Proposed Exide Sampling Plan

W o r l d w i d e E n g i n e e r i n g , E n v i r o n m e n t a l , C o n s t r u c t i o n , a n d I T S e r v i c e s

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.

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

Prepared by: Conestoga-Rovers & Associates 2270 Springlake Road, Suite 800 Dallas, Texas 75234 Office: (972) 331-8500 Fax: (972) 331-8501

web: http:\\www.CRAworld.com

029796-02 (1) CONESTOGA-ROVERS & ASSOCIATES

TABLE OF CONTENTS

Page

1.0. INTRODUCTION ...................................................................................................................1 1.1 WORK PLAN OBJECTIVES...............................................................................1

2.0 SITE HISTORY ........................................................................................................................2 2.1 SITE DESCRIPTION AND FACILITY HISTORY...........................................2 2.2 PREVIOUS INVESTIGATIONS ........................................................................2

3.0 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


3.2.2 BENEFICIAL RESOURCE DETERMINATION AND LOCATIONS............................................................................................15

3.2.3 SENSITIVE RECEPTORS .................................................................................15 3.2.4 APPLICABLE EXPOSURE SCENARIOS.......................................................16 3.2.4.1 ON-SITE OUTDOOR WORKER .....................................................................16 3.2.4.2 ON-SITE INDOOR WORKER .........................................................................16 3.2.4.3 ON-SITE CONSTRUCTION WORKER .........................................................16 3.2.4.4 OFF-SITE RECREATIONAL VISITOR...........................................................17 3.2.4.5 OFF-SITE RESIDENTIAL OCCUPANT.........................................................17 3.2.5 APPLICABLE EXPOSURE PATHWAYS.......................................................17 3.2.5.1 POTENTIAL SOURCES ...................................................................................17 3.2.5.2 EXPOSURE MEDIA ..........................................................................................17 3.2.5.3 ROUTES OF EXPOSURE..................................................................................18 3.2.5.4 POTENTIALLY-COMPLETE EXPOSURE PATHWAYS ............................18 3.3 PHYSICAL PROFILE ........................................................................................20 3.3.1 REGIONAL GEOLOGY ...................................................................................20 3.3.2 REGIONAL HYDROGEOLOGY.....................................................................21 3.3.3 SITE GEOLOGY AND HYDROGEOLOGY ..................................................22 3.3.4 SURFACE FEATURES......................................................................................23 3.3.5 SOIL.....................................................................................................................24 3.3.6 SURFACE WATER HYDROLOGY.................................................................25 3.4 ECOLOGICAL PROFILE .................................................................................25 3.4.1. LAND FEATURES ............................................................................................26 3.4.2 DESCRIPTION OF SITE RECEPTORS IN RELATION

TO HABITAT TYPE ..........................................................................................27 3.4.3 THREATENED/ENDANGERED SPECIES ..................................................27 3.4.4 DESCRIPTION OF RELATIONSHIP OF RELEASES TO

POTENTIAL HABITAT AREAS .....................................................................29 3.5 RELEASE PROFILE...........................................................................................29 3.5.1 FATE AND TRANSPORT MECHANISMS...................................................30 3.5.1.1 LEAD BIOGEOCHEMICAL CYCLES............................................................30 3.5.1.2 LEAD TRANSPORT BETWEEN POTENTIALLY

AFFECTED MEDIA ..........................................................................................30 3.5.1.3 LEAD TRANSPORT IN SEDIMENT..............................................................31 3.5.1.4 LEAD TRANSPORT IN AIR/ATMOSPHERE..............................................31 3.5.1.5 TRANSPORT OF LEAD IN SURFACE WATER ..........................................31 3.5.1.6 TRANSPORT OF LEAD IN SOIL....................................................................32 3.5.1.7 LEAD TRANSPORT IN THE SOIL TO

GROUNDWATER PATHWAY.......................................................................32 3.5.1.8 LEAD TRANSPORT IN THE SOIL TO AIR PATHWAY............................32 3.5.1.9 LEAD TRANSPORT IN THE SOIL TO SURFACE

WATER RUNOFF PATHWAY........................................................................33 3.5.1.10 TRANSPORT OF LEAD IN GROUNDWATER...........................................33 3.5.1.11 LEAD UPTAKE BY PLANTS...........................................................................33 3.6 RISK MANAGEMENT PROFILE ...................................................................33 3.6.1 RISK MANAGEMENT .....................................................................................33


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

4.0 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

5.0 DATA EVALUATION .........................................................................................................52

6.0 QUALITY ASSURANCE/QUALITY CONTROL............................................................53 6.1 PROPOSED ANALYTICAL LABORATORIES.............................................53

7.0 HEALTH AND SAFETY......................................................................................................55 7.1 MINIMUM QUALIFICATIONS FOR PERSONNEL ...................................55 7.2 ACCESS BY USEPA ..........................................................................................55

8.0 PRELIMINARY SCHEDULE AND REPORTING............................................................56

9.0 CERTIFICATION..................................................................................................................57


LIST OF FIGURES (Following Text)

FIGURE 1 SITE LOCATION MAP

FIGURE 2 SITE MAP

FIGURE 3 PRELIMINARY CONCEPTUAL SITE MODEL

FIGURE 4 PROPOSED SOIL SAMPLE LOCATIONS – NORTH DISPOSAL AREA

FIGURE 5 PROPOSED SOIL SAMPLE LOCATIONS – SLAG LANDFILL

FIGURE 6 PROPOSED SOIL SAMPLE LOCATIONS – RAW MATERIAL STORAGE AREA

FIGURE 7 PROPOSED SOIL SAMPLE LOCATIONS – SOUTH DISPOSAL AREA

FIGURE 8 PROPOSED SOIL SAMPLE LOCATIONS - BONEYARD

FIGURE 9 PROPOSED SOIL SAMPLE LOCATIONS – BAIL STABILIZATION AREA

FIGURE 10 PROPOSED SOIL SAMPLE LOCATIONS – CRYSTALLIZATION UNIT FRAC TANK

FIGURE 11 PROPOSED SOIL SAMPLE LOCATIONS – STEWART CREEK FLOOD WALL

FIGURE 12 PROPOSED SURFACE WATER AND SEDIMENT SAMPLE LOCATIONS

FIGURE 13 EXISTING GROUNDWATER MONITORING NETWORK AND PROPOSED BACKGROUND MONITOR WELL LOCATIONS

FIGURE 14 TYPICAL MONITOR WELL INSTALLATION

FIGURE 15 ECOLOGICAL RECEPTORS MAP WITHIN 1,000-FOOT RADIUS OF FACILITY BOUNDARIES


LIST OF APPENDICES

APPENDIX A QUALITY ASSURANCE PROJECT PLAN APPENDIX B HISTORICAL GROUNDWATER GRADIENT MAP APPENDIX C MONITOR WELL CONSTRUCTION DETAILS APPENDIX D ECOLOGICAL ASSESSMENT CHECKLIST AND ECOLOGICAL

EXCLUSION CRITERIA WORKSHEET APPENDIX E FACILITY DRAWINGS OF UNDERGROUND UTILITIES

LIST OF EXHIBITS

EXHIBIT 1 PRELIMINARY SCHEDULE

029796-02 (1) 1 CONESTOGA-ROVERS & ASSOCIATES

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


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-


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.


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 TNRCC’s 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.


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.


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 facility’s 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.


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.


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.


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.


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.


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 lead-impacted 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.


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 Non- Hazardous 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


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


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.


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


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.


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


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. Lead is poorly absorbed through the skin

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


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.


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.


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


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


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


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.


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.


3.4.1. LAND FEATURES

This section describes the land features present within Exide’s 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 Non- Hazardous 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


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


FEDERAL AND STATE LISTED THREATENED/ENDANGERED SPECIES

OF DENTON AND COLLIN COUNTIES, TEXAS

Species Federal Status

State Status

Description of Suitable Habitat Habitat Assessed?

Birds

American Peregrine Falcon Falco peregrinus anatum

— E

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.

No

Arctic Peregrine Falcon Falco peregrinus tundrius

— T

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.

No

Bald Eagle Haliaeetus leucocephalus

AD,T T

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.

No

*Interior Least Tern Sterna anitllarum athalassos

E E Nests along sand and gravel bars within braided streams and rivers; also known to nest on man-made structures.

No

Peregrine Falcon Falco peregrinus — E,T

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.

No

*Piping Plover Charadrius melodus E,T T

Wintering migrant along the Texas Gulf Coast; beaches and bayside mud or salt flats.

No

White-faced Ibis Plegadis Chihi — T

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.

