PB99-964201
EPA541-R99-093
1999
EPA Superfund
Record of Decision:
Texas Tin Corporation Site OU 1
Texas City, TX
5/17/1999
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RECORD OF DECISION
TEX-TIN SUPERFUND SITE
Texas City, Texas
May 17,1999
U. S. Environmental Protection Agency
Region 6
Dallas, TX
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TABLE OF CONTENTS
DECLARATION FOR THE RECORD OF DECISION i
ROD DATA CERTIFICATION CHECKLIST 4
THE DECISION SUMMARY 6
Site Name, Location and Description 6
Site History and Enforcement Activities 5
Community Participation 13
Scope and Role of the Operable Unit 14
Site Characteristics and Site Conceptual Model 15
Current and Potential Site and Resource Uses 31
Site Carcinogenic Risks and Non-carcinogenic Hazards 32
Remedial Action Objectives 57
Description and Comparative Analysis of Remedial Alternatives 59
Summary of Comparative Analysis of Site Wide Alternatives 95
Selected Remedy 98
Statutory Determinations 119
RESPONSIVENESS SUMMARY. 129
END NOTES 155
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TEX TIN CORPORATION SUPERFUND SITE
OPERABLE UNIT NO. 1
TEXAS CITY, TEXAS
DECLARATION FOR THE RECORD OF DECISION
1 Site Name and Location. The Tex-Tin Superfund Site (CERCLIS ID # TXD062113329) is located
in the cities of Texas City and La Marque, Galveston County, Texas.
1.1 Statement of Basis and Purpose. This decision document presents the selected remedy for the first
operable unit of the Tex-Tin Superfund Site, the Tex Tin Corporation smelter facility (OU1). The
remedial action was chosen in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), 42 U.S.C. § 9601, as amended, and, to the extent
practicable, the National Oil and Hazardous Substance Pollution Contingency Plan (NCP), 40 C.F.R.
Part 300.
1.1.1 The State of Texas, through the Texas Natural Resource Conservation Commission (TNRCC),
concurs with the selected remedy.
1.1.2 The Proposed Plan of Action for OU1 was released for public comment on September 9, 1998.
In response to a request, the original thirty-day comment period was extended for an additional thirty
days, ending on November 9, 1998. A public meeting was held on Oct. 6, 1998. EPA received
numerous comments, which were considered in making the final remedy selection. Responses to the
comments received during the formal comment period are included in the Responsiveness Summary.
This final remedy decision is based upon review and consideration of public comment and the entire
administrative record.
1.1.3 The Administrative Record contains the documents that form the basis for the selection of a
response action. The Administrative Record is available for review at the EPA Region 6 offices at 1445
Ross Ave., Suite 1200, Dallas, Texas 75202; the Moore Memorial Public Library, 1701 Ninth Avenue
North, Texas City, Texas 77590; and the Texas Natural Resource Conservation Commission, Technical
Park Center, Building D, 12118 North IH-35, Austin, Texas 78711 -3087.
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1.2 Assessment of the Site. The response action selected in this ROD is necessary to protect the public
health or welfare or the environment from actual or threatened releases of hazardous substances into the
environment.
1.3 Description of Selected Remedy. Operable Unit No. 1 is one of four operable units which are part
of the Tex Tin Corporation Superfund Site. OU1 is an inactive tin smelter which lies on approximately
140 acres at the intersection of FM 519 and State Highway 146 in Texas City, Texas. Process buildings,
unused since the facility ceased operations in 1991, exhibit varying stages of structural deterioration.
There are a number of ponds on-site, including wastewater treatment ponds and a four-acre Acid Pond
with a pH of less than 2, the base of which is hydraulically connected with shallow groundwater. Slag
from the smelting process is heaped across the property, as are drums and piles of spent catalyst and
other secondary smelting materials.
1.3.1 Operable Unit No. 2 refers to the Amoco property (also known as Parcel H of the Tex Tin Site),
approximately 27 undeveloped acres located adjacent to OU1. Operable Unit No. 3 refers to a
residential area located in LaMarque, Texas, approximately 2,000 ft. west-northwest from OU1, and
Operable Unit No. 4 refers to the Swan Lake Salt Marsh area located between the Texas City Hurricane
Levee and Swan Lake.
1.3.2 EPA has identified several contaminant sources at OU1 to be principal threat wastes: liquids and
sediments from the Acid Pond, slag containing radioactive material, slag or soil that leaches
contaminants in excess of Synthetic Precipitation Leaching Procedure (SPLP) standards, sludge
remaining in above-ground storage tanks, and drums containing spent catalyst. Low-level threat
materials present at OU1 include surface water and groundwater that exceed drinking water maximum
contaminant levels (MCLs) but which can be discharged under National Pollutant Discharge Elimination
System (NPDES) criteria, as well as soils and slag which do not leach contaminants into the
environment but which pose an unacceptable risk or hazard identified in the baseline risk assessment.
1.3.3 The selected remedy for OU1 uses treatment, off-site disposal, on-site stabilization and
containment, and institutional controls to mitigate the carcinogenic risk and non-carcinogenic hazards at
the site (see Box 1.3.4). The major components of the selected remedy are to: treat Acid Pond liquids
and discharge them to the Wah Chang ditch; place a geomembrane containment wall around the Acid
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Pond; stabilize onsite and construct a cover for sediments, drummed materials, slag, and soil that pose an
unacceptable carcinogenic risk or non-carcinogenic hazard; cover the low level radioactive landfill;
discharge the wastewater pond liquids to the Wah Chang ditch and backfill the ponds; cover soil
exceeding remedial action cleanup levels with 24 inches of compacted clay; dispose of organic and
inorganic sludge contained in the above-ground storage tanks; implement a long-term perimeter
monitoring program for the Shallow, Medium and Deep Transmissive Zones to ensure no further
degradation of groundwater; remove the dust and asbestos from the buildings; demolish the buildings
where appropriate and finally, bury all debris below grade in an on-site landfill.
Box 1.3.3 - Components of Selected Remedy
Treatment.
Neutralize and filter Acid Pond liquids, and discharge to the Wah Chang ditch.
Off Site Disposal.
Ship organic and inorganic sludges found in above-ground storage tanks (ASTs) off-site for disposal.
Engineering Controls.
Stabilize contaminated sediments, slag, soil and drummed material that pose an unacceptable carcinogenic risk or
non-carcinogenic hazard. Dispose of stabilized materials in on-site landfill.
Construct a cover or enhance existing covers over the low-level radioactive landfill and stabilized materials and soils
which do not leach contaminants in concentrations which pose unacceptable carcinogenic risks or non-carcinogenic
hazards.
Implement long-term groundwater monitoring.
Demolish buildings and other surface structures; landfill on site.
Institutional Controls.
File deed notices in the Galveston County property records describing the nature and location of hazardous
substances landfilled on-site and the location and concentrations of hazardous substances in groundwater.
1.3.4 The remedial alternatives EPA evaluated are summarized in Section 3.9, "Description of
Remedial Alternatives." The selected alternative is described in detail in Section 3.10, "Selected
Remedy - SW3: On-site Stabilization, Compacted Clay Cover, Groundwater Monitoring, Asbestos
Removal and Building Demolition."
1.4 Statutory Determinations. The Selected Remedy is protective of human health and the
environment, complies with Federal and State requirements that are applicable or relevant and
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appropriate to the remedial action, is cost-effective, and utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable. This remedy also satisfies the statutory
preference for treatment as a principal element of the remedy to reduce the toxicity, mobility or volume
of materials comprising principal threats. Because this remedy will result in hazardous substances
remaining on-site above levels that allow for unlimited use and unrestricted exposure, a statutory review
will be conducted within five years after initiation of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the environment.
2 ROD DATA CERTIFICATION CHECKLIST
2.1 ROD Data Certification Checklist. The following information is included in the Decision
Summary section of this Record of Decision. Additional information can be found in the Administrative
Record file for this site.
Chemicals of concern (COCs) and their respective concentrations.
Baseline risk represented by the COCs.
- Cleanup levels established for COCs and the basis for the levels.
- Current and future land and groundwater use that will be available at the site as a result of the
selected remedy.
- Estimated capital, operation and maintenance (O&M), and total present worth costs; discount
rate; and the number of years over which the remedy costs estimates are projected.
- Decisive factor(s) that led to selecting the remedy.
•okc Dale
Administrator
l.'.S. l-.mtroumental Protection Ayyturv
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3 THE DECISION SUMMARY. The Decision
Summary provides an overview of the site
characteristics, alternatives evaluated, and the aalysis of
those options. It identifies the selected remedy,
^ explaining how the remedy fulfills statutory and
regulatory requirements.Finally, it provides a substantive
summary of the information, available in the site
Administrative Record, which was used to characterize
the site and evaluate cleanup alternatives*
3.1 Site Name, Location and Description. The Tex-
Tin SuperfundSite (CERCLJS ID # TXD0621 13329) is
located in Texas City and La Marque, Galveston County,
Texas (Figure 3.1, "Site Location"). Operable Unit No.
1 (OU1), the subject of this Record of Decision, is a
smelter which closed in 1991; other industrial processes
were conducted there as well. OU1 encompasses
approximately 140 acres, including process buildings,
slag piles, an acid pond, drums of spent catalyst and
other metal-bearing materials, above-ground storage
tanks of organic wastes, and assorted other materials.
After the Remedial Investigation was completed bya
landowner PRP, EPA assumed the lead on this project.
3.2 Site History and Enforcement Activities. OU1 of
the Tex-Tin Superfund Site is located in Texas City,
Texas. EPA's investigations show there is an
inacceptable threat posed by contamination from the
incontrol led release of hazardous substances, including
carcinogens and systemic toxins, from various sources
such as the Acid Pond, radioactive materials, process
wastewater, waste oils, drummed spent catalyst and slag
left on-site. As the lead agency responsible for
administering the cleanup, EPA reviewed data from site
investigations and identified contamination from specfic
hazardous substances, discussed in the following
sections, which pose threats to the environment:
3.2.1 Site Activities That Led to the Current
Problems. While information about the operational
history of the site is still being developed,the following
paragraphs describe generally some of the industrial
processes conducted on OU1 that led to the present
condition of the property.
3.2.2 Tin Smelting and Ferric Chloride
Production. From 1941 through 1989, tin was the
primary product of the smelter plant on OU1. Other
industrial processes were also conducted there at various
points in the operational history of the plant; a 1980
products list for the Texas City facility includes the
following: ammonium vanadate, calcium molybdate,
calcium tungstate, copper oxide, ferric chlorid, an fused
vanadium oxide, molybdenum oxide (technical), tin
(electrolytic), and tin(fire refined). In approximately
1988, the smelter began copper production as well.
3.2.3 The particular components of the tin smelting
process varied over time, as plant owner/operators
attempted to maximize recovery of marketable metal
from ores and secondary smeltingmaterials which varied
widely in metal content. Basically, tin smelting producd
pure tin and waste products, including ferrous chloride,
an iron-rich liquid acid, and solid tinslag. Much of the
slag remains in large piles on the site. The liquids were
transferred to ponds 18 through 21 south of the main
plant and possibly some to ponds 2 through 14. Fora
time, ferrous chloride was reportedly converted to ferric
chloride by combining an iron-rich soiree, such as scrap
iron or spent iron-rich catalyst, with chlorine gas. The
ferric chloride was sold as a flocculating agent for
wastewater treatment facilities until 1983 when ferric
chloride production ceased. After production of ferric
chloride ceased, the remaining solution was eventually
stored in what is now the Pond 6, the Acid Pond-
3.2.4 The OU1 tin smelter was originally designed in
1941 to smelt high grade tin concentrates. The high
. amount of impurities in available low-grade concentates
reportedly limited the success of the process. Ore
delivered to the plant was weighed, crushed, sampled,
and stored in separate piles or mixes. Fromstorage piles,
the ore was transported by lift trucks to the roasting
department. The ore was transferred to rotating kilns for
roasting, which was done to eliminate sulphur, antimony,
arsenic, and lead, and to reduce the iron, making it more
soluble in acid. The roasted ore was then discharged
from the kilns and transported to the leaching plant,
where impurities in the ores were leached with
hydrochloric acid. The residue (coarse, leached OE) was
discharged into buckets, which weretransported by truck
back to the roasting department to dry, and hen by truck
to the smelting department. Liquids and fne particles of
ore were discharged into pits and pumped to thickeners
where the slimes were separated from the liquids. The
clear solution from the thickeners was originally pumpad
into an estuary of
Superscripts reference the end notes in Section 5, "End
Notes."
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Figure 3.1
Site Location
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Map
Operable Unit 1
Surrounding Land Uses
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Gafveston Bay; after mid-1944, it was stored in holding
pondson-site. Theslimeswereneutralizedwith limeand
filtered; the liquid was sent to acid waste ponds, and the
cake was re-pulped with water and sent to a dressing
plant, where concentrateswere separated from "rejects."
The concentrates were re-routed through the smelting
operation. In 1951, an acid recycling plant went into
operation.
3.2.5 Except for the addition of an electrolytic tin
refining plant by Wah Chang Corporation in 1963,
variations on the same basic smelting process described
above are recorded in articles about the smelter dating
from 1970. After acquisition of the plant in the early
1970s, Associated Metals and Minerals initiated a plant
upgrade. A pilot plant was reportedly installed in 1972;
in 1974 a new reverberatory furnace was added. A ferrc
chloride system was installed in 1976 and removed in
1984. In the late 1970s, the smelter expanded its
activities in metals other than tin. It beganproduetion of
ferric chloride for water treatment and was a major
producer of purified nickel solutions which were used as
catalysts by surrounding chemical industries. It
recovered metals from various spent catalysts, and
uranium tailings. It produced molybdenum, vanadium,
antimony, bismuth, nickel, cobalt, and copper in the forn
of oxides or solutions. A Kaldo (rotary) furnace and feed
system was installed in 1978. A chloride wash system
was built in 1979 and removed in 1984. A facility for
the production of tungsten chemicals from spent
catalysts, tin-tungsten bearing slags, and other tungsten
residues was constructed in the early 1980s. A sulphur
dioxide scrubber system was built in 1981. A new
facility for the production of copper sulfate begin
operations in 1982. Tin operations reportedly ceased in
1989, but copper recovery continued until 1991.
3.2.6 According to a 1970 article on tin smelting at the
Texas City plant, Gulf Chemical and Metallurgical
Corporation (GCMC, a division of Associated Metals
and Minerals at the time) contracted to receive 15,000
tons of Bolivian tin ore concentrates, containing high
concentrations of arsenic, annually. The concentrates
were roasted in a furnace during which sulfur and some
arsenic were removed. Crushed coke was added in part
to volatilize the arsenic. Gases were routed to the
ambient air through the main 250-foot stack. After
roasting, the concentrates were subjected to two rounds
of leaching with heated hydrochloric acid, rinsed with
water to bring the pH up to 5.0, and then smelted in a
reverberatory furnace. The acid leach liquor was
subjected to a cementation process/esulting in recovery
of silver, copper, and other soluble metals.
3.2.7 Waste Water Treatment. By about 1970,
many of the ponds south and southeast of tie production
area were filled with tin slags and possibly other waste
products from the production processes. In the 1970s a
wastewater treatment facilirywas constructed by GCMC.
That facility neutralized and precipitated heavy metals
from the process wastewater stream. Surface water
runoff from the southern areas of the Site also emptied
into the wastewater treatment system. Wastewater was
neutralized by adding lime slurry. The lime slurry
precipitated metal hydroxides which settled to the botton
of the pond. The neutralized wastewater was
subsequently discharged into the Wah Chang ditch under
National Pollutant Discharge Elimination System
(NPDES) Permit No. TXOOO4855. Precpitated metals
were not removed from the pond and no provisions
appear to have been made to prevent the migration of
dissolved contaminants vertically or laterally out of the
ponds.
3.2.8 Air Pollution Controls. During 1980, a
scrubber system was installed to remove gaseous sulfur
dioxide (SO2) from the tin smelting process1. The S02
was generated because of a change in the smelting
process from multiple-furnacesmelting to a siigle, high-
speed rotary Kaldo furnace procedure. Calcium sulfate
(gypsum) scrubber sludge was generated from the new
procedure. This sludge was placed in Pond 7 from 1980
through 1984. After Pond 7 was completely filled, the
scrubber material was placed on the southern portion of
the property in the vicinity of former Ponds 17 through
21.
3.2.9 Secondary Copper Smelting. Secondary
copper smelting began during 1989. In general, the
copper process resembled the tin process with the cqoper
process producing a copper end slag and the tin process
producing a tin end slag. Copper smelting also required
using a scrubber system; however, the scrubber system
only used water and did not produce any waste sludge.
Copper production continued until April 1991, when the
furnace collapsed and the manufacturing process was
shut down.
3.2.10 Antimony Recovery. During the 1970s, GCMC
purchased various spent catalysts containing metals and
brought them to the plant to store for a GCMC plant in
Freeport, Texas and to a lesser extent, for smelting or
resale. Efforts were made to recover antimony from
uranium/antimony catalyst, but the process was not
successful.
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3.2.11 Waste OH Recovery. Between 1982 and 1983,
Morchem Resources operated a still bottoms and waste
oil recovery plant in the north west corner, Area A, of tte
Site (Figure 3.2.11, "Site Features"). These bottoms
consisted of high boiling glycols from propylene glycol
and t-butyl alcohol manufacture, which contained
approximately 1 percent molybdenum. Morchem
merged with Royster Chemical Company on November
1,1982 and the company name was changedto Roychem
Associates. Morchem bought the operation in May 1983
and the name was again changed to Morchem Resources
Inc. The new company no longer processed still
bottoms, but began processing waste oil from chemical
and refining companies. In December 1983, Morchem's
lease with GCMC was terminated and it was given 30
days to vacate the premises. Morchem was requested to
remove all waste oils and oil contaminated soil from the
site. The site was inspected by the TDWR (Texas
Department of Water Resources) on May 12, 1984 to
evaluate the adequacy of the site cleanup and closure.
The inspection found contaminated soil and two sumps
overflowing with oily water. These contaminants had
not been removed as requested. Morchem, after
bankruptcy, abandoned the Site, leaving behind drums
and tanks of waste materials.
3.2.12 Permit Violations. During its operating life, the
plant was cited a number of times by state and local
authorities for wastewater and air emissions permit
violations. In two separate enforcement actions, the
Texas Water Commission and the Texas Air Control
Board, predecessor agencies to the Texas Natural
Resource Conservation Commission (TNRCC), put the
company on court-ordered compliance plans tobring the
facility into compliance with then-curent environmental
permitting and operating standards. Ultimately, the
TNRCC referred the site to EPA to be evaluated for
placement on the National Priorities List (NPL). The
NPL is a list of sites having uncontrolled hazardous
substance releases that are prioritized for evaluation and
long term remedial response pursuant to CERCLA.
3.2.13 NPL Listing. EPA proposed this site for listirg
on the National Priorities List in 1988. A final
rulemaking,placingthe site on the NPL, was published
in 1990; Tex Tin Corporation filed a petition for review
in the U.S. Court of Appeals for the District of Columba
Circuit. In 1991, the court remanded the final
ruiemaking to EPA. EPA supplemented the
administrative record supporting the ruiemaking. Ina
decision issued on May 11, 1993, the courtremoved the
site from the NPL. In June, 1993, EPA referred the site
to the State of Texas. TWC conducted additional oi-site
and off-site sampling and, in October, 1994, referred the
site back to EPA for evaluation for the NPL, using the
Hazard Ranking System revised in 1990. EPA
conducted additional sampling in 1994-95 The site was
proposed for the NPL on June 17, 1996, and a final
ruiemaking placingthe site on the NPL was published on
September 18, 1998. Tex Tin Corporation filed a
petition for review with the D.C. Circuit Court of
Appeals on Dec. 11, 1998.
3.2.14 Site Investigations - Remedial Investigation.
Two phases of field investigations were conducted to
prepare the June 1993 Remedial Investigation R^jort for
the Site. Phase I of the investigation was conducted by
ERM-Southwest between November 1990 and April
1991, and Phase II was conducted by Woodward-Clyde
Consultants between February and Augustof 1992. EPA
performed additional site sampling to supplement the
1993 Remedial Investigation Report. The results of
investigation known as the Supplemental Remedial
Investigation were reported in March 1997. The 1993
and 1997 reports are both part of the Administrative
Record. In addition to the aforementioned investigation
TNRCC sampled residential areas located adjacent and
west-northwestof the OU1 facility in Feb. 1994. In late
1994 and early 1995, EPA's Technical Assistance Team
(TAT) conducted additionalsite assessment sampling fa-
arsenic and other mefals in a primary target area defined
by air dispersion modeling and data from the TNRCC
assessment. EPA subsequently conducted an Expanded
Site Investigation, a Human Health Risk Assessment,
Ecological Risk Assessment, and Feasbility Study. The
results of these investigations are also filed in the
administrative record. Through the remedial
investigation process, EPA determined that the liquid
wastes in the Acid Pond (Pond 6), spent catalyst, sludge
in the above ground storage tanks, and Naturally
Occurring RadioactiveMaterial (NORM) slag waste piles
are principal threat wastes, because the chemicals of
concern contained in these sources ae highly toxic (acid
pond liquids and sludges, spent catalyst, radioactive
emissions from NORM slag), or highly mobile (sludge h
ASTs) and cannot be reliably contained. On the other
hand, the water in the wastewater ponds, Wah Chang
Ditch sediments, surface and subsurface soils and non-
NORM slag waste piles are low level threat wastes
because they are not highly mobile and they presenta
low carcinogenic risk or non-carcinogenic hazard in the
event of an exposure. Based
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Figure 3.2.11
Site Features
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upon the site characterization and risk assessment, EPA
determined that principal threat and low level threat
wastes present a carcinogenic risk or non-carcinogenic
hazard in the event of an exposure. Consequently, EPA
established remedial action goals to protect human healh
and the environment. These goals were developed by
considering:
o Applicable or relevant and appropriate Federal
and state requirements;
o Acceptable exposure levels to which humans
may be exposed without hazard;
o Acceptable exposure levels representing a less
than a 1 chance in 10,000 excess lifetime cancer
risk.
3.2.15 Enforcement Activities At the Site. As noted
above, the Tex Tin Corporation plant washistorically the
subject of numerous enforcement actions. EPA took its
first enforcement action pursuant to CERCLA in 1988,
when it issued a unilateral order to Tex Tin Corporation
to fence the facility. Corporations identified from Tex
Tin business records received general notice letters and
information requests in 1988-89; special noticefor RI/FS
was issued in November 1989. In 1990, Tex Tin
Corporation and Amoco Chemical Company entered into
an Administrative Order on Consent (AOC) with EPA b
conduct the RI/FS on their properties. Tex Tin
Corporation ceased performance in 1991,leaving Amoco
Chemical Company to complete the work. The AOC
was terminated in 1993, when the sitewas removed from
the NPL by order of the U.S. Court of Appeals for tte
D.C. Circuit.
3.2.16 In 1996, Tex Tin Corporation and Amoco
Chemical Company filed separate lawsuits under
CERCLA 113 in the U.S. District Court for the Soutlurn
District of Texas, Galveston Division, again* the United
States Dept. of the Treasury and the General Services
Administration, and a number of corporate PRPs, for
response costs incurred in conducting the Tex Tin RJ.
EPA filed counterclaims against Tex Tinand Amoco for
past and future CERCLA response costs. In 1997, Tex
Tin Corporation and Associated Metals and Minerals
filed for bankruptcy protection in White Plains, New
York. The District Court in Galveston placed the
CERCLA 113 action on administrative closure, which
was subsequently lifted effective Aug. 31, 1998. The
district court action is proceeding as to all parties except
Tex Tin and Associated Metals pursuant to a scheduling
order issued on Sept. 18, 1998.
3.3 Community Participation. Prior to sampling in
areas adjacent to the Site in 1994and 1995, EPA and
TWC held a public meeting to discuss the sampling
effort with the community. Individual homeowners
whose properties were sampled in 1994-5 received
individual written notification of results of samples take
on their property. Beginning in 1996, EPA has
periodically briefed Texas City officials and responded
to congressional inquiries concerning this Site. In
September 1998, immediately prior to releasing the
proposed plan, EPA discussed site developments which
included land reuse and the availability of a new
Technical Assistance Grant (TAG), with local officials.
The Proposed Plan of Action was released for public
comment on September 9, 1998; the Administrative
Record file was made available for public review
concurrently at each of the three repositories listed
below. On October 6, 1998, EPA held a public meeting
to provide a site update and receive comments from the
public. In response to a request, the original thirty day
comment period was extended for an additional thirty
days, ending on November 9, 1998. EPA received
numerous comments; the written and oral ccmments and
EPA's responses are summarizedin the "Responsiveness
Summary" section of this ROD. After reviewing all
comments EPA determined that no significantchanges b
the Proposed Plan were necessary.
Moore Memorial Public Library
1701 Ninth Avenue North
Texas City, Texas 77590
(409) 643-5979
Box 3.3 Site Repositories
U.S. Environmental Protection
Agency
12th Floor Library 1445 Ross
Avenue
Dallas, Texas 75202-2733
(214)665-6427
Texas Natural Resource
Conservation Commission
Technical Park Center, Building
D
12118 North I-H 35
Austin, Texas 78711-3087
(512)239-2920
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3.4 Scope and Role of the Operable Unit. Due to the
fact that many Superfund sites are complex with
multiple components, they are sometimes divided into
operable units (OU) to facilitate managing a site wide
response. Operable units are specific response actions
that comprise incremental steps toward comprehensively
addressing site problems. As noted above, the Tex-Tin
Superfund Site consists of four operable units. This
Record of Decision for OU1 addresses contaminant
sources at the Tex Tin smelter property to abate any
release or threat of release of hazardous substances at or
from the plant site. The other operable units for this site
are:
o Operable Unit 2, the 30-acre Amoco property
east of the smelter property. Amoco completed
a response action at Operable Unit 2 in 1998
pursuant to the Texas Voluntary Cleanup
Program.
o Operable Unit 3, the off-site residential property
An Action Memorandum for soil removalin this
operable unit was signed in Sept. 1998. A time-
critical removal action was initiated by EPA in
March of 1999.
o Operable Unit 4, Swan Lake Salt Marsh. Field
investigations of the Swan Lake Salt Marsh are
complete and preparation of the report is
underway. No response action has been selected
for OU4.
3.4.1 Operable Unit 1 Management Strategy. The
approach to remediation of OU1 is to provide for
beneficial reuse while protecting human health and the
environment, by reducing the carcinogenic risks and
non-carcinogenic hazards from OU1 contaminant sources
to acceptable levels. The objective will be acomplished
by a CERCLA cleanup that treats principal threat wastes
and contains low level threat wastes so that release
mechanisms or exposure pathways which allow exposue
of human or ecological receptors to hazardous
substances, which pose carcinogenic risks and/or non-
carcinogenic hazards, are eliminated.
3.4.1.1 Principal Threat Wastes. EPA has identified
several contaminant sources at the site to be principal
threat wastes. These include the acid pond liquids and
sediments with low pH levels; NORM slag; slag or soil
that leaches contamination; above ground storage tank
sludge, and drums containing spent catalyst and other
materials.
3.4.1.2 Low Level Threat Wastes. There are several
low-level threat materials present at OU No. 1 of theSite.
These include groundwater that exceeds drinking water
maximum contaminantlevels(MCLs); surface water tha
exceeds drinking water maximum contaminant levels
(MCLs) but which can be discharged under NPDES
criteria; as well as soils and slag which do not leach
contaminants into the environment but pose an
unacceptable carcinogenic risk or non-carcinogenic
hazard to human health or the environment.
Box 3.4.1 Principal Threat and Low Level Threat Wastes*
Principal threat wastes are those hazardous wastes, systemic toxins and carcinogenic source materials (Source materials act
as the reservoir source from which contamination migrates to the groundwater, surface water, air or is a source for direct
exposure.) containing chemicals of concern materials considered to be highly toxic or highly mobile that generally cannot
be reliably controlled and presenta significant risk to human health and the environment should exposure occur. Low level
threats are those contaminated waste sources that can be reliably contained with little likelihood of migration and present a
low risk in the event of exposure.
*Reference"A Guide to Principal Threat and Low Level Threat Wastes," Superfund Publication 9380.03-06FS, November
1991.
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3.4.2 Scope of the Problems Addressed By This
Operable Unit. EPA establishes specific remedial
action objectives and non-carcinogenic hazards cleanup
levels appropriate for the site given anticipated future
land use. Assuming future industrial use of OU1S EPA
concluded that there are unacceptable carcinogenic risks
and non-carcinogenic hazards to future construction or
industrial workers from exposures to hazardous
substances, including systemic toxins and carcinogens,
found in the soil and groundwater.
3.4.3 Authority Under Which This Action Will Be
Taken. This remedial action will be taken in
accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980
(CERCLA), 42 U.S.C. § 9601, as amended, and, to the
extent practicable, the National Oil and Hazardous
Substance Pollution Contingency Plan (NCP), 40 C.F.R.
Part 300.
3.5 Site Characteristics and Site Conceptual Model.
EPA must characterize the site to develop a site
conceptual model for use in the baseline risk asessment,
and ultimately, in remedy selection. This model,
described in Section 3.5.27, "Site Conceptual Model,"
illustrates the contaminant sources, release mechanisms,
exposure pathways, migration routes, and potential
human and ecological receptors.
3.5.1 Surrounding Geography. The operable unit
site is approximately 140 acres and is located in Texas
City, Texas. Texas City lies within the Texas coastal
prairies, a region characterized by more than 36 inches
of rain each year4 and heavy clay soils covered with a
heavy growth of grass.5 The site is located
approximately 10 miles north of Galveston, in the
southeast quadrant of the intersection of State Highways
146 and 519. The city of La Marque is located to the
northwest of the site. Major surface water bodies locatd
near the site include Galveston Bay, JonesBay, and West
Bay. Land use north and east of the site isdominated by
large petrochemical facilities, with the eastern boundary
being shared with the Amoco Chemical Corporation
facility. A La Marque residential neighborhood is
located 1000 to 1500 feet northwest of the facility.
More than 10,000 people reside within 1 mile cf the site.
A municipal golf course, an industrial waste disposal
facility, and marsh areas are locked less than 0.5 mile to
the south and southwest of the site.
3.5.2 Physical Features. Although the natural
topography is flat, ore processing activity left ore and
slag piles scattered across the site. Various ponds were
also constructedon site for ferric chloride production ard
industrial wastewater treatment. Six of these ponds
remain on site. Another major site feature is the Wah
Chang drainage ditch which collected site drainage and
received discharge from the wastewater treatmert ponds.
Numerous structures remain on site, but there have not
been any archeological or historical areas discovered at
the site. Most of the remaining structures are associated
with the smelting process or the Morchem Resources
still bottoms and waste oil recovery plant. The most
significant structures in those areas are the smelter, ore
storage, roasting and leaching, maintenance, warehouse,
engineering, laboratory, office, garage and generator
buildings and above ground storage tanks. Some of these
structures have deteriorated, are in disrepair, and could
collapse during high winds.
3.5.3 Site Drainage. Previously, a portion of site
runoff, primarily from the Process Area and slag piles,
was routed through ditches into the site wastewater
treatment facility. When the wastewater treatment
facility was in use, all on-site ditches were directed into
Wastewater Treatmert Pond 1. The wastewater pH was
adjusted and then discharged through a permitted
NPDES outfall into the Wah Chang Ditch. At the far
southern boundary, runoff flows into the shallow
depression area identified as Pond 23. This depression
receives surface runoff from several areas includinga
shallow ditch outside and parallel to the western fence
line. Water flowing along the site's southern boundary
flows either into the Wah Chang Ditch or into Pond 23.
Runoff from the western portion of the Process Area
including the Morchem Facility (Area L) and from the
northern slag and raw material piles flovs westward into
the ditch that parallels Highway 146. This flow travels
through a culvert beneath the highway and ultimately
into a borrow pit known as Pond 22 west of the site.
3.5.4 Site Partitioning. Since the site has various
unique surface physical and geographic features its
surface was partitioned into Areas A through Pwhile the
aquifer was partitioned hto Shallow, Medium and Deep
Transmissive Zones. These partitions facilitated site
investigations and remedial decisions allowing EPA to
determine the specific carcinogenic risks and non-
carcinogenic hazards within each area. Those areas are
shown on Figure 3.2.11, "SiteFeatures" and described h
the sections below.
3.5.5 Area A encompasses approximately 10.2 acres
of open land located outside of the Tex-Tin site perimete
fence line. Construction debris brought on site as fill
material and two tin slag piles are located in this area
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3.5.6 Area B encompasses approximately 12.4 acres
and contains copper silicon, tin, and copper slag and
sludge piles, plus 80 fifty-five gallon drums believed to
contain spent catalyst material. The slag was generated
from the tin and copper smelting processes.
3.5.7 Area C contains four closed Acid Ponds (Ponds
18 through 21) that were used to store ferric chloride
solution generated during the tin smelting process.
Process-generated slag and sludge were used as backfill
to close the ponds. In addition to the ponds, piles of slag
scrubber sludge, and river muds are present in Area C.
The river muds were brought to the Tex-Tin site to fill
the ponds in addition to construction debris obtained
from local contractors in the 1980's.
3.5.8 Area D consists of 11.4 acres and consists of,
three separated areas on site. One area is located to the
north of Pond 1 and includes backfilled Ponds 7 and 8
which occupy 3.5 and 0.5 acres, respectively. The
second area is located to the south of Pond 1 and
occupies approximately 3 acres. The third area is locate
to the south of Pond 6 and includes backfilled Pond 17,
which occupies an area of 4.4 acres. Pond 7 was used to
store calcium sulfate scrubber sludge generated from
1980 through 1984. It is uncertain how Pond 8 was
utilized. Pond 17 was probably a ferrous chloride
storage pond, similar to Ponds 18 through 21. Tex Tin
Corporation used construction debris from local
contractors to backfill these ponds?
