lead concentrations at these sample locations are shown on Figure 7. Exide proposes to advance soil borings approximately 30 to 75 feet laterally from these previous soil borings to a depth of approximately 4 ft bgs. The soil borings will be installed using DPT or other generally-accepted methods. The approximate locations of the proposed soil borings are shown on Figure 7. Soil samples will be collected from the 0 to 2 ft bgs interval and the 2 to 4 ft bgs interval and submitted for laboratory analysis of lead and cadmium. The Order states that battery cases and slag were observed in the South Disposal Area. Exide is currently scheduling a comprehensive inspection of the South Disposal Area and will repair the cap where needed. The cap is routinely inspected and maintained pursuant to the Sites SWPPP. Any deficiencies noted are repaired in accordance with the SWPPP.

4.1.4.2 4.1.4.2.1

NON-RFI UNITS BONEYARD

The Order references a boneyard where various pieces of currently unused equipment are managed, located on the south/southwest side of the Slag Landfill. The USEPA Order states that, at the time of the USEPA inspection, several pieces of equipment allegedly contained process materials/wastes, and one piece of hydraulic equipment was allegedly leaking. The hydraulic equipment was removed, all equipment in the area was emptied and decontaminated, and any stained soil was removed. Any equipment retired to the boneyard is now cleaned and decontaminated prior to placement in the boneyard. Exide proposes to advance approximately five soil borings in the boneyard to a depth of approximately 2 ft bgs. The soil borings will be installed using DPT or other generally-accepted methods. The approximate locations of the proposed soil borings are shown on Figure 8. CONESTOGA-ROVERS & ASSOCIATES

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Soil samples will be collected from the 0 to 2 ft bgs interval and submitted for laboratory analysis of lead and cadmium. If soil staining, odor, or elevated PID readings are observed at a sample location, the soil sample collected from that location will also be analyzed for TPH by Method TX1005. If the TX1005 TPH concentration in a sample exceeds the applicable TCEQ regulatory standard, the sample will be analyzed for TPH using Method TX1006.

4.1.4.2.2

BAIL STABILIZATION AREA

The Order references a gravel Bail Stabilization Area located to the west of the Truck Staging Area and northeast of the Oxide Building. The area is used to treat cardboard and shrink wrap bails in roll-off boxes prior to off-Site disposal. The Order states that cardboard was observed on the ground during the USEPA inspection. Exide proposes to advance approximately five soil borings to a depth of approximately 2 ft bgs. The soil borings will be installed using DPT or other generally-accepted methods. The approximate locations of the proposed soil borings are shown on Figure 9. Soil samples will be collected from the 0 to 2 ft bgs interval and submitted for laboratory analysis of lead and cadmium.

4.1.4.2.3

CRYSTALLIZATION UNIT FRAC TANK

The crystallizer, located on the western portion of the Site to the west of the creek, is used to remove sodium sulfate from water after treatment in the wastewater treatment plant. Approximately once a month, a boil out of the crystallizer is performed to clean the unit. The liquid from the boil out is collected in the crystallization unit frac tank (located on a concrete ramp), sampled, and sent off-Site for solidification and disposal. The liquid in the crystallization unit has occasionally failed the toxicity characteristic leaching procedure for lead. When this occurs, the liquid is sent through the on-Site wastewater treatment plant. The Order states that the USEPA inspectors observed liquid leaking from the frac tank, as well as visible drainage pathways leading from the frac tank to the edge of the concrete ramp. Since the USEPA inspection, the frac tank seals have been repaired and inspected, and curbing has been enhanced such that all runoff or spillage in the area is collected in a sump, treated if necessary, and returned to the process.

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Exide proposes to advance two soil borings along the concrete ramp on which the tank is located, to a depth of approximately 4 ft bgs. The soil borings will be installed using DPT or other generally-accepted methods. The approximate locations of the proposed soil borings are shown on Figure 10. Soil samples will be collected from the 0 to 2 ft bgs interval. The 2 to 4 ft bgs depth interval may also be sampled if visual staining or other indications of contamination is present. Boring will continue until refusal or saturated zone depth is reached. At that point, a sample from the bottom of the boring (at refusal depth) or groundwater (saturated zone depth) will be collected for laboratory analysis. Soil pH will be measured in the field. Soil samples will be submitted for laboratory analysis of selected RCRA metals (antimony, arsenic, barium, beryllium, cadmium, chromium, lead, nickel, selenium, silver, and zinc) and sulfate, consistent with the former contents of the tank.

4.1.4.2.4

STEWART CREEK FLOOD WALL

During the USEPAs inspection of the Site, the USEPA noted seepage along the Stewart Creek retaining wall, specifically in the area between the Slag Treatment Building and the Battery Receiving/Storage Building. Exide intends to install a French drain system between the retaining wall and this portion of the process area. At the request of the USEPA, Exide will collect one bottom and one sidewall soil sample for every 50 linear feet of exposed soils from the excavated areas (where feasible depending on field conditions encountered). The approximate proposed sample locations are shown on Figure 11. The soil samples will be submitted for laboratory analysis of lead, cadmium, and TPH by Method TX1005. If the TX1005 TPH concentration in a sample exceeds the applicable TCEQ regulatory standard, the sample will be analyzed for TPH using Method TX1006. Exide also proposes to collect soil samples from the 0 to 2 ft bgs interval along the retaining wall (on the creek side) at approximate 100-foot intervals. Approximate proposed sample locations are shown on Figure 11. As mentioned earlier; sample locations may be adjusted based on field observations of contamination, utilities, or other physical barriers.

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Soil samples will be collected at deeper intervals if visual or other sensual evidence of contamination is observed. The soil samples will be submitted for laboratory analysis of lead, cadmium, and TPH by Method TX1005. If the TX1005 TPH concentration in a sample exceeds the applicable TCEQ regulatory standard, the sample will be analyzed for TPH using Method TX1006.

4.1.4.2.5

FORMER SHOOTING RANGE

A shooting range formerly operated in the vicinity of the South Disposal Area. A soil pile behind the former target area is located adjacent to (to the west of) the South Disposal Area (see Figure 7). This property is owned by Exide. The pile is approximately 135 feet in length and 25 feet in width. The southernmost end of the pile is immediately west of SDA-8. Battery casings and slag were observed during the regulatory agency inspection on the easternmost surface of the pile. Exide proposes to investigate the contents of the pile. A backhoe will be used to penetrate the pile to determine if the slag and battery cases are limited to the eastern face of the pile or if they are distributed throughout the pile. Following this investigation, any further action necessary to address the pile will be discussed with USEPA and/or TCEQ.

4.2

SURFACE WATER AND SEDIMENT SAMPLING STEWART CREEK SURFACE WATER SAMPLES

4.2.1

Historical surface water sample data indicate concentrations of lead and cadmium below applicable regulatory standards. However, Exide will collect surface water samples along Stewart Creek for analysis of total and dissolved lead and cadmium. Approximate proposed surface water sample locations are shown on Figure 12. Actual sampling locations will be recoded via a GPS unit. Samples will be collected using a low-flow peristaltic pump with new, clean, plastic tubing at mid-depth (approximately 0 to 6 inches below water surface) within the creek prior to collection of any corresponding sediment samples. Sampling will commence at the downstream-most sampling location and proceed upstream. Surface water samples will not be collected for at least 72 hours following a rain event of one or more inches

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CONESTOGA-ROVERS & ASSOCIATES

reported at the nearest National Weather Service (NWS) location. Creek stages will be monitored throughout the collection of surface water sampling activities. Samples will be placed in laboratory-supplied containers, sealed, labeled, and placed on ice in an insulated ice chest for subsequent delivery to the laboratory per procedures specified in the QAPP (Appendix A). Appropriate chain-of-custody documentation will accompany the samples as required by the QAPP.

4.2.2

SEDIMENT SAMPLES

To determine current background sediment conditions, Exide will collect two sediment samples upstream of the Site within Stewart Creek. To assess current sediment conditions, Exide will also collect sediment samples within Stewart Creek and the north tributary to Stewart Creek at approximate 200-foot intervals within the Site boundaries for analysis of lead, cadmium, total organic carbon (TOC), and grain size. Approximate proposed sediment sample locations are shown on Figure 12. Sample locations may need to be adjusted so that appropriate depositional areas rather than gravel beds are sampled (see additional discussion on grain size below). Sediment samples will be collected starting at the downstream-most location and proceed upstream. Sediment samples will be collected using a small grab sampler such as petite ponar from the 0 to 6 inches depth interval. Alternate methods may be implemented for the collection of sediment samples depending on Site conditions at the time of sample collection. Any modification of field sample collection methods will be documented in the field log book. Samples will be removed from the sampling device and placed into laboratory-supplied containers, sealed, labeled, and placed on ice in an insulated ice chest for subsequent delivery to a chosen analytical laboratory. Since organic carbon fraction influences the bioavailability of chemicals in sediment, including complex/ligated metals, constituents analyzed in sediment will also be reported on an organic carbon-normalized basis. Following completion of this phase of sample collection and review of analytical data, there should be sufficient data and information to support an informed decision regarding the need for collection of additional data, such as toxicological data, and

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CONESTOGA-ROVERS & ASSOCIATES

assessment of risk to ecological receptors and to determine whether any remedial action is necessary.

4.3

GROUNDWATER IINVESTIGATIONS

Exide proposes the following to characterize groundwater flow direction(s) and groundwater quality at the Site.

4.3.1

GROUNDWATER CLASSIFICATION AND FLOW DIRECTION

Groundwater at the Site will be classified pursuant to TCEQ Regulatory Guidance RG-366/TRRP-8, Revised March 2010. Exide will complete the following to make this classification: 1. Water well database survey and contact with the City of Frisco to identify all water wells within 0.5 miles of the Site and their uses, and other sources of drinking water 2. Determination of estimated well yield (slug tests) 3. Determination of Site-specific natural TDS of the affected groundwater-bearing unit Per RG336/TRRP-8, well yield will be determined through performance of a single well aquifer (slug) test in three Site monitor wells to provide additional measurements of hydraulic conductivity throughout the Site. A minimum of three slug tests will be performed at each well. The tests will be conducted as slug-in and slug-out tests with a solid slug. Groundwater levels for all tests will be measured with an electronic water level data recorder (such as an In-Situ LevelTroll 700) or a water level probe over the duration of the water level recovery period. Additional yield testing may be performed in accordance with TRRP-8 as appropriate. The groundwater classification process will follow the Decision Tree for Guidance in Selecting Productivity Tests, Figure 3, RG-366/TRRP-8, Revised March 2010. Work will be supervised and certified by a Texas-licensed professional geologist. Further details on slug testing procedures, list of monitor wells chosen, and full monitor well construction details (similar to Appendix C) will be submitted to USEPA prior to yield testing.

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CONESTOGA-ROVERS & ASSOCIATES

Exide submits that groundwater flow direction was established during earlier Site investigations, including the Phase I RFI. These investigations indicated that groundwater flowed toward Stewart Creek as shown in Figure 10-8 of the May, 1991 RFI Report. Table 10-2 of the May 1991 lists the monitor well construction data from the existing monitor wells at the Site. To confirm groundwater flow across the Site, groundwater elevation measurements will be made in the existing and new Site groundwater monitor wells. The groundwater elevations will be calculated by subtracting the measured depth to the top of groundwater in the wells from the surveyed top of casing elevation. Appropriate groundwater contour maps will be prepared as part of the report submitted to the USEPA pursuant to this Work Plan.

4.3.2

BACKGROUND GROUNDWATER QUALITY

To provide an indication of background groundwater quality, Exide proposes to install three background monitor wells at the following locations: 1. one well east of Fifth Street 2. one well south/southeast of the South Disposal Area, and 3. one well northeast of WMA1 and upgradient of the active on-site non-hazardous waste landfill. The approximate proposed locations of the new background monitor wells are shown on Figure 13. Locations may be adjusted based on utilities, physical barriers, results of the well gauging/survey event, new potentiometric map data, and input from USEPA. The well to be placed south/southeast of the South Disposal Area will be located near the topographic saddle south/southeast of the South Disposal Area in an attempt to provide hydraulically upgradient (background) groundwater samples for WMA3, as the surficial water-bearing zone penetrated during the Phase I RFI in soil borings near Stewart Creek was not present in monitor well B1R located in the South Disposal Area. The monitor wells will be designed, constructed, and developed consistent with TCEQ guidance, or as otherwise agreed by USEPA and in compliance with applicable state requirements. All new monitor wells will be installed by an experienced and licensed driller under the supervision of the consulting engineer/geologist. Prior to installation, Texas One Call will be alerted, and each boring location will be checked and cleared of utilities to a depth of approximately five feet below ground CONESTOGA-ROVERS & ASSOCIATES

029796-02 (1)

47

surface using a hand probe. The borings will be advanced to completion depths (approximately 20 ft bgs or to bedrock refusal) utilizing DPT equipment mounted on a track-mounted Geoprobe or similar (e.g., hollow stem auger) drilling unit. Soil samples will be collected continuously from each boring using USEPA SW-846-approved samplers. Upon collection, the soil samples will be visually and manually inspected for soil characteristics and visual evidence of staining using methods described in Section 4.1. Details of the soils encountered in each boring during the sampling activities, along with initial groundwater measurements, will be included on soil boring logs and/or shown on soil cross sections. The groundwater monitor wells will be completed as two-inch diameter risers placed in sand pack and 8.25-inch boreholes. The monitor wells will be constructed with Schedule 40 PVC threaded casing and a typically a 10-foot long well screen (0.01-inch slot size). However, the actual screen length will be defined according to the purpose of a given well. Construction of each well will include the placement of a sand filter pack with a mesh size of 20 to 40 around the well screen and hydrated bentonite seal above the filter pack to the ground surface. A typical monitor well installation is shown on Figure 14. Monitor well construction diagrams will be prepared to document the monitor well installation. Stick-up wells will be fitted on 4-foot by 4-foot well pads and protected by four bollards to prevent damage from Site activities. Some wells may require a flush mount, depending on the location. Each well will be secured with a locking watertight cap and padlock to deter tampering and introduction of surface water runoff into the well. The monitor wells will be developed using a surge block until relatively clear discharge is obtained. Sampling of groundwater monitor wells is discussed in the following section. The top-of-casing elevations (in ft amsl) for the new monitor wells will be surveyed by a Texas-licensed surveyor to the nearest 0.01 feet. In addition, elevation measurements will be recorded for at least two existing wells and those measurements will be compared to previous elevation data.

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CONESTOGA-ROVERS & ASSOCIATES

4.3.3

GROUNDWATER SAMPLING

Exide submits that groundwater quality was established during the Phase I RFI and in subsequent groundwater sampling of the monitor well network at the Site from approximately 1983 through approximately 2005. The monitor well network consisted of 18 monitor wells, with wells located both upgradient and downgradient of the waste management units which were designated for groundwater monitoring purposes (see Figure 13). The groundwater data collected from 1983 to 2005 indicates that there have been no exceedances of the lead and cadmium TRRP Tier 1 Protective Concentration Levels (PCLs). Therefore, historical data supports a conclusion that groundwater has not been affected by Site operations. For purposes of compliance with the Order, Exide proposes the following additional groundwater assessment: Exide will retain a third-party contractor to inspect the monitor well network for structural integrity. Any wells with observed integrity issues that are proposed for sampling will be repaired if possible, or plugged and abandoned if repair is not possible Exide will collect groundwater samples from the newly-installed background wells and the following existing monitor wells (if not damaged beyond repair): o o o MW-16, MW-16S, MW-17, B8N, and B5N, all of which are downgradient of WMA1 MW-12, MW-13, and MW-14, all of which are downgradient of WMA2 and had sporadic detections of lead and/or low pH during the RFI B2R, B3R, and B4R, located downgradient of WMA3

The depth-to-water measurement will be made in all wells prior to sampling activities in any single well. All readings will be recorded to the nearest one-hundredth of a foot and within 12 hours. The time, point of reference, measurement method, depth-to-water level measurement, any known outside influences (e.g., nearby pumping effects, major barometric changes) will be recorded. These data will be used to develop a current groundwater gradient map. Prior to sampling, the wells will be purged using low-flow purging. Draw-down will be monitored to ensure that it does not exceed 0.1 meters (0.33 feet). Low-flow techniques and procedures will be modeled after those specified in the USEPA 1996 guidance document titled Minimal Drawdown Ground-Water Sampling Procedures (EPA/540/S95/504)

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CONESTOGA-ROVERS & ASSOCIATES

Groundwater parameters will be analyzed during purging in the field for pH, temperature, turbidity, specific conductivity, dissolved oxygen (DO), and oxidationreduction potential (ORP) until stabilization is achieved, or if the well recharge cannot support the low-flow pump rate, the well will be pumped / purged dry. Stabilization is achieved after parameter values are within allowable variations for three successive readings. The readings shall be within 0.1 for pH, 3% for specific conductivity, 10mv for ORP, and 10% for temperature, turbidity and DO. Depending on field conditions encountered, the wells will be sampled upon stabilization using low-flow techniques or, if purged dry, sampled the following day. Groundwater samples will be submitted for laboratory analysis of total dissolved solids, sulfate, total and dissolved lead, and total and dissolved cadmium, following proper chain-of-custody procedures outlined in the Quality Assurance Project Plan.