No

Whooping Crane Grus americana E E

Potential migrant via plains throughout most of state to coast. Winters in coastal marshes of Aransas, Calhoun, and Refugio countries.

No

Wood Stork Myceria americana

— T

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.

No

Mammals

Red Wolf Canis rufus

— E Extirpated; formerly known throughout eastern half of Texas in brushy and forested areas, as well as coastal prairies.

No


Reptiles

Alligator Snapping Turtle Macrochelys temminckii

— T

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 April-October.

No

Texas Horned Lizard Phrynosoma cornutum

— T Open, arid and semi-arid regions with sparse vegetation, including grass, cactus, scattered brush or scrubby trees; sandy to rocky soil.

No

Timer/ Canebrake Rattlesnake Crotalus horridus

— T Swamps, floodplains, upland woodlands, riparian zones, abandoned farmland; prefers dense ground cover, i.e. grapevines or palmetto.

No

E,T – Federally Listed Endangered/Threatened AD – Federally Proposed Delisted DL – Federally Delisted * - Only Federally listed in Denton County ___ - Not listed

E,T– State Endangered/Threatened

Source: US Fish & Wildlife Service, Texas Parks and Wildlife Department

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.


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.


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 μg/L in hard water and approximately 500 μg/L in soft water. Sulfate ions, if present in soft water, limit the


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.


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.


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


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 SOIL SAMPLING

4.1.1 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.


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.


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,


4.1.3.1 RFI UNITS

4.1.3.1.1 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


treatment building, as ordered and approved by the TCEQ in Agreed Order No. 2011-0521-MIS (Agreed Order). The portion of the current access road to the Site’s 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 Site’s 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 generally-accepted 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


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 Site’s 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.


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 Site’s SWPPP. Any deficiencies noted are repaired in accordance with the SWPPP. 4.1.4.2 NON-RFI UNITS

4.1.4.2.1 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.


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.


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 USEPA’s 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.


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

4.2.1 SURFACE WATER SAMPLES

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


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


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.


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


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.


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 MW-16, MW-16S, MW-17, B8N, and B5N, all of which are downgradient of WMA1

o 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

o 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/S-95/504)


Groundwater parameters will be analyzed during purging in the field for pH, temperature, turbidity, specific conductivity, dissolved oxygen (DO), and oxidation-reduction 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.


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.


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.


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


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.


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 Exide’s health and safety program, policy, and procedures.


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.


9.0 CERTIFICATION

029796-02 (1)

FIGURES

W Main St

N C

r Rd

S C

r Rd

Ash St

1st S

t

Dallas Pky

Dallas Pky

UV289

Preston Rd

Stewa rt Cre

ek

S tewar t Creek

S tewart Creek

Stewart C

reek

Frisco High School

Hickory Park

Figure 1SITE LOCATION MAP

SAMPLING AND ANALYSIS WORK PLANEXIDE TECHNOLOGIES, FRISCO, TEXAS

RE: 2010 Aerial Photograph0 1,000500

Feet

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

LegendBoundary of Permitted Facility

Property Owned by Exide

SITE

N

Closed Stewart Creek

Sediment Waste Piles

Oxide

Building

Slag Landfill

Slag Landfill

Storm Water

Retention Pond

Truck Staging Area

(Investigation Reported In

1998 Phase II RFI Report)

Parking Lot

Blast

Furnace

Building

Raw

Material

Storage

Building

Battery

Breaker

North Disposal Area

(Delineated in 1993 Addendum to RFI)

South Disposal Area

(Delineated in 1993 Addendum to RFI And

Further Investigated During Phase II RFI)

Wastewater

Treatment

Battery Receiving / Storage Building

Railroad Spur

Bail Stabilization

Area

Boneyard

Previous Location of Stewart Creek

North Tributary

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X

WMA-1

WMA-2

WMA-3

WMA-4

P-2

MW-10

P-1

B7N

B9N

MW-14

B4R

B3R

B2R

B1R

MW-17

B5N

MW-16S

MW-16

B8N

MW-15

Former Diesel Fuel

Tank (Closed)


Crystallization

Unit Frac Tank

Stewart Creek

MW-13

MW-11

E

a

g

a

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D

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i

v

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Closed Product

Waste Piles

Old Drum Storage Area

MW-12

Facility Boundary

Melissa Street

0 200ft100

Figure 2

SITE MAP

SAMPLING AND ANALYSIS WORK PLAN

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

LEGEND

Facility Boundary

Municipal Solid Waste

Waste Management Area (WMA)

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

Existing Monitor Well

WMA-1

WMA-2

WMA-3

WMA-4

B5N

RE: ESRI Aerial Photograph

Primary Source

Release Mechanism

Secondary Source

Secondary Release

Mechanism

ExposureMedia

Exposure Route(s)

Offsite Use Areas

Outdoor Worker

Indoor Worker

Construction/ Utility Worker

Recreational Wader

Ingestion C C C CDermal C C C C

Inhalation C C C C

Ingestion I I I CDermal I I I C

Inhalation I I I I


Inhalation I I I C

Ingestion I I C IDermal I I C I

Inhalation I I I I

Ingestion I I C IDermal I I C I

Inhalation I I I I

Ingestion I I I IDermal I I I I

Inhalation I I I I

Ingestion C I C CDermal C I C C

Inhalation C I C C


Inhalation I I I I


Inhalation I I I I


Inhalation I I I I

Ingestion C C C IDermal C C C I

Inhalation C C C I

LEGEND Ingestion I I I IC = Complete Exposure Pathway Dermal I I I II = Incomplete Exposure Pathway Inhalation I I I I

EXIDE TECHNOLOGIES FRISCO RECYCLING CENTERFRISCO, TEXAS

FIGURE 3CONCEPTUAL EXPOSURE MODEL


Spills/Leaks Surface Soil

Restricted Use Areas

Subsurface Soil

Drinking Water

Surface Soil

Sediment

Surface Water

Surface Water

Indoor Air

Foliage

Resuspension by Wind

Erosion by Water

Leaching

Deposition to Surface Run-off

Outdoor Air

Surface Water

Sediment

Groundwater

Smelting Operations

Deposition to Surface Water

Entry of Exhausted Dust

Into Building

Deposition to Botanical Surfaces

Deposition to Surface Soil

Pulverizing and Heating

Air



Oxide

Building

Slag Landfill

Slag Landfill

Parking Lot

Blast

Furnace

Building

Raw

Material

Storage

Building

Battery

Breaker

North Disposal Area



Railroad Spur

Boneyard


North Tributary

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Waste Piles

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9

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NB-48

NB-47

NB-46

NB-45

NB-44

NB-43

NB-42

NB-41

NB-40

NB-38

NB-37

NB-36

NB-35

NB-34

NB-33

NB-32

NB-30

NB-31

NB-28

NB-29

NB-27

NB-26

NB-25

NB-24

NB-1

NB-2

NB-3

NB-4

NB-5

NB-6

NB-7

NB-23

NB-22

NB-20

NB-21

NB-8

NB-10

NB-9

NB-19

NB-18

NB-16

NB-15

NB-14

NB-17

NB-11

NB-12

NB-13

NB-54

NB-53

NB-52

NB-51

NB-50

NB-39

Closed Product

Waste Piles

MW-12

MW-13

MW-17

B5N

B9N

MW-16

MW-16S

NL-12

NL-14

NL-15

NL-16

NL-17

NL-18

NL-19

NL-20

NL-21

NL-22

NL-23

NL-24

NL-25

NL-26

NL-27

NL-28

NL-29 NL-30

NL-31

NL-32

NL-33

NL-34

NL-35

NL-36

NL-37

NL-38

NL-39

NL-40

NL-42

NL-41

NL-43

NL-44

NL-45

NL-46

NL-47

NL-01

NL-02

NL-03

NL-04

NL-05

NL-06

NL-07

NL-08

NL-09

NL-10

Bail Stabilization

Area

MW-14

B7N

0 100ft50

Figure 4

PROPOSED SOIL SAMPLE LOCATIONS - NORTH DISPOSAL AREA


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


LEGEND

Facility Boundary

Municipal Solid Waste


North Disposal Area, Slag Landfill, Stewart Creek

Sediment Waste Pile

Soil Samples (1987)

Original Surveyed Delineation Boring Location

(1993)

New Delineation Boring Location (1993)


Boring Location (1991)

Proposed Approximate Soil Sample Location.

Locations May be Adjusted Based on Field

Observations of Contamination, Utilities, or Other

Physical Barriers.