3.5.9 Area E is centrally located on the site,
encompassing approximately 7 acres bordering the west
side of the Wah Chang ditch. Area E includes filled
Ponds 15 and 16 and approximately 4,200 drums
believed to contain spent catalystPonds 15 and 16 were
used to store acidic liquid waste materials and were
backfilled with slag and other site-related wastes.
3.5.10 Area F. The Wah Chang Ditch, which is the
primary drainage feature on site, runs through Area F, a
12-acre parcel of land located in the noth central area of
the site. Historical photographs indicafe that Area F was
used as a slag holding area.
3.5.11 Area G. The Wah Chang Ditch also runs
through Area G, towards the south-southeast.
Approximately 9 acres in size, Area G also contains
major drainage pathways that feed into the Wah Chang
Ditch which discha-ges into borrow pits known as Pond
24 and Pond 25. The North Central Ditch leads from tte
Process Area north of Pond 7 to the Wah Chang Ditch.
Another ditch located in Area G drains Areas B and C,
flows northward along the railroad tracks to south of the
ore storage building in Area J, andenters the wastewater
treatment facility located in Area K. A third ditch leads
from west of the site to Pond 22 and drains into a borrow
pit next to the hurricane levee.
3.5.12 Area H occupies approximately 29 acres and
includes backfilled Ponds 9 through 14. These ponds
were used to store waste add solutions generated during
tin smelting operations. These ponds were closed in
1988, and a dike was constructed around the area to
prevent site area runoff. The area is currently owned and
maintained by the Amoco Chemical Company. EPA has
designated Parcel H as Operable Unit No. 2 of the Tex-
Tin site. Amoco remediated contamination in this area
under the Texas Voluntary Cleanup Program.
3.5.13 Area I. This area includesthe off site Ponds 22
through 25. These ponds will be investigated during the
OU4 remedial investigation.
3.5.14 Area J is the Process Area where the smelting
operations were conducted. Occupying 25 acres, the
former Process Area contains 18 processing and storage
facilities that were used for production. The major
production units located in Area J include the following
structures:
o Smelter Building with associated Kaldo
Buildings and ancillary structures
o Ore Storage Building
o Roasting and Leaching (R&L) Building
o Maintenance Building
o Warehouse Nos. 1 through 3
o Engineering Building
o Laboratory and Office Building
o Change Room and Garage
o Generator House
The majority of the buildings in the Process Area are
steel-framed, open warehouses with asbestos cement
(transite) siding and roofing; however, the engineering
and laboratory buildings are wood-framed with brick
exteriors and shingle or tile roofs. Some buildings withh
the Process Area have significant structural
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Significant Site Features
Acid Pond
Drums
Ore
Storage
Building
Slag Piles
Pond22
AST's
Roasting and Leaching Building
Smelter Building
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A view of the Tex Tin Site (center) toward the northeast. This view shows the heavy
industrial land use near the facility.
-------
deterioration resulting from the corrosive and heat-
intensive nature of the processes conducted in these
buildings. Since these structures are contaminated, the
collapse or destruction of a building during high winds
could release contaminants into the environment! A
structural survey7 indicated building structures are
corroding and some buildings would require repairs to
make them useable.
3.5.15 Area K. Ponds 1 through 6 are located in Area
K and were used as settling basins for the wastewater
treatment facility, which currently treats stormwater
runoff. Ponds 1 through 5 are currently used as storm
water detention ponds and encompass approximately 22
acres. Pond 6, the Acid Pond covers 4 acres and
currently holds approximately 8.5-million gallons of
acidic ferric chloride solution.
3.5.16 Area L. The Morchem Facility is located in
Area L, which is a drum and tank storage area. Sixteen
above ground storage tanks (ASTs) with volumes
ranging from approximately 1,500 to 500,000 gallonsae
located in this area. The majority of these tanks are
empty, but a few contain sludge believed to be associated
with the still bottoms and the waste oil recovery process
carried out by Morchem. Additionally, approximately
219 drums containing process wastes are present in this
area. The central and southern portionsof this area have
a concrete pad and berm to reduce runoff from the area.
Several pipeline metering stations not belonging to the
Tex-Tin Corporation are also located in this area.
3.5.17 Area M. Located in the northwest portion of
the site, Area M covers approximately2 acresand houses
a fuel storage tank and generator house, as well as three
fuel oil tanks.
3.5.18 Area N. Catalyst tanks are located in Area N.
Five 11,000 gallon ASTs formerly used in the Process
Area to store fuel oils \\ere moved to this location in the
1970s. The tanks currently contain catalyst. An earthen
berm surrounds the tanks.
3.5.19 Area O comprises off site residential properties
which are being addressed in Operable Unit 3.
3.5.20 Area P. The Radioactive Landfill (Texas
License No. RW 1270), located in the southwest corner
of the site and designated as Area P, 'is just larger than
half an acre. Low-level radioactive material thi was not
'smelted for its antimony content was buried here
beginning in July 1975. The landfill was closed in 1978
and a clay cover was placed over the landfill. Heavy
vegetative growth covers the surfaceto provide erosion
control. Thermoluminescent dosimeter monitoring by
the state near the landfill showed results that were below
the limits of Texas Regulations for Contrd of Radiation.
The landfill does not Appear to pose a potential or actual
threat to public health if public access remains
prohibited.
3.5.21 Groundwater Characterization. The site is
atop the Upper Chicot Aquifer which extends from the
surface downward approximately 250 feet. Within the
upper 150 feet of the aquifer crossection there are three
confining zones and three transmissive zones (Figure
3.5.21, "RepresentativeGeological Crossection"). Thes
transmissive zones are of most interestsince they could
be considered potential groundwater sources. The three
zones are the "Shallow Transmissive Zone" (Zone 2),
"Medium Transmissive Zone" (Zone 4) and "Deep
Transmissive Zone" (Zone 6). The "Shallow" and
"Medium Transmissive Zones" are classified by the
Texas Groundwater Classification System as a
moderately saline groundwater with a potential use for
drinking water if fresh or slightly saline water is
unavailable. The "Deep Transmissive Zone" is classified
as slightly saline and useable for drinking water if fresh
water is unavailable. The confining zone above each
transmissive zone consist of clays and silty sandy clays,
while the transmissive zones consist of silty and clayey
sands.
Roasting and Leaching Building.
The upper Texas Gulf Coast is prone to exceptionally
destructive winds. Since 1900, eight major hurricanes have
hit the coast between Port O'Connor and Port Arthur.
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3.5.22 Site GroundwaterHydroIogy8 During the RI,
three saturated sand units (termedthe Shallow, Medium,
and Deep Transmissive Zones) were described as the
water-bearing zones beneath the site. The Shallow
Transmissive Zone is about 5 to 30 feet belowgrade; the
Medium Transmissive Zone is variable and occurs
between 45 and 55 feet below grade; the Deep
Transmissive Zone is about 100 to 140 feet belov grade.
All three transmissivezonesare part of the upper Chicot
Aquifer.
3.5.23 Shallow and Medium Transmissive Zones.
According to information obtained frcm the Woodward-
Clyde Phase II RI, the Shallow and Medium
Transmissive Zones do not appear to have been used for
any economic purposes in the past, and there is no
record of down gradient water wells producing water
from any of the three transmissive zones. However,
according to the RI, some of the wells completedin the
Shallow and Medium Transmissive Zones have Total
Dissolved Solid (TDS) values less tian 3,000 mg/1. The
average of eight wells in the Shallow and Medium
Transmissive Zone have TDS values of 3,950 mg/L and
4,350 mg/L, respectively. In addition, pumping tests in
these transmissivezones revealed potential yields geater
than 150 gallons/day. These results indicate that on-site
groundwater from the Shallow and Medium
Transmissive Zones could potentially be used as a
drinking water source. These zones are classified by the
Texas Groundwater Classification System as a
moderately saline groundwater with a potential use for
drinking water if fresh or slightly saline water is
unavailable. With regard to the Deep Zone, based on
information obtained during the RI, it has a relatively
low TDS value (1,193 mg/L average) and exhibits the
ability to maintain sufficient yield. There are several
domestic wells within a 1-mile radius of the site that are
screened in the Deep Transmissive Zone. This zone is
not a source of drinking water for the Texas City/La
Marque area, but has the potential to be used for
economic purposes, including drinking water. Vertical
flow measured between the ShallowTransmissiveZone"
and the "Medium Transmissive Zone," as well as
between the "Medium Transmissive Zone" and the
"Deep Transmissive Zone" indicated the zones are
hydraulically interconnected. The "Shallow
Transmissive Zone," Wah Chang Ditch and Ponds 4, 5,
6, 24 and 25 also appear to be hydraulically
interconnected. Suchaconnection could be a migration
pathway for contamination of the "Shallow Transmissi\e
Zone." 9- I0
3.5.24 Groundwater Flow. In this region the Upper
Chicot aquifer is characterized by horizontal flow
towards the south and southeast. Locally, horizontal
flow in the "Shallow Transmissive Zone" is to the east
and in the "Medium"and "Deep Transmissive Zones" is
to the south. Groundwater monitoring activities during
the RI indicated that the flow direction in the Shallow
Transmissive Zone was influenced greatly by surface
activities. For example, Ponds 1 through 5, the former
wastewater treatment ponds, lie at a higher elevation thai
the surrounding area. When the wastewater treatment
system was in use, a steep radial gradient from tie ponds
outward into the Wah Chang Ditch was seen through
measured groundwater elevations. In the southern
section of the site, another stasp gradient was seen from
northwest to southeastwhere pumping of the borrow pits
had lowered the shallow water table. Consequently,
shallow groundwater may migrate from the site to the
borrow ditches. The shallow groundwater is
characterized by low pH and elevated dissolved metal
concentrations. The groundwater flow direction in the
Medium and Deep Transmissive Zones is consistently
towards the southeast. The gradient is generally flat and
appears to steepen toward the south, but is variable
across the site depending on location.
3.5.25 Sampling Strategy. Considering overall site
conditions, during the remedial investigations EPA
developed a strategy to collect air, soil, surface water,
groundwater and contaminant source samples to
determine the carcinogenic risks and non-carcinogenic
hazards the contaminant sources might pose to human
health or the environment. Two phases of field
investigations were conducted to prepare the 1993
Remedial Investigation at the Site. Phase I of the
investigation was conductedby ERM Southwest between
November 1990 and April 1-991, and Phase II was
conducted by Woodward-Clyde Consultants between
February and August of 1992. EPA performed
additional site sampling in 1994-95, particularly in the
residential area now designated OU3.
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Figure 3.5.21
Representative Geological Crossection
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3.5.26 Types of Contamination and the Affected
Media. The remedial investigation sampling strategy
confirmed that industrial operations contam inated the sife
with heavy metals, acids, radioactive isotopes and
organic compounds. Some of these contaminants pose
unacceptable carcinogenic risks and non-careinogenb
hazards at the concentration levels found on site. The
specific health effects posed by these contaminants are
listed on Table 3.5.2.26 - 1, "Health Effects and
Concerns." Based upon the sampling, EPA estimated tte
volume of contaminated sources and media to be those
quantities shown on Table 3.5.26 - 2, "Estimated
Volumes of Primary, Secondary and Tertiary
Contaminant Sources Requiring Remediation." 'Lastly
EPA used the sampling results to determine if the
contaminant sources included any RCRA (Resource
Conservation and Recovery Act) listed or characteristic
hazardous wastes with chemical specific cleanup
requirements. Sampling indicated that there is a high
enough lead concentration in the sludge in the tank
bottoms located in Area L to classify this sludge asa
K0052 Hazardous Waste. There are also wastes
exhibiting the RCRA characteristic of corrosivity and
toxicity as shown on Table 3.5.26 - 3, "Characteristic
Hazardous Wastes." Some tank bottom sludges also
exhibited these hazardous waste characteristics.
Supersacks stored inside the ore storage building.
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Table 3.5.26 - 1 Health Effects and Concerns
Contaminants of
Concern
1,2-Dichlorocihanc
Antimony
Arsenic
Asbestos
Barium
Benzene
Beryllium
Cadmium
Chloroform
Chromium
Copper
Lead
Mercury
Radium 226 & 228
Selenium
Thorium 228, 230 & 232
Uranium
Health Effects and Concerns
Breathing very high levels of 1,2 - Dichloroethane vapor is deadly; the long term human health effects after exposure to lo\
concentrations ofl ,2 - Dichloroethane are not known. ' '
Breathing air contaminated with antimony can cause heart and lung problems, lead to stomach pain, diarrhea, vomiting and
stomach ulcers. It is not known if antimony is a carcinogen."
Inorganic arsenic has been recognized as a human poison since ancient times, and large doses can produce death. Inhalation
exposure to arsenic increases the risk of lung cancer.11
Workers who breath in asbestos may slowly develop scar-like tissue in their lungs and in the membrane surrounding their
lungs. This tissue makes breathing difficult. This disease is called asbestosis.14
Eating or drinking very large amounts of readily soluble barium compounds such as barium acetate, barium carbonate,
barium chloride, barium hydroxide, barium nitrate, and barium sulfide may cause paralysis or death in a few individuals.
There is no reliable information to tell if barium causes cancer. ]i
The U.S. Department of Health and Human Services has determined that benzene is carcinogenic. Leukemia (cancer of the
tissues that form the white blood cells) and subsequent death from cancer have occurred in some workers exposed to benzer
for periods of less than 5 and up to 30 years."
Beryllium can damage the lungs when breathed. Breathing large amounts of soluble beryllium compounds can cause a
disease resembling pneumonia. Some people are allergic to beryllium and develop chronic inflammatory reactions to doses
of beryllium which would not cause an effect on most other people. Both the pneumonia like disease and the chronic
inflammatory reactions can be fatal. Some studies have shown beryllium to be a probable human carcinogen. •"
Breathing air with high levels of cadmium severely damages the lungs and can cause death. Breathing lower levels of
cadmium for years leads to a build-up of cadmium in the kidneys that can cause kidney disease. Workers who inhale
cadmium for a long time may have an increased chance of contracting lung cancer."1
Chloroform affects the central nervous system, brain, liver, kidneys after a person breathes air or drinks liquids that contain
large amounts of chloroform. Studies of persons who drank chlorinated water showed a possible link between the
chloroform in chlorinated water and the occurrence of colon and urinary bladder cancer. Consequently chloroform is a
possible human carcinogen.19
The U.S. Department of Health and Human Services has determined that chromium and certain chromium compounds are
known carcinogens. Long-term exposure of workers to airborne levels of chromium higher than those in the natural
environment has been associated with lung cancer. Lung cancer may occur long after exposure to chromium has ended.2"
Very large single or daily intakes of copper can be harmful. Long term exposure to copper dust can irritate the nose, mouth
and eyes, and cause headaches, dizziness, nausea, and diarrhea. Drinking water that contains higher than normal levels of
copper may cause vomiting, diarrhea, stomach camps and nausea. Intentionally high intakes of copper can cause liver and
kidney damage and even death. Copper is not known to cause cancer.2'
Exposure to high levels of lead can cause the brain and kidneys of adults and children to be badly damaged."
Long-term exposure to either organic or inorganic mercury can permanently damage the brain and kidneys. Short-term
exposure to high levels of inorganic and organic mercury will have similar health effects; but full recovery is more likely
after short-term exposures, once the body clears itself of the contamination.2'
There is no clear evidence that long-term exposure to radium at the levels normally present in the environment is likely to
result in harmful health effects. However, exposure to higher levels of radium over a long period of time may result in
harmful effects including anemia, cataracts, cancer and possibly death.24
Selenium is an essential nutrient, however when taken in amounts five to ten times the recommended dietary allowance.
selenium can be harmful. In extreme cases, people may lose feeling and control in arms and legs. However these effects
have been seen only in cases where people were exposed to doses from about 1 to 25 ug/kg/day for several months or years
Studies show that most selenium compounds do not cause cancer. 2S
Studies on thorium workers have shown that breathing thorium dust may cause an increased chance of developing lung
disease and cancer or pancreatic cancer after many years of exposure.26
Uranium is a radioactive chemical which may cause kidney damage or a bone cancer. However, cancer from an exposure tc
naturally occurring Uranium 238 is unlikely. Most cancer is caused by an exposure to enriched uranium.27
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Table 3.5.26 - 2 Estimated Volumes of Primary, Secondary and Tertiary Contaminant Sources
Requiring Remediation
Acid Pond Surface Water
Acid Pond Sludge and Berms and Wan Chang Ditch Sediments
Wastewater Pond (Ponds 1 - 5) Sediments
Spent Catalyst (Drum and Supersack Contents)
Aboveground Storage Tanks
Surface and Subsurface Soils
NORM Slag Piles
Non-NORM Slag Piles
Quantity
8.500.000
63.000
164320
1.600
289.850
549.800
14,100
52,000
Units
gallons
cubic yards
cubic yards
cubic yards
gallons
cubic yards
cubic yards
cubic yards
Table 3.5.26 - 3 Characteristic Hazardous Wastes
Waste
Acid Pond Liquid
Spent Catalyst (Drums . Sacks and Buckets)
Above Ground Storage Tanks Waste Stream
Non-NORM Slag Piles Numbers 1, 1 1,19, 27,
28. 29, 52, 56. 57. 58, 62'
Hazardous Waste Classification Characteristic28
Corrosive
Toxicity -
WSI
WS2
WS3
WS5
WS6
WS8
-pH<2
Contents exceeded established regulatory levels for arsenic, lead and cadmium leachability.
Corrosive - pH < 2
Toxicity - Waste stream exceeded established regulatory levels for cadmium and lead
leachability.
Corrosive - pH < 2
Toxicity - Waste stream exceeded established regulatory levels for cadmium, chromium and
lead leachability.
Corrosive - pH < 2
Toxicity - Waste stream exceeded established regulatory levels for cadmium, chromium.
lead and selenium leachability.
Toxicity - Waste stream exceeded established regulatory levels for chromium leachability.
Corrosive - pH < 2
Toxicity - Waste stream exceeded established regulatory levels for cadmium leachability.
Toxicity Characteristic - Except for pile 62 contents exceeded established regulatory levels for lead
leachability. Pile 62 exceeded established regulatory levels for mercury leachability.
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3.5.27 Site Conceptual Model. The site conceptual
model is based upon the aforementioned site
characteristics and illustrates how the contaminants are
released from their primary, secondary or tertiary
sources, move down a pathway and potentially expose
human and ecological receptors. The model considers
current and potential site resources and uses and is
supported by the cross sectbns, maps, site diagrams and
tables found in Section 3.5, "Site Characteristicsand Sie
Conceptual Model." Two site conceptual model
illustrations [Figures 3.5.27- 1, "Conceptual Site Model
Soil Waste Piles and Drums" and 3.5.27-2 'Conceptual
Site Model Sediment and Surface Water"] were drawn to
explain the relationship between the source, release
mechanism, pathway, exposure route and receptors.
3.5.28 Release Mechanism. The models show how
a release mechanism from the primary, secondary or
tertiary contaminant source can contaminate the pahway
and exposure route to a receptor. The site's state of
disrepair, severe weather, high rainfall, characteristic
hazardous waste, and shallow groundwater provide
mechanisms to release contaminants into the
environment. The future land use as an industrial facilty
provides a receptor to complete the exposure route, thus
creating a possible carcinogenic risk or non-carcirogenic
hazard.
3.5.29 Contaminant Sources. Since a variety of
contaminant sources remain on site, the receptor's
carcinogenic risk and non-carcinogenic hazard was
assessed through direct pathways and exposure routes
from the contaminant sources described in Box 3.5.29,
"Contaminant Sources."
Box 3.5.29 Contaminant Sources
Drums (spent catalyst) in Areas B. E, J, and L contain pimary contaminant
sources. Exposed drum materials (spent catalyst) create pathways via leaks
and spills to industrial and construction workers through exposure routes
such as accidental ingeiion or dermal contact during work activities. As is
shown in subsequent sections the spent catalyst foundn many of the drums
appear to be highly toxic and the drums are severely deteriorated;
consequently EPA considers the spat catalyst to be a principal threat waste
since the contents arc source materials of highly toxic materials which are
not currently reliably contained.
Abovcground storage tank sludge in Area L is a primary contaminant
source. Leaking or spilled sludge creates a pathway to industrial and
construction workers through exposure routes such accidental ingestion
or dermal contact during work activities. As is shown in subsequent salons
(he sludge has a low pH and is therefore considered highly toxic ancfe
principal threat waste. Sludge is classified as RCRA K0052 hazardous
waste,
Buildings, structures and on-site process units in Area J are primary
contaminant sources. These faciltics contain spilled contaminants from the
smelting process and can be assumed t be covered with contaminated dust.
Spilled contaminants and dust from smelting create pathways to industrial
and construction workers through exposure routes such as accidental
ingestion or dcrmd contact during work activities. These contaminants are
highly mobile and considered a principal threat. The l993Remedial
Investigation Report indicated there was asbestos in some of the the
buildings.
Soil in Areas A through F, J. and L through N are secondary as well as
tertiary contaminant sources. Exposure to soils create pathways to indtrial
and construction workers through exposure routes such as accidental
ingestion. inhalation of radon gas released from the soil, or dermal contact.
In addition workers in these areas may come into contact witburface soil
or subsurface soil (which may be brought to the surface via soil excavation
activities) through maintenance or construction activitiesIJnless soils are
highly toxic or leach contaminants EPA will onsidcr soil a low level threat.
In addition any waste pile that leaches contaminants in excess of the
concentrations listed in Table 3.11.3.1. "Soil. Sediment. Slag and Sludge
Remedial Action Cleanup Leve." is also considered a principal threat since
the contaminant is mobile. Waste pile which do not leach contaminants in
excess of the leachate concentations listed in Table 3.11.3.1 are considered
a low level threat since they are notonsidered to be mobile or highly toxic.
Waste piles in Areas A through F. and J, are primary contaminant sources.
Exposure to these piles creates a pathway via soil to industrial and
construction workers through exposure routes such as accidental ingestion.
inhalation of radon gas released from the sd or dermal contact during work
activities. EPA omsiders the NORM slag waste piles to be principal threat
wastes since they are generally highly toxic source materials.
Sediments in Areas G and K. are secondary as well as tertiary contaminant
sources. Exposure to sediments creates a pathway to industrial and
construction workers through exposure routes such asaccidental ingestion
and derma) contact. Workers in these areas may come into contact with
sediments through maintenance or construction activitiesEPA considers
sediments in area G to be low level threats since they are not generally
highly toxic nor highly mobile; however EPA cosiders sediments in area K
to be a principal threat because the low pH makes them highly toxic.
Surface water in Areas G & K. Exposure to contaminants in surace water
associated with on-site drainage ditches and on-site ponds was evaluated
through dermal contact with surface water. The Acid Pond in Area K ia
primary contaminant source while Area G becomes a secondary or tertiary
source dependent upon the release mechanism shown on Figure 3.5.27 - 2.
Workers may be exposed to surface waters during work activities.
Accidental ingestion of on-sitesurface water was not evaluated because on-
site surface water bodies (drainage and ponds) are shallow; therefore. EPA
assumed that accidental ingestion of surface water would be an unlikely
route of exposure. EPA does not consideithe surface water in Area G to be
a principal threat since it is not a source material.
Groundwater. The Shallow. Medium and Deep Transmissive Zones were
each evaluated through ingestion and noningestion exposure routes (i.e.,
dermal contact while showering, and inhalation of volatiles through
showering). These exposure routes were selected because future on-site
industrial workers may use on-site groundwater for showering or drinking.
EPA does not consider the groundwater to be a principal threat waste since
it is not a source material.
-------
Figure 3.5.27 - 1
Conceptual Site Model
Soil Waste Piles and Drums
-------
-------
Figure 3.5.27-2
Conceptual Site Model
Sediment and Surface Water
-------
-------
3.6 Current and Potential Site and Resource Uses.
This section defines the current and potential site and
resource use assumptions EPA used toassess the current
and future carcinogenic risks and non-carcinogenic
hazards at the site. The site and resource uses are
necessary to identify receptors, pathways, exposure
routes and receptors through which someone may be
exposed to a carcinogenic risk or non-carcinogenic
hazard.
3.6.1 Land Uses. Since the industrial operations
ceased in 1991, all the land within the boundaries of
Operable Unit 1, shown on the map "Operable Unit 1
Surrounding Land Use," is idle and the facilities are in
disrepair. Many structures on site are contaminated, so
the collapse or destruction of a building during high
winds could release the contaminants contained in the
buildings into the environment. In addition since the
owner is bankrupt there does not appear to be any
ongoing facility maintenance to ensure the buildings do
not continue to deteriorate. Consequently, EPA
considers there can be little if any current use of the
facility without significant decontamination, demolition,
renovation or construction. Surrounding landis used for
residential, industrial or transportation purposes. Land
south of the site is within the 100 year flood plain as
shown on the "Operable Unit 1, Surround ingLand Uses"
map. Most of the land to the north, east, and south is
used primarily for chemical manufacturing and
petroleum refining. Nonchemical manufacturing
companies and residential areas are located west and
northwest of the site. The nearest residentialocation is
in La Marqueapproximateiy 1,000 to 1,500 feet from the
site. Nearby bay and estuary waters are used for
commercial and sport fishing, recreation, and
transportation.30 While there is currently no specific
future use identified for the site, based upon the
surrounding land use, conversations with local officials
and public comment, EPA assumes industrial activity is
the most reasonable anticipated general future site use.31
Therefore, EPA assessed the carcinogenic risk and non-
carcinogenic hazards to futureconstructionand industrial
workers at the site with the assumption that the biildings
will continue to deteriorate and significant construction
is required before the facility can be returned to a
beneficial industrial use.
3.6.2 GroundwaterUses. Although the site is atop a
drinking water aquifer, since there are no current
operations at the site there is no curent site groundwater
use. The groundwater immediately beneath the site is
classified by the Texas Groundwater Classification
System as a moderately saline groundwater with a
potential use for drinking water F fresh or slightly saline
water is unavailable. The "Deep Transmissive Zone" is
classified as slightly saline and useable for drinking
water if fresh water is unavailable. However, the Harris
Galveston Coastal Subsidence District (HGCSD) has the
regulatory authority to limi groundwater withdrawals at
the site to prevent"... subsidence which contributes to or
precipitates flooding, inundation, or overflow of any area
within the district...'92 To prevent subsidence the
HGCSD, through the "District Plan," has limited
groundwater withdrawals in this area to ten percert of an
industrial facility's total water use. Consequently, EPA
does not believe future groundwater withdrawals from
the site are likely.33 But since there is a potential for
limited human or natural resource groundwater use, the
risk to future industrial workers using the water for
showering was evaluated in the risk assessment3.4
3.6.3 Drinking Water. The Texas City area is
supplied by both groundwaterand surface water soirees.
Two major aquifers underlie the region, the Chicot
Aquifer and the Evangeline Aquifer. TheChicot Aquifer
is a primary drinking water source in the region while tte
Evangeline Aquifer, the deeper of the two, is considered
unsuitable for use as drinking water in the Texas City
area due to its high salinity.
Deteriorated column in Roasting and
Leaching building
-------
3.7 Site Carcinogenic Risks and Non-carcinogenic
Hazards. In previous sections EPA identified receptors
potentially affected by site contaminant sources. This
section explains how carcinogenic risks and non-
carcinogenic hazards from contaminant sources - for
which there are no applicable, relevant or appropriate
contaminant specific remediation goals - were assessed
in the Baseline Human Health Risk Assessment
(BHHRA). In addition, this section presents the nature
of the most significant carcinogenic risks and non-
carcinogenic hazards posed to human health and the
environment to demonstrate that the basis for the
remedial action selected in this ROD is warranted?5 This
section also provides a brief summary of the ecological
risk assessment. Note, because of the uncertainty
associated with the lack of chemical-specific absorption
factors, carcinogenic risks and non-carcinogenic hazards
from dermal contact exposureroutes were not considered
in EPA's remedy decision. However, as explained in the
following sections there aresufficient carcinogenic risks
and non-carcinogenic hazards within each area in this
operable unit to require remedial action without
consideringa risk or hazard from dermal exposure. The
uncertainties associated with dermal exposures are
explained in the BHHRA, Section 6.O., "Uncertainty
Analysis."
3.7.1 Summary of Human Health Risk Assessment
The baseline risk assessment estimates what carcinogens
risks and non-carcinogenic hazards the primary,
secondary and tertiary contaminant sources pose to the
receptors identified in the site conceptual models if no
environmental response action were taken. From this
assessment EPA identified the contaminant sources, and
chemicals within these sources, requiring remediation.
Since any site reuse will require significant restoration,
EPA looks to mitigate risks to future construction or
industrial workers in specific site areas (Areas A - G, J -
N and Wl - W3). Consequently, EPA has focused this
ROD on exposure pathway scenarios which include
future uses. Using the data from the investigjtions, EPA
first decided whether or not a chemical carcinogenic or
radionuciide carcinogenic risk warranted a remedial
action. If a significant carcinogenic risk was not pesent,
EPA then decided if a remedial actionwas necessary to
remediate the non-carcinogenic hazards.
3.7.1.1 Identification of Chemicals of Concern. The
chemicals of concern are specific chemials contained in
the contaminant sources on site which pose an
unacceptable risk to human health and the environment.
The detailed criteria used to select a diemical of concern
is described in the Baseline Human Health Risk
Assessment, Tex-Tin Corporation, Texas City, Texas,
March 1997, which is consistent with EPA's guidance
described by the Risk Assessment Guidance for
Superfund (RAGS) Volume 1: Human Health Evaluation
Manual - Part A. and the Supplemental Region VI Risk
Assessment Guidance. In summary the fundamental
criteria used to select a chemical of concern was
detectingthe chemical which has a remedial action goal
established by a chemical specific Federal or State
requirement or which poses an unacceptablecarcinogenc
risk or non-carcinogenic hazard in more than 95 percent
of the samples analyzed. Based upon this criteria, EPA
selected the chemicals of concern liied in Table 3.7.1.1,
"Site Wide Summary of Chemicals of Concern." This
table indicates where chemicals of concern were found
and their concentration range. The table also shows the
frequency each contaminantof concern wa found in the
source or media analyzed.
3.7.1.1.1 Exposure Point Concentration.36 For
each receptor and chemical of concern EPA developed
Table 3.7.1.1.1 - I, "Exposure Point Concentrations,"
which shows the concentration EPA used to determine
the receptor's risk from the pathways and scenarios
described by the site conceptual model. Sampling data
were used to estimate exposure point concentrations
which serve to determine the exposure dose. In
accordance with EPA guidance, potential risks are
typically based (with the exception of groundwater) on
95% upper confidence limit (UCL) concentraions of the
mean. However at this site since the 95% UCL was
greater than any concentrations found on site, so the
maximum detected concentration was used as the
exposure point concentration.37 In the case of
groundwater, EPA estimated potential risks for on-site
groundwater upon the mean concentration of chemicals
of concern in on-site wellswith chemical concentrations
equaling or exceeding primary drinking water standard
maximum contaminant levels.38 Since the organic
compounds concentration present in thegroundwaterwas
well below their solubility concentations, EPA does not
believe a dense non-aqueous phase liquid lies beneath th;
surface. Wells which equaled or exceeded drinking
water standards are listed in Table 3.7.1.1.1 - 2,
"Monitoring Wells Exceeding Primary Drinking Water
Standard Maximum Contaminant Levels," and shown en
Figure 3.7.1.1.1, "Locations of Monitoring Wells and
Piezometers." For soil-related pathways surfacesoil data
were used to develop exposure point concentrations for
the current/future scenarios.
-------
Table 3.7.1.1 Site Wide Summary of Chemicals of Concern 39
Source or Media
Drums (Spent Catalyst)
Ground water'-2
Sediment
Surface / Subsurface Soils /
Waste Piles
Contaminant of Concern
Arsenic
Copper
Lead
Molybdenum
Antimony
Arsenic
Barium
Benzene
Beryllium
Cadmium
Chloroform
Chromium
Copper
Lead
Mercury
Radium 226
Radium 228
Selenium
Thorium 228
Thorium 230
Thorium 232
Uranium 234
Uranium 235
Uranium 238
1,2 Dichloroethane
Arsenic
Arsenic3
Copper3
Lead3
Radium - 226
Radium - 228
Thorium - 228
Concentration Detected
Min
0.57
1.5
0.59
7.7
0
0.05
2
0
0
0.02
0.11
0.41
2.19
0.05
0
1.2
7
0.06
0.7
1.2
0.6
1.85
1.2
3.2
0.06
1
17.1
34.2
220.4
0.527
0.29
0.21
Max
440200
595000
198800
161000
0.0298
15.9
7.25
0.98
1.18
16.2
0.11
15.2
746
1480
0.99
6.1
7
0.3
13.6
2.6
12.7
29.3
1.3
28.7
0.21
19256
4990
108409
27362
177
92.6
212
Units
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
PPm
ppm
pCi/i
pCi/1
ppm
pCi/I
pCi/1
pCi/l
pCi/1
pCi/1
pCi/1
ppm
ppm
ppm
ppm
ppm
pCi/g
pCi/g
pCi/g
Detection
Frequency
249 / 290
209/217
288/297
77/89
12/94
16/94
26/94
4/85
27/94
45/94
1 /85
7/94
42/94
39/94
22/94
7/21
2/21
31/94
9/21
3/21
10/21
9/20
2/20
9/20
4/85
153 / 153
349 / 555
339/555
281/555
91/102
66/66
98/1 1 1
1 . Minimum groundwater concentration detected represents the lowest concentration exceeding the primary drinking water standard
maximum contaminant levels.