4.4

ABANDONMENT OF BOREHOLES

Following completion of all investigation activities described in this Work Plan and further contemplated by subsequent reports as a result of this Work Plan, all boreholes will be plugged and abandoned by filling to ground surface with hydrated bentonite chips consistent with Administrative Rules of the Texas Department of Licensing and Regulation 16 TAC Chapter 76.

4.5

INVESTIGATION-DERIVED MATERIAL

All soil cuttings, wash/decontamination/purge water, and other investigation-derived materials generated during the investigation activities will be containerized in a known location near the point of generation at the Site at the end of each work day in drums or other appropriate containers for subsequent characterization and disposal. The containers will be labeled and dated to reflect the contents. A composite sample will be generated from the soil cuttings and water-based materials. The composite samples will be placed in laboratory-supplied containers, stored on ice, and transported to an accredited laboratory for analysis of Toxicity Characterization Leaching Procedure (TCLP) RCRA metals and ignitability, reactivity, and corrosivity (IRC), and other parameters required by the waste disposal facility for waste acceptance, following proper chain-of-custody procedures. Disposable sampling equipment will be containerized with the investigation-derived material.

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CONESTOGA-ROVERS & ASSOCIATES

4.6

MODIFICATIONS TO FIELD CHARACTERIZATION ACTIVITIES

Any deviations from the field sample collection methods or procedures listed in this Work Plan will be documented in the field log book, including reasons for the deviation, and will be reported in the applicable report. Substantial modifications to the Work Plan will be approved by USEPA in advance of implementation.

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CONESTOGA-ROVERS & ASSOCIATES

5.0

DATA EVALUATION Data collected during implementation of this Work Plan will be compared to applicable TRRP standards, where available, or otherwise to applicable USEPA standards. The delineation standards proposed to be utilized for dissolved cadmium and dissolved lead in surface water are the lower of the human health and ecological risk-based exposure limits (SWRBELs). The delineation standards proposed to be utilized for total cadmium and total lead in sediments are the lower of the human health PCLs and the average of the ecological benchmark and the second effects level for sediment. More progressive levels of TRRP and/or USEPA standards will be utilized during subsequent stages of data risk assessment.

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6.0

QUALITY ASSURANCE/QUALITY CONTROL Quality Assurance/Quality Control (QA/QC) methods will be implemented at each stage of the data-acquisition process: sample collection sample transportation sample handling by the laboratory data evaluation, and data reporting

A QAPP was prepared to address the proposed field sampling, laboratory analysis, and data evaluation activities conducted pursuant to the Order. The purpose of the QAPP is to provide guidance to ensure that all environmental data collection procedures and measurements are scientifically sound and of known, acceptable, and documented quality and conducted consistent with the requirements of the project. Procedures for QA/QC at each stage of the process are described in the QAPP. The QAPP is attached in Appendix A. Analytical methods and other laboratory quality information for proposed analyses are presented in the QAPP. All drillers and laboratories utilized on this project will be licensed to conduct such work in the state of Texas. All geological and/or engineering drawings generated pursuant to this Work Plan will be certified by appropriate personnel licensed to do such work in the state of Texas. Any deviations from the QA/QC or chain-of-custody procedures listed in this Work Plan and QAPP will be documented in the field log book, including reasons for the deviation, and will be reported in the applicable report.

6.1

PROPOSED ANALYTICAL LABORATORIES

Exide proposes to use one or more of the following analytical laboratories to analyze samples collected pursuant to this Work Plan: TestAmerica 14050 Summit Drive, Ste. A100 Austin, Texas 78728 or Houston, Texas or Pensacola, Florida locations (512) 244-0855

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CONESTOGA-ROVERS & ASSOCIATES

Accutest Laboratories 10165 Harwin Dr. # 150 Houston, Texas (713) 271-4700 OXIDOR Laboratories, LLC 1825 E. Plano Parkway, Suite 160 Plano, Texas 75074 (972) 424-6422 Any laboratory used by Exide for purposes of compliance with the Order will perform analyses in accordance with the latest approved edition of Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846), or other methods approved by the USEPA, and will participate in a QA/QC program consistent with that followed by the USEPA.

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7.0

HEALTH AND SAFETY Each contractor at the Site will be responsible for development of a Site-specific Health and Safety Plan (HASP) to protect the safety of their employees following procedures consistent with the Site health and safety policy and requirements. Prior to the initiation of sampling activities, the field team will assemble and review the HASP and all job safety analysis (JSAs) forms, prepare all field equipment documentation forms (including calibration information), make provisions for access, and coordinate with the laboratory for shipment of sample containers and supplies. At the beginning of each day of field activities, a brief joint safety meeting will be held. During this meeting, the field team will describe the activities to be implemented that day, identify the safety hazards, remind employees of important safety procedures, and comment on safety issues identified the previous day.

7.1

MINIMUM QUALIFICATIONS FOR PERSONNEL

All field work performed by or on behalf of Exide pursuant to the Order shall be under the direction and supervision of an individual who has demonstrated expertise in hazardous waste site investigation. At least fifteen (15) days prior to field activities pursuant to this Work Plan, Exide will submit to USEPA the name, title, and qualifications of the supervisory personnel and of any contractors or subcontractors to be used in carrying out the terms of the Order. Field personnel will undergo a minimum of 40 hours of HazWoper training and Exide Site-specific training. Exide will ensure that, when a license is required for field work pursuant to the Order, only licensed individuals will be used to perform the work.

7.2

ACCESS BY USEPA

Access will be provided for employees, agents, and contractors of USEPA at all reasonable times for purposes of inspection and verifying compliance with the provisions of this Order, in accordance with and pursuant to Section 3007 of RCRA, 42 USC 6927, and Exides health and safety program, policy, and procedures.

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CONESTOGA-ROVERS & ASSOCIATES

8.0

PRELIMINARY SCHEDULE AND REPORTING A preliminary schedule of field activities is presented in Exhibit 1. This schedule is subject to revision based on weather conditions, modifications or additions to the scope of work described herein based on field conditions or the data obtained, or delays in obtaining access to off-Site properties to be sampled. Exide will submit quarterly progress reports to the USEPA if the Site work extends beyond a three-month period. The first quarterly report will be submitted within three months after the effective date of the Order. Quarterly reports will be submitted by the fifteenth day of the month following the end of the quarter. Exide will submit a final report addressing the Work Plan requirements and goals outlined in Paragraphs 50 through 52 of the Order. The final report will include a summary of all actions taken to comply with the Order, an evaluation/comparison of data collected to appropriate TRRP or other risk-based exposure standards, and recommendations for further action. One hard copy and one electronic copy of all documents to be submitted to be USEPA shall be sent to the following: Sunita Singhvi, Chief, Corrective Action and Compliance Inspection Hazardous Waste Enforcement Branch RCRA Corrective Action and Compliance Inspection Section U.S. Environmental Protection Agency, Region 6 1445 Ross Avenue, Suite 1200 (6EN-HC) Dallas, TX 75202-2733 Attention: Paul James Exide estimates the cost to implement the scope of work proposed herein to be approximately $200,000 to $250,000. This estimated cost is preliminary and will likely change based on changes in the work scope requested by the USEPA, competitive bidding by required subcontractors, unanticipated conditions encountered during field activities, or other circumstances.

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CONESTOGA-ROVERS & ASSOCIATES

9.0

CERTIFICATION

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FIGURES

029796-02 (1)

N Cr Rd

1st S t

W Main St

SITE

Ash S

S Cr Rd

St

r wa

tC

re

ek

ky Dallas P
Dal las P ky

Hickory Park

S tew

ar t C r e e k

V U
289

R Preston

S te

wa

rt C reek

St ew art Cr ee k

Legend
Boundary of Permitted Facility Property Owned by Exide RE: 2010 Aerial Photograph 0 500 1,000 Feet

Frisco High School

Figure 1 SITE LOCATION MAP SAMPLING AND ANALYSIS WORK PLAN EXIDE TECHNOLOGIES, FRISCO, TEXAS

29796-02(001)PR-BR001 Nov 7/2011

P-1
X X X X X

X
X

MW-11
D CATE RELO

TARY TRIBU

TO ST

EK T CRE EWAR

B9N
Previous Location of Stewart Creek North Tributary

X
X

North Disposal Area (Delineated in 1993 Addendum to RFI)

X
X

WMA-4
Slag Landfill

Slag Landfill

B7N

X
X

B8N
Boneyard Closed Stewart Creek Sediment Waste Piles
X
X
X

MW-16 MW-16S
X

WMA-1

Truck Staging Area (Investigation Reported In 1998 Phase II RFI Report)

MW-15
X

MW-17 B5N
X

Oxide Building Railroad Spur Battery Breaker

Storm Water Retention Pond

Battery Receiving / Storage Building

MW-10
X

MW-13 MW-14

Closed Product Waste Piles

Parking Lot
X X

WMA-2
Sl ag

Raw Material Storage Building

Old Drum Storage Area


X

MW-12

Tr

ea

tm en tB uil

din g

Former Diesel Fuel Tank (Closed)

Wastewater Treatment
X

Stewart Creek Flood Wall Crystallization Unit Frac Tank

Melissa Street

Stewart Creek

LEGEND Facility Boundary Municipal Solid Waste Waste Management Area (WMA) WMA-1 WMA-2 North Disposal Area, Slag Landfill, and Closed Stewart Creek Sediment Waste Pile Raw Material Storage Building, Old Drum Storage Area, Closed Product Waste Pile, Battery Receiving /Storage Building, Former Diesel Fuel Tank (Closed) South Disposal Area Stewart Creek B1R
Facility Boundary

B3R B4R

B2R
X

P-2
X

WMA-3

South Disposal Area (Delineated in 1993 Addendum to RFI And Further Investigated During Phase II RFI)

WMA-3 WMA-4 B5N

Existing Monitor Well

RE: ESRI Aerial Photograph

100

200ft

Figure 2 SITE MAP SAMPLING AND ANALYSIS WORK PLAN

029796-02(001)GN-BR001 Nov 7/2011

Blast Furnace Building

Ea
X
X

gan
X
X

Bail Stabilization Area

Driv e
X

X X

X X
X X

X X

X
X

X
X

X X X
X X

X
X

X
X

X
X X

FIGURE 3 CONCEPTUAL EXPOSURE MODEL SAMPLING AND ANALYSIS WORK PLAN EXIDE TECHNOLOGIES FRISCO RECYCLING CENTER FRISCO, TEXAS

Primary Source

Release Mechanism

Secondary Source

Secondary Release Mechanism

Exposure Media

Exposure Route(s)

Restricted Use Areas

Offsite Use Areas Recreational Wader C C C C C I C C C I I I I I I I I I C C C C C I C C I C C I I I I I I I

Outdoor Worker Resuspension by Wind Ingestion Dermal Inhalation Ingestion Dermal Inhalation Ingestion Dermal Inhalation Ingestion Dermal Inhalation Ingestion Dermal Inhalation Ingestion Dermal Inhalation Ingestion Dermal Inhalation Ingestion Dermal Inhalation Ingestion Dermal Inhalation Ingestion Dermal Inhalation Ingestion Dermal Inhalation Ingestion Dermal Inhalation C C C I I I I I I I I I I I I I I I C C C I I I I I I I I I C C C I I I

Indoor Worker C C C I I I I I I I I I I I I I I I I I I I I I I I I I I I C C C I I I

Construction/ Utility Worker C C C I I I I I I C C I C C I I I I C C C I I I I I I I I I C C C I I I

Outdoor Air

Surface Water Erosion by Water Sediment Spills/Leaks Surface Soil Subsurface Soil

Leaching

Groundwater

Drinking Water Smelting Operations Deposition to Surface Soil Surface Soil

Deposition to Surface Run-off

Surface Water

Surface Water Pulverizing and Heating Air Deposition to Surface Water Sediment

Entry of Exhausted Dust Into Building LEGEND C = Complete Exposure Pathway I = Incomplete Exposure Pathway Deposition to Botanical Surfaces

Indoor Air

Foliage

D TR CATE RELO

ST RY TO IBUTA

T EWAR

K CREE

B9N

North Disposal Area (Delineated in 1993 Addendum to RFI)

Previous Location of Stewart Creek North Tributary

B7N
Slag Landfill

Slag Landfill

NL-34 NL-22 NL-21 NL-20 NL-19 NL-18 NL-17


NB-47 NB-44 NB-46

NL-23
NB-45

NL-24
NB-43

NL-28 NL-25
NB-42 NB-41 NB-40

NL-29
NB-39

NL-30
NB-38

NL-33 NL-31
NB-37 NB-36

NB-31

NL-36
NB-1

NB-32 NB-33 NB-30 NB-34 NB-29 NB-27

NL-35
NB-26

NL-32

NL-26

NL-27

NB-35

NB-2 NB-28 NB-3 NB-4 NB-5

NL-37

NL-38

NB-25 NB-24 NB-23 NB-6 NB-7

Boneyard

NL-16 NL-15

NB-48

NB-22

Closed Stewart Creek Sediment Waste Piles


NB-49

NL-39
NB-8 NB-9 NB-17

NB-21

MW-16 MW-16S

WMA-1
5 2 6 10 1 9
NB-53 NB-52 NB-54

Bail Stabilization Area

NL-40
NB-10

NB-20 NB-18

NB-19

NL-02

NL-01

NL-47 NL-46 NL-45

NL-41 NL-42
NB-13

NB-16 NB-15

NB-11 NB-12

4 3
NB-50

NB-14

NL-44

NL-43

NL-14 NL-12 NL-10


NB-51

NL-09

NL-08

NL-07

NL-06

NL-05

NL-04

NL-03

MW-17
X

LEGEND Facility Boundary


X

B5N
Railroad Spur Battery Receiving / Storage Building Battery Breaker Blast Furnace Building Closed Product Waste Piles Closed Product Waste Piles

Oxide Building

Municipal Solid Waste Waste Management Area (WMA)


X

WMA-1

North Disposal Area, Slag Landfill, Stewart Creek MW-13 Sediment Waste Pile Soil Samples (1987) Original Surveyed Delineation Boring Location (1993) New Delineation Boring Location (1993) Existing Monitor Well Boring Location (1991) Proposed Approximate Soil Sample Location. Locations May be Adjusted Based on Field Observations of Contamination, Utilities, or Other Physical Barriers. MW-12 RE: ESRI Aerial Photograph
X

Parking Lot

5
NL-30
NB-38

MW-16S B5N

029796-02(001)GN-BR013 Nov 7/2011

MW-14
Raw Material Storage Building

Sl ag

Tr

ea

tm en

tB

uil

din

50

100ft

Figure 4 PROPOSED SOIL SAMPLE LOCATIONS - NORTH DISPOSAL AREA SAMPLING AND ANALYSIS WORK PLAN

Facility Boundary

T EWAR TO ST TARY TRIBU D CATE RELO

CREE

B9N

North Disposal Area (Delineated in 1993 Addendum to RFI)

Slag Landfill Previous Location of Stewart Creek North Tributary Slag Landfill

B8N

Boneyard Closed Stewart Creek Sediment Waste Piles

MW-16
X

WMA-1

X X
X

MW-16S

X X X

LEGEND

MW-17
X

Facility Boundary Waste Management Area (WMA) WMA-1 North Disposal Area, Slag Creek Sediment Waste Pile Existing Monitor Well Proposed Approximate Soil Sample Location. Locations May be Adjusted Based on Field Observations of Contamination, Utilities, or Other Physical Barriers.
X

B5N
Railroad Spur

Storm Water Landfill, Retention Stewart Closed Pond

X
Battery Receiving / Storage Building Battery Breaker

MW-16S

MW-13 RE: ESRI Aerial Photograph

50

100ft

Figure 5 PROPOSED SOIL SAMPLE LOCATIONS - SLAG LANDFILL SAMPLING AND ANALYSIS WORK PLAN

029796-02(001)GN-BR014 Nov 7/2011

Railroad Spur

Battery Receiving / Storage Building

Battery Breaker

Blast Furnace Building

Closed Product Waste Pile

Closed Product Waste Pile

WMA-2
W a Tr stew ea tm ate en r t

Raw Material Storage Building

Sl

ag

Tr e

atm

en

tB uil

din

Old Drum Storage Area

Former Diesel Fuel Tank (Closed)

LEGEND Waste Management Area (WMA) WMA-2 Raw Material Storage Building, Old Drum Storage Area, Closed Product Waste Pile, Battery Receiving/ Storage Building, Former Diesel Fuel Tank (Closed) Existing Monitor Well Proposed Approximate Soil Sample Location. Locations May be Adjusted Based on Field Observations of Contamination, Utilities, or Other Physical Barriers.
Stewart Creek

B5N

RE: ESRI Aerial Photograph

20

60ft

Figure 6 PROPOSED SOIL SAMPLE LOCATIONS - RAW MATERIAL STORAGE AREA SAMPLING AND ANALYSIS WORK PLAN

029796-02(001)GN-BR006 Nov 7/2011

SDA-3 SDA-4
Facility Boundary

SDA-5 SDA-6 BS1/BS-1 B3R BS3/BS-3 BS4/BS-4 BS5/BS-5 BS2/BS-2 B2R

SB-14

SL-11
B4R SB-13 SB-15

SL-10
SB-16

SDA-2

SL-12
SB-12 SB-9 SB-8 SB-6 SB-10

SB-27

SL-9 SL-8 SL-7


SB-19
SB-17 SB-18

SB-20 SB-21

SL-13
SB-7 SB-11

SL-4
SB-23

SL-14
SB-5 SB-3

SL-15
SB-4
Soil Pile

SL-6 SL-5

SL-3 SB-22

WMA-3

SB-24

SDA-7

SB-1

SDA-1

SL-16
SB-26

SL-2
SB-25

LEGEND Facility Boundary Waste Management Area (WMA) WMA-3 BS5 SL-20
SB-1

SL-17 SL-20 SL-21


SDA-10 SDA-9-2 SDA-9-1 SDA-8 B1R

SL-1 SL-22
South Disposal Area (Delineated in 1993 Addendum to RFI And Further Investigated During Phase II RFI)

South Disposal Area Boring Sample Location (1991) Original Surveyed Delineation Boring Location (1993) New Delineation Boring Location (1993) Boring Sample Location (1991) Existing Monitor Well South Disposal Area Boring Location (1998 Phase II Boring) Proposed Approximate Soil Sample Location. Locations May be Adjusted Based on Field Observations of Contamination, Utilities, or Other Physical Barriers. Sample ID

SL-18
SB-2

SL-19

B3R B4R SDA-6

Concentration, mg/kg

Sample Depth, Inch (")

RE: ESRI Aerial Photograph

NOTE: Concentration from Phase II RFI (6/1998) mg/kg = milligrams per kilogram

20

60ft

Figure 7 PROPOSED SOIL SAMPLE LOCATIONS - SOUTH DISPOSAL AREA SAMPLING AND ANALYSIS WORK PLAN

029796-02(001)GN-BR007 Nov 7/2011

Slag Landfill

Slag Landfill

B8N

Previous Location of Stewart Creek North Tributary

WMA-1

Boneyard

Closed Stewart Creek Sediment Waste Piles MW-16 MW-16S

Stewart Creek

X X
X

LEGEND
X

Facility Boundary WMA-1 B4R

North Disposal Area, Slag Landfill, and Closed Stewart Creek Sediment Waste Pile X Existing Monitor Well Proposed Approximate Soil Sample Location. Locations May be Adjusted Based on Field Observations of Contamination, Utilities, or Other Physical Barriers. RE: ESRI Aerial Photograph

MW-17

20

40ft

Figure 8 PROPOSED SOIL SAMPLE LOCATIONS - BONEYARD SAMPLING AND ANALYSIS WORK PLAN

029796-02(001)GN-BR008 Nov 7/2011

X
X X

X
X

Bail Stabilization Area

Truck Staging Area


X

Oxide Building
X

Parking Lot

LEGEND

B4R

Locations May be Adjusted Based on Field Observations of Contamination, Utilities, or Other Physical Barriers.