NB-38

WMA-1

B5N

5

MW-16S

NL-30



Slag Landfill

Slag Landfill

Storm Water

Retention Pond

Battery

Breaker

North Disposal Area



Railroad Spur

Boneyard


North Tributary

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WMA-1

MW-13

MW-17

B5N

B9N

B8N

MW-16

MW-16S

Facility Boundary

0 100ft50

Figure 5

PROPOSED SOIL SAMPLE LOCATIONS - SLAG LANDFILL


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


LEGEND

Facility Boundary


North Disposal Area, Slag Landfill, Closed Stewart

Creek Sediment Waste Pile





Physical Barriers.

WMA-1

MW-16S

Blast

Furnace

Building

Raw

Material

Storage

Building

Battery

Breaker

W

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Railroad Spur

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WMA-2

Stewart Creek

Former Diesel Fuel

Tank (Closed)

Closed Product

Waste Pile


Closed Product

Waste Pile

0 20 60ft

Figure 6

PROPOSED SOIL SAMPLE LOCATIONS - RAW MATERIAL STORAGE AREA


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

LEGEND



Area, Closed Product Waste Pile, Battery Receiving/

Storage Building, Former Diesel Fuel Tank (Closed)





Physical Barriers.

WMA-2

B5N


SL-18

SL-17

SL-16

SL-15

SL-14

SL-13

SL-12

SL-11

SL-10

SL-9

SL-8

SL-7

SL-6

SL-5

SL-4

SL-3

SL-2

SL-1

SL-22

SL-21

SL-20

SL-19

SB-4

SB-3

SB-6

SB-5

SB-9

SB-8

SB-7

SB-11

SB-12

SB-13

SB-27

SB-10

SB-14

SB-15

SB-16

SB

-17

SB

-18

SB

-19

SB

-1

SB

-20

SB

-21

SB

-22

SB

-23

SB

-24

SB

-26

SB

-25

SB-2

South Disposal Area

(Delineated in 1993 Addendum to RFI And

Further Investigated During Phase II RFI)

WMA-3

B4R

B3R

B2R

B1R

SDA-8

SDA-9-2

SDA-9-1

SDA-10

SDA-1

SDA-3

SDA-4

SDA-5

SDA-6

BS1/BS-1

BS2/BS-2

BS3/BS-3

BS4/BS-4

BS5/BS-5

Soil Pile

SDA-7

SDA-2

Facility Boundary

0 20 60ft

Figure 7

PROPOSED SOIL SAMPLE LOCATIONS - SOUTH DISPOSAL AREA


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


LEGEND

Facility Boundary


South Disposal Area

Boring Sample Location (1991)

Original Surveyed Delineation Boring Location

(1993)

New Delineation Boring Location (1993)

Boring Sample Location (1991)


South Disposal Area Boring Location

(1998 Phase II Boring)



Observations of Contamination, Utilities, or

Other Physical Barriers.

SL-20

SB-1

WMA-3

B3R

BS5

SDA-6

B4R

Sample ID

Sample Depth, Inch (")Concentration, mg/kg

NOTE:

Concentration from Phase II RFI (6/1998)

mg/kg = milligrams per kilogram

Slag Landfill

Slag Landfill

Boneyard

X

X

X

X

X

X

WMA-1

MW-17

B8N



Previous Location of

Stewart Creek North Tributary

MW-16S

MW-16

Stewart Creek

0 40ft20

Figure 8

PROPOSED SOIL SAMPLE LOCATIONS - BONEYARD


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


LEGEND

Facility Boundary

North Disposal Area, Slag Landfill, and Closed

Stewart Creek Sediment Waste Pile






B4R

WMA-1

Oxide

Building

Truck Staging Area

Parking Lot

Blast

Furnace

Building

North Disposal Area


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

X

X

X

X

X

E

a

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a

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D

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iv

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Bail Stabilization

Area

0 20 60ft

Figure 9

PROPOSED SOIL SAMPLE LOCATIONS - BAIL STABILIZATION AREA


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


LEGEND

Facility Boundary






B4R

W

a

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w

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T

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X

X

X

X

X

X

B4R

MW-14

Crystallization

Unit Frac Tank

MW-12

Stewart Creek

Facility Boundary

0 20 60ft

Figure 10

PROPOSED SOIL SAMPLE LOCATIONS - CRYSTALLIZATION UNIT FRAC TANK


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

LEGEND

Facility Boundary






MW12


Oxide

Building

Parking Lot

Blast

Furnace

Building

Raw

Material

Storage

Building

Battery

Breaker

W

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w

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T

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Railroad Spur

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X

X

X

X

X

WMA-2

MW-13

MW-14

B3R

B2R

B5N

MW-17


Stewart Creek

Former Diesel Fuel

Tank (Closed)

B4R

Closed Product

Waste Piles


Closed Product

Waste Piles

MW-12

Facility Boundary

0 100ft50

Figure 11

PROPOSED SOIL SAMPLE LOCATIONS - STEWART CREEK FLOOD WALL


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

LEGEND

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PROPOSED SURFACE WATER AND SEDIMENT SAMPLE LOCATIONS


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

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Figure 13

EXISTING GROUNDWATER MONITORING NETWORK AND

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DATE REV. NO. FILE NO

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NOTES: 1) All section dimensions are in feet (unless otherwise noted). NA: Not available at this time

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Figure 15HUMAN AND ECOLOGICAL RECEPTORS WITHIN 1,000 FEET OF THE SITE

SAMPLING AND ANALYSIS WORK PLANEXIDE TECHNOLOGIES, FRISCO, TEXAS

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

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029796-02 (1)

APPENDIX A

QUALITY ASSURANCE PROJECT PLAN

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 INTRODUCTION .............................................................................................................. 1

2.0 DATA QUALITY OBJECTIVES FOR MEASUREMENT DATA................................. 2

3.0 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

4.0 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

5.0 DECONTAMINATION PROCEDURES AND MATERIALS...................................... 10

6.0 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

LIST OF TABLES

TABLE 1 POTENTIAL CONSTITUENTS OF CONCERN

TABLE 2 POTENTIAL ANALYTICAL PROGRAM

TABLE 3 SUMMARY OF SAMPLE CONTAINERS, PRESERVATION, AND HOLDING TIMES

TABLE 4 FIELD QUALITY CONTROL SAMPLES

029796-02 (1) A-1 CONESTOGA-ROVERS & ASSOCIATES

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.


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.


3.0 SAMPLING PROCEDURES

Sample collection and handling will be conducted consistent with the contractor’s 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 day’s 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


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


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 one’s actual possession

It is in one’s view, after being in his or her physical possession

It was in one’s 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


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


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 4°C (2°C). 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


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


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


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.


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


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


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


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),


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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TPH Metals Other

Total Petroleum Hydrocarbons Antimony Sulfate

Arsenic Grain size

Barium Total dissolved solids

Beryllium pH (field parameter)

Cadmium Total organic carbon

Total Chromium

Lead

Nickel

Selenium

Silver

Zinc

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.

FRISCO, TEXAS

TABLE 1

POTENTIAL CONSTITUENTS OF CONCERNSAMPLING AND ANALYSIS WORK PLAN

EXIDE TECHNOLOGIES

CRA 029796-02 (1) APP A-Tbls

Page 1 of 1

TABLE 2

POTENTIAL ANALYTICAL PROGRAMSAMPLING AND ANALYSIS WORK PLAN

EXIDE TECHNOLOGIESFRISCO, TEXAS

Sulfate EPA Method 9056

Total Petroleum Hydrocarbons TX 1005, TX 1006, or SW 8015

pH (field parameter) EPA Method 9045

Grain size ASTM D422-63

Notes:

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

(2) Samples may also be analyzed using the Synthetic Precipitate Leaching Procedure should the soil to groundwater pathway require further evaluation.

