Corrective Action Plan Memorandum by pjx11396


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To:           Case File #04-104

Through:      James Shell, Chief
              Regulated Storage Tank Division

From:         Technical Branch Staff,
              Regulated Storage Tank Division

Date:         July 3, 2003

Subject:      Corrective Action Plan
              Shell SuperStop #102
              Rogers, AR
              ID #04000030

After a period of interim hazard abatement and remedial investigation, we have concluded a
corrective action plan is necessary for the referenced site. This document describes how the case
developed, where the Department’s regulatory interest lies, and what goals we propose for a

This case came to our attention on June 18, 2002, when employees of the Northwest (Goodyear)
Tire Service located just south (across New Hope Road) of the SuperStop #102 reported that
gasoline vapors were accumulating in the men’s restroom. The complaint was made to the
facility. The facility notified the owner/operator (O/O), and the O/O reported the problem to
ADEQ immediately.

On that same date, an investigation conducted by the ADEQ-RST area inspector discovered a
leaking O-ring on the submersible pump unit serving the unleaded regular-grade UST. The UST
system was taken out of service.

The O-ring was replaced; the UST system was tested and returned to service on June 19, 2002.
Also on that date, a contractor/consultant retained by the O/O arrived on the site to begin a
preliminary investigation and abatement measures.

During this period (the exact time is unknown), the Northwest Tire Service arranged for a
plumber to come in and replace the seal under the water closet in the men’s restroom. After this
repair, vapor accumulation in the building diminished sharply.
The O/O concluded the vapors were entering the buildings by advective vapor transport along
utility conduits, and immediately set about installing a soil vapor extraction trench just down-
gradient from the UST tankhold. The trench was completed by 6/21/02. However, the vacuum
blower was not installed until 8/28/02. Continuous vapor recovery began on that date.
Attachment #3 provides an accounting of the recovery to date.

On 6/21/02, ADEQ requested a source investigation, preparatory to remediation. The
investigation was reported out on 8/9/02. Although the O/O did not completely characterize the
source (only on-site sampling was done), sufficient work was done to fill out a working site
model, and much of the information has been used in this plan.

On 10/4/02, after meeting with ADEQ-RST technical staff, the O/O proposed an additional
investigation to meet the goals of ADEQ’s 6/21/02 request, and to continue the vapor extraction
program. ADEQ has not yet responded to this proposal.
The following profiles summarize what is currently known about the facility and the releases
which are the concern of this document. A reasonably complete investigation has been
conducted for this site, and more-detailed information can be found in the case file for the

       Facility Profile
       The SuperStop #102 is a C-store/retail gasoline operation on the NE corner of US 71
       Business and New Hope Road (aka Arkansas Highway 94) in the southern part of
       Rogers, AR. A copy of the area map is included as Attachment #1.

       The current USTs serving the facility were installed in 1982 on a clean site, and updated
       by impressed current cathodic protection on 2/19/02. Three twelve thousand gallon tanks
       store three grades of unleaded gasoline. Pressurized FRP product lines serve four MPD
       islands in front of the store. Leak detection is Statistical Inventory Reconciliation.
       Attachment #2 provides a facility plan view.

       Release Profile
       The contaminants of concern are gasoline range organics. An inspection of the inventory
       records for the twelve-month period prior to the release indicated a cumulative shortage
       of about 1,910 gallons of unleaded regular gasoline. As of this writing, about 980 gallons
       equivalent product has been recovered by the abatement program.

       Insufficient information is available to estimate the remaining mass of contaminant.
       While inventory records for the facility are available and in fairly good shape, this facility
       has a history of releases, including one (LUST #04-003) in 1988 which was prosecuted
       by ADEQ as a clean-up.

       Anecdotal reports are available of sporadic vapor accumulations over the last few years
       in the Northwest Tire Service shop and also in a telephone vault south of the SuperStop
       along the east side of US 71B.

       Physical/Geological Profile
       The facility is located directly on cherty residual soils of the Boone Limestone. There are
       two geologic/hydrogeologic horizons beneath the site.

       The uppermost horizon is an epi-Karst zone, reaching from the ground surface (around
       1360’ AMSL in the study area) down to an average of about 7 to 10’ bgs. The soils are
       residual clays with varying amounts of cherty gravel, in some parts of the site reworked
       by construction activities. About two feet of fill material similar to the native soil is
       present in the southern portion of the facility, for example.