RE: ESRI Aerial Photograph

20

60ft

Figure 9 PROPOSED SOIL SAMPLE LOCATIONS - BAIL STABILIZATION AREA SAMPLING AND ANALYSIS WORK PLAN

029796-02(001)GN-BR009 Nov 7/2011

Blast Furnace Existing Monitor Well Building Proposed Approximate Soil Sample Location.
Facility Boundary

Eag
X X X X X X X X

an
X
X

Driv

North Disposal Area (Delineated in 1993 Addendum to RFI)

Crystallization Unit Frac Tank

LEGEND Facility Boundary MW12 Existing Monitor Well Proposed Approximate Soil Sample Location. Locations May be Adjusted Based on Field Observations of Contamination, Utilities, or Other Physical Barriers. RE: ESRI Aerial Photograph

029796-02(001)GN-BR002 Nov 7/2011

MW-14

W a Tr stew ea tm ater en t

MW-12

Stewart Creek

Facility Boundary

B4R

20

60ft

Figure 10 PROPOSED SOIL SAMPLE LOCATIONS - CRYSTALLIZATION UNIT FRAC TANK SAMPLING AND ANALYSIS WORK PLAN

MW-17 B5N
X

Oxide Building Railroad Spur Battery Breaker


X

Battery Receiving / Storage Building

MW-13

Closed Product Waste Piles Closed Product Waste Piles

Blast Furnace Building Parking Lot

029796-02(001)GN-BR003 Nov 7/2011

MW-14

W a Tr stew ea tm ate en r t

WMA-2
Raw Material Storage Building

Sl
MW-12

ag

Tr

ea

tm

en

tB

Old Drum Storage Area

uil

din

g
Former Diesel Fuel Tank (Closed)

Stewart Creek Flood Wall

Stewart Creek

Facility Boundary B2R

B3R

LEGEND Facility Boundary Waste Management Area (WMA) WMA-2 Raw Material Storage Building, Old Drum Storage Area, Closed Product Waste Pile, Battery Receiving / Storage Building, Former Diesel Fuel Tank (Closed) Existing Monitor Well RE: ESRI Aerial Photograph Proposed Approximate Soil Sample Location. Locations May be Adjusted Based on Field Observations of Contamination, Utilities, or Other Physical Barriers.
B4R

B5N

50

100ft

Figure 11 PROPOSED SOIL SAMPLE LOCATIONS - STEWART CREEK FLOOD WALL SAMPLING AND ANALYSIS WORK PLAN

P-1
X X X X X

X
X

MW-11
CATE RELO DT O ARY T RIBUT STEW

ART C

REEK

B9N
Previous Location of Stewart Creek North Tributary

X
X

X
X

B7N

X
X

B8N

X
X
X

MW-16 MW-16S
X

Truck Staging Area


X

MW-15
X

MW-17 B5N
X

Oxide Building Railroad Spur Battery Breaker

Storm Water Retention Pond

Battery Receiving / Storage Building

MW-10
X

MW-13 MW-14

Parking Lot
X X

Sl

Raw Material Storage Building

ag

MW-12
Wastewater Treatment

Tr

ea tm

en tB

uil

din

Former Diesel Fuel Tank (Closed)

Stewart Creek Flood Wall

Stewart Creek

Former Crystallization Unit Frac Tank Facility Boundary

B3R B4R

B2R
X

P-2
X X

LEGEND
X

Facility Boundary B5N Existing Monitor Well Proposed Approximate Surface Water Sample Location B1R

Proposed Approximate Sediment Sample Location. Locations May be Adjusted Based on Field Observations of Contamination, Utilities, Suitable Depositional Substrate, or Other Physical Barriers.

RE: ESRI Aerial Photograph

100

200ft

Figure 12 PROPOSED SURFACE WATER AND SEDIMENT SAMPLE LOCATIONS SAMPLING AND ANALYSIS WORK PLAN

029796-02(001)GN-BR004 Nov 7/2011

Blast Furnace Building

Ea
X
X

gan
X X
X X X X

Driv e
X

X X

X X
X

X X
X

X X X
X

X
X X

X
X X

P-1
X X X

MW-19

X X

X
X

MW-11
D CATE RELO

TARY TRIBU

TO ST

T CRE EWAR

EK

B9N
Previous Location of Stewart Creek North Tributary

X
X

X
X

MW-18

Slag Landfill

B7N

X
X

B8N

Slag Landfill

X
X
X

MW-16 MW-16S
X

MWA-1
X

Truck Staging Area


X

Ea

gan

Driv e
X

X X

MW-20
X

MW-15
X

MW-17 B5N
X

Oxide Building Railroad Spur Battery Breaker

Storm Water Retention Pond

Battery Receiving / Storage Building

MW-10
X

MW-13 MW-14

Parking Lot
X X

Sl

Raw Material Storage Building

ag

MW-12

Tr

ea tm

en tB

uil

din

Former Diesel Fuel Tank (Closed)

Wastewater Treatment
X

Stewart Creek Flood Wall Crystallization Unit Frac Tank

Stewart Creek

B3R
Facility Boundary

B2R
X

B4R

P-2
X X

LEGEND
X

Facility Boundary B5N Existing Monitor Well Proposed Approximate Background Monitor Well Location. Locations May be Adjusted Based on Recent Groundwater Sampling Data, Utilities, or Other Physical Barriers. B1R

MW-21

MW-21
RE: ESRI Aerial Photograph

100

200ft

EXISTING GROUNDWATER MONITORING NETWORK AND PROPOSED BACKGROUND MONITOR WELL LOCATIONS SAMPLING AND ANALYSIS WORK PLAN

029796-02(001)GN-BR005 Nov 7/2011

X X X

Blast Furnace Building

X X
X

X
X

X X X
X

X
X X

X
X

Figure 13

(4" STEEL CASING SET 2' DEEP WITH CONCRETE)

ELEV. TOP OF RISER


Nominal 3'

NA NA NA NA

LOCKED SHROUD

ELEV. GROUND SURFACE SCREENED INTERVAL

0.0 2"

DATE INSTALLED

4"

> 6" 2" or 4"

Construction Notes: Well Casing: Shroud: Filter Pack: Bentonite Seal: Time/Date Placed: Grout: Unit Weight: Time/Date Placed:

2" or 4" PVC Schedule 40 Steel 20-40 Sand Hydrated sodium bentonite pellets/chips

Nominal 7'

Nominal 9' Nominal 10'

Remarks:
4" 0.01" Nominal 20' Nominal 20' Nominal 20' 4' 2" or 4" 0.01

4'
Protective Shroud Casing

PLAN VIEW
CONESTOGA-ROVERS & ASSOCIATES

NOTES: 1) All section dimensions are in feet (unless otherwise noted).


NA: Not available at this time

SECTION VIEW
10/21/2011
DATE

2) Actual construction details may vary slightly depending on actual well depth. Wells to be installed to bedrock.

0
REV. NO.

29796-Source
FILE NO

EXIDE TECHNOLOGIES
CLIENT

JMK

JMK

EXIDE TECHNOLOGIES Frisco Recycling Center Frisco, Texas


PROJECT LOCATION

Figure 14
Typical Monitor Well Installation

DRAWN BY:

CHECKED BY:

APPROVED BY:

N
j k

j k

Legend
1000 Foot Radius of Site Boundary of Permitted Facility Property Owned by Exide

j k

Schools Parks Commercial Government/Education Industrial Infrastructure Residential Undeveloped

RE: 2010 Aerial by Microsoft Corp and its data suppliers.

300

600 Feet

Figure 15 HUMAN AND ECOLOGICAL RECEPTORS WITHIN 1,000 FEET OF THE SITE SAMPLING AND ANALYSIS WORK PLAN EXIDE TECHNOLOGIES, FRISCO, TEXAS

29796-02(001)PR-BR002 Nov 4/2011

APPENDIX A QUALITY ASSURANCE PROJECT PLAN

029796-02 (1)

QUALITY ASSURANCE PROJECT PLAN


FRISCO RECYCLING CENTER EXIDE TECHNOLOGIES FRISCO, TEXAS

EPA ID NO. TXD006451090 DOCKET NO. RCRA-06-2011-0966

Prepared For: EXIDE TECHNOLOGIES

REVISED NOVEMBER 2011 REF. NO. 029796-02 (1) APPENDIX A

TABLE OF CONTENTS PAGE 1.0 2.0 3.0 INTRODUCTION .............................................................................................................. 1 DATA QUALITY OBJECTIVES FOR MEASUREMENT DATA................................. 2 SAMPLING PROCEDURES ............................................................................................. 3 3.1 DOCUMENTATION PROCEDURES.......................................................... 3 3.2 SAMPLE IDENTIFICATION ........................................................................ 4 3.3 CHAIN-OF-CUSTODY RECORDS.............................................................. 5 3.4 SAMPLE PACKING AND SHIPPING ........................................................ 7 QUALITY CONTROL SAMPLES .................................................................................... 8 4.1 QC FOR SAMPLING PROTOCOL .............................................................. 8 4.1.1 MS/MSD SAMPLES ...................................................................................... 8 4.1.2 FIELD BLANK SAMPLES............................................................................. 8 4.1.3 TRIP BLANK SAMPLES ............................................................................... 8 4.1.4 EQUIPMENT RINSATE BLANK SAMPLES.............................................. 8 4.1.5 DUPLICATE (BLIND) FIELD SAMPLES.................................................... 9 DECONTAMINATION PROCEDURES AND MATERIALS...................................... 10 DATA VALIDATION AND USABILITY ....................................................................... 11 6.1 DATA VALIDATION AND VERIFICATION ........................................... 11 6.1.1 DATA VALIDATION PROTOCOLS........................................................... 12 6.2 DATA VERIFICATION METHODS............................................................ 14 6.3 RECONCILIATION WITH USER REQUIREMENTS ............................... 14

4.0

5.0 6.0

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LIST OF TABLES

TABLE 1 TABLE 2 TABLE 3 TABLE 4

POTENTIAL CONSTITUENTS OF CONCERN POTENTIAL ANALYTICAL PROGRAM SUMMARY OF SAMPLE CONTAINERS, PRESERVATION, AND HOLDING TIMES FIELD QUALITY CONTROL SAMPLES

1.0

INTRODUCTION The Quality Assurance Project Plan (QAPP) presents the Quality Assurance/Quality Control (QA/QC) procedures designed to achieve specific data quality objectives for the activities covered by the Sampling and Analysis Work Plan, prepared pursuant to the Administrative Order issued by the United States Environmental Protection Agency, Docket No. RCRA-06-2011-0966, for the Exide Technologies Frisco Recycling Center, located in Frisco, Collin County, Texas (Site). The objectives of this QAPP are to provide descriptions of the measures to be used during the investigation to generate data that will be of a known and acceptable level of precision and accuracy. The QAPP has been prepared to identify procedures for sample preparation and handling, sample transport and chain of custody, laboratory analyses, and reporting to be implemented during the investigation to verify the accuracy and integrity of the data.

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2.0

DATA QUALITY OBJECTIVES FOR MEASUREMENT DATA The purpose of this Section is to define the QA goals required to meet the Data Quality Objectives (DQOs) of the project. The fundamental QA objective with respect to the accuracy, precision, and sensitivity of analytical data is to meet the QC acceptance criteria of the analytical protocol. Therefore, data used shall be obtained from an accredited laboratory and shall meet the following requirements: 1. The data were generated using rigorous analytical methods such as an approved U.S. Environmental Protection Agency (USEPA) method 2. The data are analyte-specific and the identity and concentration are confirmed 3. The method produced tangible raw data in the form of paper or electronic files 4. QA/QC documentation includes sample documentation, calibration documentation, detection limit documentation, analyte identification and quantification, QC blanks (trip, method, rinsate), matrix spike recoveries, performance evaluation samples (laboratory control samples), analytical error determination (using replicate samples), and total measurement error determination (using spike samples) Data that meet these requirements are referred to as definitive data according to Data Quality Objectives Process for Superfund, Interim Final Guidance (USEPA 540-R-93-071). Definitive data meet the DQOs and are considered acceptable for use on this project. Three potential laboratories have been identified to conduct the laboratory analyses for this project: TestAmerica, Accutest Laboratories, and OXIDOR Laboratories. All three laboratories have quality assurance programs in place and management policies, objectives, principles, organization, and functional responsibilities for achieving quality data for this project. Each laboratory has Standard Operating Procedures (SOPs) in place for analyses proposed by the Work Plan. Each of the laboratories is accredited to perform the required analyses in the state of Texas. The potential constituents of concern (COCs) are listed in Table 1 of this Appendix. COCs include Resource Conservation and Recovery Act (RCRA) metals, sulfate, and total petroleum hydrocarbons (TPH). The COCs listed in Table 1 will be analyzed in the designated media in certain areas of the Site to be investigated, as set forth in the Work Plan and Table 2 of this QAPP. The analytical methods required for each analysis for each matrix are summarized in Table 2 of this QAPP.

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3.0

SAMPLING PROCEDURES Sample collection and handling will be conducted consistent with the contractors standard operating procedures and applicable USEPA and TCEQ-recommended practices and guidelines. Samples will be collected at approximate locations and depths described in this Work Plan. Site-dedicated equipment will be used whenever possible. All sampling equipment will be properly decontaminated prior to use. Sample containers will be provided by the analytical laboratory for use during the Site activities. The required analytical sample containers, preservation, and holding times for each analysis for each matrix are summarized in Table 3 of this Appendix. All investigation-derived materials (IDM) will be managed consistent with federal and state regulations, as specified in the Work Plan.

3.1

DOCUMENTATION PROCEDURES

Field team members will maintain bound field logbooks to provide a daily record of significant events, observations, and measurements during sampling. All information pertinent to sampling will be recorded in the logbooks or on activity-specific data forms. Each days logbook entries will be signed and dated and will include the following: Name, initials, and title of author, date and time of entry, and weather and environmental conditions during the field activity Location of sampling activity Full name and title of field crew Full name and title of Site visitors Sample medium (e.g., soil, sediment, groundwater) Sample collection method (e.g., direct-push, hand auger, low-flow) Number of samples collected

The following information will be recorded either in the logbook or on the activity-specific data forms (as applicable): Volume of soil, sediment, surface water, or groundwater samples collected Date and time of collection

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Sample depth (as applicable) Sample identification number(s) Sample destination (i.e., laboratory) Water level measurement data (as applicable) Field observations Field measurements (e.g., pH, temperature, and conductivity, as applicable) and field measurement equipment calibration records Sample handling (preservation)

All original data recorded in field logbooks, field data forms, sample labels, and chain-of-custody forms must be written with waterproof, indelible ink. If an error is made on one of these accountable documents, corrections will be made by crossing a line through the error, initialing and dating the correction, and entering the correct information. The erroneous information will not be obliterated. The person who made the entry will correct any subsequent error discovered on an accountable document.