2. Groundwater detection frequency indicates the number of wells per the total number of wells sampled had groundwater
concentrations exceeding the primary drinking water standard maximum contaminant levels
3. Minimum concentration is the background level established by the Supplemental Remedial Investigation. The detection frequency
is the number of times the sample concentration exceeded the background concentration per the total number of samples analyses
performed.40
-------
These scenarios are based on the assumption thatthe soil
is not disturbed, and only surface soil is available for
direct contact and for the generation of airborne
particulates. Both surface and subsurface soil data (0 to
15 ft.) were used to develop exposure point
concentrations for the inhalation of volatiles exposure
route because chemicals may be emitted from both
surface and subsurface soil, even when the soil is
undisturbed. Surface and subsurface soil data (0 to 15
feet) were used to develop exposure point concentrdions
for all exposure routes for the future industrial and
construction worker scenarios assuming future work
would require soil excavation. Note, 15 feet was the
maximum depth evaluated; only AreaC had soil sample
collected to a depth of 15 feet. Direct and indirect
exposure to both surface and subsurface contaminants
could potentially occur in a construction worker senario
during excavation, or as a result of soil regrading ina
future industrial worker scenario. The exposure
assessmentwas based upon the previous^ described site
characteristics and site conceptual model. The default
statistic used to determine the exposure point
concentration is the 95 percent upperconfidence limit of
the mean, in other words a value for which EPA is 95
percent confident that the mean concaitration is equal to
or less than the exposure point concentration shown.
However, because the number of samples collected was
limited, in cases were the 95 percent upper confidence
limit exceeded the maximum concentration detected on
site, EPA used the maximum concentration as the
exposure point concentration.
Drums in Area E.
-------
Figure 3.7.1.1.1
Locations of Monitoring Wells and Piezometers
-------
-------
Table 3.7.1.1 .1-1
EXPOSURE POINT CONCENTRATIONS
Exposure Pathway Receptor Scenario
Chemical of
Concern
Exposure Point
Concentration
Units
Statistical
Measure
Area A
Future Exposure Surface/ Subsurface Soil
and Waste Piles
Arsenic
Radium - 226
Radium - 228
245
23.8
92.6
ppm
pCi/g
pCi/g
Maximum
Concentration
AreaB
Future Exposure Surface / Subsurface Soil
and Waste Piles
Arsenic
Copper
Radium - 226
Radium - 228
Thorium - 228
170
108000
93.6
91.8
212
ppm
ppm
PCi/g
PCi/g
pCi/g
Maximum
Concentration
Area C
Future Exposure Surface / Subsurface Soil
and Waste Piles
Arsenic
Antimony
Radium - 226
Radium - 228
Thorium - 228
1820
2850
21.6
14.0
18.2
ppm
ppm
PCi/g
pCi/g
pCi/g
Maximum
Concentration
Area D
Current/Future Exposure Surface Soil and
Waste Piles
Arsenic
Antimony
Manganese
Radium - 226
Radium - 228
Thorium - 228
238
315
48300
1.26
1.48
1.99
ppm
ppm
ppm
PCi/g
pCi/g
pCi/g
Maximum
Concentration
AreaE
Future Exposure Surface / Subsurface Soil
and Waste Piles
Future Exposure Drums (Spent Catalyst)
Arsenic
Radium - 226
Radium - 228
Thorium - 228
Copper
Molybdenum
Nickel
996
17.6
20.6
15.9
595,000
93,800
226,000
ppm
pCi/g
pCi/g
pCi/g
ppm
ppm
ppm
Maximum
Concentration
Maximum
Concentration
Area F
Future Exposure Surface / Subsurface Soil
and Waste Piles
Arsenic
Antimony
Radium - 226
Radium - 228
Thorium - 228
776
186
73.9
63.7
36.8
ppm
ppm
pCi/g
pCi/g
pCi/g
Maximum
Concentration
AreaG
Current Exposure Sediment
Current Exposure to Surface Water
Arsenic
Arsenic
1500
.506
ppm
ppm
Maximum
Concentration
Area J
Current / Future Exposure Drums (Spent
Catalyst)
Future Exposure Surface / Subsurface
Soil and Waste Piles
Arsenic
Molybdenum
Copper
Antimony
Nickel
Arsenic
Antimony
Copper
440,200
76391
496728
4950
17600
612
263
45,500
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
Maximum
Concentration
Maximum
Concentration
-------
Table 3.7.1.1 .1-1
EXPOSURE POINT CONCENTRATIONS
Exposure Pathway Receptor Scenario
Chemical of
Concern
Exposure Point
Concentration
Units
Statistical
Measure
Area K(Ponds 1-5)
Current/Future Exposure Sediment
Arsenic
10,700
ppm
Maximum
Concentration
AreaL
Future Exposure Surface/ Subsurface Soil
Future Exposure to Drums (Spent Catalyst)
Arsenic
Molybdenum
946
161,000
ppm
ppm
Maximum
Concentration
AreaM
Future Exposure Surface/ Subsurface Soil
Arsenic
263
ppm
Maximum
concentration
AreaN
Future Exposure Surface /Subsurface Soil
Arsenic
598
ppm
Maximum
Concentration
Shallow Transmissive Zone
Future Exposure Groundwater
Arsenic
Beryllium
Cadmium
Copper
Manganese
Mercury
Silver
Zinc
0.605
0.1
2.63
112
187
903
14.1
250
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
Mean
Concentration
Within the Plume
Medium Transmissive Zone
Future Exposure Groundwater
Arsenic
.035
5
ppm
Mean
Concentration
Within the Plume
Deep Transmissive Zone
Future Exposure Groundwater
Arsenic
.032
3
ppm
Mean
Concentration
Within the Plume
-------
Table 3.7.1.1.1 - 2
Monitoring Wells Exceeding
Primary Drinking Water Standard Maximum Contaminant Levels.41
MW-03S
MW-07S
MW-09S
MW-IOS
MW-11S
MW-12D
MW-12M
MW-12S
MW-14M
MW-14P
MW-14S
MW-15S
MW-17D
MW-16S
MW-17S
MW-18S
MW-19S
MW-20S
MW-25M
MW-25S
MW-33S
MW-34S
MW-35S
MW-36S
MW-38M
MW-38S
MW-39S
MW-40M
MW-40S
MW-42S
MW-43S
MW-44S
MW-45S
MW-46S
MW-47S
MW-18S
MW-52S
MW-53S
MW-53S
MW-54S
MW-55S
MW-55S
MW-56S
MW-57S
MW-6S
MW-8M
MW-8S
Lead, Selenium
Barium. Cadmium, Copper, Lead, Nickel, Radionuclide
Beryllium. Barium, Cadmium, Copper, Lead, Mercury, Nickel, Selenium
Arsenic. Beryllium, Cadmium. Copper, Lead, Nickel
Cadmium, Copper, Selenium
Arsenic, Lead, Selenium
Lead
Barium, Cadmium, Copper, Lead, Mercury, Selenium
Arsenic, Lead, Selenium
Barium, Beryllium, Cadmium, Chromium, Copper. Lead. Mercury. Nickel, Selenium
Copper. Lead
Barium, Beryllium, Cadmium, Copper. Lead, Mercury. Nickel. Selenium
Benzene, Lead. Selenium
Selenium
Barium. Beryllium, Cadmium, Copper, Lead, Mercury, Nickel
Arsenic. Barium, Beryllium. Cadmium, copper, Lead. Mercury, Nickel, Selenium.
Barium, Beryllium. Cadmium. Lead, Copper
Barium, Cadmium, Copper. Lead, Selenium
Selenium
Arsenic, Barium, Beryllium, Cadmium, copper. Lead, Mercury, Nickel. Selenium.
Arsenic, Barium, Beryllium, Cadmium, Chromium, Copper, Lead. Mercury. Nickel. Selenium
Arsenic, Barium. Beryllium. Cadmium, Chromium, Copper. Lead. Mercury. Nickel
Antimony
Arsenic
Lead
Cadmium. Copper, Lead, Selenium
Barium, Beryllium, Cadmium, Copper, Lead, Selenium
Lead
Barium, Cadmium, Copper, Lead
1 ,2-Dichloroethane, Cadmium, Copper, Lead and Selenium
Arsenic, Barium, Beryllium, Cadmium, Copper. Lead, Mercury, Nickel
Beryllium, Cadmium, Copper, Lead, Nickel
Antimony
Arsenic, Barium, Beryllium, Cadmium, Copper, Lead, Mercury. Selenium
1 .2-Dichloroethane, 1,1,2-Trichloroethane, Chloroform, Beryllium, Chromium. Selenium
1 ,2-Dichloroethane, 1 . 1 ,2-Trichloroethane. Benzene, Beryllium.
Beryllium. Lead
Cadmium. Copper, Lead
Beryllium. Lead
Barium. Cadmium. Copper. Lead. Selenium
Cadmium. Lead
Barium. Beryllium, Lead. Selenium
Lead
Beryllium. Lead
Arsenic
Lead
Lead. Selenium
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3.7.1.1.2 Exposure Assessment.42 Using the site
conceptual models described in Section 3.5.27, "Site
Conceptual Model," an exposure assessment was
conducted with mathematical models to estimate the
contaminant dose (exposure) receptors may receive
through the pathways identified in the model. In the
exposure assessment, reasonable maximum exposure
estimates were developed for the industrial land use
identified in the site characterization. The objectives of
the exposure assessment are to characterize potentially
exposed human populations in the on-and off-site areas
associated with the Tex-Tin site, to identify actual or
potential exposure pathways, and to determine theextent
of exposure. The exposure assessment involves several
key elements including the following:
o Definition of local land and water uses (See
Section, 3.6, "Current and Potential Future Site
and Resource Uses")
o Identification of the potential receptors/expoare
scenarios.
o Identification of exposure routes.
o Estimation of exposure point concentrations.
o Estimation of daily doses.
3.7.1.1.3 Identification of Potentially Exposed
Populations. This step of the assessment involves
predicting the activity patterns of potentially exposed
populations and selecting the current and future receptoB
under a reasonable maximum exposure (RME) scenario.
It is based on current and potential use of the site for
industrial purposes. The RME estimate is designed to
measure "high-end exposure." Box 3.7.1.2.1, "Receptor
Exposure," below describes the exposure duration and
frequency to the receptors identified in Section 3.5.27,
"Site Conceptual Model" and the media of concern for
each scenario. (Note the "On-Site Smokestack
Emissions" shown on Figure 3.5.27 are not addressed in
this operable unit but will be addressed in Operable Unit
3.) The sample locations chosen as exposure points are
described in the Baseline Human HeahhRisk Assessment
(BHHRA), Section 2.2, "Summary ofSamplingData For
Media of Concern." Major exposure assumptions are
summarized in Table 3.7.1.2.1, "Major Exposure
Assumptions."
Drums in the ore storage building.
-------
Box 3.7.1.2.1 - 1 Receptor Exposure
Drummed Material (Spent Catalyst). The evaluated receptors include current/future industrial workers and future
construction workers potentially exposed to drummed material. Note, drummed materials have been evaluated
separately from soil and/or waste piles that occur in the same area.
Above Ground Storage Tanks. The evaluated receptors include current/future industrial workers and future
construction workers potentially exposed to tank sludge if the sludge leaks or spills from the tank.
Buildings, Structures and Process Units. The evaluated receptors include current/future industrial workers and
future construction workers potentially exposed to contaminated dust, spilled process wastes such as slag and spent
catalyst inside these facilities.
Soil and Waste Piles. The evaluated receptors include current/future industrial and construction workers potentially
exposed to on-site surface soil and on-site waste piles, and future industrial and construction workers potentially
exposed to on-site surface and subsurface soil and on-site waste piles. Workers were assumed to be exposed to soil
and waste piles during work activities.
On Site Drainages. The evaluated receptors include current trespassers and current/future industrial workers
potentially exposed to on-site sediment and surface water associated with on-site drainages (including the Wah Chang
Ditch). EPA assumes that a trespasser would be more likely to frequent the on-site drainage locations than other on-
site areas because these areas would be most likely to attract trespassers on a regular basis. However, the evaluation
of a current worker scenario at these areas is a conservative approach that ensures the protection of the occasional
trespasser. Swimming was assumed to be an unlikely occurrence because the drainages are relatively shallow,
therefore the receptors would more likely engage in wading activities. Current/future industrial workers were assumed
to be exposed to surface water/sediment during work activities. For current/future industrial workers, exposure
durations of 25 years were used. The current/future industrial worker was estimated to be on the site for
approximately 1.0 and 0.5 hours per exposure event, respectively.
Ponds. The evaluated receptors include current/future industrial workers potentially exposed to on-site sediment in
Ponds 1 through 6 and on-site surface water in Ponds 4 and 6. It should be noted that sediment and surface water in
the Acid Pond, the only remaining waste acid pond, were evaluated separately from sediment in Ponds 1 through 5
and surface water in Ponds 4 and 5. Pond 6, the Acid Pond, was evaluated separately from Ponds 1 through 5 because
it is a waste acid pond and not a former wastewater treatment pond.
Groundwater. The evaluated receptors include future industrial workers potentially exposed to on-site groundwater
from the Shallow, Medium or Deep Transmissive Zones through showering or drinking. Exposure times for
showering were assumed to be 0.2 hours per day.
-------
Table 3.7. 1.2.1
Major Exposure Assumptions.
Source
Soil and Waste Piles
Drums (Spent Catalyst)
Sediment and Surface Water
Groundwater
Receptor
Current and Future Industrial Workers
Future Industrial Workers
Construction Workers
Current and Future Industrial Workers
Future Industrial Workers
Construction Workers
Current and Future Industrial Workers
Future Industrial Workers
Trespasser
Future Industrial Workers
Exposure
Duration
25 years
25 years
6 months
25 years
25 years
6 months
25 years
25 years
1 0 years
25 years
Frequency
250 days / year
250 days / year
5 days / week
250 days / year
250 days / year
5 days / week
lOOhrs/year
lOOhrs /year
150hrs/year
250 days / year
3.7.1.1.4 Identification of Exposure Pathways
and Routes. The exposure pathway is the unique course
through which an individual comes in direct contact (i.e,
accidental ingestion, dermal contact aid inhalation) with
a contaminant source. The exposure route is the means
by which a hazardous substance enters the body. The
pathways and routes identified for the Tex-Tin site are
presented in Table 3.7.1.2.2, "Exposure Pathways/
Routes." Box 3.7.1.2.2,"Evaluated Exposure Pathways
and Routes," identifies the various exposure pathways
and routes which were evaluated for each of the on-site
and off-site areas. Additional discussion regarding the
exposure pathways and routes is found in the BHHRA,
Section 3.3, "Identification of Exposure Routes.
Table 3.7.1.2.2
Exposure Pathways/Routes
Exposure Pathways and Receptor
Scenarios
Receptors
Exposure Routes
Samples Used For Evaluation
Area A
Future Exposure to Surface and
Subsurface Soils and Waste Piles
I
- Accidental ingestion
- Inhalation of participates
- Inhalation of volatiles1
- Inhalation of radon gas
- External Radiation (ground)
Surface and subsurface soil samples 0
to 10 ft. Composite samples from
three tin slag piles.
Radionuclide s- Surface soil samples 0
to .5 ft. Composite sample from one tin
slag pile.
Area B
Future Exposure to Surface and
Subsurface Soils and Waste Piles
I
- Accidental ingestion
- Inhalation of participates
- Inhalation of volatiles1
- Inhalation of radon gas
- External Radiation (ground)
Surface and subsurface soil samples 0
to 10 ft. Composite samples from 18
piles of metallic ore and/or slag
Radionuclides - Surface soil samples 0
to .5 ft. Composite samples from two
piles of metallic ore and /or slag
-------
Table 3.7.1.2.2
Exposure Pathways/Routes
Exposure Pathways and Receptor
Scenarios
Receptors
Exposure Routes
Samples Used For Evaluation
AreaC
Current and Future Exposure to Surface
Soils and Waste Piles
Future Exposure to Surface and
Subsurface Soil Waste Piles
Future Exposure to Surface and
Subsurface Soil
I
I
- Accidental ingestion
- Inhalation of particulates
- Inhalation of volatiles1
- Accidental ingestion
- Inhalation of particulates
-Inhalation of volatiles'
- Inhalation of radon gas
- External Radiation (ground)
Surface soil samples 0 to 0.5 ft.
Composite samples from 15 piles of
slag, scrubber sludge, and/or river mud.
Surface and subsurface soil samples 0
to 15 ft. (for inhalation ofvolatiles
only)
Surface and subsurface (fill material)
soil samples 0 to 15 ft. Composite
samples from 15 piles of slag, scrubber
sludge, and/or river mud.
Radionuclide - Surface and Subsurface
(fill material) soil samples - 0 to 12 ft.
Area D
Future Exposure to Surface and
Subsurface Soil and Waste Piles
Current and Future Exposure to Surface
Soil
C
I
-Accidental ingestion
-Inhalation of particulates
-Inhalation of volatiles1
-Accidental ingestion
-Inhalation of particulates
-Inhalation of volatiles1
- Inhalation of radon gas
- External Radiation (ground)
Surface and subsurface (fill material)
soil samples 0 to 10 ft. One composite
sample from a catalyst pile.
Radionuclide - Surface soil samples 0 -
0.5ft.
AreaE
Future Exposure to Surface and
Subsurface Soil and Waste Piles
Future Exposure to Surface and
Subsurface Soil
Future Exposure to Drums (Spent
Catalyst)
I
I
C
-Accidental ingestion
-Inhalation of particulates
-Inhalation of volatiles1
-Accidental ingestion
-Inhalation of particulates
-Inhalation of volatiles1
- Inhalation of radon gas
- External Radiation (ground)
-Accidental ingestion
-Inhalation of particulates
Surface and subsurface (fill material)
soil samples 0 to 5 ft. Composite
samples from 5 catalyst piles.
Radionuclide. Surface and subsurface
(fill material) soil samples - 0 to 10 ft.
Drum samples from 5% of drums in
Area E.
Area F
Future Exposure to Surface and
Subsurface Soil and Waste Piles
Current and Future Exposure to Surface
and Waste Piles
C
I
-Accidental ingestion
-Inhalation of particulates
-Inhalation of volatiles1
-Accidental ingestion
-Inhalation of particulates
-Inhalation ofvolatiles1
- Inhalation of radon gas
- External Radiation (ground)
Surface and subsurface soil samples 0
to 5 ft. Composite samples from two
piles of metallic ore and slag
Surface soil samples - 0 to .5 ft.
Composite samples from one pile of
metallic ore and slag.
AreaG
Current and Future Exposure to Sediment
and Surface Water
I
-Accidental ingestion
Sediment from on-site drainage ditches.
Area J
Future Exposure to Surface and
Subsurface Soil and Waste Piles
Current and Future Exposure to Drums
(Spent Catalyst)
I
C
I
-Accidental ingestion
-Inhalation of particulates
-Inhalation ofvolatiles1
-Accidental ingestion
-Inhalation of particulates
Surface and subsurface soil samples 0
to 10 ft. Composite samples from three
piles of catalyst materials.
Drum samples from 5% of drums in
Area J.
-------
Table 3.7.1.2.2
Exposure Pathways/Routes
Exposure Pathways and Receptor
Scenarios
Future Exposure to Drums (Spent
Catalyst)
Receptors
C
Exposure Routes
-Accidental ingestion
-Inhalation of participates
Samples, Used For Evaluation
Drum samples from 5% of drums in
Area J.
AreaK
Current and Future Exposure to
Sediments (Ponds 1-5)
Current and Future Exposure to Surface
Water (Ponds 4 and5)J
Current and Future Exposure to Acid
Pond Sediment
Current and Future Exposure to Acid
Pond Surface Water
I
I
1
1
-Accidental ingestion
-Dermal contact.
-Accidental ingestion
-Derma] contact with acid
water.
Sediment from on-site Ponds 1 through
5.
Surface water from on-site Ponds 4 and
5.
Sediment from the Acid Pond
Surface water from the Acid Pond.
AreaL
Future Exposure to Surface and
Subsurface Soil
Future Exposure to Drums (Spent
Catalyst)
I
I
-Accidental ingestion
-Inhalation of particulates
-Inhalation of volatiles
-Accidental ingestion
-Inhalation of particulates
Surface and subsurface soil samples 0
to 10ft.
Drum samples from 5% of drums in
Area L.
Area M
Future Exposure to Surface and
Subsurface Soil
C
-Accidental ingestion
-Inhalation of particulates
-Inhalation of volatiles
Surface and subsurface soil samples 0
to 10 ft.
AreaN
Future Exposure to Surface and
Subsurface Soil
Future Exposure to Surface and
Subsurface Soil
I
C
-Accidental ingestion
-Inhalation of particulates
-Inhalation of volatiles
-Accidental ingestion
-Inhalation of particulates
-Inhalation of volatiles
Surface and subsurface soil samples 0
to 10 ft.
Surface and subsurface soil samples 0
to 10 ft.
Shallow Transmissive Zone
Future Exposure to Groundwater from the
Shallow Transmissive Zone.
I
-Ingestion
-Dermal contact while
showering
-Inhalation of volatiles through
showering
Groundwater samples from on-site
monitoring wells established in the
Shallow Transmissive Zone.
Medium transmissive zone
Future Exposure to Groundwater from the
Medium Transmissive Zone.
-Ingestion
-Dermal contact while
showering
-Inhalation of volatiles through
showering
Groundwater samples from on-site
monitoring wells established in the
Medium Transmissive Zone.
Deep transmissive zone
Future Exposure to Groundwater from the
Deep Transmissive Zone.
I
-Ingestion
-Dermal contact while
showering
-Inhalation of volatiles through
showering
Groundwater samples from on-site
monitoring wells established in the
deep transmissive zone.
1 Inhalation of volatiles was evaluated only for the soil pathway. The soil depth interval used to evaluate inhalation was 0 feet to a
maximum depth of 15 feet.
2 Ponds 1-3 are dry and were not evaluated through the surface water exposure route.
1 - Future Industrial Worker
C - Future Construction Worker
-------
Box 3.7.1.2.2 Evaluated Exposure Pathways and Routes.
On-Site Exposed Spent Catalyst (Drummed Material). Exposure to drummed material was evaluated through
direct contact (e.g. accidental ingestion, dermal contact, and inhalation) with wind blown particulates released
from drummed material. These are potential exposure routes for industrial and construction workers who may
come into contact with drummed material located in these areas through work activities.
On-Site Soil. Exposure to contaminants in on-site surface and subsurface soil was evaluated through direct
contact (e.g. accidental ingestion, dermal contact, and inhalation) with particulates released from soil, and
inhalation of volatiles released from soil. The receptors selected for these areas were industrial or construction
workers who may come into contact with surface soil and subsurface soil during maintenance or construction
excavations.
On-Site Waste Pile. Exposure to contaminants in on-site waste piles was evaluated through direct contact (e.g.
accidental ingestion, dermal contact, and inhalation) with wind blown particulates released from waste piles.
These are potential exposure routes for industrial and construction workers who may come into contact with waste
piles located in these areas through work activities.
On-Site Shallow, Medium and Deep Groundwater Zones. Exposure to contaminants in groundwater was
evaluated through direct contact (e.g. accidental ingestion, dermal contact, and inhalation) while showering, and
inhalation of volatile compounds while showering. These exposure routes were selected because future on-site
industrial workers may use on-site groundwater for showering and drinking,
On-Site Sediment. Exposure to contaminants in sediment associated with on-site drainage ditches and on-site
ponds was evaluated through dermal contact with sediment and accidental ingestion of sediment. These exposure
routes were selected because industrial workers and trespassers in Area G may come into direct contact with
sediment in these areas while working or trespassing, respectively.
On-Site Surface Water. Exposure to contaminants in surface water associated with on-site drainage ditches and
on-site ponds was evaluated through dermal contact with surface water. These exposure routes were selected
because industrial workers and trespassers in Area G only may come into contact with surface water in these areas
while working or trespassing, respectively. Accidental ingestion of on-site surface water was not evaluated
because on-site surface water bodies are shallow; therefore EPA assumes accidental ingestion of surface water
would be an unlikely route of exposure. The Acid Pond was not evaluated through surface water ingestion
because it is a waste acid pond and will not likely be used for wading or swimming activities.
3.7.1.1.5 Identification of Exposure Models and
Assumptions. This step of the risk assessment presents
the mathematical model results used to calculate the
chemical intake for each receptor hrough the previously
identified exposure routes, frequencies, times, and
durations described above. The mathematical models
used to calculate intakes are presented in the BHHRA
Tables 3-2 through 3-20 and Tables 7.3-1 through 7.3-
11. Each table defines the variables used in estimating
intake and includes the assumptions (i.e., exposure
parameters) used in the model. In general, the exposure
parameters that were used are standard values
recommended by national and regional EPA guidance.
Intakes were calculated for chemical carcinogens and
non-carcinogens and these values are shown on Tables
3.7.1.2.3 - 1, "Chemical Carcinogenic Chronic Daily
Intake (GDI) Values" and 3.6.1.2.3(b), "Non-
Carcinogenic Chronic Daily Intake (GDI) Values." The
chemical carcinogenic and non-carcinogenic intakes aie
shown as the Chronic Daily Intake (GDI). The GDI and
total intake (TI) values are expressed as milligrams of
contaminant consumed per kilogram of body weight
during a single day.
Discarded catalyst.
-------
Table 3.7.1.2.3 - 1 Chemical Carcinogenic Chronic Daily Intake (CDI) Values
Exposure Pathway & Receptor Scenario
Receptor
Chemical
AreaB
Future Exposure to Surface and Subsurface Soil and
Waste Piles
I
Arsenic
Exposure Route
CDI
(mg /kg - day)
Accidental Ingcstion of
Surface and Subsurface
Soil
I.96E-04
AreaC
Future Exposure to Surface and Subsurface Soil and
Waste Piles
I
Arsenic
Accidental Ingestion of
Surface and Subsurface
Soil
3.29E-04
Area D
Future Exposure to Surface and Subsurface Soil and
Waste Piles
C
Arsenic
Accidental Ingestion of
Surface and Subsurface
Soil
8.27E-04
AreaE
Future Exposure to Surface and Subsurface Soil and
Waste Piles
I
Arsenic
Accidental Ingestion of
Surface and Subsurface
Soil
1.67E-04
AreaF
Future Exposure to Surface and Subsurface Soil and
Waste Piles
I
Arsenic
Accidental Ingestion of
Surface and Subsurface
Soil
I.33E-04
AreaG
Current/Future Exposure to Sediment and Surface
Water
1
Arsenic
Accidental Ingestion of
Sediment
I.15E-04
Area!
Future Exposure to Surface and Subsurface Soil and
Waste Piles
Current/Future Exposure to Drums (Spent Catalyst)
Current/Future Exposure to Sediment and Surface
Water
I
I
Arsenic
Arsenic
Accidental Ingestion of
Surface and Subsurface
Soil
Accidental Ingestion of
Drum Material
Area K(Ponds 1-5)
I
Arsenic
Accidental Ingestion of
Sediment
1.06E-04
4.15x Ifr1
8.19E-04
AreaL
Future Exposure to Surface and Subsurface Soil
Future Exposure to Surface and Subsurface Soil
1
Arsenic
AreaN
I
Arsenic
Accidental Ingestion of
Surface and Subsurface
Soil
1.81E-04
Accidental Ingestion of
Surface and Subsurface
Soil
1.04E-04
Shallow Transmissive Zone
Future Exposure to Groundwater
I
Arsenic
Beryllium
Ingestion of Groundwater
2.11E-03
3.49E-04
Medium transtnissive zone
Future Exposure to Groundwater
1
Arsenic
Ingestion of Groundwater
1.24E-04
Deep transmissive zone
Future Exposure to Groundwater
I
Arsenic
Ingestion of Groundwater
1.70E-04
I - Industrial Worker
C - Construction Worker
-------
Table 3.7.1.2.3 - 2 Non-Carcinogenic Chronic Daily Intake (CDI) Values
Exposure Pathway Scenario
Receptor
Chemical
Exposure Route
CDI
(mg /kg - day)
Area A
Future Exposure to Surface and
Subsurface Soil and Waste Piles
c
Arsenic
Accidental Ingestion of Surface and Subsurface
Soil
6.8E-04
AreaB
Future Exposure to Surface and
Subsurface Soil and Waste Piles
c
Copper
Accidental Ingestion of Surface and Subsurface
Soil and Waste Piles
2.44E-01
AreaC
Future Exposure to Surface and
Subsurface Soil and Waste Piles
c
Antimony
Accidental Ingestion of Surface and Subsurface
Soil Waste Piles
4.59E-03
Area D
Future Exposure to Surface and
Subsurface Soil and Waste Piles
c
Antimony
Arsenic
Manganese
Accidental Ingestion of Surface and Subsurface
Soil
7.69E-04
5.79E-03
1.18E-01
Area E
Future Exposure to Surface and
Subsurface Soil and Waste Piles
Future Exposure to Drums (Spent
Catalyst)
c
c
Antimony
Copper
Molybdenum
Nickel
Accidental Ingestion of Surface and Subsurface
Soil
Accidental Ingestion of Drum Material
1.38E-03
3.7E-OI
4.38E-01
I.05E-01
AreaF
Future Exposure to Surface and
Subsurface Soil and Waste Piles
c
Antimony
Arsenic
Accidental Ingestion of Surface and Subsurface
Soil
5.76E-04
1.89E-04
Area J
Future Exposure to Surface and
Subsurface Soil and Waste Piles
Future Exposure to Drums (Spent
Catalyst)
c
c
Antimony
Copper
Antimony
Copper
Molybdenum
Nickel
Accidental Ingestion of Surface and Subsurface
Soil
Accidental Ingestion of Drum Material
1.27E-04
2.21E-02
6.53E-04
6.55E-02
1.01E-02
2.32E-02
AreaL
Future Exposure to Drums (Spent
Catalyst)
c
Molybdenum
Accidental Ingestion of Drum Material
3.85E-02
Area M
Future Exposure to Surface and
Subsurface Soil
c
Arsenic
Accidental Ingestion of Surface and Subsurface
Soil
6.48E-04
AreaN
Future Exposure to Surface and
Subsurface Soil
c
Antimony
Accidental Ingestion of Surface and Subsurface
Soil
I.47E-03
-------
Table 3.7.1.2.3 - 2 Non-Carcinogenic Chronic Daily Intake (CDI) Values
Shallow Transmissive Zone
Future Exposure to Groundwater
I
Cadmium
Copper
Manganese
Mercury
Silver
Zinc
Ingestion of Groundwater
2.57E-02
1.1E-01
1.83
8.84E-04
1.38E-01
2.45
Medium transmissive zone
Future Exposure to Groundwater
I
Arsenic
Ingestion of Groundwater
3.47E-04
Deep transmissive zone
Future Exposure to Groundwater
I
Arsenic
Ingestion of Groundwater
3.16E-04
I - Industrial Worker
C - Construction Worker
3.7.1.2 Toxicity Assessment.43 Whereas Table
3.5.26 - 1 lists the contaminants of concern and their
health effects, this section presents the risk assessment
toxicity values which were applied to the chronic daily
intakes described in Section 3.7.1.2.3, "Identification of
Exposure Models and Assumptions," to determine the
carcinogenic risk or non carcinogenic hazard posed by a
specific chemical of concern. In risk assessment terms,
"toxicity" refers to the property of a chemial that causes
morphological and/or biochemical tissue or organ
damage, whereas as previously used in this Record of
Decision, "toxicity" referred to a regulatory standard at
40 C. F. R. §261.24 to determine whether a waste is
hazardous under RCRA. The methods used to assess he
toxicity of a specific chemical of concern are presented
in BHHRA, Section 4, "Toxicity Assessmenf'and
Section 7.4, "Toxicity Assessment." Table 3.7.1.3 - 1,
"EPA Categorization of Carcinogens," provides a
summary of the Carcinogenic Categories Table 3.7.1.3 -
2, "Cancer Slope Factors and EPA Carcinogenicity
Classifications" and Table 3.7.1.3 - 3, provides the
classification and slope factors for the chemical and
radionuclide carcinogenic toxicity, and Table3.7.1.3 - 4
provides the reference doses and target organs for non-
carcinogenic toxicity. Carcinogenic and non-
carcinogenic effects of a chemical depend on the dose, on
the route of administration, on the duration and
frequency of exposure, and on the species tested or
measured. Generally the lower the dose necessary to
produce an adverse effect, the more toxic the chemical.
After a single (acute) high dose, some chemicals may
produce toxic effects that range from respiratory and/or
skin irritation to lethality. However, acute exposures are
generally easily recognized and control led, and bus they
are not usually the main focus of concern in a BHHRA.
Exposure for a continual period of months or years
(chronic) at low exposure levels is potentially more
significant from a human health v iewpoint. On ly chronc
effects were evaluated in this BHHRA. Chemicals are
potentially capable of producing adverse effects through
inhalation, ingestion, and dermal contact. Some
chemicals may produce toxicity only through one route.
Others may cause toxicity through a combination of
some or all routes. Consequently, each chemical is
evaluated for cancer and non-cancer toxicity by
determining its potency through each exposure route, as
identified in the site conceptual model.
Deteriorated column base in the Roasting and
Leaching Building.
-------
Table 3.7.1.3 - 1 EPA Categorization of Carcinogens
HUMAN EVIDENCE
Sufficient
Limited
Inadequate
No Data
No Evidence
ANIMAL EVIDENCE
Sufficient
A
Bl
B2
B2
B2
Limited
A
Bl
C
C
C
Inadequate
A
Bl
D
D
D
No Data
A
Bl
D
D
D
No Evidence
A
Bl
D
E
E
Kev:
Group A
Group Bl
Group B2
Group C
Group D
Group E
Human carcinogen (sufficient evidence from epidemiological studies).
Probable human carcinogen (at least limited evidence of carcinogenicity to humans).
Probable human carcinogen (a combination of sufficient evidence in animals and inadequate data in
humans).
Possible human carcinogen (limited evidence in animals in the absence of human data).
Not classified (inadequate animal and human data).
No evidence for carcinogenicity (no evidence for carcinogenicity in at least two adequate animals tests
in different species, or in both epidemiological and animal studies).