       Standing groundwater is found in this horizon for a short time after rainfall events.
       Otherwise, a water-moist zone is present at near-saturation levels reaching from about 4
       to 6’ bgs down to the top of the competent rock. Recharge of this unit is by direct
infiltration, and discharge is by seepage into the competent Boone Limestone horizon

Soil samples collected from this zone demonstrate elevated concentrations of COCs over
much of the facility area, and the soils of this interval are believed to be the “source”
which must be addressed.

Significant horizontal contaminant movement within the epi-Karst horizon has been
verified. While groundwater discharge from this horizon is ultimately downward, there is
also a significant horizontal component to groundwater advection which is believed to be
the transport mechanism for contaminants to reach the nearby utilities. It is also probable
that preferential pathways have been created by construction rework and site utility
installation, and these pathways are influencing the direction and speed of the horizontal

The Boone Limestone is the dominant surface formation in the area, comprising a
relatively flat-lying plateau, with erosional features (streambeds and remnants of
overlying formations) providing topographical relief.

Groundwater in the Boone Limestone is recharged by direct infiltration and seepage from
overlying residual soils. Discharge from this unit provides base flow to perennial streams
such as (in this case) Prairie Creek, and springs, such as Diamond Spring, both to the
northeast into the Beaver Lake Basin.
The facility is located in a well-developed commercial area in southern Rogers. The
nearest residences are about ½ mile away, well outside the impact area. Attachment #1 is
a map of the study area.

Human Exposure Profile
It is likely that some contamination from the site is making its way into the regional
(Boone) aquifer. However, there is no beneficial use of this unit by human receptors near
enough to be impacted by contaminants from this facility.

The only known human exposure is to gasoline vapors accumulating in nearby buildings.
The release came to our attention due to complaints of gasoline vapors in two businesses
across Arkansas Hwy 94, to the south of the facility.

Investigation conducted for the initial response action confirmed the vapors were entering
the buildings through their sanitary sewer connections. A plumbing seal was replaced in
the Northwest Tire Service facility, and we have received no further complaints.
However, vapors continue to be present in the headspace of the sanitary sewer, and
further impacts are possible with the deterioration of the plumbing systems for the
affected buildings.

Also possible is attainment of explosive vapor levels in the sewer itself. While direct
public safety consequences from this condition are unlikely, an explosion could endanger
utility workers, and at the very least, result in fairly extensive damage to the sewer itself.

Since there is a strong correlation between rainfall events and the concentrations of
vapors in the sewer, ADEQ has concluded the source of the vapors in the sanitary sewer
is most likely to be contaminated groundwater and/or product infiltrating the sewer at
some point. The City of Rogers has indicated the sewer line serving this area is in poor

Ecological Profile
Although not verified by sampling, it is probable that some level of dissolved-phase
contamination from the site is making its way into the regional aquifer. While there is
substantial discharge to nearby waters of the state from the Boone unit (to springs and
stream underflows), we do not believe regulated substances from the release are reaching
known discharge points at this time. A discharge is possible in the future, however, if the
source is not remediated.
Conceptually, the goals for the corrective action are to –

    •   Control human health exposures to harmful levels of regulated substance vapors in the
        study area. As a practical matter, any level of exposure above the odor threshold will be
        unacceptable. Since a critical element in the exposure pathway is the sanitary sewer, and
        since impacts to sanitary sewers are undesirable in and of themselves, attainment of this
        goal will be measured by monitoring the headspace of the sanitary sewer.

    •   Prevent the spread of contaminants beyond the currently-impacted area and protect the
        resource value of the Boone groundwater unit by identification and remediation of
        source materials on the regulated facility and adjacent areas.

Specific goals of the project are:

   •    Attainment of the ATSDR odor threshold (0.025 ppm-v) for automotive gasoline
        (Gasoline Range Organics) in the headspace of the sanitary sewer line serving the
        immediate area.

   •    Attainment of the non-aqueous phase liquid (NAPL) equilibrium concentration of
        Gasoline Range Organics (GRO) in the residual soils of the facility and surrounding area.
        This value is tentatively set at 500 mg/kg, although it may be modified by site-specific
        information developed during design of the remedial work plan. Alternately, an easier-
        measured surrogate indicator of attainment (such as soil vapor) may be adopted.