3.2

SAMPLE IDENTIFICATION

Sample identification labels are necessary to identify and prevent misidentification of the samples. The labels will be affixed to the sample container (not the caps) prior to the time of sample collection. The labels shall be completed in waterproof ink at the time of collection. The labels will include the following information: Project number/identification Sample identification number Date and time Sample medium (i.e., soil, sediment, surface water, or groundwater) Name of collector Required analyses Type of preservation

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3.3

CHAIN-OF-CUSTODY RECORDS

Sample custody and documentation procedures described herein must be followed throughout all sample collection activities. Components of sample custody procedures include the use of field logbooks, sample labels, custody seals, and chain-of-custody forms. The chain-of-custody form must accompany the samples during shipment from the field to the laboratory. A sample is under custody under the following conditions: It is in ones actual possession It is in ones view, after being in his or her physical possession It was in ones physical possession and that person then locked it up to prevent tampering, and/or It is in a designated and identified secure area

The following procedures must be used to document, establish, and maintain custody of field samples: A sample label will be completed and attached to each sample container for every sample collected. Labels consist of a waterproof material backed with a water-resistant adhesive. Labels are to be filled out using waterproof ink, making sure that the labels are legible and affixed firmly on the sample container All sample-related information must be recorded in the project logbook or on activity-specific data forms The field sampler must retain custody of samples until they are transferred or properly dispatched To simplify the chain-of-custody record and minimize potential problems, as few people as possible should handle the samples or physical evidence. Whenever possible, one designated individual will be responsible for the care and custody of the samples until they are properly transferred to another person or facility A chain-of-custody record will accompany all samples. This record documents the transfer of custody of samples from the field investigator to another person, to the laboratory, or to other organizational entities, as a signature for relinquishment and receipt of the samples must accompany each change of possession. A chain-of-custody record will be prepared for groups of samples collected on a given day and will accompany every shipment of samples to the laboratory

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CONESTOGA-ROVERS & ASSOCIATES

The original chain-of-custody document will accompany the samples to the laboratory. The carbon copy will be kept by the field investigation team and placed in the project file. The chain-of-custody record makes provision for documenting sample integrity and the identity of any persons involved in sample transfer. Information entered on the chain-of-custody record will include the following for shipment to the laboratory: Signature of collector(s) Client name Site address (if confidential, write NA) Sample identification number for each sample in the cooler Date and time of collection for each sample Sample type (e.g., G=Grab, C=Composite) Sample matrix (e.g., W=Water, S=Soil) Type of preservative (write none if none used) Number of containers per sample Parameters requested for analysis Signature and printed name of person(s) involved in the chain of possession Date of possession Date of relinquishment Project and task numbers Total number of containers in cooler Identification number of cooler (if available) Method of shipment Airbill number (if applicable) To whom the results should be sent (project contact) Laboratory turnaround time requested Identification of any known hazards Comments such as additional sample volume identical for laboratory QC (i.e. MS, MSD, DUP) Name, address, and telephone number of laboratory Method of delivery and courier

Completed chain-of-custody forms will be sealed inside a plastic zip-top bag and taped to the inside cover of the shipping container used for sample transport from the field to

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CONESTOGA-ROVERS & ASSOCIATES

the laboratory when a courier or shipping company is used. The shipping company will not sign for custody of the samples. When samples are relinquished to a courier for transport, the tracking number from the shipping bill or receipt will be recorded on the chain-of-custody form and in the site logbook. Custody seals must be affixed on shipping containers when samples are shipped to the laboratory to prevent sample tampering during transportation.

3.4

SAMPLE PACKING AND SHIPPING

All samples will be cooled on ice at 4C (2C). Custody seals will be placed around each cooler, and the coolers will then be sealed with packing tape for shipment to the analytical laboratory. Samples will be delivered to the designated laboratory by field personnel, laboratory courier, or by commercial shipping services (such as UPS or Federal Express). The method of sample shipment will be noted on the chain-of-custody form. During field activities, the Site supervisor or a designee will inform the laboratory daily of planned shipments. Hard plastic ice chests or coolers with similar durability will be used for shipping samples. The samples will be packed to prevent damage during shipment. The following procedures must be used when transferring samples for shipment: A chain-of-custody form must accompany samples. When transferring possession of samples, the individuals relinquishing and receiving must sign, date, and note the time on the record. This record documents transfer of custody of samples from the field sampler to another person or to the laboratory. Overnight shipping companies will not be required to sign the chain-of-custody form. A copy of the receipt of shipment will accompany the chain-of-custody form Samples must be properly packaged for shipment and dispatched to the laboratory for analysis with a separate signed chain-of-custody form enclosed in each sample box or cooler. The chain-of-custody form should reflect only the contents of the cooler in which it is enclosed A chain-of-custody form identifying the contents must accompany all packages

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4.0

QUALITY CONTROL SAMPLES 4.1 QC FOR SAMPLING PROTOCOL

To assess the quality of data resulting from the field sampling activities, field duplicate and field blank samples will be collected and submitted to the analytical laboratory as samples. A summary of the QC sampling is outlined below and summarized in Table 4 of this QAPP.

4.1.1

MS/MSD SAMPLES

Matrix spike (MS) and Matrix Spike Duplicate (MSD) samples will be collected in the field to assess accuracy of the methods and precision of the method relative to the specific sample matrix. MS/MSD samples contain identical spiked components of known concentrations. One MS/MSD set (i.e., one sample plus one MS, and one MSD sample at one location) for every twenty (20) or fewer samples in each media will be collected.

4.1.2

FIELD BLANK SAMPLES

If volatile organic compounds (VOC) analyses are requested, one field blank sample will be collected per day by filling a sample container with analyte-free water in the same sampling conditions that the other field samples are collected.

4.1.3

TRIP BLANK SAMPLES

Trip blanks will be required if samples are to be analyzed for VOCs. Trip blanks consist of deionized water packaged at the laboratory and shipped with each cooler to accompany the sample containers during the trip from the lab to the Site and during the return trip. Analyses of the trip blanks are used to evaluate the potential for external interference that could have impacted the sealed sample during shipment.

4.1.4

EQUIPMENT RINSATE BLANK SAMPLES

Equipment rinsate (rinse) blanks will be used to assess decontamination procedures of collection equipment used for multiple samples. The rinse blank will be prepared using analyte-free deionized water when non-dedicated equipment is used in the field. The

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CONESTOGA-ROVERS & ASSOCIATES

rinse blank will be analyzed by the laboratory as a sample. prepared at a frequency of one per day per equipment type.

Rinse blanks will be

4.1.5

DUPLICATE (BLIND) FIELD SAMPLES

Blind duplicate field samples are collected to monitor the precision of the field sampling process. Duplicates will be collected for surface water and groundwater samples only, because the inherent variability of soil and sediment samples precludes obtaining a true duplicate. The identity of the duplicate sample is not noted on the laboratory COC form. The Site supervisor will choose at least 5 percent (1 in 20) of the total number of sample locations at which to collect a duplicate sample. The identity of the duplicate samples is recorded in the field sampling logbook, and this information is forwarded to the data quality evaluation team to aid in reviewing and evaluating the data.

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5.0

DECONTAMINATION PROCEDURES AND MATERIALS All equipment used during investigation activities that could come into contact with COCs will be thoroughly cleaned before and after each use. This will be accomplished by washing with a laboratory-grade detergent and multiple rinses with deionized or distilled water. Decontamination procedures may be modified and/or revised based upon the data obtained or the field equipment used. Wash and decontamination water will be containerized in a known location per Section 4.5 of the Work Plan. The containers will be labeled and dated to reflect the contents. A composite sample will be taken and placed in laboratory-supplied containers, stored on ice, and transported to an accredited laboratory for analysis of Toxicity Characterization Leaching Procedure (TCLP) RCRA metals and ignitability, reactivity, and corrosivity (IRC), and other parameters required by the waste disposal facility for waste acceptance, following proper chain-of-custody procedures.

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6.0

DATA VALIDATION AND USABILITY This section of the QAPP provides a description of the QA activities that will occur after the data collection phase of the project is completed. Implementation of this section will determine whether the data conform to the specified criteria to satisfy the project objectives.

6.1

DATA VALIDATION AND VERIFICATION

Data validation is the process of reviewing data and accepting, qualifying, or rejecting data on the basis of sound criteria using established USEPA guidelines. The laboratory will report laboratory data generated during field investigations as Level IV data packages. Data will be subjected to full data validation conducted by a qualified chemist. The data validation process is conducted to assess the effect of the overall sampling and analysis process on the usability of the data. All analytical data will be supported by a data package. The data package contains the supporting QC data for the associated field samples. The data validation report deliverables will include the following information: A comprehensive narrative detailing all QC exceedances and explaining qualifications of data results. In cases where data are qualified due to quantifiable QC exceedances, the bias (high or low) will be identified Data summary tables in Microsoft Excel format reporting all data results with the qualifiers that were added during the data validation review. These tables will include sample ID, date sampled, units, concentration of analytes, and validation qualifiers. These tables may be modified to report other information as needed (such as depth of soil samples, date analyzed, dilution factor) Resubmittal requests sent to the laboratory indicating missing information, verification of analytical information Electronic deliverables will contain the validated results and qualifications as presented in the data summary tables of the validation reports

Before release of each data package, the laboratory must carefully review the sample and laboratory performance QC data to verify sample identity and also the completeness and accuracy of the sample and QC data. This is performed through three levels of

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laboratory data review starting with 100 percent verification performed by the laboratory analyst, followed by a second-level review performed by a peer, supervisor, or designee. The laboratory data reviewer performs the final laboratory review to assure that project requirements are met for the analyses performed.

6.1.1

DATA VALIDATION PROTOCOLS

The data validation approach will consist of a systematic review of the analytical results, associated QC methods and results, and all of the supporting data. Best professional judgment in any area not specifically addressed by USEPA guidelines will be utilized as necessary and described in the data validation report. Data will be validated according to applicable guidelines set forth in the following sources, as appropriate: USEPA Contract Laboratory Program National Functional Guidelines for Organic Data Review EPA-540-R-08-01, June 2008 USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review EPA 540-R-10-011, January 2010

Data validation will include a data completeness check of each data package, a transcription check for sample results, and a thorough review of all laboratory reporting forms and the associated raw data for QA/QC issues. Specifically, this review will include the following: Review of data package completeness Review of the required reporting summary forms and all associated raw data to determine if the QC requirements were met and to determine the effect of exceeded QC requirements on the precision, accuracy, and sensitivity of the data Review of the overall data package to determine if contractual requirements were met (based upon National Functional Guidelines) Review of raw data and all calculations associated with one sample per sample delivery group (SDG) to a minimum of 10 percent of all samples to determine if the sample results and quantitation limits were correctly calculated and reported Review of additional QA/QC parameters, such as field blank contamination, to determine technical usability of the data Application of standard data quality qualifiers to the data

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The following QA/QC parameters indicated in the National Functional Guidelines will be included in this review (as applicable): Holding times (to assess potential for degradation that could affect accuracy) GC/MS Instrument check (to assess accuracy and sensitivity of method) Initial calibration (to assess method sensitivity) Continuing calibration (to assess method sensitivity) Blanks (to assess contamination for all analytes) System Monitoring Compounds or surrogates (to assess the success of sample preparation on an individual sample basis) MS/MSD (to assess accuracy of the methods and precision of the method relative to the specific sample matrix) Matrix Duplicates (to assess precision of the method relative to the specific sample matrix) Laboratory Control Sample/Laboratory Control Sample Duplicate (to assess precision and accuracy of the method) Internal Standards (to assess method accuracy and sensitivity) Target Compound Identification Compound reporting limits and method detection limits (to assess sensitivity as compared to project-specific requirements) System Performance (to assess accuracy and precision) Field Duplicate Relative Percent Differences (RPDs) (to assess precision of the method relative to field sampling techniques, the specific sample matrix, and representativeness of the sample aliquot to the area sampled)

Assessment of analytical and in-house data will include checks on data consistency by looking for comparability of duplicate analyses, adherence to accuracy and precision control criteria detailed in this QAPP, and anomalously high or low parameter values. The results of these data validations will be reported to the project manager and the contract laboratory, noting any discrepancies and their effect upon acceptability of the data. Data validation reports will summarize the samples reviewed, parameters reviewed, any nonconformance with the established criteria, validation actions (including data

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qualifiers). Data qualifiers will be consistent with the validation guidelines and will consist of the following or similar nomenclature: J - The analyte was positively identified; the associated numerical value is the approximate concentration of the analyte in the sample. UJ - The analyte was not detected above the sample reporting limit; however, the reporting limit is approximate. U - The sample was analyzed for but was not detected above the sample reporting limit. R - The sample result is rejected due to serious deficiencies. The presence or absence of the analyte cannot be verified.

6.2

DATA VERIFICATION METHODS

The data verification process will begin once the data packages have been validated. During verification, the entire data set will be verified for overall trends in data quality and usability. Information summarized as part of the data quality verification will include frequencies of detection, dilution factors that might affect data usability, and patterns of target compound distribution. The data set will be evaluated to identify potential data limitations or uncertainties in the laboratory. The trend analysis results will be included in the validation summary report. The validation report and notes will be archived with the analytical data.

6.3

RECONCILIATION WITH USER REQUIREMENTS

Data usability is the determination of whether a data set is sufficiently complete and of sufficient quality to support a decision or action, in terms of the specific data objectives. Based on the results from the data validator, Exide will evaluate the usability of the validated data compared to the data validation criteria and objectives. The usability assessment will be based on Guidance for Data Usability in Risk Assessment (USEPA 1992) and best professional judgment. Exide will delineate deficiencies in the data, assess their effects on the reported results, and determine usability for each compound reported in each sample included in the data package. The usability assessment will provide an overall summary of data quality. It defines acceptability or problems with accuracy, precision, sensitivity, and representativeness of the results with clear guidance to the data users of the uncertainties in the data that have been qualified as estimated (J) and a quantification of these uncertainties (e.g., bias high by a maximum of 80 percent),

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CONESTOGA-ROVERS & ASSOCIATES

wherever possible. The validator may determine specific results to be unusable because of cumulative effects of QC exceedances. Alternatively, based upon the USEPA guidelines and best professional judgment, the data validator may determine specific results to be usable when they are not significantly outside the QC criteria. The final activity of the data validation process is to assess whether the data meet project objectives. The final results, as adjusted for the findings of any data validation/data evaluation, will be checked against the objectives and an assessment will be made as to whether the data are of sufficient quality to support the objectives. The decision as to data sufficiency may be affected by the overall precision, accuracy, and completeness of the data as demonstrated by the data validation process. If the data are sufficient to achieve project objectives, the project manager will release the data and work can proceed. If the data are insufficient, corrective action will be required. The project manager will determine the appropriate corrective action.

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CONESTOGA-ROVERS & ASSOCIATES

Page 1 of 1

TABLE 1 POTENTIAL CONSTITUENTS OF CONCERN SAMPLING AND ANALYSIS WORK PLAN EXIDE TECHNOLOGIES FRISCO, TEXAS TPH
Total Petroleum Hydrocarbons

Metals Antimony Arsenic Barium Beryllium Cadmium Total Chromium Lead Nickel Selenium Silver Zinc Sulfate Grain size

Other

Total dissolved solids pH (field parameter) Total organic carbon

Notes: Not all constituents will be analyzed in all media or in all areas to be investigated. Constituents potentially to be analyzed in each media in each area are set forth in the Work Plan.

CRA 029796-02 (1) APP A-Tbls

Page 1 of 1

TABLE 2 POTENTIAL ANALYTICAL PROGRAM SAMPLING AND ANALYSIS WORK PLAN EXIDE TECHNOLOGIES FRISCO, TEXAS

Analysis Soil Metals(2)

(1)

Analytical Method

(3)

SW 6010B/6020/7471A EPA Method 9056 TX 1005, TX 1006, or SW 8015 EPA Method 9045

Sulfate Total Petroleum Hydrocarbons pH (field parameter)


Sediment Metals

SW 6010B/6020/7471A ASTM D422-63

Grain size
Surface Water Metals (total and dissolved) Groundwater Metals (total and dissolved) Total Dissoved Solids Sulfate pH (field parameter only)
Notes:

SW 6010B/6020/7470A

SW 6010B/6020/7470A SM 2540C EPA Method 300.0 (IC) or SM 4500 SO4 (Colorimetric) Method 150.1

SW = SW-846 Methods - "Test Methods For Evaluating Solid Waste, Physical/Chemical Methods", 3rd Edition, November 1986 and subsequent revisions. ASTM = American Society for Testing and Materials SM = Standard Methods for the Examination of Waste and Wastewater TX = Texas Commission on Environmental Quality (TCEQ) Methods Not all constituents will be analyzed in all samples collected. Constituents potentially to be analyzed in each sample are specified in the Work Plan. Samples may also be analyzed using the Synthetic Precipitate Leaching Procedure should the soil to groundwater pathway require further evaluation.
(3) (2) (1)

Other approved methods may be utilized depending on the laboratory chosen and other circumstances.