Table 3.7.1.3 - 2 Cancer Slope Factors and EPA Carcinogenicity Classifications
Chemical
1,2-Dichloroethane
Arsenic
Benzene
Beryllium
Cadmium
Chloroform
Chromium VI
Nickel
EPA
Carcinogenicity
Classification
Category
Reference"
B2
A
A
B2
Bl
B2
A
A
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
Slope Factors
Oral
(mg/kg-day)-i
9.1E-02
1.5E+00
2.9E-02
4.3E+00
NTV
6.1E-03
NTV
NTV
Reference
IRIS
IRIS
IRIS
IRIS
-
IRIS
-
—
Dermal"
(mg/kg-day)'1
9.1E-02
7.5E+00
2.9E-02
8.6E+01
NTV
6.1E-03
NTV
NTV
Inhalation
(mg/kg-day)'1
9.1E-02
1.5E+01
2.9E-02
8.4E+00
6.3E+00
8.1E-02
4.2E+01
8.4E-01
IRIS = Integrated Risk Information System (IRIS, 1996).
Reference"
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
3 Calculated by dividing the oral slope factor by 1 .0 for organics and 0.05 for inorganics, with the exception of arsenic. The
oral slope factor for arsenic was divided by 0.20.
b Slope factors for carcinogenic polycyclic aromatic hydrocarbons (PAHs) were derived by multiplying the slope factor for
benzo(a)pyrene by a relative potency factor (EPA, 1995b).
c Classification is for divalent mercury and methyl mercury.
d Inhalation slope factor for nickel refinery dust.
NTV = No toxicity value available.
-------
Table 3.7.1.3 - 3 Radionuclide Cancer Slope Factors and EPA Carcinogenicity Classification
Radionuclide of
Potential
Concern
Radium-226 '
Radium-228 '
Thorium-228 '
EPA Weight of
Evidence
Carcinogenicity
Classification
Category
A
A
A
Reference
EPA, 1995
EPA, 1995
EPA, 1995
Oral
Slope
Factor
(risk/pCi)
2.96E-10
2.48E-10
2.31E-10
Inhalation
Slope
Factor
(risk/pCi)
2.75E-09
9.94E-10
9.68E-08
External Radiation
Slope Factor
(risk/year per pCi/g
soil)
6.74E-06
3.28E-06
6.20E-06
Reference
EPA, 1995
EPA, 1995
EPA, 1995
1 Slope factor includes the contributions from short-lived decay products, assuming equal activity concentrations (i.e.,
secular equilibrium) with the principal nuclide in the environment.
EPA, Health Effects Assessment Summary Tables (HEAST), FY-1995 Annual. EPA540-R-95-36. PB94-92 1 1 99, May
1995.
Box 3.7.1.3.1 Slope Factors.
After EPA determines the weight-of-evidence for a chemicaUhe carcinogenic potency of the chemical is
determined. The carcinogenic potency of a chemical describes the ability of a chemical to produce cancer
over a lifetime. Cancer slope factors (CSFs)are used to express this potency. CSFs are expressed as risk
per unit dose ([mg/kg-day]"1). A cancer toxicity value quantitatively defines the relationship between
exposure and carcinogenic response for a chemcal. The larger the CSF for a given carcinogen, the greater
is the risk of cancer occurring at a specific exposure level.
3.7.1.2.1 Assessment of Chemical Carcinogenic
Toxicity. Carcinogens are evaluated in a two-phases,
first, the weight-of-evidence for causing cancer is
determined, and then a cancer toxicity valie is derived if
sufficient data are available. Both human and animal
cancer data are reviewed to determine the likelihood that
a chemical is a human and/or animal carcinogen. EPA's
weight-of-evidence classifications are defined in Table
3.7.1.3- 1, "EPA CategorizationofCarcinogens." Only
those chemicals classified in Group A have sufficient
evidence of Carcinogenicity in human studies to be
classified as known human carcinogens . Carcinogens
that have probable or possible human cancer-causing
potential are classified in Groups B and C, respectively.
Group B and C carcinogens have varying degrees of
animal data to support their cancer-causing potential.
These two groups comprise the greatest number of
carcinogens classified by the EPA. Those classified in
Group D have inadequate human and animal evidence of
Carcinogenicity. Based on adequate studies, chemicals
classified in Group E have no human or animal evidence
supporting their potential for cancer. The BHHRA
typically evaluates Group A, B, and C carcinogens for
which cancer toxicity values are available. In some
cases, EPA may withdraw a criterion from IRIS
(Integrated Risk Information System) before the review
is completed using instead the value cited in EPA's
Health Effects Assessment Summary Tables (HE/ST).44
In cases when a cancer toxicity value is not available for
a potential carcinogen of concern, it is discussed
qualitatively in the risk characterization.
3.7.1.2.2 Assessment of Non-Carcinogenic
Toxicity. The toxicity values used to evaluate potential
non-cancer health effects are termed reference doses
(RfDs). Unlike the approach used in evaluating cancer
risk, it is assumed for non-cancer effects that a threshold
exposure dose exists below which there is no potential
for human toxicity. Non-cancer toxicity values were
developed by EPA to refer to the daily intake (RfD) of
a chemical to which an individual can be exposed
without any expectation of non-carcinogeniceffects (e.g,
organ damage, biochemical alterations, birth defects)
occurring during a given exposure duration. The RfD is
derived from a no-observed-adverse-effect level
(NOAEL) or lowest-observed-adverse-effect level
(LOAEL) obtained from human or animal studies. A
NOAEL is the highest dose or exposure level of a
-------
chemical at which no toxic effects are observed in any
test. In contrast to a NOAEL, a LOAEL is the lowest
dose or exposure level at which a toxic effect is observe!
in any test. LOAELs are used to derive an RfD in the
absence of a suitable NOAEL. EPA has darived chronic
RfDs to evaluate human exposures of greater than?
years. In this risk assessment, the non-cancer toxicity
values were expressed as Chronic RfDs.
Chemical
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium III
Chromium VI
Cumjnr
V-UJJjJCl
Manganese
Meimrv
ivicii,ui.y
(inorganic)
Molybdenum
Nickel
Silver
7inc
Table 3.7.1.3 - 4 Chronic Reference Doses (RfD) and Toxicity Endpoints
Oral
4.0E-04
3.0E-04
7.0E-02
5.0E-03
1 .OE-03
5.0E-04
l.OE+00
5.0E-03
Q 7P 07 —
I.4E-01
4.7E-02
9 np (M —
5.0E-03
2.0E-02
5.0E-03
3.0E-01
Reference Dose (mg /kg - day)
Target Organ
Increased mortality; altered
blood glucose and
cholesterol
Hyperpigmentation and
teratosis; possible vascular
complications
Increased blood pressure
No observed adverse effects
Proteinuria (protein in urine)
Proteinuria (protein in urine)
No observed adverse effects
No observed adverse effects
Gastrointestinal irritation
Central nervous system
effects
Central nervous system
effects
rviuncy cuccib
ncreased uric acid levels in
)lood
Decreased body weight and
rgan weights
Argyria (silver deposition in
kin)
Decrease in red blood cell
uperoxide dismutase
Reference
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
HEAST
IRIS
IRIS
IRIS -
IRIS
IRIS
IRIS
IRIS
Inhalation
NTV
NTV
1 .OE-04
NTV
NTV
NTV
NTV
NTV
NA
1.4E-05
1 8.6E-05E —
NTV
NTV
NTV
NTV
Target Organ
Fetotoxicity
mpairment of
neurobehavioral
unction
Neurotoxicity
HEAST Health Effects Assessment Summary Tables (EPA, 1 995a).
IRIS = Integrated Risk Information System (IRIS, 1996).
b Value is for elemental mercury
Reference"
HEAST
IRIS
HEAST
3.7.1.3 Carcinogenic Risk and Non-Carcinogenic
Hazard Characterization.45 The objective of this
characterization is to integrate the information from tte
Exposure Assessment and the Toxicity Assessment to
decide if there is a carcinogenic risk or non-
carcinogenic hazard associated with any one of the
chemicals of concern on-site. An unacceptable
carcinogenic risk or non-carcinogenichazard fom any
single chemical of concern would warrant remedial
action. Consequently this subsection presents an
analysis of the nature of the most significant
carcinogenicrisksand non-carcinogenichazards posed
to the receptors identified in the "Site Conceptual
Models." It is these specific carcinogenic risks and
non-carcinogenic hazards whichjustifyEPA's decision
to take remedial action at this site. Potential
carcinogenic and non-carcinogeniceffectsof pollutants
are discussed separately because of the different
toxicological endpoints, relevant exposure durations,
and methods employed in characterizing risk. The
general approaches to evaluating carcinogenic and
non-carcinogenic risks are presented in the BHHRA
Subsection 5.2 and the general approaches to
evaluating the health effects of lead are presented in tie
-------
BHHRA Subsection 5.3. The results of the risk and
hazard evaluation are summarized in Section 3.7.1.47,
"Summary of Results." Uncertainties associated with
the risk estimates are discussed in Section 3.7.1.4.8.
3.7.13.1 Carcinogenic Risk. The Remedial
Investigation discovered chemical carcinogens as well
as radioactive carcinogens on site. In this document
the risks from these carcinogens are expressed as the
incremental probability of an individual developing
cancer over a lifetime as the result of exposure to the
carcinogen. These probabilities are expressed in
scientific notation, e.g. 1 x 106 or IE -06. An excess
lifetime cancer risk of 1 x 10* indicates that an
individual experiencing the reasonable maximum
exposure estimate has a 1 in 1,000,000 chance of
developing cancer as a result of site-related exposure.
This is referred to as an "excess lifetime cancer risk"
because it would be in addition to the risks of cancer
individuals face from all othercauses which has been
estimated to be as high as one in three. EPA's
generally acceptable risk range for site-related
exposure is 1 in 10,000 to 1 in 1,000,000.
3.7.1.3.2 Calculating Carcinogenic Risk.
Excess lifetime carcinogenic riskis calculated from the
equation in Box 3.7.1.4.2 - 1. Excess lifetime
radioactive carcinogenic risk is calculated from the
equation in Box 3.7.1.4.2 - 2. Unlike cancer slope
factors developed for chemical carcinogens,
radionuclideslope factors are the best estimates of the
age-averaged, lifetime excess total cancer risk per unit
of intake of a radionuclide (e.g., per pCi inhaled or
ingested) or per unit external radiation exposure (e.g.,
pCi/g of soil). As discussed in the BHHRA,
Subsection 7.4, radionuclide slope factors have been
calculated for individual radionuclides based on their
unique chemical, metabolic, and radiologicalpropertis
and usinga non-threshold.lineardose-responsemodel
This model accounts for the amount of each
radionuclide absorbed into the body from the
gastrointestinal tract (by ingestion) or through the
lungs (by inhalation), the distribution and retention of
each radionuclide in body tissues and organs, as well
as the age, sex, and the weight of an individual at the
time of exposure. The model then averages the risk
over the lifetime of that exposed individual (i.e., 70
years). Consequently, radionuclide slope factors are
not expressed as a function of body weight or time, and
do not require corrections for gastrointestinal
absorption or lung transfer efficiencies.
Box 3.7.1.4.2 - 1
Chemical Cancer Risk
Cancer Risk = CDI x SF
Cancer Risk =
CDI =
SF
a unitless probability
(e.g. 2 x 10'5) of an
individual's
developing cancer
Chronic daily intake
averaged over a 70-
year lifetime) (mg/kg-
day)
slope factor expressed
as (mg/kg-day)'1
3.7.1.3.3 Non-Carcinogenic Hazards. The
potential for non-carcinogenic hazards is evaluated by
comparing an exposure level over a specified time
period (e.g. life-time) with a reference dose (RfD)
derived from a similar exposure period. An RfD
represents a level that an individual may beexposed to
that is not expected to cause any deleterious effect.
The ratio of exposure to toxicity is called a hazard
quotient (HQ). An HQ less than one indicates thata
receptor's dose of a single confeminant is less than the
RfD, and that toxic non-carcinogenic effects from that
chemical are unlikely. The Hazard Index (HI) is
generated by adding the HQs for all chemical(s) of
concern that affect the same target organ or systems
(e.g. liver) within a medium or across all media to
which a given individual may reasonably be exposed.
An HI less than one indicates that, based on the sum
-------
Box 3.7.1.4.2-2
Radioactive Cancer Risk
Cancer Risk=TI/ EE x CSF
Cancer Risk =
TI
EE
CSF
Cancer incidence,
expressed as unitless
probability
Estimated total intake
(intake during time of
exposure) (pCi)
Estimated external
exposure (pCi/g of
soil)
Radionuclide and
route-specific cancer
slope factor (risk/pCi
or risk/year per pCi/g
of soil)
3.7.1.3.4 Health Effects From Lead. Because no
carcinogenic and non-carcinogenic toxicity values for
lead have been verified by EPA headquarters?6 lead
risks cannot be evaluated quantitatively by the
traditional risk assessment process. However, the
neurological effects produced in young children from
lead exposure are viewed by the scientific and
regulatory communities as the critical non-
carcinogenic effect of public health concern?7 The
Centers for Disease Control18 has stated that chronic
lead exposure resulting in blood levels as low as 10
^g/dL may be associated with these effects.
Consequently, at this site EPA promotes a pro-active
program to ensure women of child bearing age are
protected by ensuring there is less than a five percent
chance that fetal blood lead levels will exceed
10 ug/dL.
3.7.1.3.5 Predicting Fetal Blood Lead Levels.
The methodology used to predict fetal blood lead
levels is in accordance with draft guidance provided by
EPA49 for calculating lead cleanup levels for soil
based on fetal exposure (i.e., "Adult Lead Cleanup
Level" Model). The draft EPA Region 6 guidance is
a modification of a model developed by Bowers et al.
(1994). For Areas A through F, J, and L through N
fetal blood lead levels were calculated for the
current/future industrial worker, the future industrial
worker, and the future construction worker. The blood
lead levels for the current/future industrial worker
scenario were based on the accidental ingestion of
surface soil and/or waste pile material. Theblood lead
levels for the future industrial and construction worker
scenarios were based on the accidental ingestion of
surface/subsurface soil and/or waste pile material. In
addition, for Areas B, E, J, and L, fetal blood levels
were calculated for a current/future industrial worker
and a future construction workerbased on the ingestion
of drum material only. A detailed discussion
including site-specific default exposure assumptions
used in the model are presented in the BHHRA
Subsection 5.5.4 and Appendix K.
Box 3.7.1.4.3.
Non-Carcinogenic Hazard
Non-cancer HQ = GDI / RfD
GDI = Chronic daily intake
RfD = Reference Dose
GDI and RfD are expressed in the same units
and represent the same exposure period (i.e.,
chronic, subchronic or short-term.)
3.7.1.3.6 Adult Lead Cleanup Level Model
Results. The fetal blood levelscalculated based on the
Adult Lead Cleanup Level Model are summarized in
the BHHRA Table 5-5. The EPA and Centers for
Disease Control recommend that there be no more
than a five percent likelihood that achild would exceed
a blood lead level of 10 ug/dL Using the modified
Bowers50 model, predicted fetal blood lead levels
exceeded 10 ug/dL for the following scenarios based
on exposure to soil and/or waste piles:
» Area A Future Construction Worker.
« Area B Current/Future and Future Industrial
Worker and Future Construction Worker.
-------
• Area C Current/Future Industrial Worker and
Future Construction Worker.
• Area D Future Construction Worker.
• Area E Current/Future and Future Industrial
Worker and Future Construction Worker.
• Area J Current/Future and Future Industrial
Worker and Future Construction Worker.
• Area L Current/Future and Future Industrial
Worker and Future Construction Worker.
• Area M Current/Future and Future Industrial
Worker and Future Construction Worker.
• Area N Current/Future and Future Industrial
Worker and Future Construction Worker.
Predicted fetal blood lead levels exceeded 1 Oug/dL for
the Area J "Current/Future Industrial Worker and
Future Construction Worker" scenario. These results
suggest that for those scenarios inwhich predicted fetal
blood levels exceeded 10 ug/dL,there is a potential for
lead toxicity in the infants of female workers.
3.7.1.3.7 Summary of Results. Table 3.7.1.4.7,
"Carcinogenic Risk or Non-Carcinogenic Hazards
Justifying Remedial Action," summarizes the exposue
pathway scenario for which there is a carcinogenic rik
or non-carcinogenic hazard justifying a remedial
response. The results shown in the table should be
interpreted with an understanding of the associated
uncertaintiesdescribed in the BHHRA Section6.0 and
7.0.
Table 3.7.1.4.7 - Carcinogenic Risk or Non-Carcinogenic Hazards Justifying Remedial Action
Exposure Pathway &
Receptor Scenario
Receptor
Chemical
Risk
Hazard
Index
Exposure Route
Area A
Future Exposure to
Surface and Subsurface
Soil and Waste Piles
1
C
Radium - 226
Radium - 228
Arsenic
4.5E-03
1.3E-03
2.3
Inhalation of radon gas.
External Radiation
Accidental ingestion.
Area B
Future Exposure to
Surface and Subsurface
Soil and Waste Piles
I
C
Radium - 226
Radium - 228
Thorium - 228
Arsenic
Copper
2.3E-02
1.9E-02
7.5E-03
3.7
6.6
Inhalation of radon gas.
External Radiation
Accidental ingestion.
AreaC
Future Exposure to
Surface and Subsurface
Soil
Current and Future
Exposure to Surface Soils
Future Exposure to
Surface and Subsurface
Soil and Waste Piles
I
I
C
Radium - 226
Radium - 228
Thorium - 228
Arsenic
Arsenic
Antimony
6.1E-04
I .OE-04
2.0E-04
6.2E-04
15.3
14.8
Inhalation of radon gas.
External Radiation
Accidental ingestion
Accidental Ingestion
Area D
Future Exposure to
Surface and Subsurface
Soil
Future Exposure to
Surface and Subsurface
Soil and Waste Piles
C
Radium - 226
Arsenic
Antimony
Manganese
2.4E-04
19.3
1.9
3.0
Inhalation of radon gas
Accidental ingestion.
Area E
Current and Future
Exposure to Surface
I
Radium - 226
Radium - 228
Thorium - 228
5.5E-04
1.1E-04
1.7E-04
External Radiation
-------
Table 3.7.1.4.7 - Carcinogenic Risk or Non-Carcinogenic Hazards Justifying Remedial Action
Exposure Pathway &
Receptor Scenario
Future Exposure to
Surface and Subsurface
Soil and Waste Piles
Future Exposure to Drums
(Spent Catalyst)
Receptor
C
C
Chemical
Arsenic
Molybdenum
Copper
Nickel
Risk
2.5E-04
Hazard
Index
7.9
8.8
7.5
5.3
Exposure Route
Accidental Ingestion
Accidental Ingestion
AreaF
Future Exposure to
Surface and Subsurface
Soil and Waste Piles
I
C
Radium - 226
Radium - 228
Thorium - 228
Arsenic
Antimony
3.7E-03
l.OE-04
1.8E-04
2.0E-04
3.5
External Radiation
Accidental Ingestion.
Accidental ingestion.
AreaG
Current/Future Exposure
to Sediment and Surface
Water
Current and
I
Arsenic
1.6E-04
Accidental Ingestion of
Sediment
Area 3
Future Exposure to
Surface and Subsurface
Soil and Waste Piles
Current and Future
Exposure to Drums (Spent
Catalyst)
Future Exposure to Drums
(Spent Catalyst)
I
C
*-.
I
C
Arsenic
Copper
Antimony
Arsenic
Arsenic
Molybdenum
Copper
Antimony
Nickel
1.6E-04
6.3E-03
3.0
4.9
193.5
2.0
1.8
1.6
1.2
Accidental Ingestion
Accidental Ingestion
Accidental Ingestion
Area K(Ponds 1-5)
Current/Future Exposure
to Sediment and Surface
Water
I
Arsenic
UE-03
Accidental Ingestion of
Sediment
Area L
Future Exposure to
Surface and Subsurface
Soil
Future Exposure to Drums
(Spent Catalyst)
I
C
Arsenic
Molybdenum
2.5E-04
7.7
Accidental Ingestion of
Surface and Subsurface Soil
Accidental Ingestion
AreaM
Future Exposure to
Surface and Subsurface
Soil
C
Arsenic
2.1-
Accidental Ingestion
AreaN
Future Exposure to
Surface and Subsurface
Soil
I
C
Arsenic
Antimony
.6E-04
3.0
Accidental Ingestion
Shallow Transmissive Zone
Future Exposure to
Groundwater
I
Arsenic
Beryllium
Cadmium
Manganese
Copper
Silver
3.2E-03
1.5E-03
51.5
39.0
29.7
27.6
Ingestion of Groundwater
-------
Table 3.7.1.4.7 - Carcinogenic Risk or Non-Carcinogenic Hazards Justifying Remedial Action
Exposure Pathway &
Receptor Scenario
Receptor
Chemical
Zinc
Mercury
Risk
Hazard
Index
8.2
2.9
Exposure Route
Medium transmissive zone
Future Exposure to
Groundwater
I
Arsenic
1 .9E-04
1.2
Ingestion of Groundwater
Deep transmissive zone
Future Exposure to
Groundwater
I
Arsenic
1.7E-04
1.1
Ingestion of Groundwater
I - Industrial Worker
C - Construction Worker
3.7.1.3.8 Uncertainty. Virtually every step in the
risk assessment process equires numerous assumptions,
all of which contribute to uncertainty in the risk
evaluation which are described in detail inthe BHHRA
Sections 6.0 and 7.0. In the absence of emprical or site-
specific data, assumptions are developed based on best
estimates of data quality, exposure parameters, and <4se-
response relationships. To assist in the development of
these estimates, EPA provides guidelines and standard
default exposure factors to be used in risk assessments
prepared under the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980
(CERCLA).51 52 The use of these standard factors is
intended to promote consistency among risk assesments
where assumptions must be made. However, their
usefulness in accurately predicting risk depends on their
applicability to the site-specific conditions discussed in
the Baseline Human Health Risk Assessment (BfflRA).
3.7.2 Summary of Ecological Risk Assessment. In
addition to the BHHRA, in 1997 an Ecological Risk
Assessment (ERA)53 was prepared to evaluate the risk to
the environment posed by existing levels of
contamination in the soil, water, and sediment on and in
the vicinity of the Site. The ERA was developed in
response to the results of the screening level risk
assessment which suggested that ecological receptors
were exposed to and adverselyaffected by contaminants
of potential concern at the Site.
3.7.2.1 Objectives. The objectives of the ERA were to:
Collect analytical, ecological, and toxicological
data from the site.
Determine, using direct analyses and food chain
accumulation models, if exposure to site
contaminants is resulting in adverse ecological
effects.
Develop site-specificecologically based cleaiup
target levels.
3.7.2.2 Habitat. The terrestrial and aquatb portions of
the site represent poor quality wildlife habitat. About
half of the site consists of production facilities, paved
areas and roads, and disposal areas, while the remainder
is in scrub/shrub uplands and open fields that have been
disturbed by production and disposal activities.
Although several species of wildlifewere observed at the
Tex-Tin site and raccoon and deer tacks were observed,
the upland vegetative community offers low quality
wildlife habitat. A number of lagoons, low-lying
depressions, borrowpits, hurricane protection levees, and
ditches have formed or were constructed on the site and
along the periphery of the site. Some of these are
inhabited by fin fish and macroinvertebratesandare used
by wading birds and other aquatic and semiaquatic
vertebrates. In addition to the presenceof contamination,
the origin, history, management, and often ephemeral
nature of the water, substantially reduces the habitat
quality and value.
3.7.2.3 Preliminary Risk Assessment. A preliminary
risk assessment was conductedto compare the maximum
concentrations of contaminants detected in soil, water,
and sediment to various benchmark values. Using the
hazard quotient method, existing contamination data
were screened relative to exposure concentrations that
potentially cause adverse effects. The exposure
concentrations were the highest concentration for each
contaminant detected in the current study. Results
showed that nearly all inorganic benchmarks and
numerous organic benchmarks were exceeded in soil,
surface water, and sediment.
3.7.2.4 Definitive Risk Assessment. A definitive risk
assessment was conducted to compare the maximum
-------
concentrations of contaminants detected in site-specift
matrices (soil, sediment, water, and tissue) to various
benchmark values. Using the hazard quotient method,
existing contamination data were screened relative to
exposure concentrations that potentially cause adverse
effects. The exposure concentrations were the highest
concentration for each contaminant detected in the
current study. Of significance in this assessmentwas the
use of site-specific tissue values rather than estimates
based on assumptions of bioavailability and
accumulation. The concentrations that potentially cause
adverse effects were concentrations above the no
observed adverse effect level (NOAEL) and the lowest
observed adverse effect level (LOAEL) values based on
known chemical behavior and toxicity. The values used
in the risk assessment were derived from available
literature that included specialized laboratory tests. The
endpoints of these tests are based on nonlethal effects
including subtle changes in biochemical pathways and
histopathology. The results of the definitive assessment
suggest that the organic contaminants do not represent a
substantial risk to any of the receptors used in the
assessment. Most inorganic contaminants are present at
concentrations that result in a risk to receptors. Howeve?
because of the uncertainty associated with the foodchain
exposure models and receptor behavior/characteristics,
the target cleanup levels presented in the ecological risk
assessment should be viewed as guidelines only and not
as definitive remediation goals. Information presented h
the ecological assessment indicates that the risks to
ecological receptors falls within acceptable range? given
the uncertainty associated with the evaluation process,
assuming the site is remediated to achieve RAOs
(Remedial Action Objectives) established for the
protection of human health.
3.7.2.5 Future Exposure. A screening level ecological
risk assessment of future exposure conditions t>
ecological receptors was conducted for OU1 as part of
this feasibility study. Although the selected remediation
alternative was not yet known, some features commonto
most or all alternatives were identified, and these were
assumed as a basis for calculation and analysis.
Assumptions included removal or covering of much of
the contaminated soil, as well as filling of many of the
ponds on the site. Given these new conditions, many of
the previously-apparent ecological receptor exposure
routes were found to no longer be complete. An
evaluation of future exposure conditions, assuming the
new soil characteristics, was conducted for three
terrestrial receptors: the cotton rat, the American
woodcock, and the coyote. Exposure modeling was
conducted using site information— site-derived
accumulation factors and ecological receptor tissue
concentrations. A large part of the site will likely be
covered by clean soil, so reference area soil, tissue, and
accumulation factors were used. For those remaining
areas left uncapped, Area B soil (below human health
based levels), tissue and accumulation factors were used
and assumed to represent exposure conditions for the
non-capped portions of the site. Results of the on-site
terrestrial receptor modeling indicate minimal risk
potential. Mobile organisms such as the woodcock and
coyote are at little to no risk since the site provides only
a portion of their foraging range Much of the site is not
a viable habitat due to the high amounts of physical
disturbance which do not support a natural setting for
ecological receptors to thrive. Evaluation of small
organ isms that may rely solely upon the site area for ther
home and forage range, such as the hispid cotton rat,
indicates no risk in the remediated areas. Areas which
may be left uncapped, such as Area J, may be of concern
However, these areas are industrial settings and do not
support ecological receptor occurrence. Future land use
will likely be industrial also.
3.7.2.6 Conclusions. Conservative assumptions (i.e.
using maximum observed concentrations etc) were used
as part of the exposure and risk evaluation. Results of
the ecological evaluation, based on future remedial
actions at the site, indicate that risk to on-site terrestrial
receptors and off site receptors are not significant.
3.8 Remedial Action Objectives. RAOs for
contamination sources at the Tex Tin site are described
in this section. RAOs have been developed for those
chemicals from those sources on the Tex Tin site that
pose significant carcinogenic risk or non carcinogenic
hazards to human health and the environment based on
ARARs (Applicable, Relevant and Appropriate
Requirements) and site-specific risk calculations. The
RAOs refer to specific sources, contaminants, pathways,
and receptors. The RAOs developed for Tex Tin are
shown in Box 3.8, "Remedial Action Objectives."
-------
Box 3.8 Remedial Action Objectives
o Prevent direct contact,ingestion, and inhalation of surface and subsurface soil, sediments, waste piles,
drums (spent catalyst) and groundvater materials containing contaminants that exceed a carcinogenic risk
of 1 .OE-04 or a hazard index of 1.
o Prevent the release of contaminants from Acid Pond, wastewater ponds, drums (spent catalyst), above
ground storage tanks, and slag piles to surface and subsurface soils, surface water, ad groundwater. Protect
off site ecological receptors by preventing off site contaminant migration as a result of on-site releases.
o Prevent external radiation exposure and prevent direct contact, ingestiopand inhalation of soils and slag
piles that contain radium-226 material that exceeds 40 C.F.R. Part 192 criteria.
o Prevent further degradation of Shallow and Medium TransmissiveZone groundwater outside the operahd
unit boundaries.
o Prevent migration for contaminated groundwater outside the operable unit boundaries in the Deep
Transmissive Zone.
o Prevent the release of friable asbestos-containing materials in buildings and structures on-site.
-------
3.9 Description and Comparative Analysis of
Remedial Alternatives. This section briefly explains
the remedial alternatives developed to accomplish the
remedial action objectives forthe contaminant sources en
site. The description of each alternative in this section
contains enough information so that the comparative
analysis of alternatives in the following sections can
focus on the differences or similarities among the
alternatives with respect to the nine evaluation critera
specified in the NCP, 40 C.F.R. §300.430(e)(9)(iii).
Additional details necessary to designeach remedy are
found in the August 4, 1998 Feasibility Study Report,
Section 3.0, "Development and Screening of Remedial
Alternatives." Each of the following sections describe
the alternatives to accomplish the remedial action
objectives for the contaminant sources. In each section
EPA also included an estimate for the capital, O &M
and present worth cost of each alternative. The present
worth was calculated as the present worth cost for thirty
years of O & M plus the capital cost, per each remedial
alternative the present worth cost was calculated using ai
eight percent discount rate. EPA did not convert the
capital cost to a present worth since EPA expects each
alternative to be designed, competitively bid and
constructed in less than 36 months. Therefore, EPA
believes it is reasonable to assume, for the sake of
comparing alternatives, that the capita* cost is equivalent
to a single charge at the start of the cleanup. In addition
to including the cost comparison, each section also
includes tables showing the key ARARs for each
contaminant source as well as a table comparing each
remedial alternative to the nine evaluation criteria
specified in the NCP.
3.9.1 Description of Remedy Components. The
objective of this section is to provide a brief explanation
of the remedial alternatives developed for the site. The
description of each alternative contains the information
used for a comparative analysis of alternatives.
3.9.1.1 Acid Pond (AP) and Wah Chang Ditch. The
following alternatives were developed to address the
Acid Pond and the Wah Chang Ditch to the area where
the ditch discharges to the off-site ponds. The Phase I!
RI discovereda large transmissivesand channel near the
northeast corner of the Acid Pond that allows direct
hydrogeologiccommunication between the pond andthe
Wah Chang Ditch54 (Woodward-Clyde, 1993). It is for
this reason that the Acid Pond and the ditch were paired
as one contaminant source unit for the purpose of
developing a remedial alternative. The components of
each alternative are shown in Box 19.1.1, "Components
of Each AP Remedial Alternative," and the common
elements and distinguishing features of each alternative
are described in paragraphs 3.9.1.2 through3.9.1.6. The
following alternatives address isolation of tie Acid Pond
from the shallow groundwater and descrbe technologies
to treat the principal threats from the Acid Pond liquid
and sediment, as well as the Wah Chang Ditch sediment.
The key ARARs for each alternative are shown in Table
3.9.1.1-1 "Key ARARs For AP Remedial Alternatives,"
and the fundamental components along with the cost of
each alternative are shown in Box 3.9.1.1, "Components
of Each AP Remedial Alternative." A comparison of
each alternative to the nine evaluation criteria specified
in the NCP is shown in Table 3.9.1.1 - 2, "AP Remedial
Alternative Comparison."
Table 3.9.1.1 - 1
Key ARARs For AP Remedial Alternatives
Requirement
Underground Injection Control (UlC) Program 40 C.F.R. Part 144, 42 USC 300(f)
40 C.F.R. Part 264 Standards for Owners and Operators of Hazardous Waste Treatment.
Storage, and Disposal Facilities
40 C.F.R. Parts 122 to 125, National Pollutant Discharge Elimination System (NPDES)
40 C.F.R. Part 268, Land Disposal Restrictions
30 TAC. Environmental Quality, Part I, Texas Natural Resource Conservation Commission.
Chapter 335, Industrial Solid Waste and Municipal Hazardous Waste, Subchapter S, Risk
Reduction Standards.
API
N/A
YES
YES
YES
YES
AP2
N/A
YES
YES
YES
YES
AP3
N/A
YES
YES
YES
YES
AP4
N/A
YES
YES
YES
YES
APS
YES
YES
N/A
YES
YES
-------
Box 3.9.1.1 Components of Each AP Remedial Alternative
Alternative AP2: Geomembrane Wall, Metals Precipitation Treatment System, Sediment Stabilization.
o Treatment Components
Metals precipitation for acid pond water.
Stabilization for sediments and sludge
o Containment Components
Geomembrane wall to prevent groundwater from recharging the acid pond.
o Institutional Control Components
Deed Record to notify potential buyers that excavation on site may cause a release.
o Cost
Capital $6,960,000
Present Worth O&M $135.000 Annual O&M $12,000
Total Present Worth $7,095,000
Alternative APS: Geomembrane Wall, Filter Press - GAC Treatment System, Sediment Stabilization.
o Treatment Components
Granulated activated carbon (GAC) treatment to remove metals from acid pond water
Stabilization for sediments and sludge
o Containment Components
Geomembrane wall to prevent groundwater from recharging the acid pond.
o Institutional Control Components
Deed Record to notify potential buyers that excavation on site may cause a release.
o Cost
Capital $6,430,000
Present Worth O&M $135.000 Annual O&M $12,000
Total Present Worth $6,565,000
Alternative AP4: Geomembrane Wall, Metals Precipitation Treatment System
o Treatment Components
Metals precipitation for acid pond water.
o Containment Components
Geomembrane wall to prevent groundwater from recharging the acid pond.
o Institutional Control Components
Deed Record to notify potential buyers that excavation on site may cause a release.
o Cost
Capital $3,090,000
Present Worth O&M $135.000 Annual O&M $12,000
Total Present Worth $3,225,000
Alternative APS: Geomembrane Wall, Deep Well Injection of Liquid and Sediment.
o Treatment Components - None.
o Containment Components
Geomembrane wall to prevent groundwater from recharging the acid pond.
