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RESPONSE ACTION CLOSURE REPORT

6600 BANDERA SAN ANTONIO, TEXAS

VCP # 073

TABLE OF CONTENTS

I. DESCRIPTION OF ACTIVITY

II. LETTER FROM INDEPENDENT CONSULTANT

III. CONSENT LETTER FROM PROPERTY OWNERS

IV. PHOTOGRAPHS OF COVER SYSTEMS

V. METES AND BOUNDS DESCRIPTION OF COVER SYSTEMS WITH SURVEY MAP

1.0 INTRODUCTION

This report was prepared to demonstrate completion of required remediation activities at the Pilgrim Enterprise facility located at 6600 Bandera Road. This report provides the following information:

Section 1.0: Introduction - provides a brief overview of this document.

Section 2.0: Site Background - provides a description of the site, historical activities and a list ofreports generated for the Voluntary Cleanup Program (YCP).

Section 3.0: Investigation - provides a brief overview ofhistoricaI sampling activities completed at the site in support of closure activities for the VCP.

Section 4.0: Response Action - provides a detailed description of the response action completed at the site.

Section 5.0: Deed Recordation - provides a copy of the proposed language which will be included in Deed.

Response activities at this site were limited to the installation of a cap and cover system which was to prevent migration through direct contact and volatilization. In addition, the cap was designed to eliminate infiltration that will reduce migration to groundwater. The site was closed under Texas Risk Reduction Standard No.3 following the applicable requirements of30 TAC 335 Subchapter S. The response action was completed during the second quarter of 1996.

2.0 SITE BACKGROUND

The site is located at 6600 Bandera Road (Figure I) in Bexar County, Texas. The site is approximately 1/2 acres . Pilgrim built the facility in 1985 . Prior to this date no known commercial or industrial activities were conducted on this site. Figure 2 is a map of the features of the site. Pilgrim operated a dry-cleaning and laundry service at this location and routinely used chlorinated solvents in the dry-cleaning process .

The following is a complete list of reports generated during the Response Action at this facility

• Phase I ESA • Phase II Limited ESA • RMT/Jones & Neuse, Inc. Corrective Measures Study, June 1995 • RMT/Jones & Neuse, Inc. Remedial Investigation Report, June 1995 • RMT/Jones & Neuse, Inc. Risk Reduction Standard Number 3 Baseline Risk Assessment for

Soil and Groundwater Impacted with Dry Cleaning Solvents - 6600 Bandera Road. June 1995

REPORT.DOC

3.0 REMEDIAL INVESTIGATION SUMMARY AND CONCLUSIONS

The following sections sununarize the data obtained during the RI and contain the conclusions that were derived from the investigation.

3.1 Remedial Investigation Summary

The following three sections contain a summary of the soil boring, and ground-water investigations implemented during the RI .

3 .1.1 Shallow Soil Boring Investigation

Shallow soil sample laboratory analytical results indicate that PCE, TCE, and 1,2-DCE (total) are present in the shallow soil under the facility building in the vicinity of the dry cleaning equipment. Only PCE was detected in the shallow soil samples in concentrations greater than the GWP. No target compounds were detected in the shallow soil samples in concentrations greater than the SAI­Residential. Physical limitations of the facility building and equipment and hand auguring depth limitations prevented the full vertical delineation of impacted shallow soils beneath the facility .

3 .1.2 Subsurface Soil Boring Investigation

The RI soil boring investigation revealed that the subsurface soils at the site have been impacted by PCE, TCE, and 1,2-DCE (total) . No target compounds were detected in the subsurface soil samples in concentrations greater than the applicable GWP or SAl-Residential. The impacted soils are summarized as follows:

PCE was detected in the subsurface soil samples collected from the soil boring for B2 at 5 feet below ground level (BGL), at a concentration of 0.05 mglkg. In soil boring B4, PCE was detected in soil samples collected from 4 feet and 7 feet BGL at concentrations of 0 .06 mglkg and 0.1 mglkg, respectively. PCE also was detected in the subsurface soil samples taken from the soil boring B5 at depths of 5.5 feet and \0 feet BGL, at concentrations of 0.5 mglkg and 0.05 mglkg, respectively.

