Overview: Why This Matters for the SMART Terminal Site
The TriTexas Logistics Park (formerly SMART Terminal / Axis Logistics Park) involves large-scale ground disturbance in Caldwell County, Texas - including 15-foot-deep retention/detention ponds, building foundations, and utility trenching across hundreds of acres. Public records establish that the immediate area has a documented history of groundwater contamination from chlorinated solvents, tracing to operations at Gary Air Force Base (later Gary Job Corps Center) and a former municipal landfill.
The question raised by community researchers: could construction activity at this depth disturb or mobilize a contaminated alluvial aquifer that underlies the area? The documents reviewed do not answer this question - but they document that the contamination exists, that federal remediation work is incomplete, and that the aquifer sits at a depth consistent with planned construction activity.
Site Background: Gary Air Force Base / Gary Job Corps Center
Gary Air Force Base operated in San Marcos, Texas from the 1940s until it was closed in 1971 under the Base Realignment and Closure process. The site was subsequently converted to Gary Job Corps Center, a federal vocational training facility operated by the U.S. Department of Labor, located in Caldwell County near Reedville, Texas.
The base's industrial operations - including fuel storage, vehicle maintenance, and waste disposal - left a legacy of soil and groundwater contamination that has been the subject of multiple federal environmental investigations over decades.
San Marcos Municipal Landfill - Texas/EPA Superfund Record
The San Marcos Municipal Landfill (EPA Site ID: TXD980625222) was listed as a Texas Superfund site and evaluated under the federal Hazard Ranking System. EPA conducted a Phase II Site Inspection in September 1995 (Report TX1161630644), documenting contamination in the surrounding soil and groundwater.
EPA ultimately assigned a Hazard Ranking Score of 2.01 - well below the 28.5 threshold required for listing on the National Priorities List (NPL). As a result, the site was classified as NFRAP (No Further Remedial Action Planned) and archived. This means EPA determined no federal Superfund cleanup was warranted at that time based on measured contamination levels.
Documented Contamination Findings (EPA 1995 Inspection)
The EPA Phase II Site Inspection (September 1995) documented contamination in residential drinking water wells and in the Quaternary Alluvium aquifer underlying the site. The following contaminants were detected:
| Contaminant | Where Found | Levels Detected | Notes |
|---|---|---|---|
| cis-1,2-Dichloroethene (cis-1,2-DCE) | 4 residential drinking water wells | 5 – 54.3 ppb | Chlorinated solvent breakdown product; MCL = 70 ppb |
| 1,1-Dichloroethene (1,1-DCE) | Groundwater | Detected | Vinyl chloride precursor; MCL = 7 ppb |
| Vinyl Chloride | Groundwater | Detected | Known human carcinogen; MCL = 2 ppb |
| Carbon Disulfide | Groundwater | Detected | Neurotoxic solvent |
| Pyrene | Soil / groundwater | Detected | Polycyclic aromatic hydrocarbon (PAH) |
| Delta-BHC (Lindane isomer) | Soil / groundwater | Detected | Legacy organochlorine pesticide |
| Arsenic, Barium, Lead | Soil / groundwater | Detected | Heavy metals from landfill and industrial waste |
The contaminated aquifer is the Quaternary Alluvium - a shallow alluvial deposit approximately 40 feet thick, with the water table approximately 16 feet below the surface. This is a locally used water source. Four residential wells were found to contain detectable levels of cis-1,2-DCE, though none exceeded the EPA Maximum Contaminant Level (MCL) of 70 ppb at the time of the evaluation.
Soil Contamination - Fuel Dumps & Military Landfill: An Unresolved Gap
In addition to the confirmed groundwater contamination above, the 1995 EPA Site Inspection file documents an alleged former military landfill and two "fuel dumps" on the Gary Job Corps Center property - but the record shows this was never conclusively investigated.
1995 EPA Site Inspection file map: "Probable Locations of Past Landfill Activity," labeling two separate military landfill sites and two fuel dump locations, in addition to the municipal landfill.
The claim originates from a single October 21, 1987 phone call in which Gary Job Corps Environmental Coordinator Dick Moncure told an EPA Field Investigation Team chemist that he "thought there had been 2 fuel dumps, one at the east and one at the west end of the airport ramp," and that his best "guess" was that buried tetraethyl lead was near them - uncorroborated recollection, not physical evidence. Aerial photos from 1951 show no landfill activity; 1958 photos show only "possible" activity.
A sampling plan was subsequently drafted proposing soil borings at both locations (Sample #22, "East fuel dump," and Sample #23, "West fuel dump," both at 4–6 ft depth) - visible on the sampling locations map below.
1995 EPA Site Inspection file: sampling locations map. Points 22 and 23 (east and west) are the proposed fuel dump soil borings; points 19–21 are around the alleged military landfill.
U.S. Army Corps of Engineers - Incomplete Remediation (FUDS)
Gary Air Force Base is listed as a Formerly Used Defense Site (FUDS) under the U.S. Army Corps of Engineers remediation program. FUDS addresses environmental contamination at properties that were formerly owned or controlled by the Department of Defense.
As of 2019 (the most recent records reviewed), two FUDS remediation projects at the site remained incomplete:
| Project | Operable Unit | Status |
|---|---|---|
| Gary Job Corps - OU 02 | Operable Unit 02 | INCOMPLETE (as of 2019) |
| Gary Job Corps - OU 03 | Operable Unit 03 | INCOMPLETE (as of 2019) |
The Department of Labor prepared a Draft Environmental Assessment for Gary Job Corps Center in July 2022. That document acknowledges prior environmental investigations at the site. The current cleanup status of OU 02 and OU 03 beyond 2019 is not reflected in the documents reviewed.
The SMART Terminal Connection - Questions Raised
Community researchers have identified a specific concern: the TriTexas Logistics Park project plans include ground disturbance at depths potentially reaching the contaminated alluvial aquifer. Key construction features include:
- Stormwater retention/detention ponds up to 15 feet deep (per project permits)
- Building foundations for large industrial/warehouse structures
- Utility trenching across hundreds of acres in Caldwell County
The Quaternary Alluvium aquifer in the area sits approximately 16 feet below the surface. Excavation at these depths could intersect the water table and potentially disturb, expose, or mobilize contaminated groundwater - particularly if any portion of the alluvial plume extends beneath the project footprint.
This is a question for regulators, the developer's environmental consultants, and the Texas Commission on Environmental Quality (TCEQ) - not a finding of confirmed contamination at the project site.
Sources
- EPA Phase II Site Inspection Report - TX1161630644: San Marcos Municipal Landfill, Gary Job Corps Center, Reedville, Caldwell County, TX. Prepared September 1, 1995. EPA ID: TXD980625222.
- U.S. Army Corps of Engineers FUDS Records: Gary Job Corps Center - Operable Units 02 and 03. Status as of 2019. (FUDS Program, Formerly Used Defense Sites.)
- Department of Labor, Gary Job Corps Center Draft Environmental Assessment: July 12, 2022. Reviews site history and prior environmental investigations.
- CASA Research Summary - Superfund Notes: Internal research memo connecting Gary AFB contamination history to SMART Terminal construction plans; prepared by Citizens Against Smart Axis.
- SMART Terminal / TriTexas Logistics Park Permit Records: PICP 2024-49692 (Energy Parkway road and water main), City of San Marcos, issued September 30, 2024.