Deep well injection of sediments and acid pond water
o Institutional Control Components
Deed record to prevent disturbance of the plugged injection well.
o Cost
Capital $10,900,000
Present Worth O&M $135.000 Annual O&M $12,000
Total Present Worth $11,035,000
-------
Criterion
Overall protection o
human health and
the environment
Compliance with
ARARs
Long-term
effectiveness and
permanence
Reduction of
tqxicity. mobility, or
volume through
treatment
Short-term
effectiveness
Implementability
Implementability
Technical
Implementability
Administrative
Implementability
Availability of
services and
materials
State Acceptance
Community
Acceptance
API
Provides no
protection of
human health or
the environment.
Does not meet
ARARs.
Not effective or
permanent.
Provides no
reduction of wastt
toxicity, mobility,
or volume.
No associated risk
to workers.
Nearby residents
may be affected
ay continued off-
site migration of
waste.
No action
required.
therefore,
technically
feasible.
No action
required,
therefore,
administratively
feasible.
Services and
materials are not
equired.
Table 3.9.1.1. - 2
AP Remedial Alternative Comparison
AP2
Achieves protection by
treating Acid Pond liquid
and sediment, and Wan
Chang Ditch sediments.
Discharge to ditch must
comply with NPDES limits
Provides long-term
effectiveness by stabilizing
sediments. Final cover
would prevent direct
contact.
Provides reduction in
toxicity and mobility, but
sediment volume would
increase due to stabilization
Potential short-term
exposure of workers during
stabilization and water
treatment.
Geomembrane technology
las been effectively used at
other sites. Metals
jrecipitation is a proven
treatment process.
Stabilization and covering
are established construction
>rocedures.
May have difficulty
achieving NPDES limits for
Chemical Oxidation
demand.
Limited vendors can
provide the Geomembrane
echnology. Stabilization
and water treatment
processes have established
uppliers and operators.
AP3
Achieves protection by
treating Acid Pond liquid an
sediment, and Wah Chang
ditch sediments.
Discharge to ditch must
comply with NPDES limits.
Provides long-term
effectiveness by stabilizing
sediments. Final cover woult
prevent direct contact.
Provides reduction in toxicit)
and mobility, but sediment
volume would increase due
to stabilization.
Potential short-term exposure
of workers during
stabilization and water
removal phases.
Geomembrane technology
las been effectively used at
other sites. Filter press -
GAC system appears suitable
For water treatment.
Stabilization and covering an
established construction
procedures.
No anticipated problems
achieving NPDES limits wit!
liter press - GAC treatment
system.
Geomembrane Systems are
>rovided by limited vendors.
Water treatment processes
have established suppliers
and vendors.
AP4
Achieves protection by
treating Acid Pond Liquid
and isolating Acid Pond an
Wah Chang Ditch
Sediments
Discharge to ditch must
comply with ARARs.
May present long-term risk
to groundwater if the
impermeable cover or the
geomembrane wall fail to
prevent water infiltration.
Provides no reduction in
sediment toxicity. mobility
or volume, but sediment
would be isolated from the
environment.
Potential short-term
exposure to workers during
sediment excavation and
placement and water
treatment.
Geomembrane technology
las been effectively used at
other sites. Metals
irecipitation is a proven
treatment process.
Covering is an established
construction procedure.
vlay present difficulties in
>reventing leaching to
shallow groundwater which
would not provide
compliance with ARARs
.imited vendors can
provide the Geomembrane
echnology. Water treatmen
irocesses have established
uppliers and vendors.
Other than rejecting API and AP5,,the State did not express a preference for any of the other alternatives.
APS
Achieves protection by
deep well injecting
Acid Pond liquid and
Acid Pond and Wah
Chang Ditch Sediment
Must comply with
numerous state and
Federal ARARs
governing deep well
injection.
Provides long-term
effectiveness if
injection well is
properly utilized and
abandoned, and no
contamination of usab
aquifers occurs during
injection.
Provides no reduction
in toxicity. mobility, 01
volume, but waste
would be injected to a
point below any usable
aquifers.
Potential short-term
exposure to workers
during waste
excavation and
injection activities
Deep well injection has
been performed
previously at the site.
vlay be difficult to
comply with state and
Federal ARARs
requirements for deep
well injection
.imited vendors can
>rovide the mechanism
or creating the waste
lurry from sediment.
While there was no specific preference for alternatives API through AP4, two comments were received favoring deep well injectioi
-------
3.9.1.2 Alternative API: No Action. Under this
alternative, no action would be taken t» remove, treat, or
contain the water and sediments inthe Acid Pond and the
sediments in the Wah Chang Ditch. Because
contaminated media would remain in place, he potential
for off-site migration of contaminants would not be
mitigated. The No Action alternative has been included
for each of the units included in the feasibility study (F§
as a requirement of the NCP and to provide a basis of
comparison for the remaining alternatives.
3.9.13 AlternativeAP2: GeomembraneWall,Metak
Precipitation Treatment System, Sediment
Stabilization. In this alternative, a geomembrane wall
would be installed beneath the surface around the Acid
Pond to form a vertical barrier. This vertical barrier and
the natural clay confining layer beneath the pond would
preventgroundwaterfrom rechargingthe pondwhile the
pond sediments are stabilized. The Acid Pond liquid
would be neutralized through treatment (i.e., raising the
pH). This treatment would form metal species which
would precipitate. The treated effluent would be
discharged to the Wah Chang Ditch under the
requirements of Tex Tin Corporation's NPDES permit
limits. Sediments from the Wah Chang Ditch and the
Acid Pond would be stabilized in-situ?5 The water
treatment precipitates would also be stabilized. Once
stabilization is complete an impermeable cover would be
placed over the Acid Pond. Acid Pond sediments would
be stabilized through an in situ process to immobilizehe
metal contaminants. Before the start of stabilization,
sediment from an approximately 3,230-foot long section
of the Wah Chang Ditch (an estimated 16,000 cubic
yards) would be excavated, placed into the Acid Pond,
and mixed with the Acid Pond sediments. After all
stabilization was completed, common fill would be
added to the Acid Pond, if necessary, to fill in voids and
slope the surface to drain. Once a slight slope was
achieved, an impermeable cover consisting of a 60-miI
HOPE (high density poly-ethylene) geomembrane liner
and 12 inches of compacted clay would be placed over
the former pond area and topped with a 6-inch topsoil
layer. The topsoil layer would be covered with grass
chosen for long-teim erosion control. The impermeable
cover would be designed to promote drainage away from
the former pond. Stabilized contaminant sources for
other areason site may also be used to fill the Acid Pond
These could include: drummed materials and supersadc
contents, inorganic above ground storage tank contents,
non-NORM slag that exceeds the contaminant leachate
remedial action cleanup level (see Table 3.11.3.1). Thse
materials could be treated in-situ in the Acid Pond or
stabilized elsewhere on site prior to use as Acid Pond fill
The operation and maintenance (O&M) activities
associated with this alternate would include inspection
of the impermeable cover and maintenance of thetopsoil
layer. Groundwater monitoring for the Acid Pond has
been included as a component of the groundwater
alternatives. Because the contaminated sediments,
although treated, would remain on-site, this alternative
would include a deed record to prevent potential
exposure to site contaminants.
3.9.1.4 Alternative APS: GeomembraneWall, Filter
Press - Granulated Activated Carbon (GAC)
Treatment System, Sediment Stabilization. In this
alternative, the Acid Pond would be isolated from
groundwater and the surrounding soils by a
geomembrane barrier wall. This wall would form a
vertical barrier while the natural clay confining layer
beneath the pond would form a horizontal barrier to
prevent ground water from rechargingthe pondwhile the
pond sediments are stabilized. The liquid within the
Acid Pond would be pumped out, treated with a filter
press and GAC system on-site, and then discharged to
the Wah Chang Ditch under the requirements of the
NPDES limits. Sediments from the Wah Chang Ditch
and the Acid Pond would be stabilized in-situ. Once
stabilization is complete,an impermeable cover would be
placed over the Acid Pond. Acid Pond sediments would
be stabilized through an in situ process to immobilizehe
metal contaminants. Before the start of stabilization,
sediment from an approximately 3,200-foot long section
of the Wah Chang Ditch (an estimated 16,000 cubic
yards) would be excavated, placed into the Acid Pond,
and mixed with the Acid Pond sediments. After all
stabilization was completed, common fill would be
added to the Acid Pond, if necessary, to fill in voids and
slope the surface to drain. Once a slight slope was
achieved, an impermeable cover consisting of a 60-mil
HOPE (high density poly-ethylene) geomembrane liner
and 12 inches of compacted clay would be placed over
the former pond area and topped with a 6-inch topsoil
layer. The topsoil layer would be covered with grass
chosen for long-teim erosion control. The impermeable
cover would be designed to promote drainage away from
the former pond. Stabilized contaminant sources for
other areason site may also be used to fill the Acid Pond
These could include: drummed materials and supersadc
contents, inorganic above ground storage tank contents,
non-NORM slag that exceeds the contaminant leachate
remedial action cleanup level (see Table 3.11.3.1). Thee
materials could be treated in-situ in the Acid Pond or
stabilized elsewhere on site prior to use as Acid Pond fill
-------
The operation and maintenance (O&M) activities would include a deed record to prevent potential
associated with this alternative would include inspection exposure to site contaminants. The deed record would
of the impermeablecover and maintenanceof thetopsoil describe the location of the stabilized contaminants and
layer. Groundwater monitoring for the Acid Pond has provide notice to future potential buyers that excavating
been included as a component of the groundwater in that location may cause a release of hazardous
alternatives. Because the contaminated sediments, substances.
although treated, would remain on-site, this alternative
3.9.1.5 AIternativeAP4: Geomembrane Wall, Metafc
Precipitation Treatment System. The Acid Pond
would be isolated from groundwater and the surrounding
soils by a geomembrane technology as described in
Alternative AP2. The liquid within the Acid Pond would
be pumped out, treated on-site, and then discharged to
the Wah Chang Ditch under the requirements of the
NPDES limits. AlternativeAP4 is identcal to AP2 with
the exception of no in situ stabilization being
implemented. This alternative could coincide with the
placement of othermaterials in the Acid Pond including
drum and supersack contents, NORM slag, non-NORM
slag and hazardous soils." An impermeable cover
} consisting of 60-mil HOPE geomembrane liner and 12
inches of compacted clay would be placed over the
former pond area and topped will a 6-inch topsoil layer.
The O&M activities associated with this alternative
would include inspection of the impermeable cover and
maintenance of the vegetative layer. Monitoring of
groundwater in the vicinity of the Acid Pond has been
included as a componentof the groundwateralternatives
Because contaminated sediments wouldremain on-site,
institutional controls would be required in the form of a
deed record to further limit the potential for human
exposure to contaminants.
3.9.1.6 Alternative APS: Geomembrane Wall, Deep
Well Injection of Liquid and Sediment. In this
alternative, the Acid Pond would be isolated from the
groundwaterand surroundingsoilsby the geomembrane
to prevent pond recharge during treatment. The liquid
and sediment from the Acid Pond and the sedrnent from
the Wah Chang Ditch would be slurried and then
pumped to the on-site deep injection well for final
disposal. The Acid Pond would be backfilled with
materials from off-site sources or with site materials that
do not exceed contaminant source leachate remedial
action cleanup levels. To implementthis alternative, the
existing on-site deep injection well, which was
completed in 1985 to a total depth of approximately
The term "hazardous soil" is used to define soil which leaches
contaminants greater than the contaminant source leachate
concentrations shown on Table 3.11.3.1, "Remedial Action
Cleanup Levels."
-------
6,600 feet below ground surface, would be used. The
injection zone for this well is the lower Miocene sands,
which are found at depths ranging from 5,600 to 6,600
feet below ground surface. These sands extend laterally
throughout Galveston County. Massive impermeable
shale and clay beds are present both above and below ths
sands, making this formation an attractive unit for
injection. According to the permit application for this
well, dated October 23, 1984, the rate of inject on was to
average 50 gallons per minute (gpm); the maximum
instantaneous rate of injection was 100 gpm; the surface
injection pressure was not to exceed 800 pounds per
square inch (psi); and the totalmonthly volume of waste
injected was not to exceed 2.2 million gallons. At some
point during the late 1980s or early 1990s, the on-site
deep injection well was plugged. Accordingto a TDWl
interoffice memorandum, it is likely that the well was
plugged using four 50-foot cement plugs, with the tops
of the plugs being located at approximately 5,600 feet
below ground surface, 5,000 feet below ground surface,
and 1,700 feet below ground surface, and at the ground
3.9.1.7 Drummed Materials (DR) Historical
documentation and investigations disclosed numerous
drums and supersacks present in Areas B, E, J, and L.
The drums and supersacks contain a variety of materials
including spent catalysts, corrosives, trash, water
treatment chemicals, and lubricants and in many cases
these are a primary contaminant source. As of June
1996, it was estimated that approximately 6,500
deteriorated drums and supersacks were present at the
site. Many of the drums are believed to contain principd
surface. To implement this altanative, the plugged well
would need to be reentered, which would entail drilling
through the four plugs. Before injection of the
sediments, these materials wouldbe mixed with existing
liquid located in the Acid Pond, and potentially with
water from other sources, to form a slurry for pumping
purposes. After the completion of allwaste injection, the
deep well would again be plugged. The emptied Acid
Pond would be backfilled with clean fill from off-site
sources or with site materials that do not exceed
contaminant source leachate remedial action cleanup
levels. The O&M activities associated with this
alternative would include the installation of two
monitoring wells to monitorthe injection system. These
wells would monitor the first potable water aquifer
present above the lower Miocene sands to detect the
upward migration of waste. Institutional controls in the
form of a deed record would be needed to prevent
disturbance, reentry, or reuse of the plugged deep
injection well.
threat wastes; consequently treatment is the preferred
remedial alternative. The fundamental components and
cost of each alternative are shown in Box 3.9.1.7,
"Components of Each DR Remedial Alternative;" the
key ARARs for each alternative are shown in Table
3.9.1.7 - 1, "Key ARARs For DR Remedial
Alternatives;"and a comparison of each alternative to the
nine evaluation criteria specfied in theNCP is shown in
Table 3.9.1.7 - 2, "DR Remedial Alternative
Comparison."
-------
Box 3.9.1.7 Components of Each PR Remedial Alternative
Alternative DR2: Off-Site Disposal
o Treatment Components - None
o Containment Components
- Off-Site disposal.
o Cost
Capital $3,760,000
Present Worth O&M $ .000
Total Present Worth $3,760,000
Annual O&M $000
Alternative DR3: Stabilization of Drum Contents On-site
o Treatment Components
Stabilize drum contents.
o Containment Components
Bury the stabilized drum materials with the stabilized acid pond sediments beneath a topsoil cover.
o Institutional Control Components - None.
o Cost
Capital $450,000 Annual O&M $000 No additional cost to acid pond O&M.
Present Worth O&M $000
Total Present Worth $450,000
Alternative DR4: Placement of Drum Contents On-site
o Treatment Components - None
o Containment Components
Cover drum contents in the acid pond with a clay cover.
o Institutional Control Components - None.
o Cost
Capital $350,000
Present Worth O&M $.000 Annual O&M
Total Present Worth $350,000
Alternative DR5: Deep Well Injection of Drum Contents
o Treatment Components - None.
o Containment Components
Deep well injection of drum contents
o Institutional Control Components - None.
o Cost
Capital $610,000
Present Worth O&M $.000
Total Present Worth $610,000
000 No additional cost to acid pond O&M.
Annual O&M 000 Included with the AP5 cost
Table 3.9. 1.7-1
Key ARARs For DR Remedial Alternatives
Requirement
Underground Injection Control (UIC) Program 40 C.F.R. Part 144,
42 USC 300(f) .
40 C.F.R. Part 268, Land Disposal Restrictions
40 C.F.R. Part 264 Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities
DR1
N/A
YES
YES
DR2
N/A
YES
YES
DR3
N/A
YES
YES
DR4
N/A
YES
YES
DR5
YES
YES
YES
-------
Table 3.9.1.7 -1
Key ARARs For DR Remedial Alternatives
Requirement
DR1
DR2
DR3
DR4
DR5
30 TAG. Environmental Quality, Part I, Texas Natural Resource
Conservation Commission, Chapter 335, Industrial Solid Waste
and Municipal Hazardous Waste, Subchapter S, Risk Reduction
Standards.
YES
YES
YES
YES
YES
Abandoned drums in Area E.
-------
Criterion
Overall protection of human
health and the environment
Compliance with ARARs
Long-term effectiveness and
permanence
Reduction of toxicity; mobility,
or volume through treatment
Short-term effectiveness
Implementabilily
Implementability
Technical
Implementability
Administrative
Implementability
Availability of services and
materials
Community Acceptance
Table 3.9.1.7 - 2
DR Remedial Alternative Comparison
DR1
Provides no protection of human
health or the environment.
Does not meet ARARs.
Not effective or permanent.
None through treatment.
No associated risk to workers
and residents.
No action required, therefore.
technically feasible.
No action required, therefore,
administratively feasible.
Services and materials are not
required.
DR2
Protection of human health and
environment achieved by
removing waste material and
drums from site.
Drum removal and waste
disposal would be conducted in
accordance with RCRA and
other Federal, state, and local
requirements.
Provides long term effectiveness
and permanence by eliminating
future exposure and migration
through the removal of wastes
from the site.
None through treatment.
Potential risks associated with
spills/leaks on public roads and
worker exposure during loading
affect the short-term
effectiveness.
Equipment, labor, and disposal
facilities are available, making
alternative technically feasible.
Manifesting would be required.
Alternative is administratively
feasible.
No specialized labor or
equipment would be required.
Scrap yards and disposal
facilities have the necessary
capacity.
DR3
Protection is achieved by
stabilizing selected drum
contents and removing the rest
off site.
Stabilization of waste materials
could pass the RCRA toxicity
characteristic requirements
Stabilized materials do not
readily leach contaminants,
providing a long-term effective
and permanent solution.
Stabilization provides a reduction
in toxicity and mobility of site
contaminants, but does not
reduce volume.
Workers would be required to
wear appropriate PPE and adhere
to safe construction practices to
minimize short-term effects.
Stabilization of drum wastes is
now routinely performed.
Alternative is technically
feasible.
No specialized limits would be
required for stabilization.
EPA-qualified vendors are
available.
DR4
Protection is achieved by
isolating selected drum wastes
from the environment, taking the
rest off site.
Must provide adequate protection
of shallow groundwater by
preventing water infiltration
through impermeable cover
Impermeable cover and
geomembrane wall must be
maintained to prevent infiltration
ofstormwaterand shallow
groundwater
Placement on site provides no
reduction of waste toxicity,
mobility, or volume, but isolates
waste from the environment
Workers would be required to
wear appropriate PPE and adhere
to safe construction practices to
minimize short-term effects.
Equipment and contractors are
readily available.
Must show that groundwater
would be adequately protected
No specialized labor or
equipment would be required.
Other than rejecting DR1 and DR5, the State did not express a preference for any of the other alternatives
DR5
Protection is achieved by deep
well injecting drum wastes below
any usable aquifers
Must comply with numerous state
and Federal ARARs, but possible
If injection well is properly
abandoned, this method should
provide for long term
effectiveness and permanence
Provides no reduction in waste
toxicity, mobility, or volume, but
isolates waste from the
environment
Workers would be required to
wear appropriate PPE and adhere
to safe construction practices to
minimize short-term risks.
Limited vendors can supply the
technology to prepare the waste
for slurry injection.
Would require compliance with
state and Federal ARARs, must
meet TNRCC approval
Limited vendors can supply
technology to create the waste
slurry necessary for deep well
injection.
While there was no specific preference for alternatives DR1 through DR4, two comments were received favoring deep well injection DRS ~
-------
3.9.1.8 Alternative DR1: No Action. Under this
alternative, no action would be taken to remove, treat, or
contain the drums and supersacks and their contents.
Because the drum contents would remain in place, the
potential for spills and leaks of these materials wouJ not
be mitigated.
3.9.1.9 Alternative DR2: Off-Site Disposal.
Under this alternative, the drummed materials and
supersack contents would be characterized and shipped
off site for disposal at an EPA-approveddisposal facility.
Facilities in Texas, Louisiana, and Kentucky have been
identified for the disposal of these wastes. Because all
drummed materials would be taken off site for disposal,
there would be no operation and maintenance activities
associated with this alternative, nor would institutional
controls be required.
3.9.1.10 Alternative DR3: Stabilizing Inorganic
Drummed Materials and Supersack Contents,
Disposing of Drummed Organic Material Off site.
Under this alternative, all drums and supersacks would
be emptied, decontaminated and hauled of site for scrap
metal recycling or disposal, or would be landfilled on
site. The inorganic drummed materials and supersack
contents would be stabilized and used to fill the Acid
Pond. The organic contents would be disposed of off sife
at an EPA approved treatment and disposal facility.
Drum decontamination water would be treated with the
Acid Pond liquids. Because the drummed materials
would be treated along with the Acid Pond sediments,
there are no O&M activities for this alternative.
Likewise, institutional controls are not included win this
alternative but are part of the Acid Pond alternatives.
3.9.1.11 Alternative DR4: Placement of Drum
Contents On-site. This alternative is identical to
Alternative DR3, except that no stabilization would be
implemented for the drum contents. All drums and
supersacks would be emptied, decontaminated, and
hauled off site for scrap metal recyclhg or disposal. For
purposes of cost estimation, the assumption has been
made that drum inorganic contentswould be deposited in
the Acid Pond. Organic wastes removed from
approximately220 drums in the former Morchem facilty
would be disposed of off site with the AST wastes.
O&M activities and institutional controls associatd with
this alternative have been included as a component in tie
Acid Pond alternatives, not as a part of this alternative.
3.9.1.12 AlternativeDRS: Deep Well Injection of
Drum Contents. Under this alternative, all drums and
supersacks would be emptied of their contents,
decontaminated, and hauled off site for scrap metal
recycling or off-site disposal, or landfilled on site. The
inorganic waste contents of the drums and supersacks
would be crushed (as needed), and then mixed with the
organic wastes and water to form a slurry of
approximately 30 percent solids. Thisslurry would then
be injected through the existing on-site deep injection
well into the subsurface. Monitoring of the deep well
injection system has been included as an O&M activity
under the injection of the Acid Pond Alternative.
Slag Piles
Drums
Southern portion of the Site
-------
3.9.1.13 NORM SLAG (NSL). The following
alternatives were developed to addressNORM slag piles
12, 13, 30, and 31. During the Phase II RI slag emitting
radiation above regulatory standards and containing
inorganic concentrations above the proposed slag
remedial action cleanup levels was identified as a
primary contaminant source. The elevated radioactive
levels are believed to be from naturally occurring
radiation sources concentrated in the slag during the
smelting operations. The estimated NORM slag piles
volume is 14,100 cubic yards. All of the following
NORM slag remedial alternatives, withthe exception of
NSL1, "No Action," involve either placing the material
under an impermeable cap, disposingat a Department of
Energy disposal facility, or deep well injection. These
alternatives remediate the external and internal
carcinogenic human health risk associated with the
radioactive material by preventing external radiation
exposure and preventing direct contact, ingestion, and
inhalation of any contaminant sources containing
radium-226 exceeding the criteria in 40 C.F.R. Part 192.
Covering the radioactive material on site is consistent
with remedies previously employed at two other
Superfund sites: the Denver Radium site inColorado and
the Monticello Mill Tailings site in Utah. At Denver
Radium56 radiation in building and Process Areas was
detected to a depth of 40 inches with an average
concentration of 90 pCi/g, and in open areas to an
average depth of 39 inches atan average concentration of
69 pCi/g. Like the Denver Radium site, he Tex-Tin site
was found to contain radium, thorium, and uranium.
However, in contrast to Denver Radium, the Tex-Tin
slag piles were found to have radium-226 or radium-228
concentrations generally less than 20 pCi/g with a
maximum recorded concentration of 107 pCi/g. Soils
and sediments at Tex-Tin averagedless than 5 pCi/g. For
the Monticello57 site, primary contaminants of concern
affecting the soil and debris are metals includng arsenic,
chromium, and lead; and radioactive materials including
thorium-230,radium-266,andradon-222. Uianium mill
tailings, which were left on the site or taken away to be
used as fill at construction sites inthe nearby town, are to
be consolidated in a repository near the mill site. The
repository will then be capped to protect groundwater,
isolate the waste from the environment, and control the
escape of radon gas. Average waste concentrations at
Monticello ranged from 590 to 879 pCi/g of radium-226
in various tailings piles. In contrast, Tex-Tin radium-226
concentrations peaked at 107 pCi/g and most of them
were less than 20 pCi/g. The fundamental components
and cost of each alternative are shown in Box 3.9.1.13,
"Components of Each NSL Remedial Alternative," the
key ARARs for each alternative are shown in Table
3.9.1.13 - 1, "Key ARARs For NSL Remedial
Alternatives," and a comparison of each alternative to tte
nine evaluation criteria specfied in the NCP is shown in
Table 3.9.1.1 - 2, "NSL Remedial Alternative
Comparison."
Table 3.9.1.13 - 1
Key ARARs For NSL Remedial Alternatives
Requirement
Underground Injection Control (UIC) Program 40 C F R Part
144, 42 USC 300(f)
40 C.F.R. Part 268, Land Disposal Restrictions
40 C.F.R. Part 264 Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities
40 C.F.R. Part 192, Subpart B, Health and Environmental
Standards for Thorium Mill Tailings
30 TAG. Environmental Quality, Part I, Texas Natural Resource
Conservation Commission, Chapter 335, Industrial Solid Waste
and Municipal Hazardous Waste, Subchapter S, Risk Reduction
Standards.
NSL1
N/A
YES
YES
YES
YES ,
NSL2
N/A
YES
YES
YES
YES
NSL3
N/A
YES
YES
YES
YES
NSL4
N/A'
YES
YES
YES
YES
NSL5
YES
YES
YES
YES
YES
-------
Box 3.9.1.13 Components of Each NSL Remedial Alternative
Alternative NSL2: Off Site Disposal of NORM Slag.
o Treatment Component - None
o Containment Component
Off site disposal
o Institutional Control Components - None
o Cost
Capital $16,730,000
Present Worth O&M £000 Annual O&M $000
Total Present Worth $15,730,000
Alternative NSL3: Stabilization of NORM Slag
o Treatment Components
- Stabilize NORM slag.
o Containment Components
Landfill and Cover stabilized slag with impermeable cover so radioactive exposure levels are not exceeded
o Institutional Control Components
Deed recordation to protect the integrity of the cap.
o Cost
Capital $970,000
Present Worth O&M SQQO Annual O&M $000 No additional cost, included with
Total Present Worth $970,000 groundwater O&M activities.
Alternative NSL4: Placement of NORM Slag On-site
o Treatment Components - None
o Containment Components
- Dispose of slag with the acid pond sediments in the acid pond beneath an impermeable cap.
o Institutional Control Components - None.
o Cost
Capital $130,000
Present Worth O&M $.000 Annual O&M $000 No additional cost included with
Total Present Worth $ 130,000 acid pond O&M.
Alternative NSL5: Deep Well Injection of NORM Slag
o Treatment Components - None
o Containment Components
Deep well injection for NORM slag.
o Institutional Control Components - None
o Cost
Capital $2,810,000
Present Worth O&M $000 Annual O&M $000 No additional cost included with
-------
Criterion
Overall
protection of
human health and
the environment
Compliance with
ARARs
Long-term
effectiveness and
permanence
Reduction of
toxicity, mobility,
or volume through
treatment
Short-term
effectiveness
Implementability
Implementability
Technical
Implementability
Administrative
Implementability
Availability of
services and
materials
State Acceptance
Community
Acceptance
Table 3.9.1.13 - 2
NSL Remedial Alternative Comparison
NSL1
Provides no protection
of human health or the
environment.
Does not meet
ARARs.
Not effective or
permanent.
None through
treatment.
No associated risk to
workers and residents.
NSL2
NORM slag would be removed from the
site, which would provide protection of
human health and the environment.
Contaminated material would be re-
moved to levels that would meet the
applicable ARARs. Off-Site disposal
would need to comply with applicable
regulations.
Removal of waste and off-site disposal at
an appropriate licensed landfill would
provide long-term effectiveness and
permanence.
None through treatment.
On-site workers and nearby residents
could be exposed to waste materials or
dust in the short term.
No action required,
therefore, technically
feasible.
No action required,
therefore,
administratively
feasible.
Services and materials
are not required.
Equipment, labor, and the necessary
disposal facilities are available, making
alternative technically feasible.
Radioactive waste would be shipped a
minimum distance of 1,400 miles.
Logistical problems associated with rail
shipping and disposal facility may arise.
All materials and services needed for this
alternative are routinely used in
construction activities. Special
consideration to handling of NORM
material and decontamination of
equipment may be required.
NSL3
Stabilizing NORM slag is protective of
human health and the environment.
Compliance with ARARs can be
achieved by stabilizing and covering to
meet radioactive exposure levels
Stabilized material would not readily
leach contaminants, providing a long-
term effective and permanent solution.
Stabilization would provide a reduction
in mobility of site contaminants, but
would increase volume.
Workers would be required to wear
appropriate PPE and adhere to safe
construction practices to minimize
short-term effects.
NSL4
Provides protection of human health
and the environment by isolating
waste, but may not sufficiently protect
shallow groundwater
Shallow groundwater must be
monitored to verify compliance
Dependent on the effectiveness of the
impermeable cover and the
geomembrane wall to prevent the
infiltration of stormwater and shallow
groundwater
No reduction of toxicity, mobility, or
volume. Dependent on the
effectiveness of the impermeable
cover and the geomembrane wall.
Workers would be required to wear
appropriate PPE and adhere to safe
construction practices to minimize
short-term effects.
NSL5
Protects human health and the
environment by isolating waste
from the surrounding environment
Numerous state and Federal
ARARs must be closely
monitored for groundwater
protection
If injection well is properly
abandoned, this should provide
adequate long-term protection of
the environment
No reduction of toxicity, mobility,
or volume, but should provide
adequate protection of the
environment.
Workers would be required to
wear appropriate PPE and adhere
to safe construction practices to
minimize short-term effects
Stabilization technology is routinely
applied for radioactive materials.
No specialized limits would be required
for stabilization.
EPA-qualified stabilization vendors are
available.
Can be Implemented using standard
construction technology
No specific requirements for this
alternative
Equipment and EPA-approved
contractors readily available.
Limited vendors can supply the
technology required to crush the
slag and create the slurry required
for deep well injection.
Would require compliance with
numerous ARARs and the
permission of the TNRCC
Limited vendors are available that
can provide the technology
necessary to crush the slag and
create an injectable slurry.
Other than rejecting NSL1 and NSL5, the State did not express a preference for any of the other alternatives.
While there was no specific preference for alternatives NSLI through NSL4, two comments were received favoring deep well injection, NSL5.
-------
3.9.1.14 Alternative NSL1: No Action. Under this
alternative, no action would be taken t> remove, treat, or
contain NORM slag piles 12, 13, 30, and 31. Because
the NORM slag would be left in place, thepotential for
this material to migrate would not be mitigated.
3.9.1.15 Alternative NSL2: Off-Site Disposal of
NORM Slag. Under this alternative, the NORM slag
piles would be loaded onto railcars and/or vehicles
permitted to transport NORM waste, and transported to
an off-site NORM disposal facility. A facility in the
Western United States has been identified as a potential
disposal site for the NORM slag. Because all NORM
slag would be disposed of off site, there would be no
O&M associated with this alternative. There are no
institutional controls associated with this alternative.
3.9.1.16 Alternative NSL3: Stabilizing NORM
Slag. Under this alternative, the NORM slag would be
stabilized on site, buried below grade and sealed beneath
an impermeable cover in a landfill within Area C. The
NORM slag will be buried in a manner to ensure that
allowable radioactive dosage levels are not exceeded at
the surface. O&MactivitieswouH include groundwater
monitoring, cover inspection and maintenance, and
institutional controls, which are included under SS2 and
GW2 alternatives; consequently there are no additional
O&M activities associated with this alternative. Beause
stabilized contaminated slag would be buried on site,
this alternative would also include a deed record as an
institutional control to limit the potential for future
human exposure to contaminants. The deed record
would describe the location of the slag and provide
notice to potential buyers that excavations in that location
may cause a release of hazardous substances.
3.9.1.17 Alternative NSL4: Placement of NORM
Slag On-site. Under this alternative, the NORM slag
would be transported to anon-site location and deposited
under an impermeablecover. For purposes of estimating
the assumption has been made that the NORM slag
would be deposited in the Acid Pond. No stabilization
would be performed. Because maintenance of the Acid
Pond is included as an O&M activity under the Acid
Pond alternatives, and because groundwater monitoring
is included under the groundwater alternatives, there are
no O&M activitiesassociatedwith this alternative. Theie
are no institutional controls associated with this
alternative.
3.9.1.18 AlternativeNSL5: Deep Well Injection cf
NORM Slag. Under this alternative, the NORM slag
would be crushed, mixed with water, and disposed of va
deep well injection. The crushed NORM slag would be
mixed with water from the Acid Pond,wastewater ponds,
or other sources, to achieve a 30-percent solids slurry.
The slurry would then be pumped into the existing on-
site deep injection well. At the completion of deep well
injection activities, the well would be plugged.
Monitoring of the deep injection system has been
included as an O&M activity under Acid Pond
Alternative APS. Therefore, there are no O&M
activities associated with this alternative.
3.9.1.19 NON-NORM SLAG (SL) The following
alternatives were developed to address the 58 non-
NORM slagpiles(piles 1 through 11,14 through 29, and
32 through 62). The Phase II RI noted that the majority
of the slag piles consist of metallic ore and slag but that
some piles contain construction debris and scrubber
sludge. As described in the site conceptual model, EPA
identified these piles as primary contaminant sources.