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Page 1 of 1 TABLE 3 SUMMARY OF SAMPLE CONTAINERS, PRESERVATION, AND HOLDING TIMES SAMPLING AND ANALYSIS WORK PLAN EXIDE TECHNOLOGIES FRISCO, TEXAS
(2)

Analysis Soil Metals Sulfate

Sample Containers

Preservation

Maximum Holding Times

Shipping Means

Comments

1 - 4 ounce glass 1 - 4 ounce wide-mouth glass

Cool to 4C ( 2C) Cool to 4C ( 2C)

180 days 28 days TX 1005: 48 hours to prep or freeze and 14 days to analyze SW 8015: 14 days from collection to extraction; 14 days from extraction to analysis (or as specified by method) Field 180 days Not applicable Courier or Federal Express Courier or Federal Express

Fill completely Fill completely

Total Petroleum Hydrocarbons

1 - 4 ounce wide-mouth glass or 3 - 40 mL vials

Cool to 4C ( 2C)

Fill completely

pH (field parameter) Sediment Metals Grain size Surface Water Metals (total) Metals (dissolved) (1) Groundwater Metals (total) Metals (dissolved) (1) Total Dissoved Solids Sulfate pH (field parameter only)
Notes:
(1) (2)

4 ounce wide-mouth glass 1 - 4 ounce wide-mouth glass 1 - 8 ounce wide-mouth glass

Cool to 4C ( 2C) Cool to 4C ( 2C) Cool to 4C ( 2C) HNO3 to pH<2 Cool to 4C ( 2C) HNO3 to pH<2 Cool to 4C ( 2C) HNO3 to pH<2 Cool to 4C ( 2C) HNO3 to pH<2 Cool to 4C ( 2C) Cool to 4C ( 2C) Cool to 4C ( 2C) Not applicable

Not applicable Fill completely Fill completely

1 - 500 mL plastic 1 - 500 mL plastic

180 days 180 days

Courier or Federal Express

Fill to neck Fill to neck

1-500 mL plastic 1-500 mL plastic 1-500 mL plastic 1-250 mL wide-mouth plastic 125 ounce plastic

180 days 180 days 7 days to analysis 28 days to analysis Field Courier or Federal Express

Fill to neck Fill to neck Fill to neck Fill to neck Not applicable

Samples for dissolved metals analysis will be filtered in the field. Containers may vary slightly depending on analytical laboratory.

mL = milliliter HNO3 = nitric acid


CRA 029796-02 (1) APP A-Tbls

Page 1 of 1

TABLE 4 FIELD QUALITY CONTROL SAMPLES SAMPLING AND ANALYSIS WORK PLAN EXIDE TECHNOLOGIES FRISCO, TEXAS Type of Quality Control Sample Equipment rinsate blank Matrix spike/matrix spike duplicate (MS/MSD) Field blank 1 per day per equipment type Frequency SW-846 Acceptance Criteria

1 per 20 field samples for surface water, sediment, and groundwater

SW-846

1 per day per equipment type for volatile organics

SW-846 Laboratory-established relative percent difference (RPD) SW-846

Field duplicate

1 per 20 groundwater and/or surface water samples

Trip blanks

1 per cooler with volatile organics

SW-846 = "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," 3rd Ed., November 1986 and subsequent revisions.

CRA 029796-02 (1) APP A-Tbls

APPENDIX B HISTORICAL GROUNDWATER GRADIENT MAP

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APPENDIX C MONITOR WELL CONSTRUCTION DETAILS

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APPENDIX D ECOLOGICAL ASSESSMENT CHECKLIST AND ECOLOGICAL EXCLUSION CRITERIA WORKSHEET

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Region 6 Corrective Action Strategy (CAS)

Appendix B

APPENDIX B ECOLOGICAL EXCLUSION SCREENING

ECOLOGICAL EXCLUSION CRITERIA WORKSHEET AND ECOLOGICAL ASSESSMENT CHECKLIST

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Ecological Screening Introduction

Appendix B

Region 6 is providing an Ecological Exclusion Criteria Worksheet and Ecological Assessment Checklist to help facilities and regulators determine whether or not further ecological evaluation is necessary at an affected property where corrective action is being pursued. Chapter 2 of the CAS provides additional information on the Ecological Screening process. Ecological screening under the CAS is a relatively simple process. It involves; 1) collecting general information about the facility, its operation, physical site characteristics, ecological habitats and receptors utilizing the Ecological Exclusion Criteria Worksheet and determining if incomplete or insignificant exposure pathways exist at the affected property that eliminate the need for further ecological evaluation, and 2) if an area cannot be excluded from further evaluation, collecting more detailed information about ecological areas utilizing the Ecological Assessment Checklist to assist in further ecological risk evaluations. If the affected property meets the exclusion criteria, then the facility should document the site conditions and justification for how the criteria have been met within the risk evaluation report. Upon review and approval of the exclusion by the administrative authority, the facility will not be required to conduct any further evaluation of ecological risk. If the affected property does not meet the exclusion criteria, then further evaluation is warranted and the facility should address the conduct of additional activities (screening level or detailed risk assessment, interim measures) within the risk management plan. Additional ecological risk screening/assessment should be conducted following EPAs Risk Assessment Guidance for Superfund: Process for Designing and Conducting Ecological Risk Assessments dated June 5, 1997 and Guidelines for Ecological Risk Assessment (EPA/630/R-95/002F) dated April 1998 or a state approved guidance for ecological risk evaluation. Natural Resources Trustees should also be notified to see if they choose to participate, in order to ensure that natural resources under their jurisdiction are adequately protected. Additional references and sources of information to aid further ecological assessment follows: U.S. EPA. 1999. Ecological Risk Assessment and Risk Management Principles for Superfund Sites, Final. OSWER Directive 9285.7-28 P. http://www.epa.gov/superfund/programs/risk/ecorisk/ final99.pdf U.S. EPA. 1999. ECOTOX Version 2.0. Office of Research and Development, National; Health and Environmental Effects Lab, Mid-Continent Ecology Division. http://www.epa.gov/ecotox U.S. EPA. 1998. Guidelines for Ecological Risk Assessment, Final. EPA/630/R95/002F. http://www.epa.gov/ncea/ecorsk.htm U. S. EPA. 1997. Ecological Risk Assessment Guidance for Superfund, Process for Designing and Conducting Ecological Risk Assessments, Interim Final. EPA 540-R-97006, OSWER Directive # 9285.7-25.

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Appendix B

http://www.epa.gov/superfund/programs/risk/ecorisk/ecorisk.htm U.S. EPA. 1996. ECOTOX Thresholds. ECO Update, Interim Bulletin, Volume 3, Number 2. Washington, D.C. Office of Emergency and Remedial Response, Hazardous Site Evaluation Division; Publication 9345.0-12Fsi EPA/540/F-95/038; NTIS PB95963324. U.S. EPA. 1996. Ecological Significance and Selection of Candidate Assessment Endpoints. ECO Update, Interim Bulletin, Volume 3, Number 1. Washington, D.C. Office of Emergency and Remedial Response, Hazardous Site Evaluation Division; Publication 9345.0-11Fsi; EPA/540/F-95/037; NTIS PB95-963323. U.S. EPA. 1994. Selecting and Using Reference Information in Superfund Risk Assessments. ECO Update, Interim Bulletin, Volume 2, Number 4. Washington, D.C. Office of Emergency and Remedial Response, Hazardous Site Evaluation Division; Publication 9345.10; EPA/540/F-94/050; NTIS PB94-963319. U.S. EPA. 1994. Field Studies for Ecological Risk Assessment. ECO Update, Interim Bulletin, Volume 2, Number 3. Washington, D.C. Office of Emergency and Remedial Response, Hazardous Site Evaluation Division; Publication 9345.05I; EPA/540/F-94/014; NTIS PB94-963305. U.S. EPA. 1994. Catalogue of Standard Toxicity Tests for Ecological Risk Assessment. ECO Update, Interim Bulletin, Volume 2, Number 2. Washington, D.C. Office of Emergency and Remedial Response, Hazardous Site Evaluation Division; Publication 93450-05I; EPA/540/F-94/013; NTIS PB94-963304. U.S. EPA. 1994. Using Toxicity Tests in Ecological Risk Assessment. ECO Update, Interim Bulletin, Volume 2, Number 1. Washington, D.C. Office of Emergency and Remedial Response, Hazardous Site Evaluation Division; Publication 9345.05I; EPA/540/F-94/012; NTIS PB94-963303. U.S. EPA. 1992. Briefing the BTAG: Initial Description of Setting, History and Ecology of a Site. ECO Update, Interim Bulletin, Volume 1, Number 5. Washington, D.C. Office of Emergency and Remedial Response, Hazardous Site Evaluation Division; Publication 9345.0-05I. U.S. EPA. 1992. Developing a Work Scope for Ecological Assessments. ECO Update, Interim Bulletin, Volume 1, Number 4. Washington, D.C. Office of Emergency and Remedial Response, Hazardous Site Evaluation Division; Publication 9345.005I. U.S. EPA. 1992. The Role of the Natural Resource Trustees in the Superfund Process. ECO Update, Interim Bulletin, Volume 1, Number 3. Washington, D.C. Office of Emergency and Remedial Response, Hazardous Site Evaluation Division; Publication 9345.0-05I. U.S. EPA. 1991. Ecological Assessment of Superfund Sites: An Overview. ECO Update, Interim Bulletin, Volume 1, Number 2. Washington, D.C. Office of Emergency and Remedial Response, Hazardous Site Evaluation Division; Publication 9345-0-05I. U.S. EPA. 1991. The Role of BTAGs in Ecological Assessment. ECO Update, Interim Bulletin, Volume 1, Number 1. Washington, D.C. Office of Emergency and Remedial Response, Hazardous Site Evaluation Division; Publication 9345-0-05I.

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ECOLOGICAL EXCLUSION CRITERIA WORKSHEET

Appendix B

The Exclusion Criteria Worksheet is intended to aid facilities and regulators in determining whether or not further ecological evaluation is necessary at an affected property where a response action is being pursued utilizing the CAS. Exclusion criteria refer to those conditions at an affected property which preclude the need for a formal ecological risk assessment (ERA) because there are incomplete or insignificant ecological exposure pathways due to the nature of the affected property setting and/or the condition of the affected property media. The person completing the worksheet should be familiar with the affected property but need not be a professional scientist in order to respond, although some questions will likely require contacting a wildlife management agency (U.S. Fish and Wildlife Service, etc.). The worksheet is designed for general applicability to all affected property; however, there may be unusual circumstances which require professional judgement in order to determine the need for further ecological evaluation (e.g., cave-dwelling receptors). In these cases, it is strongly encouraged to contact your state regulatory agency for additional guidance before proceeding. The worksheet consists of three major parts. Part 1, identification of the affected property and background information, Part 2, the actual exclusion criteria and supportive information, and Part 3, a qualitative summary statement and certification of the information submitted. Answers to the worksheet should reflect existing conditions and should not consider future remedial actions at the affected property. Completion of the worksheet should lead to a logical conclusion as to whether further ecological evaluation is warranted. Definitions of terms used in the worksheet are provided and users are encouraged to review these definitions before completing the worksheet. The Exclusion Worksheet has been adapted from and follows the Texas Natural Resources Conservation Commission (TNRCC) Texas Risk Reduction Program (TRRP) Tier 1 Checklist. TNRCC has developed some additional information regarding the use of their Tier 1 Checklist which should also be consulted in completing the CAS Ecological Exclusion Criteria Worksheet. This information can be found in Chapter 2 of TNRCCs Guidance for Conducting Ecological Risk Assessments at Remediation Sites in Texas, Draft Final, August 2000; http://www.tnrcc.state.tx.us/permitting/remed/techsupp/erag8_00.pdf

Part 1. Affected Property Identification and Background Information 1) Provide a description of the specific area of the response action and the nature of the release. Include estimated acreage of the affected property and the facility property, and a description of the type of facility and/or operation associated with the affected property. Also describe the location of the affected property with respect to the facility property boundaries and public roadways. ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ Attach available USGS topographic mas and/or aerial or other affected property photographs to this form to depict the affected property and surrounding area.

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_____ Topo map 2) _____ Aerial photo

Appendix B
_____ Other _____________

Identify the environmental media known or suspected to contain chemicals of concern (COCs) at the present time. Check all that apply: Known/Suspected COC Location _____ Soil < 5 ft below ground surface _____ Soil > 5 ft below ground surface _____ Groundwater _____ Surface Water/Sediments Based on sampling data? _____ Yes _____ No _____ Yes _____ No _____ Yes _____ No _____ Yes _____ No

Explain (previously collected information may be referenced): ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ 3) Provide the information below for the nearest surface water body which has become or has the potential to become impacted from migrating COCs via surface water runoff, air deposition, groundwater seepage, etc. Exclude: wastewater treatment facilities and stormwater conveyances/impoundments authorized by permit. Also exclude: conveyances, decorative ponds, and those portions of the process facilities which are: a. Not in contact with surface waters of the State or other surface waters which are ultimately in contact with surface waters of the State; and Not consistently or routinely utilized as valuable habitat for natural communities including birds, mammals, reptiles, etc.

b.

The nearest surface water body is ______________ feet/miles from the affected property. The surface water body is named ____________________________________________ The surface water body is best described as a: _____ Freshwater stream: _____ perennial (has water year round) _____ intermittent (dries up completely for at least one week per year) _____ intermittent with perennial pools

_____ Freshwater swamp/marsh/wetland

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Appendix B

_____ Saltwater or brackish swamp/marsh/wetland _____ Reservoir, lake or pond; approximate surface acres ________________________ _____ Drainage ditch _____ Tidal stream _____ Other (specify) _____________________________________________________

Is the water body listed as a State classified segment? _____ Yes Segment # ______________ Use classification: ______________________ _____ No If the water body is not a State classified segment, identify the first downstream classified segment. Name: _________________________________________________________________ Segment #: _____________________________________________________________ Use classification ________________________________________________________ As necessary, provide further description of surface waters in the vicinity of the affected property: ________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________

Part 2. Exclusion Criteria and Supportive Information Subpart A. Surface Water/Sediment Exposure 1) Regarding the affected property where a response action is being pursued, have COCs migrated and resulted in a release or imminent threat of release to either surface waters or to their associated sediments via surface water runoff, air deposition, groundwater seepage, etc. Exclude: wastewater treatment facilities and stormwater conveyances/impoundments authorized by permit. Also exclude: conveyances, decorative ponds, and those portions of the process facilities which are: a. Not in contact with surface waters of the State or other surface waters which are ultimately in contact with surface waters of the State; and Not consistently or routinely utilized as valuable habitat for natural communities including birds, mammals, reptiles, etc. _____ No

b.

_____ Yes

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Appendix B

Explain: __________________________________________________________ _________________________________________________________________ _________________________________________________________________ _________________________________________________________________ If the answer is Yes to Subpart A above, the affected property does not meet the exclusion criteria. (However, complete the remainder of Part 2, to determine if there is a complete and/or significant soil exposure pathway, then complete Part 3, Qualitative Summary and Certification). If the answer is No to Subpart A above, go to Subpart B.

Subpart B. Affected Property Setting In answering Yes to the following question, it is understood that the affected property is not attractive to wildlife or livestock, including threatened or endangered species (i.e., the affected property does not serve as valuable habitat, foraging area, or refuge for ecological communities). May require consultation with management agencies. 1). Is the affected property wholly contained within contiguous land characterized by: pavement, buildings, landscaped area, functioning cap, roadways, equipment storage area, manufacturing or process area, or other surface cover or structure, or otherwise disturbed ground? _____ Yes _____ No Explain: ________________________________________________________________ _______________________________________________________________________ _______________________________________________________________________ _______________________________________________________________________ If the answer is Yes to Subpart B above, the affected property meets the exclusion criteria, assuming the answer to Subpart A was No. (Skip Subparts C and D and complete Part 3, Qualitative Summary and Certification). If the answer is No to Subpart B above, go to Subpart C.

Subpart C. Soil Exposure 1) Are COCs which are in the soil if the affected property solely below the first 5 feet beneath ground surface or does the affected property have a physical barrier present to prevent exposure to receptors to COCs in the surface soil? _____ Yes _____ No Explain: ________________________________________________________________

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Appendix B

_______________________________________________________________________ _______________________________________________________________________ If the answer is Yes to Subpart C above, the affected property meets the exclusion criteria, assuming the answer to Subpart A was No. (Skip Subpart D and complete Part 3, Qualitative Summary and Certification). If the answer is No to Subpart C above, go to Subpart D.

Subpart D. DeMinimus Land Area In answering Yes to the question below, it is understood that all of the follow conditions apply: The affected property is not known to serve as habitat, foraging area, or refuge to threatened/endangered or otherwise protected species. (Will likely require consultation with wildlife management agencies). Similar but unimpacted habitat exists within a half-mile radius. The affected property is not know to be located within one-quarter mile of sensitive environmental areas (e.g., rookeries, wildlife management areas, preserves). (Will likely require consultation with wildlife management agencies). There is no reason to suspect that the COCs associated with the affected property will migrate such that the affected property will become larger than one acre.

Using human health protective concentration levels as a basis to determine the extent of the COCs, does the affected property consist of one acre or less and does it meet all the conditions described above? _____ Yes _____ No

Explain how the conditions are/are not met: ____________________________________ _______________________________________________________________________ _______________________________________________________________________ If the answer is Yes to Subpart D, then no further ecological evaluation is needed at the affected property, assuming the answer to Subpart A was No. (Complete Part 3, Qualitative Summary and Certification). If the answer is No to Subpart D, Proceed to an Ecological Risk Evaluation. Part 3. Qualitative Summary and Certification (Complete in all cases) Attach a brief statement (1 page or less) summarizing the information you have provided in this form. This summary should include sufficient information to verify that the affected property meets or does not meet

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Appendix B

the exclusion criteria. The facility should make the initial decision regarding the need to conduct further ecological evaluation based on the results of this worksheet. However, the State will make a final determination on the need for further ecological assessment. Note : the facility has the continuing obligation to re-enter the ERA process if changing circumstances result in the affected property not meeting the exclusion criteria requirements presented in this worksheet.