TCE was detected in the subsurface soil samples collected from soil borings B4 and B5 at a concentrations of 0.013 mglkg and 0.18 mglkg, respectively at depths of 4 feet and 5.5 feet BGL, respectively.

The compounds comprising 1,2-DCE (total) were detected in the subsurface soil sample collected from B2 at a depth of 5 feet BGL at a concentration of 0.08 mglkg. In soil boring B5, 1 ,2-DCE (total) was detected in samples collected from 5.5 feet and \0 feet BGL, at concentrations of 108 mg/kg and O.ll mglkg, respectively.

3.1.3 Ground-Water Investigation

The RI ground-water investigation revealed the presence of a very localized, perched aquifer in the vicinity of MW -I , the only monitoring well installed at the site. A ground-water sample taken from

REPORT.DOC 2

MW -I had no detectable target compounds, indicating that the ground-water had not been impacted. A potentiometric surface map was not constructed.

3.1.4 Soil Vapor Investigation

A soil vapor investigation was implemented during the RI at a sample station selected in the area of the most heavily impacted subsurface soils. Four volatile organic compounds were detected in the soil vapor sample obtained from BSASV-2. Two of the compounds are common laboratory contaminant. The total volatile organic compounds present in soil vapor sample BSASV-2 are 1.632 ppmv.

3.2 RI Conclusions

Shallow and subsurface soils are impacted by PCE, TCE, and 1,2-DCE (total) . The subsurface soils impacted by these constituents are localized under the facility building and in the B4 and B5 area, at depths of approximately 5 to 12 feet BGL.

No target compounds were detected in the ground-water sample taken from MW-I , indicating that the very localized, perched ground-water at the site is not impacted. the vertical and a real extent of contamination has been delineated except directly under the facility building where site access was limited.

4.0 RESPONSE ACTION

The corrective action selected as the most appropriate technology for the remediation of contaminated soils at the site is described in detail in the section.

4 .1 Design and Engineering Considerations

Pilgrim used a cap and cover system to complete the substantial requirements of Response Action. The following design and engineering considerations were conducted under the Response Action for this site:

• Cover System

The existing building will serve as a cover system for the residual contaminants located beneath building footprint . Ifnecessary, areas immediately adjacent to the building will be regraded to carry roof drainage and run-off away from the building. The paving which covers the remainder of the site also prevents the infiltration of stormwater run-off. Two additional areas were also capped. The cap included to the insta1lation of a HDPE linear and 8-inches of reinforce concrete. The location of the cover system is provided in Figure 3 .

4.2 Operation. Maintenance. and Monitoring Requirements

Operation and maintenance of this system will consist of periodic inspections. Maintenance activities will consist of maintaining the building slab as an impermeable cover by repairing cracks in the slab as needed. At a minimum, a formal, comprehensive review of the condition of the site

REPORT. DOC 3

will be made every five years. The new cover systems will also be inspected on a quarterly basis to verifY the integrity of the system.

4.3 Response Action Activities

The cover systems were installed in the second quarter of 1996. Copies of photographs of the cover system are included in Appendix A. State-of-the-art dry cleaning machines have been installed at this facility to prevent future releases of perchloroethylene to the envirorunent. Included in Appendix B is a letter from Mr. Harold Corbin that inspected and certified no more releases of perchlorethylene are occurring.

4.4 Detailed Evaluation of Response Action

A detailed evaluation of Response Action was conducted based on the previously identified criteria. Each individual criterion was addressed during the evaluation and is presented in the following discussion.

• Overall Protection of Human Health and the Envirorunent

Under the conducted Response Action the potential risks to human health and the environment identified in the Baseline Risk Assessment was reduced to within the acceptable ranges based upon TNRCC RRS#3 Standards. The migration of contaminants to ground water will be mitigated through the effects of the cover system. Stormwater run-off can not contact contaminated soils under this alternative. Human contact with any remaining contaminated soils is prevented. lbis alternative therefore eliminates and controls potential contamination pathways of concern (i.e., air, surface water, surface soils, and subsurface soils) .

• Compliance with Applicable Regulations

The Response Action meets all of the requirements of the TNRCC RRS#3 as promUlgated under 30 TAC §335 Subchapter S.