The metallic ore and slag were generated during the
smelting operations. Phase II RI analytical results
indicated that composite samples collected from
non-NORM slag piles 1, 11, 19,27,28, 29, 52, 56, 57,
58, and 62 exhibit hazardous waste toxic characteristics
because they leach lead and/or mercury concentrations
exceeding the maximum concentrations listed in 40
C.F.R. §261.24 "Toxicity Characteristic" (see also
section 3.5.26, "Types of Contamination and the
Affected Media"). Consequent^, if disposed of off site,
this slag would be classified as a RCRA hazardous waste
The total volume of the hazardous non-NORM slag pies
is approximately20,000 cubic yards. The remaining 47
non-NORM slag piles did not fail TCLP (Toxicity
Characteristic Leach ing Procedure) testing and would net
be classified as RCRA hazardous waste. However, ttese
piles contain CERCLA hazardous substances (heavy
metals) in concentrations that pose an unacceptable
carcinogenic risk or non-carcinogenic hazard to human
health and the environment. The estimated non-NOFM
non-hazardous*" slag piles volumeis 32,000 cubic yards
Non-Hazardous is used to identify slag or soil which is not a
RCRA hazardous waste but was determined to pose a
carcinogenic risk or non-carcinogenic hazard through the
BHHRA.
-------
3.10.4 Reduction of Toxicity, Mobility, or
Volume Through Treatment. Reduction of toxicity,
mobility, or volume through treatment refers to the
anticipated performance of the treatment technologies
that may be included as part of a remedy. There is no
reduction of toxicity, mobility, or volume through
treatment under Alternative SW1. Under SW3 and SW,
acid pond sediments, Wah Chang Ditch sediments, (him'
contents, NORM slag and hazardous non-NORM slag
are stabilized thereby reducing the tocicity and mobility.
In Alternative SW5, where all of the aboveground
storage tank contents, drum wastes, and NORM and
hazardous non-NORM slag are disposed of off site, thee
is no reduction in toxicity, mobility, and volume of
contaminants on site. In SW2, there is a reduction of
mobility by minimizing infiltration with the
geomembrane and impermeable cap. In SW5, there is
also a reduction of mobility, toxicity, and volume of
contaminants in groundwater but no reduction through
treatment. Alternative SW6 doesnot reduce toxicity or
mobility but isolates the waste from the environment.
3.10.5 Short-Term Effectiveness. Short-term
effectiveness addresses the period of time needed to
implement the remedy and any adverse impacts th* may
be posed to workers and the community during
construction and operation of the remedy until the
cleanup levels in Table 3.11.3.1, "Soil Sediment, Slag
and Sludge Remedial Action Cleanup Levels," are met.
For the short-term effectiveness criteria, the no action
alternative(SWl)has no associated carcinogenic risk to
workers. Alternatives SW2, SW3, SW4, SW5, and SW6
all have short-term effects to workers which could be
minimized by the use of personal protective equipment
and dust control measures, and other engineering
techniques.
3.10.6 Implementabiliry. Implementability
addresses the technical and administrative feasibility of
a remedy from design through construction and
operation. Factors such as availability of services and
materials, administrative feasibility, and coordination
with other governmental entities are also considered. AI
of the alternatives can be implemented. Thetechnology,
in situ stabilization,treatmait, removal, and disposal are
all well-documented technologies. Deep wellinjection of
slurried materials is a proven oil field technology, but
reentry of the existing on-site injection well will require
caution and significantwell integrity testing. Alternative
SW2, SW3, SW4, SW5, and SW6, all would require
institutional controls in the form of a deed record to
prohibit groundwater use and assure the integrity of the
soil covers. Alternatives SW4, SW5, and SW6 would
optimize future land uses at the site.
3.10.7 State Acceptance. TNRCC reviewed the
Remedial Investigation, BHHRA, and Feasibility Study
and provided comments to EPA. TNRCC also reviewed
the proposed plan and submitted comments to EPA on
November 4, 1998. Lastly, TNRCC accepted the
remedy, SW3, on May 3, 1999.
3.10.8 Community Acceptance. Community
acceptance is an important consideration in the final
decision for the Site, and accordingly a public meeting
was held on October 6, 1998, at the Texas City, City
Hall. At this meeting EPA received oral and written
public comments. EPA also accepted written comments
by mail from September 9, 1998 through November 9,
1998, the end of the public comment period. EPA
carefully considered all public comments received duriig
the comment period before making a final decision on
the remedy for OU1. A summary of tie comments EPA
received is included in this ROD as Section 4.
3.10.9 Qualitative Comparison. Table3.10..9
provides a qualitative comparison between the site wide
alternatives. A "-" indicates the alternative does not med
the criteria, an "O" indicates the criteria are met, anda
"+" indicates a best fix.
Discarded Drums in Area E.
-------
Table 3.10.9
Qualitative Comparison
Evaluation Criteria
Protection of human
health
Compliance with ARARs
Long-term effectiveness
and performance
Reduction of toxicity,
mobility and volume
Short-term effectiveness
Implementability
Cost (Present Worth)
SW1
—
—
—
—
+
+
SO
SW2
+ "
O
—
—
O
+
$15,580,000
SW3
+
+
+
0
O
+
$28,610,000
SW4
+
+
+
O
0
+
$88,280,000
SW5
+
+
+
O
O
+
$1 12,060,000
SW6
0
—
+
O
O
0
$36,930,0
00
Legend:
- Unacceptable
O Acceptable
+ Best Fix
-------
3.11 Selected Remedy. This section expands
upon the details of the Selected Remedy from thit which
was provided in the "Description of Alternatives"
section. This section also provides the general
engineering details and estimated costs for the selected
remedy so the design engineer can initiate the remedial
design. The remedy is discussed in three sections:
"Description of the Selected Remedy," "Summary of
Estimated Remedy Costs," and "Expected Outcomes of
the Selected Remedy."
3.11.1 Description of the Selected Remedy -
SW3: On-site Stabilization, Compacted Clay Cover,
Groundwater Monitoring, and Asbestos Removal,
and Buildings Demolition. EPA's selected remedy is
SW3, (see Figure 3.11.1). The component remedial
alternatives are summarized in the following setions. A
summary of the Site Wide Alternative SW3 is shown in
Box 3.11.1. Under this alternative, a geamembrane wall
would be placed around the Acid Pond. The Acid Pond
liquids would be treated and discharged into the Wah
Chang Ditch. Stabilization will be used for treatment of
the Acid Pond and Wah Chang Ditch sediments.
Drummed materials, hazardous non-NORM slag, and
soils exceeding the leachate concentrations shown on
Table 3.11.3.1, "Soil Sediment, Slag and Sludge
Remedial Action Cleanup Levels" would be stabilized
and used to fill the Acid Pond. The total volume of
materials for on-site stabilization would be
approximately 94,000 cubic yards. The wastewater pond
liquids would be discharged into the Wah Chang Ditch.
Soil exceeding any remedial action cleanup level in
Table 3.11.3.1 but not exceeding leachate concertrations
would be covered with a 24-inch clay soil cover. The
above ground storage tank contents would be shipped of
site for disposal at an EPA approved treatment and
disposal facility. A perimetermonitoringprogram woufl
be implemented to ensure no further groundwater
degradation. Each building would be evaluated during
Remedial Design using the criteria described in Section
3.11.3.5. If demolition is appropriate dust and asbestos
would be removed from the buildings, the buildings
demolished, and the debris landfilled on site. Buildings
which are not demolished will be decontaminated. A
detailed description of this remedial alternative is
discussed in the following sections. The first section
describes the distinguishing and unique features of the
remedial alternatives for eachcontaminant source, while
the second section describes the features common to eah
remedial alternative. A cost estimate for eachalternative
is also included in the first section.
Tex-Tin site looking towards the waste-water ponds and acid pond.
-------
BOX 3.11.1 Site Wide Alternative 3
Alternative AP3: Geomembrane Wall, Filter Press - GAC Treatment System, Sediment Stabilization.
o Treatment Components
Granulated activated carbon (GAC) treatment to remove metals from acid pond water
Stabilization for sediments and sludge
o Containment Components
Geomembrane wall to prevent groundwater from recharging the acid pond.
Impermeable cover over stabilized sediments
° Institutional Control Components
Deed Record to notify potential buyers that excavation on site may cause a release of hazardous
substances.
o Total Present Worth $6,575,000
Alternative WP2: NPDES Discharge of Water, 24-Inch Clay Cover
o Treatment Components
None
o Containment Components
Clay and topsoil cover over the pond sediments
o Institutional Control Components - None.
o Total Present Worth $2,695,000
Alternative GW2: Long-Term Monitoring
o Treatment Components - None
o Containment Components - None
o Groundwater Monitoring
Installing monitoring wells to provide perimeter monitoring to ensure groundwater does not exceed
alternate concentration limits
o Institutional Control Components
Deed records to prevent on-site use of the Shallow, Medium and Deep Transmissive Zone groundwater
o Total Present Worth $331,000
Alternative DR3: Stabilization of Drum Contents On-site
o Treatment Components
Stabilize drum contents.
o Containment Components
Stabilize drummed materials and use them to fill the acid pond.
0 Institutional Control Components - None.
o Total Present Worth $450,000
Alternative AST2: Off-Site Disposal of AST Contents
o Treatment Components -None
° Containment Components
Off-Site disposal.
o Total Present Worth $450,000
-------
Box 3.11.1 fconU Site Wide Alternative 3
Alternative SS2: Cover Soils Exceeding Soil Remedial Action Cleanup Levels - Stabilize and Cover Soils That
Exceed Contaminant Source Leachate Remedial Action Cleanup Levels.
0 Treatment Component
Stabilize soils exceeding contaminant source leachate remedial action cleanup levels and use them to
fill the acid pond.
° Containment Component
Cover contaminated soils which do not leach contaminants with concentrations exceeding contaminant
source leachate level but exceed human health risk levels.
o Institutional Control Components
Deed record to protect the integrity of the clay cover.
o Total Present Worth $3,967,000
Alternative NSL3: Stabilization of NORM Slag
° Treatment Components
Stabilize NORM slag.
° Containment Components
Landfill and cover stabilized slag with impermeable cap.
o Institutional Control Components
Deed record to protect the integrity of the cap.
o Total Present Worth $970,000
Alternative SL4: Stabilization and Covering of Hazardous non-NORM slag, Backfilling and Covering of Non-
NORM slag.
o Treatment Components
Stabilize hazardous non-NORM slag and use it to fill the acid pond.
o Containment Components
Cover hazardous non-NORM slag exceeding with an impermeable cover.
Cover non-NORM non-hazardous slag with a compacted clay and topsoil.
o Institutional Control Components
Deed record to protect the integrity of the clay and topsoil cover.
o Total Present Worth $1,300,000
Alternative BLD4: Asbestos Removal and Building Demolition with On-site Disposal
o Treatment Components - None
° Containment Components
Asbestos and building debris disposed of in an on site landfill.
o Institutional Control Components - None
o Total Present Worth $11,950,000
-------
Figure 3.11.1
Site Wide Alternative 3 (SW3)
Roastina& Leaching Bldg.
1
Pond 7
Smelter
Bldg.
LEGEND
Hurricane Wall
Radioactive
Landfill
Drainage and
Treatment, Discharge
of Fluids Under NPDES
Permit, Regrade and
Cover Ponds (WP2).
Area to Be Covered
with Clay Cover (SS2),
Including Low-level
Radioactive Landfill
Proposed Disposal
Area of Hazardous
Material for
Stabilization in Acid
Pond, Including Drum
Contents (DR3) and
Hazardous Non-norm
Slag (SL4). Area to Be
Covered by
Impermeable Cover
(APS)
Buildings Where Dust
and Friable Asbestos
Removed, Building
Demolished (BLD4)
Existing Perimeter Monitoring Wells
New Perimeter Monitoring Wells
-------
Distinguishing and Unique Features of Each
Remedial Alternative Comprising SW3.
3.11.1.1 AP3 On-site Stabilization of Acid Pond
Sediments and Wah Chang Ditch Sediments. The
principal threat from Wah Chang Ditch and the Acid
Pond sediments would be treated on site through
stabilization. The liquid within the pond would be
treated using the filter press - GAC treatment. Treated
water would be discharged to the Wah Chang Ditch
under the NPDES limits. The filter cake from the press
would be stabilized. The stabilized mixtures would be
placed, graded and compacted as backfill in the Acid
Pond.
3.11.1.1.1 Liquid Treatment. The pH of the liquid
in the Acid Pond would be raised to eliminate theacidity
and precipitate metals contaminating the water in the
pond, thus eliminating the principal threat. A fitter press
would remove suspended solids and the filter press
effluent would be passed through a granulated activated
carbon filter to remove other dissolved and suspended
contaminants. To comply with ARARs, effluent from
the carbon filter would be required to meet NPDES
discharge permit requirements before it is discharged to
the Wah Chang Ditch. Precipitated metal species would
be stabilized along with pond and ditch sediments and
disposed of on-site.
3.11.1.1.2 Geomembrane Vertical Barrier Wall.
Prior to stabilization the Acid Pond would be isolated
from groundwater and the surrounding soils by a
geomembrane vertical barrier to prevent pond recharge
during treatment. Care will be taken to ensure that the
geomembrane wall is properly keyed intotheunderlying
clay layer.
-------
Table 3.1 1.1.1.
Cost Estimate, Remedial Alternative AP3
Geomembrane Wall, Filter Press-GAC Treatment System, In-Situ Sediment Stabilization, Impermeable
Cover
Item Description
Capital Costs
Field Overhead and Oversight
Health and Safety
Geomembrane Wall Installation
Excavation and Transportation of Wah Chang Ditch
Sediment
nitration I reatment System
Metal Precipitate Recycling
In-Situ Stabilization Mobilization and Demobilization
In-Situ Stabilization
impermeable Acid Pond Cover
General Equipment Mobilization and Demobilization (6%)
Quantity
6
6
48,600
1
8,500,000
10,000
1
63,000
196,020
1
Unit
1 Cost/Unit
Cost**
month
month
square ft.
lump sum
gallon
cubic yard
lump sum
cubic yard
square ft.
lump sum
$8,967.00
$6,247.00
$16.50
$408,708.00
$0.004
($3.00)
$60,000.00
$35.00
$1.00
$226,015.00
Subtotal Direct Capital Costs
Overhead and Profit (25%)
Total Direct Capital Costs (Rounded to Nearest $10,000)
Indirect Capital Costs
$53,802
$37,482
$801,900
$408,708
$34,000
($30,000)
$60,000
$2,205,000
$196,020
$226,015
$3,992,927
$998,232
$4,990,000
Engineering and Design (7%)
Legal Fees and License/Permit Costs (5%)
Total Indirect
Capital Costs
Subtotal Capital Costs
Contingency Allowance (15%)
Total Capital Costs (rounded to the nearest $10,000)
O&M Costs
Cover Inspection and Maintenance
1
$349,300
$249,500
$598,800
$5,588,800
$838,320
$6,430,000
lump sum
5,862.00
Subtotal
Overhead and Profit (25%)
Subtotal (Rounded to nearest $10,000)
Administration (5%)
Insurance, Taxes, L
.icenses (2.5%)
Contingency Allowance (15%)
Total O&M Costs (rounded to the nearest $1,000)
30 year cost projection. Assumed discount rate per year: 8.0%
Present Worth of O&M (rounded to nearest $1,000)
Total Alternative Cost (Capital Cost plus O&M) to nearest $10,000
$5,862
$5,862
$1,466
$10,000
$500
$250
$1,500
$12,000
$135,093
$135,000
$6,570,000
Notes: ~ —
*The factors represent adjustments for difficulty, size, and other intangibles that will affect the work.
**Due to rounding, the amount in the Cost column may be slightly different than the product
of the values in the Quantity, Cost/Unit, and Factor columns.
-------
3.11.1.2 DR3: Stabilizing Inorganic Drummed
Materials and Supersack Contents, Disposing of
Drummed Organic Materials Off Site. Under this
alternative, all drums and supersacks would be emptied
of their contents, decontaminated, andhauled off site for
scrap metal recycling, off-site disposal, or disposal in an
on-site landfill. Spent catalyst and other materials
classified as principal threat wastes from drummed
materialsand supersacks would be stabilized aid used to
fill the Acid Pond. The organic contents would be
disposed of off site at an EPA approved treatment and
disposal facility.
Drums stored inside the ore
storage building.
Table 3.11.1.2
Cost Estimate, Remedial Alternative DR3
Stabilization of Drums and Drum Contents
Tex Tin Corporation Superfund Site
Texas City, Texas
Field Overhead and Oversight
Loading and Crushing of Drums
Sample and Analysis of Drum Contents
jn-Situ Stabilization ~ —
General Equipment Mobilization and Demobilization
f £t\/ \
10
1,600
1
sample
cubic yards
Total Direct Capital Costs (Rounded to Nearest $10,000)
Indirect Capital Costs
lump sum
$1,507.70
$35.00
$15,700.00
Subtotal Direct Capital Costs
Overhead and Profit (25%)
$175,370
$15,077
$56,000
$15,700
$277^361
$69,340
$350,000
Engineering and Design (7%)
Legal Fees and License/Permit Costs (5%)
Total Indirect Capital Costs
Subtotal Capital Costs
Contingency Allowance (15%)
Total Alternative Cost (rounded to the nearest $10,000)
$24,500
$17,500
$42,000
$392,000
$58,800
$450,000
va,Ues in
3'"-L3"SL3: N°rm Slag Stabilization. Under this alternative, the NORM slag would be stabilized 01
-------
the site, buried below grade and sealed with an
impermeable cover within Area C. Stabilization isa
treatment which will reduce this principal threat waste's
toxicity and mobility. The slag will be buried deep
enough below grade so that the cover reduces the
radionuclide dosage concentration at the surface to an
acceptable level.
Table 3.1 1.1.3.
Cost Estimate, Remedial Alternative NSL3
Stabilization of NORM Slag
Item Description Quantity Unit Cost/Unit
Cost*
Capital Costs
Field Overhead and Oversight 3 month $8,967.00
Health and Safety 3 month $6,247.00
Loading of NORM Slag 14,100 cubic yard $1.69
Sample and Analysis of Soil below NORM Pile 10 sample $607.60
In-Situ Stabilization 14,100 cubic yard $35.00
General Equipment Mobilization and Demobilization (6%) 1 lump sum $34,143.00
Subtotal Direct Capital Costs
Overhead and Profit (25%)
Total Direct Capital Costs (Rounded to Nearest $10,000)
$26,901
$18,741
$23,829
$6,076
$493,500
$34,143
$603,190
$150,797
$750,000
Indirect Capital Costs
Engineering and Design (7%)
Legal Fees and License/Permit Costs (5%)
Total Indirect Capital Costs
Subtotal Capital Costs
Contingency Allowance (15%)
Total Alternative Cost (rounded to the nearest $10,000)
$52,500
$37,500
$90,000
$840,000
$126,000
$970,000
Notes:
* Due to rounding, the amount in the Cost column may be slightly different than the product of the values in the Quantity,
Cost/Unit, and Factor columns.
-------
3.11.1.4 SL4i Covering non-Hazardous non-
NORM Slag and Stabilizing Hazardous non-NORM
Slag. This alternative would cover non-hazardous non-
NORM slag with clay as described in soil alternative
SS2. The remaining hazardous non-NORM slag would
be stabilized on site to eliminate the principal threat and
used to fill the Acid Pond as described in remedial
alternative APS.
Table 3.11.1.4.
Cost Estimate, Remedial Alternative SL4
Stabilization and Covering of Hazardous non-NORM Slag
Backfilling and Covering Remaining Slag
Item Description
~|" Quantity
Unit
Cost/Unit
Cost*
Capital Costs
Field Overhead and OversighF
month
$8,967.00
$26,901
Health and Safety
month
$6,247.00
$18,741
General Equipment Mobilization and Demobilization
Stabilization of Hazardous non-NORM slag piles
1
lump sum
$9,914.00
$9,914
20,000
cubic yard
$35.00
$700,000
Loading of Non-NORM slag
52,000 cubic yard
$0.96
$49,972
Subtotal Direct Capital Costs
$805,528
Overhead and Profit (25%)
$201,382
Total Direct Capital Costs (Rounded to Nearest $10,000)
$1,010,000
Indirect Capital Costs
Engineering and Design (7%)
$70,700
Legal Fees and License/Permit Costs (5%)
$50,500
Total Indirect Capital Costs
$121,200
Subtotal Capital Costs
$1,131,200
Contingency Allowance (15%)
$169,680
Total Alternative Cost (rounded to the nearest $10,000)
$1,300,000
Notes: ~~~
* Due to rounding, the amount in the Cost column may be slightly different than the product of the values in the Quantity,
Cost/Unit, and Factor columns.
-------
3.11.1.5 SS2: Cover Contaminated Soils, Stabilize
and Cover Hazardous Soils. This alternative would
cover contaminated soils which do not leach
contaminants in concentrationsgreaterthan those shown
in Table 3.11.3.1, "Soil Sediment, Slag and Sludge
Remedial Action Cleanup Levels," stabilize soils which
leach contaminants in concentrations greater than those
shown in Table 3.11.3.1 and use these soils to fill the
Acid Pond. Additional soil cover will be added to the
low-level radioactive landfill to improve drainage and
prevent water from ponding in the low areas on the
existing cover. The additional cover would consist of a
24-inch clay and a six-inch topsoil layer.
Table 3.11.1.5
Cost Estimate, Remedial Alternative SS2
24 Inch Clay Cover
Item Description
Quantity
Unit
Cost/Unit
Cost*
Capital Costs
Field Overhead and Oversight
month
$8,967
$26,901
Health and Safety
month
$6,247
$18,741
Clay Cover
42
acre
$41,200
$1,730,400
Clay Cover Radioactive Landfill
acre
$41,200
$82,400
In-Siru Stabilization
1855
cubic yard
$35
$64,925
General Equipment Mobilization and Demobilization (6%)
1
lump sum
$115,402
$115,402
Subtotal Direct Capital Costs
$2,038,769
Overhead and Profit (25%)
$509,692
Total Direct Capital Costs (Rounded to Nearest $10,000)
$2,550,000
Indirect Capital Costs
Engineering and Design (7%)
$178,500
Legal Fees and License/Permit Costs (5%)
$127,500
Total Indirect Capital Costs
$306,000
Subtotal Capital Costs
$2,856,000
Contingency Allowance (15%)
$428,400
Total Capital Costs (rounded to the nearest $10,000)
$3,280,000
O&M Costs
Vegetative Cover Inspection and Maintenance
lump sum
$38,716
$38,716
Subtotal
$38,716
Overhead and Profit (25%)
$9,679
Subtotal (Rounded to nearest $10,000)
$50,000
Administration (5%)
$2,500
Insurance, Taxes, Licenses (2.5%)
$1,250
Contingency Allowance (15%)
$7,500
Total O&M Costs (rounded to the nearest $1,000)
$61,000
30 year cost projection. Assumed discount rate per year: 8.0%
$686,725
Present Worth of O&M (rounded to nearest $ 1,000)
$687,000
Total Alternative Cost (Capital Cost plus O&M) to nearest $10,000
$3,970,000
Due to rounding, the amount in the Cost column may be slightly different than the product of the values in the
Quantity, Cost/Unit, and Factor columns.
-------
3.11.1.6 WP2: Wastewater Pond Liquids
Discharged to Wah Chang Ditch, and Fill Ponds.
Under this alternative, the water within the ponds would
be directly discharged without treatment to the Wah
Chang Ditch under the requirements of the NPDES
limits. The ponds wouJd then be filled with clean soil, if
necessary, and covered with a 24-inch compacted clay
cover. This alternative requires only 24 inches of
compacted clay to cover the pond sediments plus any
additional fill needed to raise the total cover to grade.
Table 3.1 1.6.
Cost Estimate, Remedial Alternative WP2
NPDES Discharge of Water, 24-inch Clay Cover
Item Description Quantity
Capita] Costs
Field Overhead and Oversight 3
Health and Safety 3
Surface Water Removal System ]
Backfill for Wastewater Ponds (Non-Haz slag or soils) 1 67,464
Vegetative Wastewater Pond Cover 1
General Equipment Mobilization and Demobilization (6%) 1
Unit | Cost/Unit
Cost*
month $8,967.00
month $6,247.00
lump sum $28,670.00
cubic yard $6.56
lump sum $345,330.00
lump sum $70,373.00
Subtotal Direct Capital Costs
Overhead and Profit (25%)
Total Direct Capital Costs (Rounded to Nearest $10,000)
$26,901
$18,741
$28,670
$1,098,564
$345,330
$70,373
$1,588,578
$397,145
$1,990,000
Indirect Capital Costs
Engineering and Design (7%)
Legal Fees and License/Permit Costs (5%)
Total Indirect Capital Costs
Subtotal Capital Costs
Contingency Allowance (15%)
Total Capital Costs (rounded to the nearest $10,000)
O&M Costs
Vegetative Cover Inspection and Maintenance 1
$139,300
$99,500
$238,800
$2,228,800
$334,320
$2,560,000
Year | $7,072.00
Subtotal
Overhead and Profit (25%)
Subtotal (Rounded to nearest 510,000)
Administration (5%)
Insurance, Taxes, Licenses (2.5%)
Contingency Allowance (15%)
Total O&M Costs (rounded to the nearest $1,000)
30 year cost projection. Assumed discount rate per year: 8.0%
Present Worth of O&M (rounded to nearest $ 1 ,000)
Total Alternative Cost (Capital Cost plus O&M) to nearest $10,000
$7,072
$7,072
$1,768
$10,000
$500
$250
$1,500
$12,000
$135,093
$135,000
$2,700,000
* Due to rounding, the amount in the Cost column may be slightly different than the product of the values in the Quantity,
Cost/Unit, and Factor columns.
-------
3.11.1.7 GW2: Long-term Groundwater
Monitoring. Under this alternative a deed record
prohibiting groundwater use in the Shallow, Medium,
and DeepTransmissiveZones wouldbe implemented. In
addition, a perimeter monitoring program would be
implemented to monitorthe Shallow, Medium, and Deep
Transmissive Zones. Action levels for triggering re-
evaluation of the site groundwater and subsequent
response actions would be based on the perimeter ACLs
(Alternate Concentration Limits) calculated for the
Shallow and Medium Zones, and MCLs in the Deep
Zone.' ACLs and MCLs are listed in Table 3.11.3.4,
"Groundwater Remedial Action Levels." The site
specific ACL calculations arediscussed in the Feasibility
Study Report. Tex Tin Site, Operable Unit No. J,
Appendix D.
3.11.1.7.1 Groundwater Monitoring. The monitoring
program would consist of four nestedwell sets along the
perimeter. Therewill be three wells in each nest, one to
monitor each transmissive zone. For cost estimating
purposes, it is assumed thatfour three-well nests and four
singular wells would be monitored on an annual basis for
the contaminants listed in Table 3.7.1.1, "Site Wide
Summary of Chemical of Concern." Ten existing
monitoring wells would be used for the perimeter
monitoring program, and six new wells would be
installed. Theproper well location to monitorthe down
gradient extent of groundwater contaminants will be
determined during the remedial design. In the event
groundwater monitoring indicates groundwater
contaminant concentrations are greater than
"Groundwater Remedial Actions Levels," EPA will
initiate further investigations to determine why those
concentrations have increased and then propose an
appropriate remedial response.
3.11.1.7.2 Operations and Maintenance. O&M
activities associated withthis alternative include annual
groundwater sampling to determine if a trend in the
contaminant concentrations indicates the groundwater
concentrations are exceeding the remedial action levels
listed in Table 3.11.3.4 The action levels for triggering
an additional groundwater response action for the
Shallow and Medium Transmissive Zones are based on
ACLs for industrial use. The two principal ecological
In accordance with theNCP §300.430.(e)(l)(B). "An
Alternate Concentration Limit (ACL) may be established in
accordance with CERCLA section 121(d)(2)(B)(ii)." In this
case, the use of ACLs is allowable because based upon
information contained in the RI and SRI reports, the point of
human exposure lies at or within the boundary of the facility.
contaminant sources are the Acid Pond and the Wah
Chang Ditch sediments. The Acid Pond will be isolated
and the Wah Chang Ditch Sediments will be stabilized.
Action levelsfor the Deep Transmissive Zone would be
set at MCLs. The basis for these concentrations is
explained in Section 3.10.3.4 "Groundwater."
4»
-------
Table 3.1 1.1.7
Cost Estimate, Remedial Alternative GW2
No Action with Long-Term Monitoring
Item Description Quantity Unit Cost/Unit
Cost*
Capital Costs
Health and Safety 0.25 month $6,247
Field Overhead and Oversight 0.25 month $8,967
Installation of Six New Monitoring Wells 1 lump sum $27,517
Subtotal Direct Capital Costs
Overhead and Profit (25%)
Total Direct Capital Costs (Rounded to Nearest $1,000)
$1,562
$2,242
$27,517
$31,321
$7,830
$39,000
Indirect Capital Costs
Engineering and Design (7%)
Legal Fees and License/Permit Costs (5%)
Total Indirect Capital Costs
Subtotal Capital Costs
Contingency Allowance (15%)
Total Capital Costs (rounded to the nearest $10,000)
$2,730
$1,950
$4,680
$43,680
$6,552
$50,000
O&M Costs
Groundwater Monitoring 16 sample $837.23
Subtotal
Overhead and Profit (25%)
Subtotal (Rounded to nearest $10,000)
Administration (5%)
Insurance, Taxes, Licenses (2.5%)
Contingency Allowance (15%)
Total O&M Costs (rounded to the nearest $1,000)
30 year cost projection. Assumed discount rate per year: 8.0%
Present Worth of O&M (rounded to nearest $1,000)
Total Alternative Cost (Capital Cost plus O&M) to nearest $10,000
$13,396
$13,396
$3,349
$20,000
$1,000
$500
$3,000
$25,000
$281,445
$281,000
$330,000
Notes:
* Due to rounding, the amount in the Cost column may be slightly different than the product of the values in
the Quantity, Cost/Unit, and Factor columns.
-------
3.11.1.8 AST2: OfT-SiteDisposal of Above Ground
Storage Tank Contents. Under this alternative all liquid
and solid wastes would be removed from the ASTs,
characterized, properly manifested, then transported
offsite for treatment and disposal. The tanks would then
be dismantled,decontaminated,and properly disposed cf
or recycled. This alternativewould protect human health
and the environment by removing all AST contentsfrom
the site and eliminating the potential for the wastes to
leak from the tanks and migrate. Removal of the AST
contents would achieve long-term effectiveness and
permanence by eliminating potential future exposure aid
migration of site- related contaminants. Reduction in
toxicity, mobility, and volume would be achieved by
removing the AST contents from the site and disposing
of these materials in a secure disposal facility. During
removal of the AST contents, onsite removal workers
could be exposed to contaminantsthrough direct contact
with waste materials. Such exposure could be mirimized
through the use of protective clothing and equipment.
Transportation of the AST contents over public roads to
the disposal facility is a concern due to the risk of
accidents with the potential for spillsand leaks of wastes.
Alternative AST2 is technicallyfeasible, with equipment;
labor, and disposal facilities readily available.
Demolition firms are available for the dismantling and
decontaminationof the ASTs once emptied. Scrap yards
in the site vicinity should be readily available for
scrapping of the dismantled ASTs. Since all AST
contents would be disposed of offsite, long-term O&M
measures would not be required. Institutional controls
would not be required.
Above ground storage tanks.
-------
Table 3J 1.1.8
Cost Estimate , Remedial Alternative AST2
Off-Site Disposal of Above-G round Storage Tank Contents
Item Description
Capital Costs
Field Overhead and Oversight
Health and Safety
Loading of Above-Ground Storage Tank Contents for Disposa
Decontamination and Disassembly of ASTs
Salvage Value of ASTs
Transportation to Carlyss, LA disposal facility***
Transportation to Port Arthur, TX disposal facility****
Transportation to Atascocita, Humble, TX disposal facility***
Disposal of Base Liquid and Sludge to Carlyss, LA
Disposal of Acid Oxidizer, Flammable, and Mixed Liquid to Port
Arthur
General Equipment Mobilization and Demobilization (6%)
Subtotal Direct Capital Costs
Overhead and Profit (25%)
Total Direct Capital Costs (Rounded to Nearest $10,000)
Indirect Capital Costs
Engineering and Design (7%)
Legal Fees and License/Permit Costs (5%)
Total Indirect Capital Costs
Subtotal Capital Costs
Contingency Allowance (15%)
Total Alternative Cost (rounded to the nearest $10,000)
Quantity
3
3
289,850
73
872
2
19
57
7,000
55,800
1
Unit
month
month
gallon
tank
ton
trip
trip
trip
gallon
gallon
lump sum
Cost/Unit
$8,967.00
$6,247.00
$0.35
$951.07
$-45.00
$600.00
$550.00
$350.00
$1.60
$0.25
14,042.00
Factor*
1
1
1
1
I
I
1
1
1
1
I
Cost**
$26,901
$18,741
$101,448
$69,428
($39,240)
$1,200
$10,450
$19,950
$11,200
$13,950
$14,042
$248,069
$62,017
310,000
$21,700
$15,500
$37,200
347,200
$52,080
400,000
Notes:
*The factors represent adjustments for difficulty, size, and other intangibles that will affect the work
Due to rounding, the amount in the Cost column may be slightly different that the product of the values in the Quantity
Cost/Unit, and Factor columns.
***4000 gallons of inorganic waste are transported in one trip load to Carlyss and Atascocita disposal facilities
3000 gallons of organic waste are transported in one trip load to Port Arthur facility.
-------
3.11.1.9 BLD4: Removal of Dust and All Asbestos
from Buildings and Structures, Demolition of
Buildings and Structures and On-site Disposal of
Debris. Prior to building demolition grossly
contaminated surfaces would be cleaned and all known
asbestos-containingmaterial(ACM) would be removed.
