Important disclaimer: EPA classified the San Marcos Municipal Landfill site as NFRAP (No Further Remedial Action Planned) with a Hazard Ranking Score of 2.01, well below the NPL listing threshold of 28.5. No Maximum Contaminant Level (MCL) exceedances were confirmed at the time of that determination. This page presents documented historical findings from public records; it does not allege that any active Superfund hazard exists today. All information is sourced from official government documents.

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.

Key fact: The contaminated Quaternary Alluvium aquifer is described in federal documents as approximately 40 feet thick, with the water table approximately 16 feet below the surface - within range of planned retention pond excavation at the SMART Terminal site (which proposes ponds up to 15 feet deep).

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.

1940s
Gary AFB opened for military aviation training
1971
Base closed; converted to Job Corps Center
1995
EPA Phase II Site Inspection completed
2019
USACE remediation work still incomplete (OU 02 & OU 03)

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.

NFRAP does not mean "clean." NFRAP means EPA determined the site did not meet the threshold for federally-funded cleanup under CERCLA at the time of evaluation. Contamination documented in the inspection reports remains in the historical record and may still be present in soil and groundwater.

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 map showing probable locations of past landfill activity, including two military landfill sites and two fuel dumps

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 sampling locations map showing numbered sample points including the east and west fuel dump soil borings

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.

No soil sample results were ever found in the record. Every analytical results table in the 198-page Site Inspection file is explicitly labeled matrix "WATER," tied to residential and monitoring wells - there is no "SOIL" matrix results table anywhere in the document. The report's own conclusions confirm this gap directly: "The soil exposure pathway received a score of 0.00... however, the exact location of the contaminants is unknown," and overall, "the surface water, soil exposure, and air exposure pathways are of minimal concern because there has been no documentation of a release of hazardous constituents to these pathways." A 0.00 score here reflects an absence of data, not a confirmed clean result.

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.

Note on scope: The FUDS projects cover the Gary Job Corps Center itself. The SMART Terminal / TriTexas Logistics Park site is a separate property. The question raised in community research is whether the groundwater plume from the Gary AFB contamination extends toward, or underlies, the SMART Terminal site given the shared Quaternary Alluvium aquifer in the area.

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:

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.

What is not known: The documents reviewed do not establish that contaminated groundwater extends beneath the SMART Terminal site specifically. No sampling data for the SMART Terminal parcels was found in the records reviewed. This concern warrants independent environmental due diligence - including groundwater sampling and review of current USACE FUDS project status - before major ground disturbance proceeds.

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

  1. 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.
  2. 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.)
  3. Department of Labor, Gary Job Corps Center Draft Environmental Assessment: July 12, 2022. Reviews site history and prior environmental investigations.
  4. CASA Research Summary - Superfund Notes: Internal research memo connecting Gary AFB contamination history to SMART Terminal construction plans; prepared by Citizens Against Smart Axis.
  5. SMART Terminal / TriTexas Logistics Park Permit Records: PICP 2024-49692 (Energy Parkway road and water main), City of San Marcos, issued September 30, 2024.