• Long-term Effectiveness and Permanence

The risk associated with the Site were reduced by the implementation of Response Action as the soil contaminants will be effectively contained. Formal site reviews conducted every five years will ensure the long-term effectiveness of this alternative. Therefore, the potential for future problems resulting from the release of contaminants are controlled under this alternative.

• Reduction of Toxicity, Mobilitv, or Volume

Under this alternative, the toxicity and volume of contaminants will not be reduced. The cover system should effectively immobilize any residues that remain in the unsaturated zone throughout the site.

5 .0 PROPOSED TEXT FOR DEED RECORDATION

(See Attached) .

REPORT.DOC 4

6.0 CONCLUSIONS

Based on the information contained in this report and the requirements for the Response Action specified in the VCP, it is concluded that this site bas met the substantial requirements for closure and sbould be granted a certificate of completion.

REPORT.DOC 5

SOURCE: USGS 7.5 MIN. CASll£ HlUS, CUlEBRA HIlL., HEl..OTES &: SAN ANTONIO WEST, TEXAS QUAD SHEETS (1982)

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FIGURE 1 SITE LOCATION

PIT.GRDl ENTERPRlSl:~, . lIiC..oollEllEDlAL INVES'1'lGATION 6600 BANDERA "'ROAD - SAN ANTONIO TEXAS

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NOTES: 1. UTIUTY LOCATIONS SHOWN ARE APPROXIMATE

&: WERE LOCATED BY SURFACE OBSERVATION, ARCHITECTURAL & MUNICIPAL RECORDS, CONTRACTOR IS RESPONSIBLE FOR FIELD LOCATING AlL UTILITIES PRIOR TO BEGINNING OF CONSTRUCTION AcnvmES.

2 . ALL ELEVATIONS ARE BASED ON AN ASSUMED SITE DATUM OF 100.00.

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REMEDI!i?JriNgrALLATION SITE PLAN

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February 19, 1996

HAROLD W. CORBIN 1212 PERTHSHIRE

HOUSTON, TEXAS 77024

(713) 464-7149

Texas Natural Resource Conservation Commission Pollution Cleanup Division Voluntary Cleanup Unit MC-143 P.O. Box 13087 Austin, Texas 78711-3087

Attn: Mr. Jay Carsten

Re: 6600 Bandera Road, San Antonio, Texas - VCP 073

Gentlemen:

I have inspected the drycleaning system at the Pilgrim plant located at the referenced address.

I hereby certify that Pilgrim has installed certain mechanical controls on its drycleaning equipment which effectively eliminates any further release of perchlorethylene into the soil and groundwater via the sewer system or other appurtenances associated with the drycleaning equipment.

Very truly yours,

~d~ Harold W. Corbin

PILGRIM CLEANERS, INC.

October 2, 1997

6723 STELLA LINK HOUSTON, TEXAS 77005

(713) 666-0351

Texas Natural Resource ConseIVation Commission PO.Box 13087 Austin, Texas 78711-3087 Attn: Mike Frew

Project Manager Voluntary Cleanup Section

Re: 6600 Bandera Road, San Antonio, Texas, Tx. VCPNo. 073

Gentlemen:

The undersigned is the owner of the property located at the referenced address and hereby consents to filing the Certificate of Completion (a form of which is attached hereto) of record in Bexar County, Texas.

Pilgrim Cleaners, Inc.

By:

PCLDOC

TEXAS NATURAL RESOURCE CONSERVATION COMMISSION

(Texas State Seal)

VOLUNTARY CLEANUP PROGRAM FINAL CERTIFICATE OF COMPLETION

As provided for in §361.609, Subchapter S, Solid Waste Disposal Act (SWDA), Texas Health and Safety Code,