Known ACM includes pipe insulation, roof shingles and
transite wall panels. Building demolition would remove
all remaining contamination from the environment to
preclude a contaminant release from the collapse or
demolition during a storm. The demolition debris wuld
be decontaminatedandsalvaged or buried with ACM in
a hazardous waste landfill on site. The landfilkiting will
be coordinated with local officials to provicb for the best
beneficial site reuse. Contaminated soil from beneath tte
buildings would be handled in accordance with soil
remedial alternative SS2. To estimate the cost of this
alternative EPA assumed 30 percent of the soil or 4,830
cubic yards would be stabilized in the Acid Pond and
buried in the pond as backfill. BLD4 includes
demolition of the following facilities when appropriate:
o Roasting and Leaching Building
o Maintenance Building
o Change Room
o Laboratory and Office Building
o Smelter Building
o Ore Storage Building
o General (Engineering) Office
o Warehouses No. 1, No. 2, and No. 3
o Smelter Stack
o Water Tower
-------
The fundamental components and cost of each
alternative are shown in Box 3.9.1.19, "Components of
Each SL Remedial Alternative," the key ARARs for
each alternative are shown in Table 3.9.1.19 - 1, "Key
ARARs For SL Remedial Alternatives," and a
comparison of each alternative to the nine evaluation
criteria specified in the NCP is shown in Table
3.9.1.19 - 2 "SL Remedial Alternative Comparison."
3.9.1.20 Alternative SL1: No Action. Under this
alternative, no action would be taken to remove, treat, or
contain the non-NORM slag piles. Because the non-
NORM slag would be left in place, the potential for this
material to migrate would not be mitigated.
3.9.1.21 Alternative SL2: Off-Site Disposal of Non-
NORM slag. Under this alternative, the non-NORM
slag piles would be loaded into vehicles permitted to
carry hazardous wastes, and transported off sie, to EPA-
approved waste disposal facilities. Several potential
disposal facilities located in Texas, Louisiana, and
Kentucky have been identified for the disposal of the
non-NORM slag. Because all non-NORM slag would be
disposed off site, there would be no O&M activities
associated with this alternative. There are no institutiona
controls associated with this alternative.
3.9.1.22 Alternative SL3: Recycling of Selected
Slag Piles, Stabilization, or Backfilling of Remaining
Slag. Under this alternative, selected piles of the non-
NORM slag would be loaded and transportedto a metals-
recycling facility for processing. The slag piles being
considered for recycling include slag piles 2, 3, 53, and
55 (non-hazardous). After the slag is processed and the
recovered metals are sold, EPA would receive a metals
recovery fee or procesang credit depending on the mass
of metals recovered. Hazardous non-NORM slag piles
(piles 1, 11, 19, 27 through 29, 52, 56 through 58, and
62) would be placed on site under an impermeable cap.
For purposes of estimating, the assumption has been
made that the NORM slag would be placed in the Acid
Pond and stabilized insitu along with the Acid Pond
sediments or stabilized on-site and disposed of in the
Acid Pond. The remaining non-NORM slag would be
either placed into the wastewater ponds as backfill or
graded over the site and capped with the 24-inch clay
cover if the non-NORM slag. Because the non-NORM
slag would be taken off site for recycling, treated in the
Acid Pond, or used as backfill in the wastewater ponds,
no O&M activities are included with this alternative.
Slag pile on the east side of the Smelter Building.
-------
Box 3.9.1.19 Components of Each SL Remedial Alternative
Alternative SL2: Off-Site Disposal of Non-NORM slag
o Treatment Component - None
o Containment Component
Off site disposal
o Institutional Control Components - None
o Cost
Capital $19,000,000
Present Worth O&M SOOQ Annual O&M $000
Total Present Worth $ 19,000,000
Alternative SL3: Recycling of Selected Slag Pile, Stabilization or Backfllling of Remaining Slag.
o Treatment Components
Recycle metal from slag with recoverable metals.
o Containment Components
Seal hazardous non-NORM slag with an impermeable cover.
Cover non-NORM slag with topsoil and compacted clay.
o Institutional Control Components
Deed record to protect the integrity of the cap.
o Cost
Capital $970,000
Present Worth O&M $000 Annual O&M $000 No additional O&M cost
Total Present Worth $970,000 O&M activities would be included in
the Acid Pond alternative.
Alternative SL4: Stabilization and Covering of Hazardous non-NORM slag, Backfllling and Covering of Non-
NORM slag.
o Treatment Components
Stabilize hazardous non-NORM slag
o Containment Components
Cover hazardous non-NORM slag exceeding with an impermeable cover.
Cover non-NORM non-hazardous slag with a compacted clay and topsoil.
o Institutional Control Components
- Deed recond to protect the integrity of the clay and topsoil cover.
o Cost
$1,300,000
SOOO Annual O&M $000
-------
Table 3.9.1.19 - 1
Key ARARs For SL Remedial Alternatives
Requirement
Underground Injection Control (UIC) Program 40 C.F.R. Part 144,
42 USC 300(f)
40 C.F.R. Part 268, Land Disposal Restrictions
40 C.F.R. Part 264 Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities
30 TAG. Environmental Quality, Part I, Texas Natural Resource
Conservation Commission, Chapter 335, Industrial Solid Waste and
Municipal Hazardous Waste, Subchapter S, Risk Reduction
Standards.
SL1
N/A
YES
YES
YES
SL2
N/A
YES
YES
YES
SL3
N/A
YES
YES
YES
SL4
N/A
YES
YES
YES
SLS
YES
YES
YES
YES
3.9.1.23 Alternative SL4: Stabilize and Cover
Hazardous Non-NORM slag, Cover Non-Hazardous
Slag That Exceeds Slag Remedial Action Cleanup
Levels. Hazardous non-NORM slag piles that exceed
contaminant source leachate remedial action cleanup
levels (i.e. piles 1, 11,19, 27 trough 29, 52, 56 through
58, and 62) would be stabilized on site. The stabilized
hazardous non-NORM slag would be used to fill the
Acid Pond. The remaining non-hazardous non-NORM
slag would be covered with clay in accordance with soil
remedial alternative SS2. Because contaminated slag
would be buried on site above health based levels, this
alternative would also include a deed record as an
institutional control to limit the potential for future
human exposure to contaminants. The deed record
would describe the location of the stabilized aid covered
slag and provide notice to potential buyers that
excavations in those locations may cause a release of
hazardous substances. Because the non-hazardous non-
NORM slag would be placed in the Acid Pond no
additional O&M activities are included with this
remedial alternative.
3.9.1.24 Alternative SLS: Deep Well Injection of
Hazardous non-NORM slag, Placement of Non-
NORM slag. Under this alternative, the hazardous non-
NORM slag would be crushed, mixed with water, and
disposed of via deep well injection. The crushed slag
would be mixed with water from the Acid Pond,
wastewater ponds, or other sources, to achieve a 30-
percent solids slurry. The slurry would then be pumped
into the existing on-site deep injection well. At the
completion of deep well injection activities, the well
would be plugged to avoid future disturbance of the
injected wastes materials. The non-NORM slag may be
placed in the wastewater ponds as backfill, in the Acid
Pond, or graded across the site and covered with a 24
inches of compacted clay. Monitoring of the deep
injection system has been included as an O&M activity
under Acid Pond Alternative APS.
Slag pile south of smelter building.
-------
Table 3.9.1.19 - 2
SL Remedial Alternative Comparison
Criterion
Overall protection of human
health and the environment
Compliance with ARARs
Long-term effectiveness and
permanence
Reduction of toxicity. mobility,
or volume through treatment
Short term effectiveness
Implcmcnlability
Implcmcntability
Technical
Implcmcntabilily
Administrative feasibility
Implcmcnlability
Availability of services and
materials
State Acceptance
Community Acceptance
SLl
Provides no
protection of human
health or the
environment.
Does not meet
ARARs."
Not effective or
permanent.
None provided
through treatment
No associated risk
to workers and
residents.
No action required,
therefore,
technically feasible.
No action required,
therefore,
administratively
feasible.
Services and
materials are not
required.
SL2
Protection of human
health and the
environment would
be achieved by
removing slag from
the site.
Off-Site disposal
would need to
comply with
applicable
regulations.
Removal activities
and off-site disposal
at an appropriate
licensed landfill
would provide long-
term effectiveness
and permanence.
None provided
through treatment.
On-site workers
could be exposed to
waste materials or
dust in the short
term.
Equipment, labor,
and the necessary
disposal facilities
are available,
making alternative
technically feasible.
Slag would pose no
special limiting
issues associated
with off-site
disposal.
Manifesting would
be required.
All materials and
services needed for
this alternative are
routinely used in
construction
activities.
SL3
Protection should
be achieved by
stabilization and
recycling of the
slag, or by isolating
it.
Compliance with
ARARs can be
achieved by
stabilization.
Stabilized materials
would not readily
leach contaminants,
providing a long-
term effective and
permanent solution.
Stabilization would
provide a reduction
in mobility of site
contaminants, but
would increase
Workers would be
required to wear
appropriate PPE
and adhere to safe
construction
practices to
minimize short term
effects.
Alternative is
technically feasible.
Stabilization is a
proven technology.
No specialized
limits would be
required for
stabilization.
EPA-qualified
stabilization
vendors are
available.
SL4
Provides for
protection of the
environment by
stabilization and
isolation of the slag
Compliance with
ARARs can be
achieved through
isolation from
humans and the
environment.
Should be effective
if clay cover
prevents direct
contact by humans
and the environ-
ment.
Stabilization would
provide a reduction
in mobility' of site
contaminants, but
would increase
Workers would be
required to wear
appropriate PPE
and adhere to safe
construction
practices to
minimize short-term
effects.
Alternative is
technically feasible
with standard
construction
technology
No special limits or
requirements are
needed for this
alternative
Materials and EPA-
approved
contractors are
readily available.
SL5
Provides for
protection of the
environment by
isolation of the slag
Meets ARARs for
deep well injection.
Effective and
permanent if
injection well is
properly abandoned
No reduction of
toxicity. mobility,
or volume, but the
waste is isolated
from humans and
Workers would be
required to wear
appropriate PPE
and adhere to safe
construction
practices to
minimize short-
term effects.
Alternative is
technically feasible
using oil field
technology
Requires
coordination with
TNRCC for
issuance of limits
Jmited number of
vendors can supply
the technology
necessary
Other than rejecting SLl and SL5, the State did not express a preference for any of the other alternatives
While there was no specific preference for alternatives SLl through SL4. two comments were received favoring deeJ
well miection, SL5. 6 1
-------
3.9.1.25 SURFACE AND SUBSURFACE SOILS
(SS). The following alternatives were developed to
address surface and subsurface secondary and tertiay
contaminants sources soils that have concentrations of
inorganic contaminants above the remedial action
cleanup levels. The term "contaminated soil" is used in
this Record of Decision to define soil with contaminant
concentrations greater than those concentrations listed in
Table 3.11.3.1, "Soil, Sediment, Slag and Sludge
Remedial Action Cleanup Levels." The fundamental
components and cost of each alternative are shown in
Box 3.9.1.25, "Components of Each SS Remedial
Alternative"and the key ARARs foreach alternative are
shown in Table 3.9.1.25 - 1, "Key ARARs For SS
Remedial Alternatives" and a comparison of each
alternative to the nine evaluation criteria specified in the
NCP is shown in Table 3.9.1.25 - 2
.3.9.1.26 Low-Level Radioactive Landfill. The
existing Low-Level Radioactive Landfill will be include}
in all soil alternatives considered for OU1. A 24-inch
compacted clay cover topped with 6 inches of topsoil
will be placed over the landfill to improve drainage and
reduce surface water infiltration, thus adding
groundwater protection. O&M would include inspection
of the clay cover and groundwater monitoring. Because
the radioactive material would be buried on site, this
alternative would also include a deed record as an
institutional control to limit the potential for future
human exposure to contaminants. The deed record
would describe the location of the landfill and provide
notice to potential buyers that excavations in that locatim
may cause a release of hazardous substances.
Groundwater monitoring would be requiredas part of the
O&M for the Low-Level Radioactive Landfill.
3.9.1.27 Alternative SSI: No Action. Under this
alternative, no action would be taken b remove, treat, or
contain hazardous or contaminated surface and
subsurface soils. Because no action wouldbe taken for
these soils, the potential for contaminants migrating off
site or leaching to the groundwater would not be
mitigated.
3.9.1.28 Alternative SS2: Cover Soils Exceeding
Soil Remedial Action Cleanup Levels - Stabilize and
Cover Soils That Exceed Contaminant Source
Leachate Remedial Action CleanupLevels. Under this
alternative, soils exceeding the soil remedial action
cleanup levels in Table 3.11.3.1, "Remedial Action
Cleanup Levels," but not exceeding leachate
concentrations in Table 3.11.3.1 would be covered with
a 24-inch compacted clay cover and topped with six
inchesof topsoil.This alternative would also include the
Low-Level Radioactive Landfill area. Thetopsoil would
be seeded with native grass chosen for long-termerosion
control. Approximately44 acres would be covered with
the clay cover. Soils exceeding contaminant source
leachate remedial action cleanup levels in Table 3.11.3. \
"Soil Sediment, Slag and Sludge Remedial Action
Cleanup Levels," would be stabilized and used to fill the
Acid Pond. Because contaminatedsoils would be buried
on site above health based levels, this alternative would
also include a deed record as an institutional control to
limit the potential for future human exposure to
contaminants. This remedial alternative also applies to
any contaminated soils found beneath buildings
demolished as part of remedial alternative BLD4. The
deed record would describe the location of the
contaminated soils and provide notice to potential buyeis
that excavations in that location may cause a release of
hazardous substances. Consequently, future site
development would require EPA's evaluationto ensure
construction activities are conducted safely and that the
cover remains protective. O&M activitiesassociated with
this alternative would include clay cover inspection and
maintenance.
Table 3.9.1.25 - 1
Key ARARs For SS Remedial Alternatives
Requirement
Underground Injection Control (UIC) Program 40 C.F.R. Part 144, 42 USC 300(0
40 C.F.R. Part 268. Land Disposal Restrictions
40 C.F.R. Part 264 Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and
Disposal Facilities
30 TAC. Environmental Quality, Pan I, Texas Natural Resource Conservation Commission, Chapter 335.
Industrial Solid Waste and Municipal Hazardous Waste. Subchapter S, Risk Reduction Standards.
SSI
N/A
YES
YES
YES
SS2
N/A
YES
YES
YES
SS3
N/A
YES
YES
YES
SS4
N/A
YES
YES
YES
SSS
YES
YES
YES
YES
-------
Box 3.9.1.25 Components of Each SS Remedial Alternative
Alternative SS2: Cover Soils Exceeding Soil Remedial Action Cleanup Levels - Stabilize and Cover Soils That
Exceed Contaminant Source Leachate Remedial Action Cleanup Levels.
o Treatment Component
Stabilize soils exceeding contaminant source leachate remedial action cleanup levels and dispose of them with the stabilized
acid pond soils
o Containment Component
Cover contaminated soils which do not leach contaminants with concentrations exceeding contaminant source leachate levels
but exceed human health risk levels.
o Institutional Control Components
Deed recordation to protect the integrity of the clay cover.
o Cost
Capital $3,280,000
Present Worth O&M S 687.000 Annual O&M $61,000
Total Present Worth $3,967,000
Alternative SS3: On-site Stabilization of Hazardous and Contaminated Soils
o Treatment Components
Stabilize hazardous soils
o Containment Components
Cover stabilized soils-with topsoil cover.
o Institutional Control Components
Deed recordation to protect the integrity of the topsoil cover.
o Cost
Capital $34,720,000 Annual O&M $61,000
Present Worth O&M $687.000
Total Present Worth $35,407,000
Alternative SS4: Excavation and Consolidation of Hazardous or Contaminated Soils On Site.
o Treatment Components - None
o Containment Components
Excavate hazardous soils and use them to backfill acid pond then cover the pond with compacted clay.
Cover contaminated soils with topsoil and compacted a clay.
o Institutional Control Components - None.
o Cost
Capital $6,710,000
Present Worth O&M $.000 Annual O&M $000 No additional cost to acid pond O&M
Total Present Worth $6,710,000
Alternative SSS: Deep Well Injection of Hazardous Soil, Cover Contaminated Soils With Compacted Clay.
o Treatment Components - None
o Containment Components '
Deep well injection for hazardous soils
Cover contaminated soils with topsoil and compacted clay.
o Institutional Control Components
Deed recordation to protect the integrity of the clay / topsoil cover.
o Cost
Capital $3,210,000
Present Worth O&M $687.000 Annual O&M $61,000
Total Present Worth $3,897,000
-------
Table 3.9.1.25 - 2
SS Remedial Alternative Comparison
Criterion
Overall protection of
human health and the
environment
Compliance with
ARARs
Long-term
effectiveness and
permanence
Reduction of toxici-
ty, mobility, or
volume through
treatment
Short-term
effectiveness
Implemcntability
Implementability
Technical
Implementability
Administrative
Implementability
Availability of
services and
materials
State Acceptance
Community
Acceptance
SSI
Provides no protec-
tion of human health
or the environment.
Does not meet
ARARs.
Not effective or
permanent.
Provides no reduction
of waste toxicity,
mobility, or volume.
No associated risk to
workers. Nearby
residents could be
affected by continued
off-site migration of
wastes.
No action required.
therefore, technically
feasible.
No action required,
therefore,
administratively
feasible.
Services and
materials are not
required.
SS2
Protection provided
by preventing direct
contact through
stabilizing and
covering hazardous
soils. However,
contamination would
remain in place.
In compliance with
ARARs
Stabilized materials
would not readily
leach contaminants,
providing a long-term
effective and
permanent solution.
Reduction in surface
mobility is achieved
and volume would be
increased.
Grading and cover
placement could
cause exposure in the
short term. Dust
control measures
would be required.
Covering is an
established
construction
procedure.
Future site
development may
require special
limiting. Deed
recordations would be
required.
AH materials and
services needed for
this alternative are
routinely used in
construction
activities.
SS3
Protection is achieved
by stabilizing
contaminated site
soils. Cover would
prevent direct contact
with stabilized mate-
rial.
Stabilization of
hazardous soils could
meet the ARARs
Stabilized materials
would not readily
leach contaminants,
providing a long-term
effective and
permanent solution.
Stabilization would
provide a reduction in
mobility of site
contaminants, but
would increase the
volume.
Workers would be
required to wear
appropriate PPE and
adhere to safe
construction practices
to minimize short-
term effects.
Stabilization of soil to
fix metal
contamination is well
documented and
technically feasible.
No specialized limits
would be required for
stabilization. Deed
recordation would be
required.
EPA-qualified
vendors are available.
SS4
Protection provided
by preventing direct
contact through
covering hazardous
and contaminated
soils. However.
contamination would
remain in place.
Compliance with
ARARs achievable
with institutional
controls
Provides long-term
effectiveness when
combined with
institutional controls.
Reduction in surface
mobility is achieved.
Toxicity and volume
unchanged, but
hazardous soils are
isolated from the
environment
Excavation, grading
and cover placements
could cause short-
term exposure. Dust
control measures
would be required.
Excavation and
consolidation is an
established
construction
procedure.
Deed recordations
would be required.
All materials and
services needed for
this alternative are
routinely used in
construction
activities.
SS5
Protection provided by
isolating the
hazardous soil from
humans and the
environment
Waste meets ARARs
compliance criteria
Provides long tern
effectiveness with
proper deep well
injection abandonment
Reduction in surface
mobility is achieved.
Toxicity unchanged.
but hazardous soils are
isolated from the
environment.
Excavation, grading.
slurry mixing, and
cover placements
could cause short-term
exposure. Dust control
measures would be
required
Technically feasible
using oil field
technology
Coordination with
TNRCC would be
required
Limited vendors can
supply this technology
Along with rejecting SS 1 and SS5, the State expressed a preference to include a cover over the radioactive landfill with each of
the alternatives. However the State did not express a preference for any of the remaining alternatives.
While there was no specific preference for alternatives SSI through SS4. two comments were received favoring deep well
injection. SS5. In addition one comment was received rejecting all soil stabilization.
-------
3.9.1.29 Alternative SS3: On-site Stabilization of
Soils. Under this alternative, all surface and subsurface
soils exceeding remedial action cleanup levels would be
treated on site by an in situ stabilization process. The
stabilized soil would immobiliz the metal contaminants
and reduce the teachability of the waste. For cost
estimation purposes, it has been assumed that in situ
stabilization would be performed. The volume of soil
requiring treatment is estimated at 549,800 cubic yards.
Upon the completion of in situ stabilization, the area
would be covered with a 6-inch topsoil layer that would
be seeded with native grass chosen for long-termerosion
control capabilities. The topsoil cover would be
designed for stormwater management. Also included
with this alternative, would be placement of a 24-inch
clay cover and 6-inch topsoil layer over the Low-Level
Radioactive Landfill. Institutional controls in the form cf
deed recordations would be required to prevent
disturbance of the vegetative cover, treated soils, and
Low-Level Radioactive Landfill. Future redevelopment
of the site would require a reevaluation of the
protecti veness of the vegetative layer, based on projectd
land use. O&M activities included withthis alternative
include inspection and maintenance of the vegetative
layer and clay cover for the Low-Level Radioactive
Landfill. Groundwater monitoring would also be
included for the Low-Level Radioactive Landfill.
3.9.1.30 Alternative SS4: Excavation and
Consolidation of Soils Exceeding Remedial Action
Cleanup Levels On Site. Under this alternative, soils
exceeding remedial action cleanup levels would be
excavated and consolidated on site in either the Acid
Pond or Area C. While soils may be consolidated
elsewhere on-site, these areas have been chosen for
estimating purposes. Soils that exceed contaminant
source leachate remedial action cleanuplevels would be
disposed in the Acid Pond; soils exceeding remedial
action cleanup levels but not the contaminant source
leachate remedial action cleanup levels would be
consolidated in Area C. The volume of soil excavated
would be 285,900 cubic yards. Soils exceeding remedid
action cleanup levels would be excavated, placed in
trucks, and transported to Area C. The excavated areas
would be backfilled with clean compacted fill materials
from off-site sources or on-site materials that do not
exceed remedial action cleanup level concentrations.
Area C, where soils exceeding remedial action cleanup
levels would be consolidated, would be graded and
covered with 24 inches of compacted clay common fill
and topped with a 6-inch topsoil layer. The compacted
clay cover would also be placed over the Low-Level
Radioactive Landfill area. The portion of Area C to be
covered under this alternative will be approximately 18
acres. The costs associated with sealing the Acid Pond
with an impermeablecoverare includedin the Acid Pond
alternatives. The O&M activities associated with this
alternative would include clay cover inspection and
maintenance. Groundwater monitoring would be
included for the Low-Level Radioactive Landfill. Deed
recordations would be required to prevent potential
exposure to site contaminants.
3.9.1.31 Alternative SS5: 24-Inch Clay Cover on
Non-hazardous Soils Exceeding Remedial Action
Cleanup Levels; Deep Well Injection of Hazardous
Soils. Under this alternative, soils that exceed
contaminant source leachate remedial action cleanup
levels would be excavated and deep well injected Other
soils exceeding remedial action cleanup levels but not
contaminant source leachate remedial action cleanup
levels would be covered with 24 inches of compacted
clay. For estimation purposes, it has been assumed that
the non-hazardous soils exceeding remedial action
cleanup levels would be consolidated in Area C.
Excavated areas wmld be backfilled with clean soil and
graded. Soils exceeding remedial action cleanup levels
would be consolidated in Area C, covered with24 inches
of compacted clay fill and topped with a 6-inch topsoil
layer. The Low-Level Radioactive Landfill would also
be covered with 24 inches of compacted clay fill and
topped with a 6-inch topsoil layer. Approximately 18
acres in Area C would be covered. Deed records would
be required for covered areas exceeding remedial action
cleanup levels and the Low-Level Radioactive Landfill.
Remediation of OU1 would be suitable for industrial
redevelopment. Deed records would be required for the
deep injection well following closure. O&M activities
associated with this alternative would include cover
inspection and maintenance. Monitoringof thedeep well
injection zone would be included under the deep well
injection alternative. Groundwater monitoring of the
Shallow, Medium, and Deep transmissive zones would
be required for the Low-Level Radioactive Landfill.
-------
3.9.1.32 WASTEWATER PONDS (WP). The
following alternatives were developed to address on-
site water and sediments in Wastewater Ponds 1
through 5 which are identified in the site conceptual
model as primary and tertiary contaminant sources.
The analytical results of sediment samples collected
during the Phase II RI indicate that the wastewater
pond sediments contain heavy metals at concentration
exceeding the remedial action cleanup levels. Since
EPA does not consider pond water or sediments to be
principal threats, there is no preference for treatment.
Heavy metal concentrations in the pond water appear
to be below the NPDES discharge limits, whidi would
allow direct discharge to the Wah Chang Ditchas long
as the maximum allowable flowrate was not exceeded
The following alternatives focus on discharging the
pond water to the Wah Chang Ditch and treating or
containing the pond sediments. The fundamental
components and cost of each alternative are shown in
Box 3.9.1.32, and the key ARARs for each alternative
are shown in Table 3.9.1.32 - 1. A comparison of each
alternative to the nine evaluation criteria specified in
the NCP is shown in Table 3.9.1.32 - 2.
Slag pile in Area B.
Box 3.9.1.32 Components of Each WP Remedial Alternative
Alternative WP2: NPDES Discharge of Water, 24-Inch Clay Cover
o Treatment Components
None
o Containment Components
Clay and topsoil cover over the pond sediments
o Institutional Control Components - None.
o Cost
Capital $2,560,000
Present Worth O&M SI35.000 Annual O&M $12,000
Total Present Worth $2,695,000
Alternative WP3: NPDES Discharge of Water, Sediment Stabilization
o Treatment Components
Stabilize pond sediments. Stabilization treatment mixes treatment agents into the contaminated sediments to
reduce the contaminant solubility.
P Containment Components
Topsoil cover over the stabilized sediments
o Institutional Control Components - None.
Cost
Capital
Present Worth O&M
Total Present Worth
$11,940,000
$135.000
$12,075,000
Annual O&M $12,000
-------
Table 3.9.1.32 - 1
Key ARARs For Wastewater Pond (WP) Remedial Alternatives
Requirement
40 C.F.R. Parts 122 to 125, National Pollutant Discharge Elimination System (NPDES)
40 C.F.R. Part 268, Land Disposal Restrictions
40 C.F.R. Part 264 Standards for Owners and Operators of Hazardous Waste Treatment, Storage,
and Disposal Facilities
30 TAG. Environmental Quality, Part I, Texas Natural Resource Conservation Commission,
Chapter 335, Industrial Solid Waste and Municipal Hazardous Waste, Subchapter S, Risk
Reduction Standards.
WP1
YES
YES
YES
YES
WP2
YES
YES
YES
YES
Criterion
Overall protection of human health
and the environment
Compliance with ARARs
Long-term effectiveness and
permanence
Reduction of toxicity, mobility, or
volume through treatment
Short-term effectiveness
Implcmcntability
Implcmentability
Technical
Implcmcntability
Administrative
Implementability
Availability of services and
materials
State Acceptance
Community Acceptance
Table 3.9.1.32 - 2
WP Remedial Alternative Comparison
WPl
Provides no protection of human
health or the environment.
Does not meet ARARs.
Not effective or permanent.
Provides no reduction of waste
toxicity. mobility', or volume.
No associated risk to workers.
Nearby residents may be affected
by continued off-site migration of
waste.
No action required, therefore,
technically feasible.
No action required, therefore,
administratively feasible.
Services and materials are not
required.
WP2
Protection provided by preventing
direct contact through covering
pond sediments. However,
contamination is left on site
untreated.
Discharge to ditch must comply
with NPDES permit limits.
Provides long-term effectiveness.
Does not alter toxicity or volume
of waste. Surface mobility of
waste reduced.
Short-term effects may include
worker exposure to pond
sediments during cover placement.
Pumping of water and cover
construction are established
construction practices.
No anticipated problems
achieving NPDES limits.
Cover materials, construction
equipment are readily available.
WP3
Alternative is protective of human
health and the environment since
contaminants are solidified.
Contaminated media is stabilized.
Cover and stabilization
provide for long term
effectiveness and
permanence.
Provides a reduction in waste
mobility, but volume is
increased.
Short-term effects include
potential worker exposure to
stabilization reagents and dust
Treatability studies may be
required for stabilization process.
Pumping of water and cover
construction are established
No anticipated problems
achieving NPDES limits.
EPA-qualified vendor for
stabilization process is available.
Cover construction and water
discharge can be performed by
Along with rejecting WPl, the State did not express a preference for either WP2 or WP3
While there was no specific preference for alternatives WPl through WP3
-------
3.9.1.33 Alternative WP1: No Action. Under this
alternative, no action would be taken to remove, treat, or
contain the water and sediments contained in Wastewabr
Ponds 1 through 5. Because contaminated media would
be left in place, the potential for off-site contaminant
migration would not be mitigated.
3.9.1.34 Alternative WP2: NPDES Discharge of
Water, 24-Inch Clay Cover. Under this alternative, the
pond water would be analyzed to confirmthat it could be
directly discharged without treatment to the Wah Chang
Ditch in accordancewith the requirementsof the NPDES
permit. Once empty, the pond berms would be leveled
to the grade of the surrounding site. Once an even grade
was achieved, a clay cover consisting of 24 inches of
compacted common clay fill would be constructed over
the former pond area and topped with a 6-inch topsoil
layer. The topsoil layer would be seeded with grass to
provide for erosion control. If more than 24 inches of
compacted clean clay fill is needed to bring the pond
level to grade, then only the 6-inch topsoil layer would
be needed. The intent is to provide 24 inches of clean
compacted clay fill over contaminated materials that
exceed the site remedial action cleanup levels. If this is
achieved in part by adding clean fillto bring the ponds to
grade, the additional 24-inch clay coveris not required.
The O&M activities associated with this alternative
would include the inspectionof the compacted clay cover
and maintenance of the vegetative layer. Because
contaminated sediments would beburied on site above
health based levels, this alternative would include a ded
record as an institutional control to limitthe potential for
future human exposure to contaminants. The deed recoil
would describe the location ofthe covered contaminants
and provide noticeto potential buyers that excavations h
that location may cause a release of hazardous
substances.
3.9.1.35 Alternative WP3: NPDES Discharge of
Water, Sediment Stabilization. Under this alternative,
the water within the ponds would be directly discharged
without treatment to the Wah Chang Ditch under the
requirements of the NPDES limits. Treatment of the
wastewaterpond sediment would consist of stabilization
Stabilization treatment mixes treatment agents into the
contaminated sediments to reduce the contaminant
solubility. After all stabilization was completed, the
berms would be graded and common fill would be
added, if necessary, to fill in voids and to bring the
former ponds to an even grade with the rest ofthe site.
Upon the completion of stabilization, the former
wastewater ponds would be covered with a 6-inch topsol
layer, which would be seeded with grasschosen for long-
term erosion control capabilities. The O&M activities
associated with this alternati\e would include inspection
and maintenance of the vegetative layer. Because
contaminated sediments, although trated, would remain
on-site, this alternative would also include institutional
controls in the form of deed records to prevent
disturbance of stabilized sediments or unsafe site
development that could expose future site workers to
contaminants.
Ore pile inside smelter building.
-------
3.9.1.36 GROUND WATER (GW). The results of
the Phase II RI and the SRI show that groundwater isa
secondary contaminant source and a low level threat.
Since the most likely potential future use of the Shallow
and Medium TransmissiveZones would be for induirial
use the site groundwater RAOs include preventing
further degradation of the Shallow and Medium
TransmissiveZones off sife and preventing migration of
contaminated groundwater to the Deep Transmissive
Zone off site. This includes preventing discharge of
groundwater contaminants to off-site ponds at
concentrations that would impact ecological receptors.
The fundamental components and cost of each alternative
are shown in Box 3.9.1.36, "Components of Each GW
Remedial Alternative" and the key ARARs for each
alternative are shown in Table 3.9.1.3 6 -1, "Key ARARs
For GW Remedial Alternatives" and a comparison of
each alternative to the nine evaluation criteria specified
in the NCP is shown in Table 3.9.1.36 - 2, "GW
Remedial Alternative Comparison."
Box 3.9.1.36 Components of Each GW Remedial Alternative
Alternative GW2: Long-Term Monitoring
o Treatment Components - None
o Containment Components - None
o Groundwater Monitoring
Installing monitoring wells to provide perimeter monitoring to ensure groundwater does not exceed alternate
concentration limits
o Institutional Control Components
- Deed records to prevent on-site use of the Shallow, Medium and Deep Transmissive Zone groundwater.
o Cost
Capital $50,000
Present Worth O&M $281.000 Annual O&M $25,000
Total Present Worth $331,000
Alternative GW3: Extraction Well System, Filter Press-GAC Treatment System
o Treatment Components
Granulated activated carbon (GAC) treatment to remove contaminants from the groundwater.
Stabilization for sediments and sludge
o Containment Components
Geomembrane wall to prevent groundwater from recharging the acid pond.
o Institutional Control Components - None.
o Cost
Capital $430,000
Present Worth O&M $1.238.000 Annual O&M $110,000
Total Present Worth $ 1,668,000
-------
Table 3.9.1.36 - 1
Key ARARs For GW Remedial Alternatives
Requirement
40 C.F.R. Parts 122 to 125, National Pollutant Discharge Elimination System (NPDES)
40 C.F.R. Part 300, §430(e)«)F, National Contingency Plan, Alternate Concentration
Limits
30 TAC. Environmental Quality, Part I, Texas Natural Resource Conservation
Commission, Chapter 335, Industrial Solid Waste and Municipal Hazardous Waste,
Subchapter S, Risk Reduction Standards.
GW1
YES
YES
YES
GW2
YES
YES
YES
GW3
YES
YES
YES
Criterion
Overall protection of human health
and the environment
Compliance with ARARs
Long-term effectiveness and
permanence
Reduction of toxicity, mobility, or
volume through treatment
Short-term effectiveness
Implementability
Implementability
Technical
Implementability
Administrative
Implementability
Availability of services and
materials
State Acceptance
Community Acceptance
3.9.1.36-2
GW Remedial Alternative Comparison
GWI
Provides no protection of human
health or the environment
Does not meet ARARs in the three
transmissive zones.
Not effective or permanent.
Provides no reduction in
groundwater toxicity or mobility.