TX = Texas Commission on Environmental Quality (TCEQ) Methods

ASTM = American Society for Testing and Materials

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

SM = Standard Methods for the Examination of Waste and Wastewater

Analysis (1)

Surface Water

SW 6010B/6020/7471A Metals(2)

Metals SW 6010B/6020/7471A

Soil

(1) Not all constituents will be analyzed in all samples collected. Constituents potentially to be analyzed in each sample are specified in the Work Plan.

pH (field parameter only) Method 150.1

Total Dissoved Solids SM 2540C

Sulfate EPA Method 300.0 (IC) or SM 4500 SO4 (Colorimetric)

Analytical Method (3)

Groundwater

Metals (total and dissolved) SW 6010B/6020/7470A

SW 6010B/6020/7470AMetals (total and dissolved)

Sediment

CRA 029796-02 (1) APP A-Tbls

Page 1 of 1

TABLE 3

SUMMARY OF SAMPLE CONTAINERS, PRESERVATION, AND HOLDING TIMESSAMPLING AND ANALYSIS WORK PLAN


Analysis Sample Containers (2) Preservation Maximum Holding Times Shipping Means Comments

Soil

Metals 1 - 4 ounce glass Cool to 4°C (± 2°C) 180 days Fill completely

Sulfate 1 - 4 ounce wide-mouth glass Cool to 4°C (± 2°C) 28 days Fill completely

Total Petroleum Hydrocarbons

1 - 4 ounce wide-mouth glass or3 - 40 mL vials

Cool to 4°C (± 2°C)

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)

Fill completely

pH (field parameter) 4 ounce wide-mouth glass Cool to 4°C (± 2°C) Field Not applicable

Sediment

Metals 1 - 4 ounce wide-mouth glass Cool to 4°C (± 2°C) 180 days Fill completely

Grain size 1 - 8 ounce wide-mouth glass Cool to 4°C (± 2°C) Not applicable Fill completely

Surface Water

Groundwater

Metals (total) 1-500 mL plasticHNO3 to pH<2

Cool to 4°C (± 2°C)180 days Fill to neck

Metals (dissolved) (1) 1-500 mL plasticHNO3 to pH<2

Cool to 4°C (± 2°C)180 days Fill to neck

Total Dissoved Solids 1-500 mL plastic Cool to 4°C (± 2°C) 7 days to analysis Fill to neck

Sulfate 1-250 mL wide-mouth plastic Cool to 4°C (± 2°C) 28 days to analysis Fill to neck

pH (field parameter only) 125 ounce plastic Not applicable Field Not applicable

Notes:(1) Samples for dissolved metals analysis will be filtered in the field.(2) Containers may vary slightly depending on analytical laboratory.

mL = milliliterHNO3 = nitric acid

Fill to neck

HNO3 to pH<2Cool to 4°C (± 2°C)

Fill to neck

Courier or Federal Express




Metals (dissolved) (1)

HNO3 to pH<2Cool to 4°C (± 2°C)

180 days

180 days

Metals (total) 1 - 500 mL plastic

1 - 500 mL plastic

CRA 029796-02 (1) APP A-Tbls

Page 1 of 1

FIELD QUALITY CONTROL SAMPLES SAMPLING AND ANALYSIS WORK PLAN


Type of Quality Control Sample Frequency Acceptance Criteria

Equipment rinsate blank 1 per day per equipment type SW-846

Matrix spike/matrix spike duplicate (MS/MSD)

1 per 20 field samples for surface water, sediment, and groundwater SW-846

Field blank 1 per day per equipment type for volatile organics SW-846

Field duplicate 1 per 20 groundwater and/or surface water samplesLaboratory-established relative percent difference (RPD)

Trip blanks 1 per cooler with volatile organics SW-846

TABLE 4

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

029796-02 (1)

APPENDIX B

HISTORICAL GROUNDWATER GRADIENT MAP

029796-02 (1)

APPENDIX C

MONITOR WELL CONSTRUCTION DETAILS

029796-02 (1)

APPENDIX D

ECOLOGICAL ASSESSMENT CHECKLIST AND

ECOLOGICAL EXCLUSION CRITERIA WORKSHEET

Region 6 Corrective Action Strategy (CAS) Appendix B

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APPENDIX B

ECOLOGICAL EXCLUSION SCREENING

ECOLOGICAL EXCLUSION CRITERIA WORKSHEET AND

ECOLOGICAL ASSESSMENT CHECKLIST


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Ecological Screening

Introduction

Region 6 is providing an Ecological Exclusion Criteria Worksheet and Ecological AssessmentChecklist to help facilities and regulators determine whether or not further ecological evaluation isnecessary at an affected property where corrective action is being pursued. Chapter 2 of the CAS providesadditional information on the Ecological Screening process.

Ecological screening under the CAS is a relatively simple process. It involves; 1) collectinggeneral information about the facility, its operation, physical site characteristics, ecological habitats andreceptors utilizing the Ecological Exclusion Criteria Worksheet and determining if incomplete orinsignificant exposure pathways exist at the affected property that eliminate the need for further ecologicalevaluation, and 2) if an area cannot be excluded from further evaluation, collecting more detailedinformation about ecological areas utilizing the Ecological Assessment Checklist to assist in furtherecological risk evaluations.

If the affected property meets the exclusion criteria, then the facility should document the siteconditions and justification for how the criteria have been met within the risk evaluation report. Uponreview and approval of the exclusion by the administrative authority, the facility will not be required toconduct any further evaluation of ecological risk.

If the affected property does not meet the exclusion criteria, then further evaluation is warrantedand the facility should address the conduct of additional activities (screening level or detailed riskassessment, interim measures) within the risk management plan. Additional ecological riskscreening/assessment should be conducted following EPAs Risk Assessment Guidance for Superfund:Process for Designing and Conducting Ecological Risk Assessments dated June 5, 1997 and Guidelinesfor Ecological Risk Assessment (EPA/630/R-95/002F) dated April 1998 or a state approved guidance forecological risk evaluation. Natural Resources Trustees should also be notified to see if they choose toparticipate, 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 forSuperfund 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/R-95/002F. http://www.epa.gov/ncea/ecorsk.htm

• U. S. EPA. 1997. Ecological Risk Assessment Guidance for Superfund, Process forDesigning and Conducting Ecological Risk Assessments, Interim Final. EPA 540-R-97-006, OSWER Directive # 9285.7-25.

http://www.epa.gov/superfund/programs/risk/ecorisk/

http://www.epa.gov/ecotox

http://www.epa.gov/ncea/ecorsk.htm


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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, HazardousSite Evaluation Division; Publication 9345.0-12Fsi EPA/540/F-95/038; NTIS PB95-963324.

• U.S. EPA. 1996. Ecological Significance and Selection of Candidate AssessmentEndpoints. 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 RiskAssessments. 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, InterimBulletin, Volume 2, Number 3. Washington, D.C. Office of Emergency and RemedialResponse, 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 ofEmergency and Remedial Response, Hazardous Site Evaluation Division; Publication93450-05I; 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 andRemedial 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 andEcology 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 andRemedial Response, Hazardous Site Evaluation Division; Publication 9345.0-05I.

• 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 ofEmergency and Remedial Response, Hazardous Site Evaluation Division; Publication9345.0-05I.

• U.S. EPA. 1991. Ecological Assessment of Superfund Sites: An Overview. ECOUpdate, Interim Bulletin, Volume 1, Number 2. Washington, D.C. Office of Emergencyand Remedial Response, Hazardous Site Evaluation Division; Publication 9345-0-05I.

• U.S. EPA. 1991. The Role of BTAGs in Ecological Assessment. ECO Update, InterimBulletin, Volume 1, Number 1. Washington, D.C. Office of Emergency andRemedial Response, Hazardous Site Evaluation Division; Publication 9345-0-05I.

http://www.epa.gov/superfund/programs/risk/ecorisk/ecorisk.htm


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ECOLOGICAL EXCLUSION CRITERIA WORKSHEET

The Exclusion Criteria Worksheet is intended to aid facilities and regulators in determiningwhether or not further ecological evaluation is necessary at an affected property where a response action isbeing pursued utilizing the CAS. Exclusion criteria refer to those conditions at an affected propertywhich preclude the need for a formal ecological risk assessment (ERA) because there are incomplete orinsignificant ecological exposure pathways due to the nature of the affected property setting and/or thecondition of the affected property media. The person completing the worksheet should be familiar with theaffected property but need not be a professional scientist in order to respond, although some questions willlikely require contacting a wildlife management agency (U.S. Fish and Wildlife Service, etc.). Theworksheet is designed for general applicability to all affected property; however, there may be unusualcircumstances which require professional judgement in order to determine the need for further ecologicalevaluation (e.g., cave-dwelling receptors). In these cases, it is strongly encouraged to contact your stateregulatory agency for additional guidance before proceeding.

The worksheet consists of three major parts. Part 1, identification of the affected property andbackground information, Part 2, the actual exclusion criteria and supportive information, and Part 3, aqualitative summary statement and certification of the information submitted. Answers to the worksheetshould 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 evaluationis warranted. Definitions of terms used in the worksheet are provided and users are encouraged to reviewthese definitions before completing the worksheet.