I, DAVID L. DAVIS, DIVISION DIRECTOR OF THE POLLUTION CLEANUP DIVISION, TEXAS NATURAL RESOURCE CONSERVATION COMMISSION, CERTIFY UNDER §361.609, SWDA, TEXAS HEALTH AND SAFETY CODE, THAT NECESSARY RESPONSE ACTIONS HAVE BEEN COMPLETED AS OF , 1997 FOR THE TRACT OF LAND DESCRIBED IN EXIDBIT "A", BASED ON THE AFFIDAVIT OF RESPONSE ACTION COMPLETION FOR VCP NO. 073 EXIDBIT"B", WIDCR ARE FURTHER DESCRIBED IN THE APPROVED FINAL REPORT FOR THE SITE, AND DO NOT REQUIRE MAINTENANCE OF ENGINEERING CONTROLS, REMEDIATION SYSTEMS, POST CLOSURE CARE, OR NON-PERMANENT INSTITUTIONAL CONTROLS. AN APPLICANT WHO ON THE DATE OF APPLICATION SUBMITTAL WAS NOT A RESPONSIBLE PARTY UNDER §361.271 OR §361.275(g), SWDA AND ALL FUTURE OWNERS AND LENDERS ON THE DATE OF ISSUANCE OF THIS CERTIFICATE, WHO WERE NOT RESPONSIBLE PARTIES UNDER §361.27I OR §361.275 (g), SWDA, ARE QUALIFIED TO OBTAIN THE PROTECTION FROM LIABILITY PROVIDED BY §361.61O, SUBCHAPTER S, SWDA

EXECUTED this _ _ day of ______ ~, 1997.

STATE OF TEXAS ( )COUNTY

David L. Davis, Director Pollution Cleanup Division

BEFORE ME, on this the _ day of , personally appeared David L. Davis, Director, Pollution Cleanup Division, of the Texas Natural Resource Conservation Commission, known to me to be the person and agent of said commission whose name is subscribed to the foregoing instrument, and he acknowledged to me that he executed the same for the purposes and in the capacity therein expressed.

GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the __ day of , 1997.

Notary Public in and for the State of Texas

6600 BANDERA

METES AND BOU NDS DESCRIPTION 0 . 0315 ACRE

OUT OF LOT 102, BLOCK 1 MAYFLOWER SUBDIVIS ION

COUNTY BLOCK 4430 CI TY OF LEON VALLEY BEXAR COU NT Y, TEXAS

(COVER SYSTEM, TRAC T I, BANDERA)

Being a tract or parcel of land conta ini ng 0.0315 acre , more or les s, located i n Bexar Co unty, Texas, and bei ng out of Lot 102, Block I , of the Mayflower Subdivision, in County Bl ock (CB) 4430, an addition to the City of Leon Va lley , as recorded in Volume 9505, Page 159, of the Bexar County Deed and Plat Records (BCDPR), said 0.0315 acre being more particularly described by metes and bounds as fo llows:

COMMENC I NG at a 5/8-inch ir on rod found marking the most easterly corner of Lot 33, CB 4430, of the Jeff Lucky Subdivision, as recorded in Vo l ume 3975, Page 195, BCDPR, said rod being on the southwest right -of-way (ROW) l ine of Bandera Road - State Highway 16 (195± feet wide) , said rod also being on the arc of a curve and t he most northerl y corner of the aforesaid Lot 102;

THENCE al ong the southwest ROW l i ne of sa id Bandera Road, 114 .38 feet along the arc of a curve to the left, said curve ha ving a chord which bears S 50"01 ' 36" E, a chord distance of 114.38 feet, a radius of 5789.65 feet, and a cent ral ang le of 01"07'55" to a 5/8·inch iron rod found for most easterly corner of said Lot 102 , sai d rod marking the intersection of the southwest ROW line of said Bandera Road with the northwest ROW line of El Verde Road (50 feet wide);

THENC E S 36"49 ' 00" W, leavi ng t he southwest ROW line of sa i d Bandera Road and along the northwest ROW li ne of sa i d El Verde Road, 205.82 f eet to a 5/8 -i nch iron rod found for most southerly corner of said Lot 102, sa i d rod being the most easterly corner of Lot 34-B, CB 4430, of sai d Jeff Lucky Subdiv i si on;

THENCE N 30"46'42 " E, leavi ng sai d no rthwest ROW line, 68.67 f eet to a P. K. nail set for most southerly corner of the existing cover system, the POINT OF BEG IN NING;

THEN CE N 53"34'04" W, al ong the sout hwest l i ne of sa i d exi sting cover sys tem, 19.94 feet to a P.K. nai l set for most westerly corner;