   •    Attainment of the specific goals described above within 36 months of ADEQ approval of
        the Corrective Action Plan.

   •    Verification of the attainments described above by not less than two years of post-
        remediation monitoring.
In order of priority, the following actions must be taken to meet the goals of the CAP:

   •   Offer the Draft CAP for public participation.

   •   Design and implement a remedy for the source of the contamination, including provisions
       for monitoring/reporting progress toward the goals. A work plan for this task will be
       required, and the proposed remedy must be public noticed.

   •   After the remedy has been fully implemented, conduct post-remediation monitoring to
       verify long-term attainment of the goals.

   •   At the successful conclusion of the post-remediation monitoring period, decommission
       the corrective action program.

   •   Issue a no further action letter to close out the project.
Review/comment on this proposed Corrective Action Plan will be solicited in two ways:

   •   A hard-copy of the Draft CAP will be sent under cover letter to the stakeholders directly
       impacted. These include the Owner/Operator, the Benton County Environmental Affairs
       office, the Rogers Water and Sewer Utility, and all landholders in the general vicinity of
       the release. A list of the proposed addressees is found in Attachment #4.

   •   A notification of the availability of the Draft CAP for review and invitation to comment
       will be made by a legal notice advertisement in a newspaper of general circulation in the
       area. This action will be taken by the O/O, at the request of ADEQ, according to the
       procedure outlined in Attachment #5.

The comment period will be thirty days, measured from the date upon which all stakeholders are
notified. Comments should go to:

              Mr. Mike Shinn
              Regulated Storage Tank Division
              Arkansas Dept. of Environmental Quality
              P.O. Box 8913
              Little Rock, AR 72219-8913
              (501) 682-0989

Comments may be received by ADEQ staff in any form, but only those attributable to specific
persons and in writing will enter the casefile to be formally considered.

At the end of the comment period, the comments will be evaluated by the technical staff of the
RST Division, and if significant changes are advised, a new Draft CAP will be advertised.
Otherwise, the CAP will be finalized, and work plans to implement the specified tasks will be
requested in writing from the O/O.
Attachment #1
Attachment #2
Attachment #3
Attachment #4
Following is a list of proposed stakeholders for public notice by direct mail-out.

Mr. Tom McAlister
Rogers Water and Sewer Utility
P.O. Box 338
Roger, AR 72757

Mr. Mark Simpson
Coulson Oil Company
P.O. Box 68
North Little Rock, AR 72115

Mr. Al Inman
Northwest Tire Service
P.O. Box 293
Rogers, AR 72756
(479) 636-8018

Mr. Tom Peterson
Ben Jack’s Arkansas Music
732 West New Hope Road
Rogers, AR 72756
(479) 636-1125

Mr. Jim Ecker
Benton County Environmental Affairs
215 East Central, Suite 8
Bentonville, AR 72712
(479) 271-1083

Mr. Clayton Eversole
P.O. Box 183
Rogers, AR 72757
(479) 271-7758
Attachment #5

After a Corrective Action Plan has been drafted for a site, ADEQ will cause to be placed by the
responsible party a legal notice in a newspaper of general circulation in the area adjacent to and
directly affected by the release. In the absence of a local newspaper, the state-wide newspaper
may be selected.

The advertisement should only run one day. If it runs more than one day, the start of the
comment period will be the last day the advertisement appeared.

The legal notice must be substantially in the form below:


                             STATE OF ARKANSAS

The Arkansas Department of Environmental Quality gives notice that a Corrective Action Plan
has been drafted for the Shell SuperStop #102 facility, located at the intersection of US Hwy 71B
and New Hope Road in Rogers, Arkansas. Pursuant to Title 40 Part 280.67(b), the Draft
Corrective Action Plan is available for public inspection during normal business hours at:

                       Arkansas Department of Environmental Quality
                       Regulated Storage Tank Division
                       8001 National Drive
                       Little Rock, AR 72209
                       Case File #04-104

Public comment on authorization, according to the procedures in the Draft Plan, will be received
by the Department for not less than 30 days from the date of this advertisement.

ADEQ may authorize implementation of the Corrective Action Plan before the public comment
period is completed, if such action is necessary to protect public health and welfare.

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