The Exclusion Worksheet has been adapted from and follows the Texas Natural ResourcesConservation Commission (TNRCC) Texas Risk Reduction Program (TRRP) Tier 1 Checklist. TNRCChas developed some additional information regarding the use of their Tier 1 Checklist which should also beconsulted in completing the CAS Ecological Exclusion Criteria Worksheet. This information can be foundin Chapter 2 of TNRCCs Guidance for Conducting Ecological Risk Assessments at Remediation Sites inTexas, 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 thetype of facility and/or operation associated with the affected property. Also describe the locationof 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 tothis form to depict the affected property and surrounding area.

http://www.tnrcc.state.tx.us/permitting/remed/techsupp/erag8_00.pdf


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_____ Topo map _____ Aerial photo _____ Other _____________

2) Identify the environmental media known or suspected to contain chemicals of concern (COCs) atthe present time. Check all that apply:

Known/Suspected COC Location Based on sampling data?_____ Soil < 5 ft below ground surface _____ Yes _____ No_____ Soil > 5 ft below ground surface _____ Yes _____ No

_____ Groundwater _____ Yes _____ No_____ Surface Water/Sediments _____ 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 thepotential to become impacted from migrating COCs via surface water runoff, air deposition,groundwater seepage, etc.

Exclude: wastewater treatment facilities and stormwater conveyances/impoundments authorized bypermit.

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 areultimately in contact with surface waters of the State; and

b. Not consistently or routinely utilized as valuable habitat for natural communitiesincluding birds, mammals, reptiles, etc.

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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_____ 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 migratedand resulted in a release or imminent threat of release to either surface waters or to their associatedsediments via surface water runoff, air deposition, groundwater seepage, etc.

Exclude: wastewater treatment facilities and stormwater conveyances/impoundments authorized bypermit.

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 areultimately in contact with surface waters of the State; and

b. Not consistently or routinely utilized as valuable habitat for natural communitiesincluding birds, mammals, reptiles, etc.

_____ Yes _____ No


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Explain: _____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

If the answer is Yes to Subpart A above, the affected property does not meet the exclusioncriteria. (However, complete the remainder of Part 2, to determine if there is a complete and/orsignificant 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 notattractive to wildlife or livestock, including threatened or endangered species (i.e., the affected propertydoes not serve as valuable habitat, foraging area, or refuge for ecological communities). May requireconsultation 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 orprocess 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 groundsurface or does the affected property have a physical barrier present to prevent exposure toreceptors to COCs in the surface soil?_____ Yes _____ No

Explain: ________________________________________________________________


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______________________________________________________________________________________________________________________________________________

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, QualitativeSummary 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 tothreatened/endangered or otherwise protected species. (Will likely require consultationwith 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 likelyrequire consultation with wildlife management agencies).

• There is no reason to suspect that the COCs associated with the affected property willmigrate 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 describedabove?

_____ 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 theaffected property, assuming the answer to Subpart A was No. (Complete Part 3, QualitativeSummary 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. Thissummary should include sufficient information to verify that the affected property meets or does not meet


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the exclusion criteria. The facility should make the initial decision regarding the need to conduct furtherecological evaluation based on the results of this worksheet. However, the State will make a finaldetermination on the need for further ecological assessment.

Note : the facility has the continuing obligation to re-enter the ERA process if changing circumstancesresult in the affected property not meeting the exclusion criteria requirements presented in thisworksheet.

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) whichcontains releases of chemicals of concern at concentrations equal to or greater than the assessment levelapplicable 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 affectedproperty assessments where the human health protective concentration level is established by Stateregulation or guidance .

Bedrock - the solid rock (i.e., consolidated, coherent, and relatively hard naturally formed material thatcannot normally be excavated by manual methods alone) that underlies gravel, soil, or other surficialmaterial.

Chemicals of concern - any chemical that has the potential to adversely affect ecological or humanreceptors due to its concentration, distribution, and mode of toxicity.

Community - an assembledge of plant and animal populations occupying the same habitat in which thevarious species interact via spatial and trophic relationships (e.g., a desert community or a pondcommunity).

Complete exposure pathway - an exposure pathway where a human or ecological receptor is exposed to achemical of concern via an exposure route (e.g., incidental soil ingestion, inhalation of volatiles andparticulates, consumption of prey, etc).


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De Minimus - the description of an area of affected property comprised of one acre or less where theecological risk is considered to be insignificant because the small extent of contamination, the absence ofprotected species, the availability of similar unimpacted habitat nearby, and the lack of adjacent sensitiveenvironmental areas.

Ecological protective concentration level - the concentration of a chemical of concern at the point ofexposure within an exposure medium (e.g., soil, sediment, groundwater, or surface water) which isdetermined to be protective for ecological receptors. These concentration levels are intended to beprotective for more mobile or wide-ranging ecological receptors and, where appropriate benthicinvertebrate communities within waters of the State. These concentration levels are not intended to bedirectly protective of receptors with limited mobility or ranges (e.g., plants, soil invertebrates, and smallrodents), particularly those residing within active areas of a facility, unless these receptors arethreatened/endangered species or unless impacts to these receptors result in disruption of the ecosystem orother unacceptable consequences fo the more mobile or wide-ranging receptors (e.g., impacts to an off-sitegrassland 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 mayoccur 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-wastefill 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 removalprocesses, and is made up of primarily of natural environmental material.

Exclusion criteria - those conditions at an affected property which preclude the need to establish aprotective concentration level for an ecological exposure pathway because the exposure pathway betweenthe 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 tochemicals of concern by human or ecological receptors occurs.

Facility - the installation associated with the affected property where the release of chemicals of concernhave occurred.

Functioning cap - a low permeability layer or other approved cover meeting its design specifications tominimize water infiltration and chemical of concern migration, and prevent ecological or human receptorexposure to chemical of concern, where design requirements are routinely maintained.

Landscaped area - an area of ornamental, or introduced, or commercially installed, or manicuredvegetation, 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.

Physical barrier - any structure or system, natural or manmade, that prevents exposure or preventsphysical 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 havea reasonable potential to come into contact with chemicals of concern. The point of exposure may be adiscrete point, plane, or an area within or beyond some location.

Protective concentration level - the concentration of a chemical of concern which can remain within thesource medium and not result in levels which exceed the applicable human health risk based exposure limitconsidering cumulative risk and hazard index for both carcinogenic and non-carcinogenic effectsrespectively, or ecological protective concentration level at the point of exposure for that exposurepathway.

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 aclaim 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 thoseterms identified by the Atomic Energy Act of 1954, as amended (42 USC 2201 et. seq.); ifthe release area is subject to requirements concerning financial protection established bythe Nuclear Regulatory Commission under Section 170 of that Act;

• for the purpose of the environmental response law Section 104, as amended, or otherresponse action, release of source, by-product, or special nuclear material from aprocessing site designated under Section 102(a)(1) for Section 302(a) of the Uranium MillTailings Radiation Control Act of 1978 (42 USC Section 7912 and Section 7942) asamended; 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). Dredgedsediments 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, andoverwintering. 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 sourcemedium may be the exposure medium for some exposure pathways.


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Stressor - any physical, chemical, or biological entity that can induce an adverse response; however, asused in this context, only chemical entities apply.

Subsurface soil - for human health exposure pathways, the portion of the soil zone between the base of thesurface soil and the top of the groundwater-bearing unit(s). For ecological exposure pathways, the portionof 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 feetin depth for residential land use and from ground surface to 5 feet in depth for commercial/industrial landuse; or to the top of the uppermost groundwater-bearing unit or bedrock, whichever is less in depth. Forecological 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 thedeveloped and undeveloped/ecological portions of the site. The checklist is patterned after ERAGSAppendix A - Checklist for Ecological Assessment/Sampling, June 1997 and consists of five majorsections: 1 - Site Description, 2 - Terrestrial Habitat Checklist, 3 - Aquatic Habitat Checklist (non-flowingsystems), 4 - Aquatic Habitat Checklist (flowing systems), and 5 - Wetlands Habitat Checklist. Answersto 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 unusualcircumstances which require professional judgement in order to determine the need for further ecologicalevaluation. Sources and general information available for the identification of ecological receptors andhabitats may include: the U.S. Fish and Wildlife Service (http://www.fws.gov), State Game and FishConservation Services, United States Geological Service (USGS), National Wetland Inventory Maps(http://nwi.fws.gov) National Audubon Society, National Biological Survey, national and local wildlifeclubs, National and State Heritage Programs, State and National Parks System, and tribal organizations.