Completed by: _________________________________________ (Typed Name) _________________________________________ (Title) _________________________________________ (Date) I believe that the information submitted is true, accurate, and complete, to the best of my knowledge. _________________________________________ (Typed Name of Person) _________________________________________ (Title of Person) _________________________________________ (Signature of Person) _________________________________________ (Date Signed)

Definitions (applicable to Exclusion Worksheet) Affected property - The entire area (i.e., on-site and off-site; including all environmental media) which contains releases of chemicals of concern at concentrations equal to or greater than the assessment level applicable for the land use (i.e., residential or commercial/industrial) and groundwater classification. Assessment level - a critical protective concentration level for a chemical of concern used for affected property assessments where the human health protective concentration level is established by State regulation or guidance . Bedrock - the solid rock (i.e., consolidated, coherent, and relatively hard naturally formed material that cannot normally be excavated by manual methods alone) that underlies gravel, soil, or other surficial material. Chemicals of concern - any chemical that has the potential to adversely affect ecological or human receptors due to its concentration, distribution, and mode of toxicity. Community - an assembledge of plant and animal populations occupying the same habitat in which the various species interact via spatial and trophic relationships (e.g., a desert community or a pond community). Complete exposure pathway - an exposure pathway where a human or ecological receptor is exposed to a chemical of concern via an exposure route (e.g., incidental soil ingestion, inhalation of volatiles and particulates, consumption of prey, etc).

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Appendix B

De Minimus - the description of an area of affected property comprised of one acre or less where the ecological risk is considered to be insignificant because the small extent of contamination, the absence of protected species, the availability of similar unimpacted habitat nearby, and the lack of adjacent sensitive environmental areas. Ecological protective concentration level - the concentration of a chemical of concern at the point of exposure within an exposure medium (e.g., soil, sediment, groundwater, or surface water) which is determined to be protective for ecological receptors. These concentration levels are intended to be protective for more mobile or wide-ranging ecological receptors and, where appropriate benthic invertebrate communities within waters of the State. These concentration levels are not intended to be directly protective of receptors with limited mobility or ranges (e.g., plants, soil invertebrates, and small rodents), particularly those residing within active areas of a facility, unless these receptors are threatened/endangered species or unless impacts to these receptors result in disruption of the ecosystem or other unacceptable consequences fo the more mobile or wide-ranging receptors (e.g., impacts to an off-site grassland habitat eliminate rodents which causes a desirable owl population to leave the area). Ecological risk assessment - a process that evaluates the likelihood that adverse ecological effects may occur or are occurring as a result of exposure to one or more stressors; however, as used in this context, only chemical stressors (i.e., COCs) are evaluated. Environmental medium - a material found in the natural environment such as soil, (including non-waste fill materials), groundwater, air, surface water, and sediments, or a mixture of such materials with liquids, sludges, gasses or solids, including hazardous waste which is inseparable by simple mechanical removal processes, and is made up of primarily of natural environmental material. Exclusion criteria - those conditions at an affected property which preclude the need to establish a protective concentration level for an ecological exposure pathway because the exposure pathway between the chemical of concern and the ecological receptors is not complete or is insignificant. Exposure medium - the environmental medium or biological tissue in which or by which exposure to chemicals of concern by human or ecological receptors occurs. Facility - the installation associated with the affected property where the release of chemicals of concern have occurred. Functioning cap - a low permeability layer or other approved cover meeting its design specifications to minimize water infiltration and chemical of concern migration, and prevent ecological or human receptor exposure to chemical of concern, where design requirements are routinely maintained. Landscaped area - an area of ornamental, or introduced, or commercially installed, or manicured vegetation, which is routinely maintained. Off-site property - all environmental media which is outside the legal boundaries of the on-site property. On-site property - all environmental media within the legal boundaries of a property that has become

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subject to corrective action, either through voluntary action, permit or order.

Appendix B

Physical barrier - any structure or system, natural or manmade, that prevents exposure or prevents physical migration of chemicals of concern to points of exposure. Point of exposure - the location within an environmental medium where a receptor will be assumed to have a reasonable potential to come into contact with chemicals of concern. The point of exposure may be a discrete point, plane, or an area within or beyond some location. Protective concentration level - the concentration of a chemical of concern which can remain within the source medium and not result in levels which exceed the applicable human health risk based exposure limit considering cumulative risk and hazard index for both carcinogenic and non-carcinogenic effects respectively, or ecological protective concentration level at the point of exposure for that exposure pathway. Release - any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment, with the exception of: a release that results in an exposure to a person solely within a workplace, concerning a claim that the person may assert against the persons employer; an emission from the engine exhaust of a motor vehicle, rolling stock, aircraft, vessel, pipeline pumping station engine; a release of source, by product, or special nuclear material a nuclear incident, as those terms identified by the Atomic Energy Act of 1954, as amended (42 USC 2201 et. seq.); if the release area is subject to requirements concerning financial protection established by the Nuclear Regulatory Commission under Section 170 of that Act; for the purpose of the environmental response law Section 104, as amended, or other response action, release of source, by-product, or special nuclear material from a processing site designated under Section 102(a)(1) for Section 302(a) of the Uranium Mill Tailings Radiation Control Act of 1978 (42 USC Section 7912 and Section 7942) as amended; and the normal application of fertilizer.

Sediment - non-suspended particulate material lying below surface waters such as bays, the ocean, rivers, streams, lakes, ponds, or other similar surface water body (including intermittent streams). Dredged sediments which have been removed from surface water bodies and placed on land shall be considered soils. Sensitive environmental areas - areas that provide unique and often protected habitat for wildlife species. These areas are typically used during critical life stages such as breeding, hatching, rearing of young, and overwintering. Examples include; critical habitat for threatened and endangered species, wilderness areas, parks and wildlife refuges. Source medium - an environmental medium containing chemicals of concern which must be removed, decontaminated and/or controlled in order to protect human health and the environment. The source medium may be the exposure medium for some exposure pathways.

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Appendix B

Stressor - any physical, chemical, or biological entity that can induce an adverse response; however, as used in this context, only chemical entities apply. Subsurface soil - for human health exposure pathways, the portion of the soil zone between the base of the surface soil and the top of the groundwater-bearing unit(s). For ecological exposure pathways, the portion of the soil zone between 0.5 feet and 5 feet in depth. Surface cover - a layer of artificially placed utility material (e.g., shell, gravel). Surface soil - for human health exposure pathways, the soil zone extending from ground surface to 15 feet in depth for residential land use and from ground surface to 5 feet in depth for commercial/industrial land use; or to the top of the uppermost groundwater-bearing unit or bedrock, whichever is less in depth. For ecological exposure pathways, the soil zone extending from ground surface to 0.5 feet in depth. Surface water - any water meeting the definition of surface water as defined by the authorized State.

ECOLOGICAL ASSESSMENT CHECKLIST The evaluation associated with the checklist is intended to be a screening-level survey of the developed and undeveloped/ecological portions of the site. The checklist is patterned after ERAGS Appendix A - Checklist for Ecological Assessment/Sampling, June 1997 and consists of five major sections: 1 - Site Description, 2 - Terrestrial Habitat Checklist, 3 - Aquatic Habitat Checklist (non-flowing systems), 4 - Aquatic Habitat Checklist (flowing systems), and 5 - Wetlands Habitat Checklist. Answers to the checklist should reflect existing conditions and should not consider future remedial actions at the site.

In general, the checklist is designed for applicability to all sites, however, there may be unusual circumstances which require professional judgement in order to determine the need for further ecological evaluation. Sources and general information available for the identification of ecological receptors and habitats may include: the U.S. Fish and Wildlife Service (http://www.fws.gov), State Game and Fish Conservation Services, United States Geological Service (USGS), National Wetland Inventory Maps (http://nwi.fws.gov) National Audubon Society, National Biological Survey, national and local wildlife clubs, National and State Heritage Programs, State and National Parks System, and tribal organizations. Section 1. 1. Site Site Description Name:_______________________________________________________________

Location:______________________________________________________________________ _______________________________________________________________________ County/Parish:_____________________ City:_______________________ State:_____________ Type of Facility: _________________________________________________________________

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2. 3. 4. Latitude:______________________

Appendix B
Longitude:________________________

What is the approximate area of the site?_____________________________________________ Is this the first site visit? Yes _____ No _____. If no, attach trip report of previous site visit(s), if available. Date(s) of previous site visit(s):______________________________ Please attach to the checklist USGS topographic map(s) of the site, if available. Are aerial or other site photographs available? Yes ____ No ____. If yes, please attach any available photo(s) to the site map at the conclusion of this section. The land use on the site is: _____ % Urban _____ % Rural _____ % Residential _____ % Industrial __ light __ heavy _____ % Agriculture (Crops: _______________________) _____ % Recreational (Describe; note if it is a park, etc.) ______________________________ ______________________________ _____ % Undisturbed _____ % Other The area surrounding the site is: ________________ mile radius _____ % Urban _____ % Rural _____ % Residential _____ % Industrial __ light __ heavy _____ % Agriculture (Crops: ______________________) _____ % Recreational (Describe; note if it is a park, etc.) _____________________________ _____________________________ _____ % Undisturbed _____ % Other

5. 6.

7.

8.

Has any movement of soil taken place at the site? Yes ___ No ___. If yes, please identify the most likely cause of this disturbance: _____ Agricultural Use _____ Heavy Equipment _____ Mining _____ Natural Events _____ Erosion _____ Other Please describe: _________________________________________________________________ ______________________________________________________________________________

9. Do any potentially sensitive environmental areas exist adjacent to or in proximity to the site, e.g., Federal and State parks, National and State Monuments, wetlands, prairie potholes? Remember, flood plains and wetlands are not always obvious; do not answer no without confirming information. ______________________________________________________________________________ ______________________________________________________________________________ 10. What type of facility is located at the site? _____ Chemical_____ Manufacturing _____ Mixing _____ Waste Disposal _____ Other (specify) ____________________________________________________________

B-13

Region 6 Corrective Action Strategy (CAS)

Appendix B

11. What are the suspected contaminants of concern at the site? If known, what are their maximum concentration levels? ____________________________________________________________ ______________________________________________________________________________ 12. Check any potential routes of off-site migration of contaminants observed at the site: _____ Swales _____ Depressions _____ Drainage ditches _____ Runoff _____ Windblown particulate _____ Vehicular traffic _____ Other (specify) ____________________________________________________________ 13. If known, what is the approximate depth to the water table? __________________________ 14. Is the direction of surface runoff apparent from site observations? Yes ___ No ___. If yes, to which of the following does the surface runoff discharge? Indicate all that apply. _____ Surface water _____ Groundwater _____ Sewer _____ Collection impoundment 15. Is there a navigable waterbody or tributary to a navigable waterbody? Yes ___ No ___. ______________________________________________________________________________ 16. Is there a waterbody anywhere on or in the vicinity of the site? If yes, also complete Section 3: Aquatic Habitat Checklist - non-flowing systems and /or Section 4: Aquatic Habitat Checklist - flowing systems. Yes ____ (approximate distance ________________) No _____. 17. Is there evidence of flooding? Yes _____ No _____. Wetlands and flood plains are not always obvious; do not answer no without confirming information. If yes, complete Section 5: Wetland Habitat Checklist. _____________________________________________________________________ ______________________________________________________________________________ 18. If a field guide was used to aid any of the identifications, please provide a reference. Also, estimate the time spent identifying the fauna. (Use a blank sheet if additional space is needed for text). ______________________________________________________________________________ ______________________________________________________________________________ 19. Are any threatened and/or endangered species (plant or animal) known to inhabit the area of the site? Yes _____ No _____. If yes, you are required to verify this information with the U.S. Fish and Wildlife Service. If species identities are known, please list them in the text. ________________________________ ______________________________________________________________________________ 20. Record weather conditions at the time this checklist was prepared: Date: _________________ ____________ Temperature (0C /0F) ___________ Normal daily high temperature ____________ Wind (direction/speed) ___________ Precipitation (rain,snow) ____________ Cloud cover Section 1A. Summary of Observations and Site Setting ______________________________________________________________________________ ______________________________________________________________________________

B-14

Region 6 Corrective Action Strategy (CAS)

Appendix B

______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ Completed by _______________________________ Affiliation _________________________ Additional Preparers _____________________________________________________________ Site Manager ___________________________________________________________________ Date _______________________

Section 2. Terrestrial Habitat Checklist Section 2A. Wooded 1. Are there any wooded areas on the site? Yes _____ No _____. If no, go to Section IIB: Shrub/Scrub. 2. What percentage of the area of the site is wooded? (_____ % _____ acres). Indicate the wooded area on the site map which is attached to a copy of this checklist. Please identify what information was used to determine the wooded area of the site. _______________________________________________ ______________________________________________________________________________ 3. What is the dominant type of vegetation in the wooded area? (Circle one: Evergreen/Deciduous/Mixed) Provide a photograph if available. Dominant plant, if known: ________________________________________________________ 4. What is the predominant size of the trees at the site? Use diameter at breast height. _____ 0-6 inches _____ 6-12 inches _____ > 12 inches 5. Specify type of understory present, if known. Provide a photograph, if available. __________ ______________________________________________________________________________ ______________________________________________________________________________ Section 2B. Shrub/scrub 1. Is shrub/scrub vegetation present at the site? Yes _____ No _____. If no, go to Section IIC: Open Field. 2. What percentage of the site is covered by shrub/scrub vegetation? ( ______ % _____ acres). Indicate the acres of shrub/scrub on the site map. Please identify what information was used to determine this area. ______________________________________________________________________________ ______________________________________________________________________________ 3. What is the dominant type of shrub/scrub vegetation, if known? Provide a photograph if available. ______________________________________________________________________

B-15

Region 6 Corrective Action Strategy (CAS)


4. What is the approximate average height of the shrub/scrub vegetation? _____ 0-2 feet _____ 2-5 feet _____ > 5 feet 5. Based on site observations, how dense is the shrub/scrub vegetation? _____ Dense _____ patchy _____ Sparse Section 2C. Open Field

Appendix B

1. Are there open (bare, barren) field areas present at the site? Yes _____ No _____. If yes, please indicate the type below: _____ Prairie/plains _____ Savannah _____ Old field _____ Other (specify) _______ ______________________________________________________________________________ 2. What percentage of the site is open field? (_____ % _____ acres). Indicate the open field areas on the site map. 3. What is/are the dominant plant plants? Provide a photograph if available. ________________ ______________________________________________________________________________ 4. What is the approximate average height of the dominant plant? _________________________ 5. Describe the vegetation cover: _____ Dense Section 2D. Miscellaneous 1. Are other types of terrestrial habitats present at the site, other than woods, shrub/scrub, and open field? Yes _____ No _____. If yes, identify and describe below. _______________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 2. Describe the terrestrial miscellaneous habitat(s) and identify these areas on the site map. 3. What observations, if any, were made at the site regarding the presence and/or absence of insects, fish, birds, mammals, etc? _____________________________________________________________ ______________________________________________________________________________ 4. Review the questions in Section I to determine if any additional habitat checklists should be completed for this site. ____________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ _____ Sparse _____ Patchy

B-16

Region 6 Corrective Action Strategy (CAS)


Section 3. Aquatic Habitat Checklist Non-flowing Systems

Appendix B

Note: Aquatic systems are often associated with wetland habitats. Please refer to Section 5, Wetland Habitat Checklist. 1. What type of open-water, non-flowing system is present at the site? _____ Natural (pond or lake) _____ Artificially created (lagoon, reservoir, canal, impoundment) 2. If known, what is the name(s) of the waterbody(ies) on or adjacent to the site? ______________________________________________________________________________ 3. If a waterbody is present, what are its known uses (e.g., recreation, navigation, etc.)? ______________________________________________________________________________ 4. What is the approximate size of the waterbody(ies)? _______________________ acre(s). 5. Is any aquatic vegetation present? Yes _____ No _____. If yes, please identify the type of vegetation present, if known. _____ Emergent _____ Submergent _____ Floating 6. If known, what is the depth of the water? __________________________________________ 7. What is the general composition of the substrate? Check all that apply. _____ Bedrock _____ Sand _____ Muck (fine/black) _____ Boulder (>10 in.) _____ Silt (fine) _____ Debris _____ Cobble (2.5-10 in.) _____ Marl (shells) _____ Detritus _____ Gravel (0.1-2.5 in.) _____ Clay (slick) _____ Concrete _____ Other (specify) ____________________________________________________________ 8. What is the source of water in the waterbody? _____ River/Stream/Creek _____ Groundwater _____ Industrial discharge _____ Surface runoff

_____ Other (specify) __________________

9. Is there a discharge from the site to the waterbody? Yes _____ No _____. If yes, please describe this discharge and its path. ________________________________________________________ ______________________________________________________________________________ 10. Is there a discharge from the waterbody? Yes _____ No _____. If yes, and the information is available, identify from the list below the environment into which the waterbody discharges. _____ River/Stream/Creek _____ onsite offsite _____ Distance _________________ _____ Groundwater _____ onsite offsite _____ _____ Wetland _____ onsite offsite _____ Distance _________________ _____ Impoundment _____ onsite offsite _____