TH EN CE N 36' 59'21" E, along said existing cover system, 17 .52 feet to a P.K. nail set for corner ;

THENCE N 14'34'48" W, along said existing cove r system, 3.74 feet to a P.K . nai l set for corner;

THEN CE N 36'43 '14" E, along said existing cover system, 24.7 1 fe et to a P. K. nai 1 set for corner;

Page 2 of 2 0.0315 Acre Bandera Tr . 1

THENCE N 86°48 ' 52" E, along said existing cover sys tem, 3.75 feet to a P.K. nail set for corner;

THENCE N 36°25'23 " E, along sa id existing cover system, 18 . 18 feet to a 5/S-inch iron rod set for most norther l y corner;

THEN CE S 53°33'40" E, along said existing cover system, 19.91 feet to a 5/S-inch iron rod set for most easterly corner ;

THENCE S 36°38'47" W, a distance of 65.15 feet to the POINT OF BEGINN ING and containing 0.0315 acre (1,372 square feet) of land, more or less.

GALLOWAY & ASSOC IATES, INC. Jul y 19, 1996 Job No. 103-037BA1 Compiled by John N. Galloway II File #M10337B1

METES AND BOUNDS DESCRIPTION 0.0021 ACRE

OUT OF LOT 102, BLOCK 1 MAYF LOWER SUBDIVISION

COUNTY BLOCK 4430 CITY OF LEON VALLEY BEXAR COUNTY, TEXAS

(COVER SYSTEM, TRACT 2, BANDERA)

Being a tract or parcel of land contain i ng 0.0021 acre, more or less, located in Bexar County, Texas, and being out of Lot 102, Block 1, of the Mayflower Subdivision, in County Block (CB) 4430, an addition to the City of Leon Valley, as recorded in Volume 9505, Page 159, of the Bexar County Deed and Plat Records (BCDPR), sa id 0 .0021 acre being more particularly described by metes and bounds as follows:

COMMENCING at a 5/8-inch iron rod found marking the most easterly corner of Lot 33, CB 4430, of the Jeff Lucky Subdivision, as recorded in Vo lume 3975, Page 195, BCDPR, said rod being on the southwest right -of-way (ROW) line of Bandera Road - State Highway 16 (195± feet wide), said rod also being on the arc of a curve and the most northerly corner of the aforesaid Lot 102;

THENCE along the southwest ROW line of said Bandera Road, 114 .38 feet along the arc of a curve to the left, said curve having a chord which bears S 50°01'36" E, a chord distance of 114,38 feet, a radius of 5789.65 feet, and a central angle of 01°07'55" to a 5/8 -inch iron rod found for most easterly corner of said Lot 102, said rod marking the intersection of the southwest ROW line of said Bandera Road with the northwest ROW line of E1 Verde Road (50 feet wide);

THENCE S 36°49'00" W, leaving the southwest ROW line of said Bandera Road and along the northwest ROW line of said E1 Verde Road, 205.82 feet to a 5/8-inch iron rod found for most southe rly corner of said Lot 102, said rod being the most easterly corner of Lot 34-B, CB 4430, of said Jeff Lucky Subdivision;

THENCE N 01°00'48" W, l eaving said northwest ROW l ine, 73.33 feet to a P.K. nail set for most westerly corner of the existing cover system, the POINT OF BEGINNING;

THENCE N 37°06'44" E, along the northwest line of said existing cover system, 8 .99 feet to a P. K. nail set for most northerly corner;

THENCE S 53°47'58" E, along said existing cover system, 14.09 feet to a 5/8- i nch iron rod set for most easterly corner;

THENCE S 36°22'07" W, along said existing cover system, 4.02 feet to a 5/8-inch iron rod set for corner;

Page 2 of 2 0.0021 Acre Bandera Tr. 2

THENCE N 73'04'29" W, a distance of 15.06 feet to the POINT OF BEGINNING and contain ing 0.0021 acre (92 square feet) of land, more or less.

GALLOWAY & ASSOC IATES, INC. July 19, 1996 Job No. 103-037BA2 Compiled by John N. Galloway II File #M10337B2

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