Section 1. Site Description

1. Site Name:_______________________________________________________________

Location:______________________________________________________________________

_______________________________________________________________________

County/Parish:_____________________ City:_______________________ State:_____________

Type of Facility: _________________________________________________________________

http://www.fws.gov

http://nwi.fws.gov


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2. Latitude:______________________ Longitude:________________________

3. What is the approximate area of the site?_____________________________________________

4. Is this the first site visit? Yes _____ No _____. If no, attach trip report of previous site visit(s), ifavailable. Date(s) of previous site visit(s):______________________________

5. Please attach to the checklist USGS topographic map(s) of the site, if available.

6. Are aerial or other site photographs available? Yes ____ No ____. If yes, please attach any availablephoto(s) to the site map at the conclusion of this section.

7. The land use on the site is: The area surrounding the site is:________________ mile radius

_____ % Urban _____ % Urban_____ % Rural _____ % Rural_____ % Residential _____ % Residential_____ % Industrial __ light __ heavy _____ % Industrial __ light __ heavy_____ % Agriculture _____ % Agriculture(Crops: _______________________) (Crops: ______________________)_____ % Recreational _____ % Recreational(Describe; note if it is a park, etc.) (Describe; note if it is a park, etc.)______________________________ ___________________________________________________________ __________________________________ % Undisturbed _____ % Undisturbed_____ % Other _____ % Other

8. Has any movement of soil taken place at the site? Yes ___ No ___. If yes, please identify the mostlikely 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., Federaland State parks, National and State Monuments, wetlands, prairie potholes? Remember, flood plains andwetlands 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) ____________________________________________________________


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11. What are the suspected contaminants of concern at the site? If known, what are their maximumconcentration 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 ofthe 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: AquaticHabitat 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 alwaysobvious; do not answer “no” without confirming information. If yes, complete Section 5: Wetland HabitatChecklist. ___________________________________________________________________________________________________________________________________________________

18. If a field guide was used to aid any of the identifications, please provide a reference. Also, estimate thetime 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-15

______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

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 onthe site map which is attached to a copy of this checklist. Please identify what information was used todetermine 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 theacres 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-16

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

1. Are there open (bare, barren) field areas present at the site? Yes _____ No _____. If yes, please indicatethe 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 sitemap.

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 _____ Sparse _____ Patchy

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 forthis site. ______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________


B-17

Section 3. Aquatic Habitat Checklist – Non-flowing Systems

Note: Aquatic systems are often associated with wetland habitats. Please refer to Section 5, Wetland HabitatChecklist.

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 vegetationpresent, 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 _____ Other (specify) _______________________ Industrial discharge _____ Surface runoff

9. Is there a discharge from the site to the waterbody? Yes _____ No _____. If yes, please describe thisdischarge 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-18

11. Identify any field measurements and observations of water quality that were made. For those parametersfor 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 benthicmacroinvertebrates, 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 HabitatChecklist.

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-19

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 thisdetermination? _______________________________________________________________________________________________________________________________________________

7. Is the flow intermittent? Yes _____ No _____. If yes, please note the information that was used in makingthis determination. ______________________________________________________________________________________________________________________________________

8. Is there a discharge from the site to the waterbody? Yes _____ No _____. If yes, please describe thedischarge 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 parametersfor which data were collected, provide the measurement and the units of measure in the appropriate spacebelow:__________ 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 vegetationpresent, if known._____ Emergent _____ Submergent _____ Floating

13. Mark the flowing water system on the attached site map.


B-20

14. What observations were made at the waterbody regarding the presence and/or absence of benthicmacroinvertebrates, fish, birds, mammals, etc.? ________________________________________________________________________________________________________________________________________________________________________________________________

Section 5. Wetland Habitat Checklist

1. Based on observations and/or available information, are designated or know wetlands definitely present atthe site? Yes _____ No _____. Please note the sources of observations and information used (e.g., USGS Topographic maps, NationalWetland 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., standingwater; 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 _____ Whatis 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 _____ Groundwater_____ Flooding _____ Surface runoff


B-21

8. Is there a discharge from the site to a known or suspected wetland? Yes _____ No _____. If yes, pleasedescribe. ____________________________________________________________________________________________________________________________________________________

9. Is there a discharge from the wetland? Yes _____ No _____. If yes, to what waterbody is the dischargereleased?_____ 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 inthe 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.

029796-02 (1)

APPENDIX E

FACILITY DRAWINGS OF UNDERGROUND UTILITIES

LEGEND EXISTING FIRE HYDRANTEXISTING POWER POLE

EXISTING SIGNEXISTING WATER VALVE

EXISTING SANITARY SEWER MANHOLE

PROPOSED UNDERGROUND ELECTRICEXISTING OVERHEAD ELECTRICOE

UGE

FULL DEPTH SAWCUT LIMIT

GUY ANCHOR

WATER METER

EXISTING LIGHT POLE

POSTTREETELEPHONE MANHOLE

BENCHMARKPROPOSED FIRE HYDRANT

EXISTING FENCEPROPOSED GRATE INLET

UGE

UGE

UGE

UGE

UGE

EX. SLAG TREATMENT

BUILDING

RAW MATERIALSTORAGE ROOM

MAINTENANCEBUILDING

OFFICEBUILDING

EX. TRUCK SCALES

MAINTENANCESTORAGEBUILDING

EX. EMPLOYEEPARKING

PROPOSED POLE

PROPOSED 10 ' WIDEELEC. EASEMENT

PROP.SWITCHGEAR

PROP.2 EA-2000 KVA TRANS.

PROP.2500 KVATRANS.

PROP. BATTERYBREAKER

EXTENSION

EX. CONC.TRUCK

PARKING

EX. RAILROAD SPUR

EX. ASPHALT DRIVE

EX. CONC. ACCESS ROADEX. CONC. ACCESS ROAD

EX. CONC. ACCESS ROAD

PROP. TRUCKSCALE

PROP. LOADING DOCKS& TRUCK WASH

FEMA

FEMA 100-YR FLOODPLAIN

FLOODPLAIN LIMIT100-YR

PROP. CONC. PAVINGFOR TRUCK TURN AROUND

AT LOADING DOCKS

PROP. CONC.PARKING LOTEXPANSION

PROP. SLAGTREATMENT

BUILDING

APPROX. LIMITS OFCLOSED DISPOSAL AREA

OXIDE ROOM

REVERB FURNACE/REFINING/CASTING ROOM

BLAST FURNACEFEED ROOM

BATTERY BREAKER BUILDINGBATTERY STORAGE AREA

PROP. WINDBREAK

EX

. EA

GA

N

WA

Y

PARKWOOD BLVD

CO

NC

RE

TE

DR

IVE

WA

Y

23 LIMIT

(24,370 SF) (23,514 SF)

(14,973 SF)

(7,526 SF)

(15,776 SF)

(22,934 SF)

(17,384 SF)

(2,572 SF)

(7,996 SF)

5

4

37

21

3

8

14

(1,875 SF) (1,209 SF)

EX. FIRETRAINING

BLDG.

PROP 100-YR FLOODPLAIN LIMITPROP. CONDITIONS 100-YR FLOODPLAIN (S

EE

NO

TE

1)

PROP. CONDITIONS100-YR

FLOODPLAIN

(SEE NOTE 1)

PROP. COOL DOWNROOM & RESTROOMS

PROP. TRUCKSCALE

PROP.SECONDARY FILTRATIONFOR EXIST. PROCESSES

AND EQUIPMENT

PROP. DUSTCOLLECTOR WITH

SECONDARYFILTRATION FOR

BATTERY BREAKERBLDG

PROP. ELECTRICALEQUIPMENT ENCLOSURE

FFE=641.80

PROP.SECONDARY FILTRATION FOR

EXIST. PROCESSES ANDEQUIPMENT

PROP. DUSTCOLLECTORS FORREVERB/REFINING/CASTING ROOMS

PROP. DUSTCOLLECTORS AND


SLAG TREATMENTBUILDING

PROP.SECONDARY

FILTRATION FOROXIDE ROOM

PROP. CONC.

PROP. CONC.

PROP. CONC.

PROP.BUILDING

ENCLOSURE

PROP. CONC.

PROP. CONC.

(PRIVATE ROAD)

(PR

IVA

TE

RO

AD

)

W.W

.T.P.