B-17

Region 6 Corrective Action Strategy (CAS)

Appendix B

11. Identify any field measurements and observations of water quality that were made. For those parameters for which data were collected provide the measurement and the units of measure below: __________ Area __________ Depth (average) __________ pH __________ Dissolved oxygen __________ Salinity __________ Turbidity (clear, slightly turbid, turbid, opaque) (Secchi disk depth _____) __________ Other (specify) 12. Describe observed color and area of coloration. ____________________________________ ______________________________________________________________________________ 13. Mark the open-water, non-flowing system on the site map attached to this checklist. 14. What observations, if any were made at the waterbody regarding the presence and/or absence of benthic macroinvertebrates, fish, birds mammals, etc.? _______________________________________ ______________________________________________________________________________ ______________________________________________________________________________

Section 4. Aquatic Habitat Checklist Flowing Systems Note: Aquatic systems are often associated with wetland habitats. Please refer to Section 5, wetland Habitat Checklist. 1. What type(s) of flowing water system(s) is (are) present at the site? _____ River _____ Stream _____ Creek _____ Dry wash _____ Arroyo _____ Brook _____ Artificially created _____ Intermittent stream _____ Channeling (ditch, etc,) _____ Other (specify) _________________________________ 2. If known, what is the name of the waterbody? ______________________________________ 3. For natural systems, are there any indicators of physical alteration (e.g., channeling, debris, etc.)? Yes _____ No _____. If yes, please describe indicators that were observed. _________________ ______________________________________________________________________________ ______________________________________________________________________________

4. What is the general composition of the substrate? Check all that apply. _____ Bedrock _____ Sand _____ Muck (fine/black) _____ Boulder (>10 in.) _____ Silt (fine) _____ Debris _____ Cobble (2.5-10 in.) _____ Marl (shells) _____ Detritus _____ Gravel (0.1-2.5 in.) _____ Clay (slick) _____ Concrete _____ Other (specify) ____________________________________________________________

B-18

Region 6 Corrective Action Strategy (CAS)

Appendix B

5. What is the condition of the bank (e.g., height, slope, extent of vegetative cover)? __________ ______________________________________________________________________________ ______________________________________________________________________________ 6. Is the system influenced by tides? Yes _____ No _____. What information was used to make this determination? _________________________________________________________________ ______________________________________________________________________________ 7. Is the flow intermittent? Yes _____ No _____. If yes, please note the information that was used in making this determination. ________________________________________________________ ______________________________________________________________________________ 8. Is there a discharge from the site to the waterbody? Yes _____ No _____. If yes, please describe the discharge and its path. ___________________________________________________________ ______________________________________________________________________________ 9. Is there a discharge from the waterbody? Yes _____ No _____. If yes, and the information is available, please identify what the waterbody discharges to and whether the discharge in onsite or off site. _____________________________________________________________________________ _____________________________________________________________________________ 10. Identify any field measurements and observations of water quality that were made. For those parameters for which data were collected, provide the measurement and the units of measure in the appropriate space below: __________ Width (feet) __________ Depth (feet) __________ Velocity (specify units) __________ Temperature (depth of the water at which the temperature was taken) __________ pH __________ Dissolved oxygen __________ Salinity __________ Turbidity (clear, slightly turbid, turbid, opaque) (Secchi disk depth ______________________) __________ Other (specify) ______________________________________________ 11. Described observed color and area of coloration. ___________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 12. Is any aquatic vegetation present? Yes _____ No _____. If yes, please identify the type of vegetation present, if known. _____ Emergent _____ Submergent _____ Floating 13. Mark the flowing water system on the attached site map.

B-19

Region 6 Corrective Action Strategy (CAS)

Appendix B

14. What observations were made at the waterbody regarding the presence and/or absence of benthic macroinvertebrates, fish, birds, mammals, etc.? ______________________________________ _____________________________________________________________________________ _____________________________________________________________________________

Section 5. Wetland Habitat Checklist 1. Based on observations and/or available information, are designated or know wetlands definitely present at the site? Yes _____ No _____. Please note the sources of observations and information used (e.g., USGS Topographic maps, National Wetland Inventory, Federal or State Agency, etc.) to make this determination. ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 2. Based on the location of the site (e.g., along a waterbody, in a floodplain) and site conditions (e.g., standing water; dark, wet soils; mud cracks; debris line; water marks), are wetland habitats suspected? Yes _____ No _____. If yes, proceed with the remainder of the wetland habitat identification checklist. 3. What type(s) of vegetation are present in the wetland? _____ Submergement _____ Emergent _____ Shrub/scrub _____ Wooded _____ Other (specify) _____________________________ 4. Provide a general description of the vegetation present in and around the wetland (height, color, etc.). Provide a photograph of the known or suspected wetlands, if available. _____________________ ______________________________________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ 5. Is standing water present. Yes ____ No ____. If yes, is this water: Fresh _____ Brackish _____ What is the approximate area of the water (sq. ft.)? _____________________________________ Please complete questions 4, 11, 12 in Checklist 3 - Aquatic Habitat -- Non-Flowing Systems. 6. Is there evidence of flooding at the site? What observations were noted? _____ Buttressing _____ Water marks _____ Mud cracks _____ Debris line _____ Other (describe below) ______________________________________________________________________________ 7. If known, what is the source of water in the wetland? _____ Stream/River/Creek/Lake/Pond _____ Flooding _____ Groundwater _____ Surface runoff

B-20

Region 6 Corrective Action Strategy (CAS)

Appendix B

8. Is there a discharge from the site to a known or suspected wetland? Yes _____ No _____. If yes, please describe. ______________________________________________________________________ ______________________________________________________________________________ 9. Is there a discharge from the wetland? Yes _____ No _____. If yes, to what waterbody is the discharge released? _____ Surface stream/River _____ Groundwater _____ Lake/pond _____ Marine 10. If a soil sample was collected, describe the appearance of the soil in the wetland area. Circle or write in the best response. Color (blue/gray, brown, black, mottled) _____________________________________________ Water content (dry, wet, saturated/unsaturated) ________________________________________ 11. Mark the observed wetland area(s) on the attached site map.

B-21

APPENDIX E FACILITY DRAWINGS OF UNDERGROUND UTILITIES

029796-02 (1)

11/11/11

LEGEND
EXISTING FIRE HYDRANT EXISTING POWER POLE EXISTING LIGHT POLE GUY ANCHOR POST TREE TELEPHONE MANHOLE EXISTING SIGN EXISTING WATER VALVE WATER METER PROPOSED FIRE HYDRANT BENCHMARK EXISTING SANITARY SEWER MANHOLE PROPOSED GRATE INLET EXISTING FENCE PROPOSED UNDERGROUND ELECTRIC EXISTING OVERHEAD ELECTRIC FULL DEPTH SAWCUT LIMIT

GENERAL NOTES:
1. PROPOSED 100 YR FLOOD PLAIN BASED ON A FULLY DEVELOPED WATERSHED. 2. NOMINAL HIGHEST BUILDING HEIGHT IS 73'-4". EQUIPMENT HEIGHTS VARY AND MAY IN PLACES EXCEED 73'-4" IN HEIGHT. THESE MAY INCLUDE BUT ARE NOT LIMITED TO STACKS, DUST COLLECTORS, SECONDARY FILTRATION, ETC. 3. HANDICAP PARKING IS PROVIDED IN ACCORDANCE WITH ADA STANDARDS. 4. NO TREES WILL BE REMOVED ON SITE.

ZONED "I"

ZONED "O-2" (PD-121) ZONED "SF" (PD-125)

PROJECT LOCATION

UGE OE

ZONED "O-2" (PD-124)

ZONED "O-2" (PD-123)

PROP

100 -Y

IN DPLA FLOO

LIMIT

ZONING MAP
DRIVEWAY

LOCATION MAP

AIN PL OD S TION 100-YR FLO NDI . CO OP PR

BL VD
(SEE E 1) NOT

CONCRETE

EX. FIRE TRAINING BLDG.

PROPOSED POLE ISSUED FOR CITY SUBMITTAL

UGE

A FEM
PROP. CON C.

10 0-Y R

IN FLOODPLA

LIMIT

EX. ASPHALT DRIVE


E UG

APPROX. LIMITS OF CLOSED DISPOSAL AREA


E X. CON C.

ES S A CC

D ROA

E UG

(PR EX IVA . E TE AG AN ROAD WA ) Y

PROP. SLAG TREATMENT BUILDING


PROP. DUST COLLECTORS AND SECONDARY FILTRATION FOR SLAG TREATMENT BUILDING PROP. DUST COLLECTORS AND SECONDARY FILTRATION FOR BLAST FURNACE FEED ROOM

PROP. CONC. PROP. DUST COLLECTORS FOR REVERB/REFINING/ CASTING ROOMS

PROP. CONC.

SPUR

PROP. 2500 KVA TRANS. PROP. COOL DOWN ROOM & RESTROOMS BATTERY STORAGE AREA (14,905 SF) PROP. BATTERY BREAKER EXTENSION

PROP. SECONDARY FILTRATION FOR EXIST. PROCESSES AND EQUIPMENT BLAST FURNACE FEED ROOM (23,514 SF) PROP. BUILDING ENCLOSURE REVERB FURNACE/ REFINING/CASTING ROOM (15,776 SF)

-YR FEMA 100


BATTERY BREAKER BUILDING (24,370 SF)

AIN FLOODPL

LIMIT

23

PURSUANT TO EXIDE TECHNOLOGIES' RIGHTS AS A GRANDFATHERED PROJECT, THE USE IS A HEAVY MANUFACTURING OR INDUSTRIAL USE MEETING PERFORMANCE STANDARDS IN THE HEAVY INDUSTRIAL DISTRICT UNDER ORDINANCE NO. 196. IN THE ALTERNATIVE, EXIDE TECHNOLOGIES' USE IS A RECYCLING PLANT UNDER ORDINANCE NO. 11-04-09.

PROP. CONC. PROP. TRUCK SCALE

SITE DATA SUMMARY TABLE


ZONING PROPOSED USE LOT AREA (AC) LOT AREA (SF) SITE AREA (AC) SITE AREA (SF) BLDG AREA (SF) MAX BLDG HEIGHT (FT) LOT COVERAGE (SF) FLOOR AREA RATIO TOTAL PARKING REQUIRED TOTAL PARKING PROVIDED HC PARKING REQUIRED HC PARKING PROVIDED LANDSCAPING REQUIRED (SF) IMPERVIOUS SURFACE (SF) OPEN SPACE REQUIRED (SF)
"I", "AG", "O-2"

230.692 10,048,944 18.0 784,000 169,134 73'-4" (NOMINAL) 169,134 22% 115 115 5 5 0 670,191 0

PROP. CONDITION S

(2,572 SF) PROP. TRUCK SCALE PROP. BUILDING ENCLOSURE RAW MATERIAL STORAGE ROOM (14,973 SF)

10 0-Y R

EX. TRUCK SCALES

W .W .T .P .

FLOODPLAIN 1) 14 (SEE NOTE


4

PROP. WIND BREAK

EX
E

ST

CR YS

EW AR

T CR EE K

TA

LL

IZ

EX BU . S IL LAG DI NG TR (7 EA ,9 TM 96 E SF NT )

OFFICE BUILDING (17,384 SF) MAINTENANCE BUILDING (7,526 SF) 5 MAINTENANCE STORAGE BUILDING (1,875 SF) (1,209 SF) 3 37

ER W AY

21

(PR I VA
CITY OF FRISCO STANDARD SITE PLAN NOTES
F

TE

RO AD )

EX. EMPLOYEE PARKING

DRN:

EXIDE TECHNOLOGIES NAAQS PROGRAM

PROP. SECONDARY FILTRATION FOR EXIST. PROCESSES AND EQUIPMENT

1 INCH AT FULL SCALE

DES:

AH

RH

ISSUE DATE:

11/11/2011
DRAWING NUMBER:

1. ANY REVISION TO THIS PLAN WILL REQUIRE CITY APPROVAL AND WILL REQUIRE REVISIONS TO ANY CORRESPONDING PLANS TO AVOID CONFLICTS BETWEEN PLANS. 2. OPEN STORAGE, WHERE PERMITTED, SHALL BE SCREENED IN ACCORDANCE WITH THE COMPREHENSIVE ZONING ORDINANCE. 3. BUILDINGS OF 5,000 SQUARE FEET OR GREATER SHALL BE 100% FIRE SPRINKLED. ALTERNATIVE FIRE PROTECTION MEASURES MAY BE APPROVED BY THE FIRE DEPARTMENT. 4. ALL SIGNAGE IS SUBJECT TO BUILDING INSPECTION DIVISION APPROVAL. 5. ALL FENCES AND RETAINING WALLS SHALL BE SHOWN ON THE SITE PLAN AND ARE SUBJECT TO BUILDING INSPECTION DIVISION APPROVAL.

000-C-01
SHEET NUMBER:

**

**

- PERTAINS TO NEW BUILDINGS.

REVISION

EXIDE FRISCO PLANT AIR QUALITY IMPROVEMENTS CITY OF FRISCO, COLLIN. CO, TX PRELIMINARY SITE PLAN
CHK: APP:

NRB

NRB

C1
A

60213972

RAILR

OAD

EX. ELEC. EQUIPMENT

NOTE:

TBPE REG. F-3580

PROJECT NUMBER:

EX.

PROP. SECONDARY FILTRATION FOR OXIDE ROOM OXIDE ROOM (22,934 SF)

16000 DALLAS PARKWAY, STE 3500 (972) 735-3000 www.aecom.com

PROP. DUST COLLECTOR WITH SECONDARY FILTRATION FOR BATTERY BREAKER BLDG

PROP. SWITCHGEAR

PROP. CONC.

FRISCO RECYCLING CENTER FRISCO, TX

PROP. ELECTRICAL EQUIPMENT ENCLOSURE PROP. CONC. PAVING FFE=641.80 FOR TRUCK TURN AROUND AT LOADING DOCKS PROP. LOADING DOCKS & TRUCK WASH

PROP. 2 EA-2000 KVA TRANS.

PROP. CONC. PARKING LOT EXPANSION

EX. CONC. TRUCK PARKING

REV

OAD SS R ACCE . CONC D EX. ROA ESS CC UGE C. A CON X.

UGE

PROPOSED 10 ' WIDE ELEC. EASEMENT

DESCRIPTION

DRN

AH

ZONED "O-2" (PD-122)

RH

PA RK W O O D

NB CHK

ZONED "I"

ZONED "MF-19" (PD-46) ZONED ZONED "I" "AG" (PD-46)

DATE

GENERAL NOTES:
1. LIME STABILIZATION OF PAVEMENT SUBGRADE IS REQUIRED UNDER ALL PAVEMENTS EXCEPT IN AREAS WHERE SLAG GRAVEL OR RAILROAD BALLAST IS ENCOUNTERED. IN SUCH AREAS, PLACE A LAYER OF NON-WOVEN GEOTEXTILE ON TOP OF SUBGRADE AFTER PROOF-ROLLING.

TREE (TO REMAIN) IRRIGATION CONTROL VALVE POWER POLE GUY WIRE MONITORING WELL ELECTRICAL LINE TYPICAL TRAFFIC FLOW LIGHT DUTY 6" 3500 PSI REINFORCED CONCRETE WITH #3 BARS (GRADE 60) ON 18" CENTERS, BOTH WAYS ON LIME TREATED SUBGRADE (SEE NOTE 1). HEAVY DUTY 8" 5000 PSI REINFORCED CONCRETE WITH #5 BARS (GRADE 60) ON 12" CENTERS, BOTH WAYS ON LIME TREATED SUBGRADE (SEE NOTE 1). APPROX. LIMITS OF CLOSED DISPOSAL AREA RH
UGE

NB

SIGN BOLLARD FIRE HYDRANT A

A FEM
D ROA

100-Y R

MATCH LINE SEE THIS SHEET

00 S 1 ION NDIT CO OP. PR PROP. CONC. PAVING


PROP. LOADING DOCKS & TRUCK WASH

NC. . CO EX

ACC

UGE

PROP. ELECTRICAL EQUIPMENT ENCLOSURE PROP. SLAG TREATMENT BUILDING

PROP. DUST COLLECTOR WITH SECONDARY FILTRATION FOR BATTERY BREAKER BLDG

(PRI VAT E RO EX. EAG AD) AN WAY

PROP. DUST COLLECTORS AND SECONDARY FILTRATION FOR SLAG TREATMENT BUILDING PROP. DUST COLLECTORS AND SECONDARY FILTRATION FOR BLAST FURNACE FEED ROOM

PROP. DUST COLLECTORS FOR REVERB/REFINING/ CASTING ROOMS

ISSUED FOR CITY SUBMITTAL


16000 DALLAS PARKWAY, STE 3500 (972) 735-3000 www.aecom.com

FOR TRUCK TURN AROUND AT LOADING DOCKS

PROP. CONC. PARKING LOT EXPANSION

EX. CONC. TRUCK PARKING

UGE

PROP.