STEWART CREEK

EX. CRYSTALLIZER WAY

EX. ELEC.EQUIPMENT

PROP. BUILDINGENCLOSURE



BLAST FURNACE FEEDROOM

(14,905 SF)

ZONED"I"

ZONED"SF"

(PD-125)ZONED"O-2"

(PD-124)

ZONED"O-2"

(PD-123)

ZONED"O-2"

(PD-121)

ZONED"O-2"

(PD-122)

ZONED"AG"

ZONED"I"

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

(PD-46)

PROJECT LOCATION

A

B

C

D

E

F

DE

SC

RIP

TIO

NR

EV

REVISION

SHEET NUMBER:

DRAWING NUMBER:

DRN: DES: CHK: APP:

ISSUE DATE:

1 2 3 4 5 6 7 8

1 INCH AT FULL SCALE

PR

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ME

NT

SC

ITY

OF

FR

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O, C

OL

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. CO

, TX

EX

IDE

TE

CH

NO

LOG

IES

NA

AQ

S P

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11/11/2011

A

60

21

39

72

AH RH NRB NRB

FR

ISC

OR

EC

YC

LIN

G C

EN

TE

RF

RIS

CO

, TX

16

00

0 D

AL

LA

S P

AR

KW

AY

, ST

E 3

500

(97

2)

73

5-3

000

ww

w.a

ecom

.com

TB

PE

RE

G. F

-358

0

CITY OF FRISCO STANDARD SITE PLAN NOTES

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.

- PERTAINS TO NEW BUILDINGS.

C1

000-C-01

PR

EL

IMIN

AR

Y S

ITE

PL

AN

A

ISS

UE

D F

OR

CIT

Y S

UB

MIT

TA

LA

HR

HN

B1

1/1

1/1

1

SITE DATA SUMMARY TABLEZONING "I", "AG", "O-2"

PROPOSED USE

LOT AREA (AC)

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)

230.692

169,134

73'-4" (NOMINAL)

169,134

22%

115

115

5

5

0

670,191

SITE AREA (AC) 18.0 ±

LOCATION MAPZONING MAP

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.

NOTE: PURSUANT TO EXIDE TECHNOLOGIES' RIGHTS AS AGRANDFATHERED PROJECT, THE USE IS A HEAVY MANUFACTURINGOR INDUSTRIAL USE MEETING PERFORMANCE STANDARDS IN THEHEAVY INDUSTRIAL DISTRICT UNDER ORDINANCE NO. 196. IN THEALTERNATIVE, EXIDE TECHNOLOGIES' USE IS A RECYCLING PLANTUNDER ORDINANCE NO. 11-04-09.

LOT AREA (SF) 10,048,944

SITE AREA (SF) 784,000

OPEN SPACE REQUIRED (SF) 0

**

**

*

*

UG

E

UGE

UGE

UGE

UGE

UGE

UGE

W.W

.T.P.

EX. SLAG TREATMENT

BUILDING


MAINTENANCEBUILDING

OFFICEBUILDING

EX. TRUCK SCALES

MAINTENANCESTORAGEBUILDING

EX. EMPLOYEEPARKING


EXTENSION

EX. CONC.TRUCK

PARKING

EX. ASPHALT DRIVE

ACCESS ROADEX. CONC. ACCESS ROAD

PROP. TRUCKSCALE

PROP. BAGHOUSE ACCESS ROAD

FEMA

FEMA

100-YR FLOODPLAIN LIMIT


PROP. CONC. PAVINGFOR TRUCK TURN AROUND

AT LOADING DOCKS

PROP. CONC.PARKING LOTEXPANSION

PROP. SLAGTREATMENT

BUILDING

APPROX. LIMITS OFCLOSED DISPOSAL AREA

OXIDE ROOM


BLAST FURNACE FEED ROOM

BATTERY BREAKER BUILDING

EX. CONC.

ACCESS ROAD

EX. CONC.

PROP. PARKING

EX

. EA

GA

N

WA

Y

(PRIVATE ROAD)

(PR

IVA

TE

RO

AD

)

CONDITIONS 100-YR FLOODPLAIN

PROP. DUSTCOLLECTORS FORREVERB/REFINING/CASTING ROOMS

PROP.SECONDARY

FILTRATION FOROXIDE ROOM

CONDITIONS100-YR

FLOODPLAIN



SLAG TREATMENTBUILDING




PROP. DUSTCOLLECTOR WITH


BATTERY BREAKERBLDG

PROP. ELECTRICALEQUIPMENT ENCLOSURE

PROP. LOADING DOCKS& TRUCK WASH


EXTENSION

PROP. COOL DOWNROOM & RESTROOMS

EX. RAILROAD SPUR

BATTERY STORAGE AREA

STEWART CREEK

CRYSTALLIZER WAY

PROP. TRUCKSCALE

PROP.SECONDARY FILTRATIONFOR EXIST. PROCESSES

AND EQUIPMENT

PROP.BUILDING

ENCLOSURE

PROP. BUILDINGENCLOSURE

PROP. WINDBREAK

PROP.

CONDITIONS

PROP.

100-YRFLOODPLAIN

SIGNBOLLARDFIRE HYDRANT

TREE (TO REMAIN)

IRRIGATION CONTROL VALVE

POWER POLE

GUY WIRE

MONITORING WELLELECTRICAL LINE

TYPICAL TRAFFIC FLOW

HEAVY DUTY 8" 5000 PSI REINFORCED CONCRETE WITH#5 BARS (GRADE 60) ON 12" CENTERS, BOTH WAYSON LIME TREATED SUBGRADE (SEE NOTE 1).

LEGEND .

LIGHT DUTY 6" 3500 PSI REINFORCED CONCRETE WITH#3 BARS (GRADE 60) ON 18" CENTERS, BOTH WAYSON LIME TREATED SUBGRADE (SEE NOTE 1).

PARKWOOD

BLVD

A

B

C

D

E

F

DE

SC

RIP

TIO

NR

EV

REVISION

SHEET NUMBER:

DRAWING NUMBER:

DRN: DES: CHK: APP:

ISSUE DATE:

1 2 3 4 5 6 7 8


PR

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OF

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ISC

O, C

OL

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. CO

, TX

EX

IDE

TE

CH

NO

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IES

NA

AQ

S P

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GR

AM

11/11/2011

A

60

21

39

72

AH RH NRB NRB

FR

ISC

OR

EC

YC

LIN

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EN

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RF

RIS

CO

, TX

16

00

0 D

AL

LA

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(97

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C3

000-C-03

PR

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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 OFNON-WOVEN GEOTEXTILE ON TOP OF SUBGRADE AFTER PROOF-ROLLING.

MA

TC

H L

INE

SE

E T

HIS

SH

EE

T

MA

TC

H L

INE

SE

E T

HIS

SH

EE

T

EXISTING FIRE HYDRANT

EXISTING POLE

EXISTING SIGN

EXISTING WATER VALVE


PROPOSED ELECTRIC

EXISTING OVERHEAD ELECTRICOE

UGE

GUY ANCHOR

WATER METER

EXISTING LIGTH POLE

POST

TREE

TELEPHONE MANHOLE

BENCHMARK

PROPOSED WATER HYDRANT

LEGEND .

UG

E

UGE

UGE

UGE

UGE

UGE

UGE

W.W

.T.P.

SLAG TREATMENT

BUILDING


MAINTENANCEBUILDING

OFFICEBUILDING

EX. TRUCK SCALES

MAINTENANCESTORAGE BUILDING

EX. EMPLOYEEPARKING

STEWART CREEK

PROP.BATTERYBREAKER

EXTENSION

EX. RAILROAD SPUR

EX. ASPHALT DRIVE


PROP. TRUCKSCALE

FEMA

FEMA



PROP. SLAGTREATMENT

BUILDING

OXIDE ROOM



BATTERY BREAKERBUILDING


PROP. WINDBREAK

EX

. EA

GA

N

WA

Y

EX

. EA

GA

N

WA

Y


(PRIVATE ROAD)

(PR

IVA

TE

RO

AD

)


FLOODPLAIN

PROP.

CO

ND

ITIO

NS

100-

YR

FLO

OD

PLA

IN

PROP 36" SD

Q100 = 44.05 CFS

PR

OP

36" SD

Q1

00

= 4

2.53

CF

S

PROP 18" SDQ100 = 7.64 CFS

PR

OP

36" SD

Q1

00

= 4

1.43

CF

S

PROP 36" SD

Q100 = 33.79 CFS

PROP 30" SD

Q100 = 28.49 CFS

PROP 24" SD

Q100 = 21.51 CFS

PR

OP

18" SD

Q1

00

= 1

0.32

CF

S

PROP 24" SDQ100 = 19.26 CFS

PROP 18" SDQ100 = 5.25 CFS

PROP 18" SDQ100 = 2.25 CFS

PROP 18" SD

Q100 = 5.30 CFS

36" FL = 626.3

PROP. M.H.RIM = 633.9

36" FL = 627.1

PROP SUMPFL=626.0TOP=631.0

PROP 8" SD

PR

OP

8"

SD

PRO

P 12"

SD

PROP 8" SD PROP 12" SD

PROPINLET

PR

OP

8"

SD

A18.87

A20.47

A30.39

B12.51

A41.08

B20.22

A18.99

A30.63

A50.27

A41.24

A20.44

A60.84

A70.58

A80.06A11

0.18

A91.13

A100.13

PROP INLETTOP=640.118" FL N=635.612" FL SE=636.18" FL SW=636.4

PROP MHRIM=640.124" FL E=633.030" FL W=632.5

EX. INLETS(TO BE REMOVED)

PROP INLETTOP=639.318" FL NW=634.812" FL S=635.3

PROP INLETTOP=637.518" FL=633.0

PROP INLET24" FL=633.5TOP=640.8

EX 36" FIBERGLASS

PROP.

ONS100-YR

FLOODPLAIN

TIONC

DI

EX. SUMP

EX

12"

SD

EX. 12" SD

EX. RETAINING WALL

EX. RETAINING WALL

DRAINS TOSTORMWATER

RETENTION POND

PROP 12" SD

EX. RET. WALLT/W=636.7±

EX. RET. WALLT/W=636.7± CHANGE IN

RET WALL HT.

EX. RET. WALLT/W=638.2±

EX. INLET(PLUGGED)

EX. INLET(PLUGGED)

EX. INLET(PLUGGED)

EX. INLET(PLUGGED)

PROPINLET

PROP MHRIM=642.224" FL N=634.218" FL SE=634.718" FL SW=637.7

18" FL=640.0

EX. 36" CMPTO BE REMOVED

PROP INLETTOP=639.930" FL=632.9

EX. 18' CMP(TO BE REMOVED)

36" FL W=631.430" FL E=631.918" FL SE=632.9PROP MH

RIM=640.536" FL S=631.036" FL W=631.018" FL W=632.5

PROP TRENCHDRAIN

PROP TRENCHDRAIN

PROP TRENCHDRAIN

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B12.51

A50.27

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

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

DRAINAGE LEGEND

Existing Condition Runoff Calculations

Area Tc I100 Q100

acres min in/hr cfsA1 8.87 0.92 10 8.74 71.08 Sheet flow to Exist 36" SD, which discharges to Stormwater Retention PondA2 0.47 0.95 10 8.74 3.92 Exist 10' Curb Inlet; drains to sump at Exist 36" SDA3 0.39 0.95 10 8.74 3.25 Exist 10' Curb Inlet; drains to sump at Exist 36" SDA4 1.08 0.73 10 8.74 6.89 Exist 12" CMP; drains to sump at Exist 36" SD

Total A 10.81 85.14

B1 2.51 0.42 10 8.74 9.13 Exist 36" CMP; drains into Stewart Creek Tributary 4B2 0.22 0.35 10 8.74 0.67 Exist 15" CMP; drains into DA B1

Total B 2.73 9.80

ID C Comments

Proposed Condition Runoff Calculations

Area Tc I100 Q100

acres min in/hr cfsA1 8.99 0.92 10 8.74 72.11 Sheet flow to Exist 36" SD, which discharges to Stormwater Retention PondA2 0.44 0.95 10 8.74 3.69 East/west access road, East of Prop Slag Treatment BldgA3 0.63 0.95 10 8.74 5.25 Open area North of Oxide RoomA4 1.24 0.95 10 8.74 10.32 Paved area East of Prop Slag Treatment BldgA5 0.27 0.95 10 8.74 2.25 Open area North of Blast FurnaceA6 0.84 0.95 10 8.74 6.98 Prop Slag Treatment Bldg, east/west access road sump areaA7 0.58 0.95 10 8.74 4.78 Paved area North of Battery Breaker BldgA8 0.06 0.95 10 8.74 0.51 Prop Loading Docks at Battery Breaker BldgA9 1.13 0.78 10 8.74 7.64 Fire Lane Turnaround areaA10 0.13 0.95 10 8.74 1.10 Prop Loading Docks at Battery Storage AreaA11 0.18 0.95 10 8.74 1.52 Battery Breaker Expansion

Total A 14.50 116.16

ID C Comments

Runoff Volume ComputationsPlant

InteriorArea

StormwaterRetention

Pond14.50 2.30

92% 100%9.84 9.84

10.94 1.89

Plant Interior Area Volume (acre-ft)Stormwater Retention Pond Volume (acre-ft)

Area (ac)Percent Runoff100-yr, 24 hr Rainfall Depth (in)Runoff Volume (acre-ft)

12.82

100-yr Ponding Elevation4 634.72.5410.28

Total Runoff Volume (acre-ft)

Plant Interior Area Storage Stormwater Retention Pond Storage

ElevationVolume1

(acre-ft) ElevationVolume(acre-ft)

631.0 0.00 629.0 0.00632.0 0.10 630.0 1.65633.0 0.44 631.0 3.37634.0 1.41 632.0 5.17635.0 3.04 633.0 7.05636.0 5.18 634.0 9.00

636.72 6.80 635.03 11.00

Adequacy of Existing Drainage System to Handle Proposed Runoff Volume

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.

NOTES: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

NOTE:1 ALL PROPOSED RUNOFF ENTERS THE PLANT'S STORMWATER RETENTION POND. THERE ISNO DIRECT RELEASE OF STORMWATER RUNOFF INTO STEWART CREEK.

EXISTING FIRE HYDRANT

EXISTING POLE

EXISTING SIGN

EXISTING WATER VALVE


PROPOSED ELECTRIC

EXISTING OVERHEAD ELECTRICOE

UGE

GUY ANCHOR

WATER METER

EXISTING LIGTH POLE

POST

TREE

TELEPHONE MANHOLE

BENCHMARK

PROPOSED WATER HYDRANT

LEGEND .

UG

E

UGE

UGE

UGE

UGE

UGE

UGE

W.W

.T.P.

SLAG TREATMENT

BUILDING


MAINTENANCEBUILDING

OFFICEBUILDING

EX. TRUCK SCALES

MAINTENANCESTORAGE BUILDING

EX. EMPLOYEEPARKING

STEWART CREEK

PROPOSED 10 ' WIDEELEC. EASEMENTPROP.

2 EA-2000 KVA TRANS.

PROP.2500 KVATRANS.

EX. RAILROAD SPUR

EX. ASPHALT DRIVE


PROP. TRUCKSCALE

FEMA

FEMA



OXIDE ROOM


BLAST FURNACE FEED ROOM

BATTERY BREAKER BUILDING


PROP. WINDBREAK


EXTENSION

PROP. SLAGTREATMENT

BUILDING

PROP. ELECTRICALCONDUIT (2 EA.-4" PVC)

FOR SIGNAL HEAD


FLOODPLAIN

PROP.CONDITIONS

100-YRFLOODPLAIN

PROP.

CO

ND

ITIO

NS

100-

YR

FLOODPLAIN

PROP.

ONS100-YR

FLOODPLAIN

TIONC

DI

PROP. ELECTRICALEQUIPMENTENCLOSURE

PROP.SWITCHGEAR

EX

. EA

GA

N

WA

Y


(PRIVATE ROAD)

(PR

IVA

TE

RO

AD

)

PROP. ELECTRICALCONDUIT (2 EA.-4" PVC)

FOR TRUCK SCALE

PROP. COOL-DOWNROOM AND

RESTROOMS

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SC

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1GENERAL NOTES

1. THE PROPOSED 8 INCH FIRELINE IS INTENDED TO BE PRIVATE AND MAINTAINED BY THEOWNER.

2. DOMESTIC WATER SOURCE TO BE PROVIDED THROUGH INTERIOR BUILDING CONNECTIONSON METERED "HOUSE SIDE" WATER LINES. ADDITIONAL PLANT WATER SUPPLIES MAY ALSOBE UTILIZED.

3. THE PROPOSED SANITARY SEWER LATERAL UTILIZES AN EXISTING MANHOLE CURRENTLYSERVING THE PLANT. OTHER EXISTING BUILDINGS ARE SERVED VIA A SEPARATE EXISTINGCONNECTION.

029796-02 (1)

EXHIBIT 1

PRELIMINARY SCHEDULE

PRELIMINARY SCHEDULE(1)(2)

SAMPLING AND ANALYSIS WORK PLANEXIDE TECHNOLOGIES

FRISCO, TEXAS

Week

Task Description Duration 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

1Site Characterization Field Work Preparation

4 weeks

2

Establishing Background Sampliing Locations and Obtaining Access Agreements

4 weeks

3Site Characterization Field Work

6 weeks

4 Laboratory Analysis 4 weeks

5 Data Validation 3 weeks

6 Report Preparation 4 weeks

7Submittal of the Report to USEPA

1 day

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

Documents

Proposed Exide Sampling Plan