BAGHOUSE

ACCESS

ROAD

EX.
C

RAIL

ROAD

SPUR

PROP. SECONDARY FILTRATION FOR OXIDE ROOM


PROP. BATTERY BREAKER EXTENSION OXIDE ROOM BLAST FURNACE FEED ROOM

PROP. COOL DOWN ROOM & RESTROOMS BATTERY STORAGE AREA PROP. BATTERY BREAKER EXTENSION

FE

MA

100-YR

AIN FLOODPL

LIMIT

PROP. PARKING

BATTERY BREAKER BUILDING


TBPE REG. F-3580

REVERB FURNACE/ REFINING/CASTING ROOM

CONDITI

ONS

10

0-Y R

EX. TRUCK SCALES

.W

PROP. TRUCK SCALE


.T .P .

PROP. BUILDING ENCLOSURE

PROP. SECONDARY FILTRATION FOR EXIST. PROCESSES AND EQUIPMENT

FLOODPLAIN

MATCH LINE SEE THIS SHEET

RAW MATERIAL STORAGE ROOM

PROP. WIND BREAK

CR

YS TA

ST EW

LA G BU TR IL EA DI NG TM EN T

MAINTENANCE BUILDING

OFFICE BUILDING

LL

AR T CR EE K

IZ

ER W AY

MAINTENANCE STORAGE BUILDING

EX. EMPLOYEE PARKING

(PR

IVA

TE RO AD )
AH

DRN:

EXIDE TECHNOLOGIES NAAQS PROGRAM

EX .S

1 INCH AT FULL SCALE

DES:

RH

ISSUE DATE:

11/11/2011
DRAWING NUMBER:

000-C-03
SHEET NUMBER:

REVISION

EXIDE FRISCO PLANT AIR QUALITY IMPROVEMENTS CITY OF FRISCO, COLLIN. CO, TX PRELIMINARY PAVING PLAN
CHK: APP:

PA BL RK VD W O O

NRB

NRB

C3
A

60213972

PROP. BUILDING ENCLOSURE

PROJECT NUMBER:

PROP. TRUCK SCALE

FRISCO RECYCLING CENTER FRISCO, TX

REV

DESCRIPTION

ESS AIN ACC C. OD PL FLO CON EX. R -Y

AIN DPL O FLO YR 00S 1 ION IT ROAD OND C ESS . ACC ROP X. CONC. OAD P UGE SS R E E

FLOODPLA

IN

LIMIT
E UG

E UG

EX. ASPHALT DRIVE

UGE

DRN

AH

CHK

DATE

LEGEND

11/11/11

3
Proposed Condition Runoff Calculations Area Tc ID A1 A2 A3 A4 A5 A6 A7 A8 A9 A10 A11 Total A acres 8.99 0.44 0.63 1.24 0.27 0.84 0.58 0.06 1.13 0.13 0.18 14.50 C 0.92 0.95 0.95 0.95 0.95 0.95 0.95 0.95 0.78 0.95 0.95 min 10 10 10 10 10 10 10 10 10 10 10

5
Existing Condition Runoff Calculations Area Tc ID A1 A2 A3 A4 Total A B1 B2 Total B acres 8.87 0.47 0.39 1.08 10.81 2.51 0.22 2.73 C 0.92 0.95 0.95 0.73 min 10 10 10 10

7
Adequacy of Existing Drainage System to Handle Proposed Runoff Volume Plant Interior Area Storage Volume (acre-ft) 0.00 0.10 0.44 1.41 3.04 5.18 6.80
1

8
Runoff Volume Computations Stormwater Plant Retention Interior Pond Area 14.50 2.30 92% 100% 9.84 9.84 10.94 1.89 12.82 634.7 2.54 10.28

OE

ND

DRAINAGE LEGEND

NOTE: 1 ALL PROPOSED RUNOFF ENTERS THE PLANT'S STORMWATER RETENTION POND. THERE IS NO DIRECT RELEASE OF STORMWATER RUNOFF INTO STEWART CREEK.

EX. 36" CMP TO BE REMOVED

E UG

C. CON EX.

OAD S R ES ACC

UGE

A2 0.47
PROP MH RIM=640.5 36" FL S=631.0 36" FL W=631.0 18" FL W=632.5
SD P 36" PRO 3.79 CFS =3 Q10 0
12" SD
PROP 36" SD Q100 = 41.43 CFS

PROP INLET TOP=639.9 30" FL=632.9 EX. INLETS (TO BE REMOVED)

PROP INLET TOP=637.5 18" FL=633.0

A6 0.84
PROP 8" SD
UGE

PROP 18" SD Q100 = 7.64 CFS

PROP. SLAG TREATMENT BUILDING

A5 0.27
PROP INLET
12 "S D

PROP TRENCH DRAIN


PROP 8" SD

PR O P

EX.

PROP TRENCH DRAIN D

BATTERY STORAGE AREA

36" FL = 626.3
EX 36" FIBER GLASS
EX. 12" SD

BATTERY BREAKER BUILDING

EX. INLET (PLUGGED)

DRAINS TO STORMWATER RETENTION POND

EX. RET. WALL T/W=636.7

.W

.T .P .

RAW MATERIAL STORAGE ROOM PROP. WIND BREAK

EX. INLET (PLUGGED)

FLOODPLAIN

EX

CR

ST EW

YS T

AR T CR EE K
EX . RE

AL

ONDITI ON C S

LI ZE

SL AG T BU R E ILD AT IN ME G NT

MAINTENANCE BUILDING

OFFICE BUILDING

R W AY

TA I

NI NG

PR O

10

P.

W AL L

0YR

MAINTENANCE STORAGE BUILDING


E X . R E TA INING WA LL

EX. EMPLOYEE PARKING

DRN:

EXIDE TECHNOLOGIES NAAQS PROGRAM

EX. SUMP PROP SUMP FL=626.0 TOP=631.0

PROP 36" SD Q100 = 44.05 CFS PROP. M.H. RIM = 633.9 36" FL = 627.1

A1 8.99

A1 8.87

REVERB FURNACE/ REFINING/CASTING ROOM

PROP. CONDITION S

10

0-Y R

EX. TRUCK SCALES

1 INCH AT FULL SCALE

DES:

AH

RH

FL OO

ISSUE DATE:

DP

11/11/2011
EX. RET. WALL T/W=636.7 EX. RET. WALL T/W=638.2
DRAWING NUMBER:

LA IN

(PR

IVA

TE RO AD )

CHANGE IN RET WALL HT.

000-C-04
SHEET NUMBER:

REVISION

EXIDE FRISCO PLANT AIR QUALITY IMPROVEMENTS CITY OF FRISCO, COLLIN. CO, TX PRELIMINARY STORM SEWER PLAN
CHK: APP:

PROP. BATTERY BREAKER EXTENSION

A11 0.18

FE

A8 0.06

LIMIT DPLAIN LOO MA 100-YR F

PROP INLET TOP=639.3 18" FL NW=634.8 12" FL S=635.3

EX. 18' CMP (TO BE REMOVED)

BLAST FURNACE FEED ROOM

OXIDE ROOM

PROP. TRUCK SCALE

NRB

NRB

C4
A

60213972

SPUR

PROP 12" SD

TBPE REG. F-3580

PROJECT NUMBER:

RAIL

ROAD

A10 0.13

PROP TRENCH DRAIN PROP 8" SD

A7 0.58

PROP INLET TOP=640.1 18" FL N=635.6 12" FL SE=636.1 8" FL SW=636.4

16000 DALLAS PARKWAY, STE 3500 (972) 735-3000 www.aecom.com

A4 1.08

B2 0.22

EX. INLET (PLUGGED)

EX. INLET (PLUGGED)

A4 1.24

EX

PROP 8" SD

PROP 12" SD

( PR IVA TE R EX. OAD EAG ) AN WA Y

PROP MH RIM=640.1 24" FL E=633.0 30" FL W=632.5

FRISCO RECYCLING CENTER FRISCO, TX

A9 1.13

36" FL W=631.4 30" FL E=631.9 18" FL SE=632.9

SD P 30" PRO 8.49 CFS =2 Q10 0

PROP INLET 24" FL=633.5 TOP=640.8

PROP INLET

B1 2.51

REV

SD 24" OP .51 CFS P R 21 0= Q10

A2 0.44

UGE

PROP 24" SD Q100 = 19.26 CFS

PROP 18" SD Q100 = 5.25 CFS 18" FL=640.0 PROP MH PROP 18" SD RIM=642.2 Q100 = 2.25 CFS 24" FL N=634.2 18" FL SE=634.7 18" FL SW=637.7

UGE

A3 0.63

ISSUED FOR CITY SUBMITTAL

A5 0.27

POST-DEVELOPMENT DRAINAGE AREA I.D. AREA IN ACRES

A FEM

100-Y R

IN FLOODPLA

LIMIT

A3 0.39

P. O R PR 0-Y 10

UGE

EX. ASPHALT DRIVE


E UG

DESCRIPTION

B1 2.51

CO

PRE-DEVELOPMENT DRAINAGE AREA I.D. AREA IN ACRES

FL O

OD

ON S PL AI N

UGE

EXISTING FIRE HYDRANT EXISTING POLE EXISTING LIGTH POLE GUY ANCHOR POST TREE TELEPHONE MANHOLE EXISTING SIGN EXISTING WATER VALVE WATER METER PROPOSED WATER HYDRANT BENCHMARK EXISTING SANITARY SEWER MANHOLE PROPOSED ELECTRIC EXISTING OVERHEAD ELECTRIC

in/hr 8.74 8.74 8.74 8.74 8.74 8.74 8.74 8.74 8.74 8.74 8.74

Comments cfs 72.11 Sheet flow to Exist 36" SD, which discharges to Stormwater Retention Pond 3.69 East/west access road, East of Prop Slag Treatment Bldg 5.25 Open area North of Oxide Room 10.32 Paved area East of Prop Slag Treatment Bldg 2.25 Open area North of Blast Furnace 6.98 Prop Slag Treatment Bldg, east/west access road sump area 4.78 Paved area North of Battery Breaker Bldg 0.51 Prop Loading Docks at Battery Breaker Bldg 7.64 Fire Lane Turnaround area 1.10 Prop Loading Docks at Battery Storage Area 1.52 Battery Breaker Expansion 116.16

in/hr 8.74 8.74 8.74 8.74

Comments cfs 71.08 Sheet flow to Exist 36" SD, which discharges to Stormwater Retention Pond 3.92 Exist 10' Curb Inlet; drains to sump at Exist 36" SD 3.25 Exist 10' Curb Inlet; drains to sump at Exist 36" SD 6.89 Exist 12" CMP; drains to sump at Exist 36" SD 85.14 9.13 Exist 36" CMP; drains into Stewart Creek Tributary 4 0.67 Exist 15" CMP; drains into DA B1 9.80

Stormwater Retention Pond Storage Elevation 629.0 630.0 631.0 632.0 633.0 634.0 635.0
3

636.7
NOTES:

11.00

ASSUMPTIONS:
VOLUME-BASED CALCULATIONS PROVIDED TO SHOW ADEQUACY OF EXISTING SYSTEM TO STORE THE PROPOSED RUNOFF VOLUME FROM A 100-YEAR STORM EVENT OCCURRING ON THE PLANT INTERIOR AREA, WITHOUT OVERTOPPING THE EXISTING RETAINING WALL OR STORMWATER RETENTION POND, AND SUBSEQUENTLY DISCHARGE INTO STEWART CREEK. DETAILED HYDRUALIC MODELING AND ANALYSIS WILL BE PERFORMED TO DETERMINE ADEQUACY OF EXISTING 36" SD BETWEEN PLANT INTERIOR AREA AND STORMWATER RETENTION POND TO TRANSFER PEAK DISCHARGES.

1 FLOOD STORAGE INSIDE EXISTING BUILDINGS/STRUCTURES EXCLUDED FROM VOLUME CALCULATIONS 2 TOP OF RETAINING WALL 3 TOP OF STORMWATER RETENTION POND 4 FINAL PONDING ELEVATION - BELOW TOP OF WALL AND POND

ITI

DRN

0.42 0.35

10 10

8.74 8.74

Elevation 631.0 632.0 633.0 634.0 635.0 636.0

Volume (acre-ft) 0.00 1.65 3.37 5.17 7.05 9.00

100-yr Ponding Elevation Plant Interior Area Volume (acre-ft) Stormwater Retention Pond Volume (acre-ft)

CHK

Area (ac) Percent Runoff 100-yr, 24 hr Rainfall Depth (in) Runoff Volume (acre-ft) Total Runoff Volume (acre-ft)

DATE

I100

Q100

I100

Q100

11/11/11

LEGEND

PROP 18" SD Q100 = 10.32 CFS

SD FS " 18 0 C P .3 O 5 PR 0 = 10

PROP 36" SD Q100 = 42.53 CFS

11/11/11

OE

A FEM
B

100-Y R

FLOODPLA

IN

LIMIT

EX. ASPHALT DRIVE


E UG

P. PRO

C. ION CON NDIT EX. CO

D ROA SS E ACC S

R 100-Y

UGE

UGE

PROP. ELECTRICAL EQUIPMENT ENCLOSURE PROP. ELECTRICAL CONDUIT (2 EA.-4" PVC) FOR SIGNAL HEAD PROP. SLAG TREATMENT BUILDING

UGE

PROPOSED 10 ' WIDE ELEC. EASEMENT PROP. 2 EA-2000 KVA TRANS.

ISSUED FOR CITY SIBMITTAL

PLAIN FLOOD

E UG

( PR IVA TE R EX. OAD EAG ) AN WA Y

C
UGE

PROP. SWITCHGEAR

EX.

SPUR

TBPE REG. F-3580

PROJECT NUMBER:

BATTERY STORAGE AREA

PROP. BATTERY BREAKER EXTENSION

FE

MA

DPLAIN R FLOO 100-Y

LIMIT

BLAST FURNACE FEED ROOM

BATTERY BREAKER BUILDING PROP. ELECTRICAL CONDUIT (2 EA.-4" PVC) FOR TRUCK SCALE REVERB FURNACE/ REFINING/CASTING ROOM

PROP. CONDITION S

10

0-Y R

EX. TRUCK SCALES

.W

FLOODPLAIN
.T .P .

RAW MATERIAL STORAGE ROOM PROP. WIND BREAK

EX

CR

ST EW

YS T

AR T CR EE K

AL

ONDITI ON C S

LI ZE

SL AG T BU R E ILD AT IN ME G NT

MAINTENANCE BUILDING

OFFICE BUILDING

R W AY
MAINTENANCE STORAGE BUILDING EX. EMPLOYEE PARKING

PR O

10

P.

0YR

1 INCH AT FULL SCALE

FL OO
F

DRN:

DES:

DP

AH

RH

LA IN

ISSUE DATE:

(PR

IVA

11/11/2011

TE RO AD )

DRAWING NUMBER:

000-C-05
SHEET NUMBER:

REVISION

EXIDE FRISCO PLANT AIR QUALITY IMPROVEMENTS CITY OF FRISCO, COLLIN. CO, TX PRELIMINARY UTILITY PLAN
CHK: APP:

EXIDE TECHNOLOGIES NAAQS PROGRAM

NRB

NRB

C5
A

60213972

PROP. 2500 KVA TRANS.

16000 DALLAS PARKWAY, STE 3500 (972) 735-3000 www.aecom.com

RAIL

PROP. COOL-DOWN ROOM AND RESTROOMS


ROAD

PROP. TRUCK SCALE OXIDE ROOM

FRISCO RECYCLING CENTER FRISCO, TX

REV

DESCRIPTION

P. O PR

CO

ND

UGE

EXISTING FIRE HYDRANT EXISTING POLE EXISTING LIGTH POLE GUY ANCHOR POST TREE TELEPHONE MANHOLE EXISTING SIGN EXISTING WATER VALVE WATER METER PROPOSED WATER HYDRANT BENCHMARK EXISTING SANITARY SEWER MANHOLE PROPOSED ELECTRIC EXISTING OVERHEAD ELECTRIC

1. THE PROPOSED 8 INCH FIRELINE IS INTENDED TO BE PRIVATE AND MAINTAINED BY THE OWNER. 2. DOMESTIC WATER SOURCE TO BE PROVIDED THROUGH INTERIOR BUILDING CONNECTIONS ON METERED "HOUSE SIDE" WATER LINES. ADDITIONAL PLANT WATER SUPPLIES MAY ALSO BE UTILIZED. 3. THE PROPOSED SANITARY SEWER LATERAL UTILIZES AN EXISTING MANHOLE CURRENTLY SERVING THE PLANT. OTHER EXISTING BUILDINGS ARE SERVED VIA A SEPARATE EXISTING CONNECTION.

PLAIN FLOOD
R -Y 0

.
UGE

ITI

ON S

DRN

10

CHK

DATE

LEGEND

GENERAL NOTES

EXHIBIT 1 PRELIMINARY SCHEDULE

029796-02 (1)

PRELIMINARY SCHEDULE(1)(2) SAMPLING AND ANALYSIS WORK PLAN EXIDE TECHNOLOGIES FRISCO, TEXAS Week Task 1 Description Site Characterization Field Work Preparation Establishing Background Sampliing Locations and Obtaining Access Agreements Site Characterization Field Work Duration 4 weeks 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

4 weeks

6 weeks

Laboratory Analysis

4 weeks

Data Validation

3 weeks

Report Preparation

4 weeks

Submittal of the Report to USEPA

1 day

Note:
(1) (1)

Schedule assumes Day 1 is USEPA Approval of Sampling and Analysis Work Plan. Quarterly Progress Reports will be submitted to USEPA by the 15th day of February, May, August, and November of each year.

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