Does not reduce volume of
contaminants in groundwater.
No associated risk to workers and
residents.
No action required, therefore,
technically feasible.
No action required, therefore,
administratively feasible.
Services and materials are not
required.
GW2
Provides protection of human
health and environment by
restricting groundwater use.
The monitoring well network will
be designed to demonstrate :
compliance with ARARs at the
perimeter in the Deep Transmissive
Zone and with ACLs in the shallow
and medium zones at the perimeter.
Deed records are effective in
preventing groundwater use.
Provides no reduction in
groundwater toxicity or mobility.
Does not reduce volume of
contaminants in groundwater.
Short-term potential exposure
during groundwater monitoring
sampling.
Groundwater monitoring and deed
records are feasible. Monitoring
well installation is feasible.
Deed record would require
administration, but feasible.
Groundwater monitoring services
readily available. Monitoring well
materials, equipment and
contractors are readily available.
GVV3
Achieves protection by extracting
and treating contaminated
groundwater.
Compliance with ARARs would
be achieved both on and off site.
Extraction and treatment of
groundwater is a long-term
effective and permanent solution.
Achieves a reduction in toxicity,
mobility, and volume of
groundwater contaminants through
treatment.
Short-term potential exposure
associated with extraction well
installation and operation of
treatment facility.
Groundwater extraction and filter
press - GAC systems appear
suitable to remove metals and
VOCs from extracted
groundwater.
No anticipated problems achieving
NPDES limits with filter press -
GAC treatment system.
Limited vendors would install and
operate treatment system.
Other than rejecting GW 1 . the State indicated a preference for G W3 over GW2 .
While there was no specific preference for any of the alternatives, there was one comment received critical of
EPA's groundwater investigation.
3.9.1.37 Alternative GWI: No Action. Under this
alternative,no action would be taken t> remove, treat, or
contain site groundwater. Because contaminated
groundwater would not be treated, the potential for off-
-------
site contaminant plume migration would not be
mitigated.
3.11.3.4, "Groundwater Remedial Action Cleanup
Levels."
3.9.1.38 Alternative GW2: Long-Term
Monitoring. Under this alternative, a long-term
perimeter groundwater monitoring program in the
Shallow, Middle, and Deep Transmissive Zones would
be implemented. This would ensure no further off-site
migration of contamination after the source control
remedy is implemented. A deed record would provide
notice to landowners that groundwater remains
contaminated and would notify landowners that contact
with untreated groundwater may pose an unacceptable
risk or hazard to site workers. The record would also
prevent the use of the shallow, medium, and deep
groundwater. The monitoring progiam would consist of
four nested wells sets along the perimeter. There will be
three wells in each nest, one to monitor each transmissi\e
zone. For cost estimating purposes, it is assumed that
four three well nests and four singular wells would be
monitored on an annual basis for fie contaminants listed
in Table 3.1 1 .3.4. Ten existing monitoring wells would
be used for the perimeter monitoring program, and six
new wells would be installed. During the remedial
design EPA will determine the best locations to monitor
the down gradient contamination. O&M activities
associated with this alternative include annual
groundwater sampling and assessing the condtion of the
monitoring wells. The action levels triggering additional
groundwater response actions for the Shallow, Medium
and Deep Transmissive Zones are shown in Table
3.9.1.39 Alternative GW3: Extraction Well
System, Filter Press-GAC Treatment System. Under
this alternative, groundwater would be pumped to the
surface using an extraction well system, treated on-site,
and discharged to the Wah Chang Ditch under the
NPDES limits. The number, locations, and depths of
extraction wells would be determined during the
remedial design phase based upon the results of
groundwater modeling. This alternative would prevent
further migration of contaminants in the Shallow and
Medium Transmissive Zones off site or vertically
downward. For this alternative, it was assumed that the
treatment system used for treating the Acid Pond would
be modified for use in treating contaminated
groundwater. The main modification would consist of
downsizing the system to treat a lower flow rate. It is
anticipated that the Acid Pond liquid treatment system
would operate at a flow rate in the range of 100 to 300
gpm, whereas the groundwater treatment system would
operate at approximately 1 0 gpm. O&Mactivities would
include operation of the extraction well and treatment
system, as well as a perimeter ground water sampling ad
monitoring program similar to what is described in
Alternative GW2, plus an On-site sampling program to
monitor the progress of the cleanup. Institutional
controls in the form of deed records would be required to
prevent the installation or use of on-site water wells in
the Shallow, Medium, and Deep Transmissive Zones.
3.9.1.40 ABOVEGROUND STORAGE TANKS
(ASTs). Above ground storage tanks contain
approximately 289,850 gal Ions of hazardous waste (see
Section 3.5.26, "Types of Contamination and the
Affected Media") considered to be a principal threat
waste. The fundamental components and cost of each
alternative are shown in Box 3.9.1.40, "Components of
Each AST Remedial Alternative" and the key ARARs
for each alternative are shown in Table 3.9.1.40 -1, "Key
ARARs for AP Remedial Alternatives," and a
comparison of each alternative to the nine evaluation
criteria specified in the NCP is shown in Table
3.9.1.40 - 2, "AST Remedial Alternative Comparison."
3.9.1.41 Alternative AST1: No Action. Under this
alternative.no action would be taken t> remove, treat, or
contain the AST contents. The potential for spills and
leaks of the AST contents would not be mitigated.
3.9.1.42 Alternative AST2: Off-Site Disposal of
AST Contents. Facilities in Texas, Louisiana, and
Kentucky have been identified as potential locations for
AST wastes disposal. Individual waste streams would be
manifested, and then transported off-site for treatment
and disposal. Empty ASTs would be dismantled,
decontaminated,and recycled at an off-site scrap yard or
disposed of off site. Because all AST contents would be
disposed of off site, there wouldbe no O&M activities or
institutional controls associated with this alternative.
-------
Box 3.9.1.40 Components of Each AST Remedial Alternative
Alternative AST2: Off-Site Disposal of AST Contents
o Treatment Components - None
o Containment Components
Off-Site disposal.
o Cost
Capital $400,000
Present Worth O&M $ OOP
Total Present Worth $400,000
Annual O&M $000
Alternative AST3: Off-Site Disposal of Organic Wastes, Treatment of Inorganic Wastes.
o Treatment Components
Stabilizing inorganic waste
o Containment Components
- Off-Site disposal
Bury the stabilized inorganic wastes on-site with the stabilized acid pond sediments beneath a clay cover.
o Institutional Control Components
Deed Record.
o Cost
Capital $370,000 Annual O&M $000 No additional cost to acid pond O&M.
Present Worth O&M $000
Total Present Worth $370,000
Alternative AST4 Deep Well Injection of AST Contents.
o Treatment Components - None
o Containment Components
Cover drum contents in the acid pond with a clay cover.
o Institutional Control Components - None.
o Cost
Capital $390,000
Present Worth O&M $.000 Annual O&M 000
Total Present Worth $390,000
No additional cost to acid pond Q&M.
Table 3.9.1.40 - 1
Key ARARs For AST Remedial Alternatives
Requirement
Underground Injection Control (UIC) Program 40 C.F.R. Part 144, 42 USC 300(f)
40 C.F.R. Part 268, Land Disposal Restrictions
40 C.F.R. Part 264 Standards for Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities
30 TAG. Environmental Quality, Part I, Texas Natural Resource Conservation
Commission, Chapter 335, Industrial Solid Waste and Municipal Hazardous Waste,
Subchapter S, Risk Reduction Standards.
AST1
N/A
YES
YES
YES
AST2
N/A
YES
YES
YES
AST3
N/A
YES
YES
YES
AST4
YES
YES
YES
YES
-------
Criterion
Overall protection of
human health and (he
environment
Compliance with ARARs
Long-term effectiveness
and permanence
Reduction of toxicity,
mobility, or volume
through treatment
Short-term effectiveness
Implcmemability
Implementability
Technical
Implementability
Administrative
Implementability
Availability of services and
materials
State Acceptance
Community Acceptance
Table 3.9.1.40 -2
AST Remedial Alternative Comparison
ASTI
Provides no protection of
human health or the
environment.
Does not meet ARARs.
Not effective or
permanent.
None through treatment
No associated risk to
workers.
No action required,
therefore, technically
feasible.
No action required,
therefore, administratively
feasible.
Services and materials
would not be required.
AST2
All AST contents would
be removed from site,
providing protection of
human health and the
environment.
Disposal of AST contents
would be conducted in
accordance with RCRA
and other Federal, state,
and local requirements.
Removal action provides
long-term effectiveness
and permanence.
None through treatment
Worker exposure to AST
contents could pose
potential short-term risks.
AST demolition, waste
hauling, and disposal are
common industrial
practices.
Manifesting would be
required. Alternative is
administratively feasible.
No specialized
equipment, labor, or
materials would be
required. Scrap yards and
disposal facilities have
the necessary capacity.
AST3
Off-Site disposal
accompanied with waste
treatment would provide
protection of human health
and the environment.
Disposal of organic AST
contents would have to
comply with applicable
regulations. Stabilization
of inorganic wastes meets
ARAR criteria.
Long-term effectiveness
and permanence would be
provided
None through off site
disposal, however on-site
stabilization of inorganic
waste would reduce waste
toxicity and mobility, but
not volume.
On-site workers could be
exposed to waste materials
in the short term.
Activities associated with
AST demolition, off-site
disposal, and waste
treatment are established
industrial practices.
Manifesting would be
required for off-site
disposal. Alternative
would be administratively
feasible.
Labor and equipment
associated with both off-
site disposal and treatment
of wastes is available.
AST4
Deep well injection would
provide protection of
human health and the
environment
Deep well injection is in
compliance with ARARs
Long-term effectiveness
and permanence would be
provided by isolating the
waste from the
No reduction in toxicity,
mobility, or volume and
mobility of inorganic
wastes.
On-site workers could be
exposed to waste
materials in the short
term. Potential spills and
leaks of organic AST
waste during transport.
Slurry mixing operations
could expose workers.
Technically feasible using
oil field technology.
Coordination with
TNRCC would be
required.
Limited vendors can
supply this technology.
Other than rejecting ASTl and AST4, the State did not expressed a preference to any of the other alternatives
While there was no specific preference for alternatives ASTl through AST3. two comments were received favorine deeo
well injection. AST4.
4»
-------
3.9.1.43 Alternative AST3: Off-Site Disposal of
Organic Wastes, Treatment of Inorganic Wastes.
Under this alternative, ASTs containing organic liquid
and sludge would be emptied and the contents properly
disposed of off site. Those ASTs with inorganic liquid
and sludge concentrations exceeding the soil, sediment
and sludge contaminant leachate remedial action clanup
levels would be emptied and their contents treated and
disposed of on-site. Liquids requiring treatment would
be treated along with he Acid Pond liquid. Sludge from
these ASTs would be stabilized and used to fill the Acid
Pond. Empty ASTs would be dismantled,
decontaminated,and recycled at an off-site scrap yard or
landfilled on site. Because the AST organic contents
would be disposed of off site and the inorganic materials
treated along with the Acid Pond sediments, O&M
activities and institutional controls are not required for
this alternative.
3.9.1.44 Alternative AST4: Deep Well Injectbn of
AST Contents. Under this alternative, ASTs would be
emptied, and their contents mixed with water to create a
30 percent solids slurry (if necessary) for deep well
injection. Empty ASTs would be dismantled,
decontaminated, and recycled at an off-site scrap yard.
Because monitoring of the deep well injectionzone has
been included under Alternative APS, O&M activities
have not been included in this alternative. There are no
institutional controls associated with this alternative.
3.9.1.45 BUILDINGS AND STRUCTURES
ALTERNATIVES. Site buildings are contaminated
with spills and dust from the smelting process creating a
principal threat. Eleven buildings remain in the Process
Area, many of which contain or are covered with
asbestos-containing materials (ACM). The
fundamental components and cost of each altanative are
shown in Box 3.9.1.45, "Components of Each BLD
Remedial Alternative" and the key ARARs for each
alternative are shown in Table 3.9.1.45 - 1, "Key ARARs
For BLD Remedial Alternatives," and a comparison of
each alternative to the nine evaluation criteria specified
in the NCP is shown in Table 3.9.1.45 - 2, "BLD
Remedial Alternative Comparison."
Inside the Smelter Building.
Table 3.9.1.45 - 1
Key ARARs For BLD Remedial Alternatives
Requirement
40 C.F.R. Part 264 Standards for Owners and Operators of Hazardous Waste Treatment,
Storage, and Disposal Facilities
40 C.F.R. Part 268, Land Disposal Restrictions
40 C.F.R. Part 40 Part 61.145, Asbestos Standards for Demolition and Renovation
30 TAG. Environmental Quality, Part I, Texas Natural Resource Conservation
Commission, Chapter 335, Industrial Solid Waste and Municipal Hazardous Waste,
Subchapter S, Risk Reduction Standards.
BLD I
YES
YES
YES
YES
BLD2
YES
YES
YES
YES
BLD3
YES
YES
YES
YES
BLD4
YES
YES
YES
YES
-------
Box 3.9.1.45 Components of Each BLD Remedial Alternative
Alternative BLD2: Asbestos Removal
o Treatment Component - None
o Containment Component
Asbestos disposal in off site landfill.
o Institutional Control Components - None
o Cost
Capital $3,170,000
Present Worth O&M $000
Total Present Worth $3,170,000
Annual O&M None, all asbestos removed off site.
Alternative BLD3: Asbestos Removal and Building Demolition, Off-Site Disposal Alternative
o Treatment Components - None
o Containment Components
Asbestos and building debris disposal in off site landfill.
o Institutional Control Components - None
o Cost
Capital $19,750,000
Present Worth O&M $000 Annual O&M None all asbestos and debris removed off site.
Total Present Worth $19,750,000
Alternative BLD4: Asbestos Removal and Building Demolition with On-site Disposal
o Treatment Components - None
o Containment Components
Asbestos and building debris disposed of in an on-site landfill.
o Institutional Control Components - None
o Cost
Capital $11,940,000
Present Worth O&M $11.000 Annual O&M $1,000
Total Present Worth $11,951,000
Slag pile. Smelter building in the background.
-------
Table 3.9.1.45 - 2
BLD Remedial Alternative Comparison
Criterion
Overall protection of
human health and the
environment
Compliance with ARARs
Long-term effectiveness
and permanence
Reduction of toxicity,
mobility, or volume
through treatment
Short term effectiveness
BLD1
Provides no protection of
human health or the
environment.
Does not meet ARARs.
Not effective or permanent.
Would provide no
reduction of toxicity,
mobility, or volume.
No associated risk to
workers and residents.
BLD2
Protection of human health
and environment would be
achieved by removing dust
and friable asbestos.
Off-Site disposal would
comply with ARARs.
The long-term effective-
ness is met but is not a
permanent solution since
non-friable asbestos
remains on-site.
There is a reduction of
mobility and volume of the
ACM by removal and
disposal.
On-site workers could be
exposed during removal but
measures could be taken to
minimize this risk.
BLD3
Protection of human
health and environment
would be achieved by
removing all dust and
ACM and demolishing
buildings.
Off-Site disposal would
comply with ARARs.
Removal of all ACM
achieves long term
effectiveness and
permanence.
There is a reduction of
mobility and volume of
the ACM by removal and
disposal.
On-site workers could be
exposed during removal
but measures could be
taken to minimize this
risk.
BLD4
Protection of human
health and the
environment would be
achieved by removing all
dust and ACM and
demolishing buildings.
Packaging and landfilling
requirements would meet
ARARs.
Isolation of ACM
achieves long term
effectiveness and
permanence.
There is a reduction of
mobility due to
landfilling. No reduction
in volume.
On-site workers could be
exposed during removal
but measures could be
taken to minimize this
risk.
Implementabiiity
Implementability
Technical
Implementability
Administrative
Implementability
Availability of services
and materials
State Acceptance
Community Acceptance
No action required,
therefore, technically
feasible.
No action required,
therefore, administratively
feasible.
Services and materials are
not required.
Removal of asbestos is
technically feasible.
Measures to prevent
remaining non-friable
asbestos from future
exposure would be
required.
All materials available.
Removal of asbestos and
building demolition is
technically feasible.
Feasible, no asbestos left
on-site.
All materials available.
Removal of asbestos and
building demolition is
technically feasible.
Would require compliance
with ARARs.
All materials available.
Other than rejecting BLD1, the State did not expressed a preference to any of the other alternatives.
The mayor of Texas City supported the proposed alternative BLD4 while EPA received one comment opposing this
alternative. EPA also received two comments proposing to leave the buildings standing.
3.9.1.46 AlternativeBLD1: No Action. Under this
alternative, no action would be taken to remove any of
the ACM from the buildings and structures.
3.9.1.47 Alternative BLD2: Asbestos Removal.
This alternative would first require bracing unstable
buildings to allow for safe entry; removing contamimted
dust from building surfaces; and removing friable
asbestos. Friable asbestos includes 4,100 linear feet of
pipe insulation and 6,200 cubic feet and 17,800 square
feet of other ACM. For purposes of estimating the
volume of ACM, it is assumed that all building asbestos
is friable except for the shingles and the transite panels
on the walls and roofs. Non friable asbestos (shingles
and transite panels) would not be removed from
buildings. A structural survey conducted in 1996
indicated that several buildings are not safe and would
require bracing before the asbestos-containing materials
could be removed from them. These buildings are the
Roasting and Leaching Building, Maintenance Building,
Smelter Building, .and Ore Storage Building.
Additionally,chemicalsare still sbred in the Laboratory
and Office Building. These chemicals would be
collected and removed before conducting the asbestos
-------
abatement. Contaminated dust would also be removed
from interior surfaces of all buildings.
Southwest side of the Roasting and Leaching Bldg.
3.9.1.48 Alternative BLD3: Asbestos Removal and
Building Demolition, Off-Site Disposal. Friable
asbestos and dust would be removed, as described in
Alternative BLD2. In addition,all otherevident asbestos
such as transite siding and roofing as well as pipe
insulation would be removed from the buildings and
structures. Several structures would no longer have
exterior walls or roofs and would be demolished. All
building materials would be disposed off site. Buildings
on this site are clad with an estimated 356,000 square
feet of asbestos-containing siding and roofing materials,
over 90 percent of it being transite panels. Removal of
all asbestos-containing siding and roofing materials
would eliminate the need to catalog them and inform
future building occupants, would eliminate the need for
special care should any inadvertent damage ocoir during
future occupancy, and would eliminate the asbestos
hazard to any future workers. Removing this material
would expose building columns and beams to the
elements, and they would rapidly deteriorate, quickly
becoming unsafe. Site buildings would therefore be
slated for demolition immediately following asbestos
abatement when appropriate. The demolished building
materials would be disposed of at an off-site landfill.
Site buildings include:
o Maintenance Building
o Warehouses No. 1, No.2, and No.3
o Smelter Building and Stack
o Laboratory and Office Building
o General (Engineering) Office
o Change Room
o Kaldo Furnace and Kaldo Works
o Water Tower
Soil beneath some of the building foundations would be
excavated following demolition cf the foundations. The
contaminated soil volume is estimated at 16,100 cubic
yards. It is assumed that 30 percent of that volume
(4,830 cubic yards) would exceed contaminant source
leachate remedial action cleanup levels and would be
combined with other materials in the Acid Pond. O&M
costs and institutional controls would be included under
other alternatives.
3.9.1.49 Alternative BLD4: Asbestos Removal and
Building Demolition with On-site Disposal
Alternative BLD4: Under Alternative BLD4, all
asbestos would be removed as described in BLD3, but it
would be buried below grade in an on-site landfill. All
building demolition debris would be decontaminated to
be sold for salvage or disposed of in a landfill on-site.
Contaminated soil beneath the building foundations may
require remediation in accordance with Section 3.9.1.24
"Surface and Subsurface Soils," Remedial Alternative
SS2. Because building debris would remain on site
above health based levels, this alternative would also
include a deed record as an institutional control to limit
the potential for future human exposure to contaminants.
The deed record would describe the location of the
covered or stabilized landfill debrisand buried soils. The
record would also provide notice to potential buyers that
excavations in those locations may cause a release of
hazardous substances. O&M costs and institutional
controls would be included under other alternatives.
Kiln inside the Roasting and Leaching building.
-------
3.9.2 Site Wide Alternatives. The similar
individual alternatives, i.e. stabilization, water treatment
or offsite disposal, previously discussed were combind
into site wide (SW) alternatives that address each of the
contaminant primary, secondary or tertiary contaminant
sources (see Table 3.9.2, Site Wide Alternative
Similarities"). As a result six (6) site wide alternatives
were developed to address the OU1 contamination. The
alternatives include the no action alternative (SW1) that
is required by the NCP. The other alternatives covera
range of technologies, cost, protection, containment or
treatment to address OU1 contaminant sources. The
design and construction for each site wide alternative
should not last more than 36 months.
Table 3.9.2
Site Wide Alternative Similarities
KSi^RSI^KSI^R&EHE&HJ
STABILIZATION ALTERNATIVES INCLUDED IN SITE WIDE ALTERNATIVES '
WP3 - Stabilization Sediments
SL3 - Recycling, Stabilization or Backfilling
SS3 - Stabilizing All Soils Exceeding Soil Remedial Action Cleanup Levels
DR3 - Stabilization of Drummed Materials
AP3 - Sediment Stabilization
SL4 - Stabilizing non-NORM slag
SS2 - Stabilizing Soil That Exceed Contaminant Source Leachate Levels
NSL3 - Stabilizing and Landfilling NORM Stag
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
. WATER TREATMENT REMEDIAL ALTERNATIVES INCLUDED IN SITE WIDE ALTERNATIVES
AP3 - Filter Press - GAC Treatment System,
AP4 - Metals Precipitation Treatment System
GW3 - Extraction and Treatment
WP3 - Treatment
X
X
X
X
X
X
ON SITE LAND DISPOSAL W/O TREATMENT
BLD4 - Asbestos Removal and Building Demolition, On-Site Disposal of
Building Debris
SS5 - Land Disposal w/o Treatment
NSL4 - Landfilling NORM Slag On Site w/o Treatment
DR4 - Landfill Drummed Materials On Site w/o Treatment.
X
X
X
X
OFF SITE DISPOSAL
AST2 - Off Site Disposal of AST Contents
NSL2 - Off Site Disposal of NORM Slag
SL2 - Off Site Disposal of non-NORM Slag
BLD3 - Building Demolition, Off Site Disposal of Building Debris
AST3 - Off Site Disposal of Organic Wastes
X
X
X
X
DEEP WELL INJECTION
APS - Wall, Deep Well Injection of Liquid and Sediment
SL5 - Deep Well Injection of non-NORM slag
AST4 - Deep Well Injection of AST Contents
DR5 - Deep Well Injection of Drummed Materials
NSL5 - Deep Well Injection of NORM Slag
X
X
X
X
MISCELLANEOUS REMEDIAL ALTERNATIVES
GW2 - Long Term Monitoring
WP2 - Discharge w/o Treatment
BLD2 - Asbestos Removal
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
3.9.3 SW1: No Action Alternative. Under this
alternative,no action would be taken t> remove, treat, or
contain any of the contamination found on OU1. No
action would betaken at the acid pond and sediments in
the Wah Chang Ditch, the wastewater ponds,
groundwater, drums, aboveground storage bnks, surface
and subsurface soils, NORM and non-NORM slag, or
buildings and structures. Because contaminated media
would remain in place, the potential for off-site migratia
of contaminants would not be mitigated. The no action
alternative is required by the NCP andprovides a basis of
comparison for the remaining alternatives. No costs are
associated with this alternative.
3.9.4 SW2: Consolidation of Hazardous
Materials and Covering with Impermeable Cap,
Groundwater Monitoring, and Asbestos and Dust
Removal from Buildings. Components of this
alternative include the following elements:
o A vertical geomembrane barrier would be
installed around the Acid Pond, the liquids
in the pond would be removed and treated
on site to remove the metals by
precipitation, the Wah Chang Ditch and
Acid Pond sediments would be placed in the
Acid Pond, and an impermeable cover
would be placed over the Acid Pond (AP-4).
Non-NORM slag leaching contaminants
greater than the contaminant source leachae
remedial action level would also be
consolidated (SL-4)
o The drum contents, NORM slag, and soils
exceeding a contaminant source remedial
action cleanup level would be placed under
an impermeable cover (DR-4, NSL-4)
o Soils exceeding a remedial action cleanup
levels but not exceeding the contaminant
source remedial action cleanup level would
be covered in place with a clay compacted
cover(SS-2)
£g>
o The aboveground storage tank contents
would be disposed off-site (AST-2)
o The wastewater pond liquids would be
discharged into the Wah Chang Ditch and
the wastewater ponds backfilled (WP-2)
o A perimeter groundwater monitoring
program would be initiated (GW2)
o The dust and friable asbestos would be
removed from the buildings on site (BLD-2)
3.9.5 SW3: On-site Stabilization, Compacted
Clay Cover, Groundwater Monitoring, Asbestos
Removal, and Building Demolition. This is the
selected alternative and includesthe following elements:
o On-site stabilizationof Acid Pond sediments
and Wah Chang Ditch sediments (AP3),
stabilization of drum and supersack
inorganic contents, off-site disposal of
organic contents (DR3), stabilization of
NORM and hazardous non-NORM slag
(NSL3 and SL4);
o Soils exceeding remedial action cleanup
levels but not soils exceeding the
contaminant source remedid action cleanup
level would be covered with compacted clay
cover including the low-level radioactive
landfill; soils exceeding the contaminant
source remedial action cleanup levels wnild
be stabilized and capped (SS2)
o Wastewater pond liquids would be
discharged to Wah Chang Ditch, and ponds
backfilled (WP2)
o Long-term groundwater monitoring (GW2)
o Off-Site disposal of organic Aboveground
Storage Tank contents (AST2) at a facility
approved for K0052 waste disposal.
o Removal of dust and all asbestos from
buildings, demolition of buildings and on-
site disposal of debris (BLD4)
Under this alternative, a geomembrane wall would be
placed around the Acid Pond. The Acid Pond liquids
would be treated and discharged into the Wah Chang
Ditch. Stabilization will be used to treat the Acid Pond
and Wah Chang Ditch sediments, drummed materials,
hazardous non-NORM slag. Soils exceedingthe leachafe
concentrations shown on Table 3.11.3.1, "Soil Sediment,
Slag and Sludge Remedial Action Cleanup Levels"
would be stabilized and used to fill the Acid Pond. The
estimated volume of materials for on-site stabilization is
94,000 cubic yards. The wastewater pond liquids would
be discharged into the Wah Chang Ditch while soil
exceeding any remedial action cleanup level in Table
3.11.3.1, "Soil Sediment, Slag and Sludge Remedial
4ft
-------
Action Cleanup Levels," would be covered with a 24-
inch clay soil cover. The above ground storage tank
contents would be disposed of off site at an EPA
approved treatment anddisposal facility and a perimeter
groundwater monitoring program would be implemented
to ensure no further degradation of groundwater. Lastly
the dust and asbestos from the buildings would be
removed, the buildings would be demolished, and the
building debris would be landfilled on-site.
3.9.6 SW4: On-site Stabilization,
Consolidation, and Covering of Soils, Groundwater
Monitoring, and Asbestos Removal. The components
of SW4 include the following:
o On-site stabilizationof Acid Pond sediments
and Wah Chang Ditch sediments (APS),
drum contents stabilization (DR3), non-
NORM slag stabilization and recycling
(SL3) and off-site landfill NORM disposal
(NSL2).
o On-site stabilization of soils that exceed
remedial action cleanup levels (SS3)
o Wastewaterpond liquids discharged t> Wah
Chang Ditch and ponds backfilled (WP2)
o
o
Long-term groundwater monitoring (GW2)
Off-Site disposal of Aboveground Storage
Tank contents (AST2)
Removal of dust and all asbestos from
buildings, building demolition, and on-site
disposal of debris (BLD4)
The alternative is similar to SW-3 except that soils
exceeding remedial action cleanup levels would be
stabilized on-site, NORM slag would be disposed of off
site, and selectednon-NORM, non-hazardousslag wouH
be recycled.
3.9.7 SW5: On-site Stabilization of the Acid
Pond, Off-Site Disposal of Hazardous Wastes,
Groundwater Extraction, and Building Demolition
This alternative consists of the following components:
o On-site stabilizationof Acid Pond sediments
and Wah Chang Ditch sediments (AP-3),
and waste pond sediment stabilization
(WP3)
o On-site stabilization of soils exceeding
remedial action cleanup levels (SS-3)
o Stabilization of drum contents on site
(DR3), off-site disposal of NORM and
hazardous non-NORM slag (NSL2 and
SL2), off-site disposal of aboveground
storage tank contents (AST2)
o Groundwater extraction and treatment
(GW3)
o Removal of dust and all asbestos from
buildings, building demolition, and buibing
materials disposed of off site (BLD3)
Under this alternative wastes would be removed from the
site for disposal, or else treated or stabilized at the site.
3.9.8 SW6: Deep Well Injection of Drum
Contents, Sediment, and Slag; and Building
Demolition.
This alternative consists of the following components:
o Waste pond drainage/NPDESdischargeand
placement of 24-inch clay cover (WP2)
o Excavate and consolidate soils that exceed
remedial action cleanup levels and cover
with a clay cap, injectTCLP hazardous soils
(SS5)
o Deep well injectionof drum contents (DR5),
deep well injection of NORM and hazardous
non-NORM slag (NSL5 and SL5), deep
well injection of Acid Pond liquid and
sediments as well as Wah Chang Ditch
sediments (APS), and deep well injection of
AST contents (AST4)
o Long-term groundwater monitoring (GW2)
o Removal of dust and all asbestos from
buildings, building demolition, and on-site
disposal of building materials (BLD4)
This alternative would involve reentering the existing
deep injection well on-site, and installing two new deep
monitoring wells to monitor the injection well waste
perimeter radius.
The soils exceeding remedial action cleanup levels but
-------
not TCLP-hazardous would be excavated and
consolidatedon-site. Soils exceedingTCLP limits woild
be deep well injected as would the NORM slag and nost
other contaminated materials from the site.
3.10 Summary of Comparative Analysis of
Site Wide Alternatives. The alternatives for OU1 were
evaluated in accordancewith the nine criteria specified h
the NCP, 40 C.F.R. 300.430(e)(9) and (f)(l). These
criteria are:
1. Overall Protection of Human Health andthe
Environment
2. Compliance with Applicable or Relevant
and Appropriate Requirements (ARARs)
3. Long-term Effectiveness and Permanence
4. Reduction of Toxicity, Mobility or Volume
Through Treatment
5. Short-Term Effectiveness
6. Implementability
7. Cost
8. State Acceptance
9. Community Acceptance.
3.10.1 Overall Protectionof Human Health and
the Environment. Overall protection of human health
and the environment addresses whether each alternative
adequately protects human health and the environment
and describes how carcinogenic risks and non-
carcinogenic hazards posed through each exposure
pathway are eliminated, reduced or controlled, through
treatment, engineering controls, and/or institutional
controls. The only OU1 alternative that does not meet
the threshold criteria (protecting human health and the
environment and complying with ARARs) is SW1, the
no action alternative. Alternatives SW2, SW3, SW4,
SW5, and SW6 all areprotective of human health and tte
environment.
3.10.2 Compliance with Applicable or Relevant
and Appropriate Requirements. Section 121(d) of
CERCLA requires that remedial actions at CERCLA
sites at least attain legally applicable or relevant and
appropriate Federal and State requirements, standards,
criteria and limitationswhich are collectively referred to
as ARARs. AlternativesSW2, SW3, S W4,and S W5 are
in compliance with ARARs. Remedial Alfernative SW6
will require a waiver of 30 Texas Administrative Code
Chapter 331. "Underground Injection Control,
Subchapter D. Standards For Class I Wells Other Than
Salt Cavern Solid Waste Disposal Wells, § 331.63
Operating Requirements." This ARAR requires
regulating injection pressure at the wellhead so as to
assure that the pressure in the injection zone during
injection does not initiate new fractures or propagate
existing fractures in the injection zone, initiate new
fractures or propagateexisting fractures in the confining
zone, or cause movement of fluid out of the injection
zone that may pollute drinking water or surface water.
3.10.3 Long-Term Effectiveness and
Permanence. Long-term effectiveness and permanence
refers to expected residual carcinogenic risk and the
ability of a remedy to maintain reliable protection of
human health andthe environment over time, once clear*
up levels have been met. This criterion includes the
consideration of residual carcinogenic risk and the
adequacy and reliability of controls. All alternatives,
except the no action alternative, meet the long-term
effectiveness and permanence criteria Alternatives SW3
and SW4 permanently stabilize the most mobile
contaminants. Under Alternative SW5, the drums,
aboveground storage tank contents, and NORM and non-
NORM slag are removed and disposed of off site toa
permanently monitored treatment and disposal facility.
Off-site disposal provides the greatest long-term
effectiveness and permanence at the site. In Alternative
SW2, hazardous materials are consolidated on site and
permanently covered with an impermeable cap. BLD3
and 4 provide the most effective long-term and
permanent remedies since there is no specific use
identified for the site and many structures on site are
contaminated, so the collapse or destruction of these
building during high winds could release the
contaminants contained in the buildings into the
environment. Consequently, EPA considers there can be
little if any current use of the buildings without
significant decontamihation, demolition, renovation or
construction. In addition since the current building
owner is in bankruptcy and there is no long-term
maintenance plan, the buildings will most likely continue
to deteriorate. As the buildings deteriorate friable
asbestos fibers from siding and roofing could be released
Therefore, EPA believes building demolition provides
the most effectivelong-term permanent remedy to ensue
there is no release of friable asbestos or other hazardous
substances into the environment.
-------
Table 3.11.1.9.
Cost Estimate, Remedial Alternative BLD4
Dust Removed, Friable and Non-friable Asbestos Remediated and Landfilled On-site, Structures*
Demolished
Item Description
Capita] Costs**
Structural Inspection - Roasting & Leaching Bide
Structural Inspection - Maintenance Bldg
Structural Inspection - Smelter Bldg
Structural Inspection - Ore Storage Bldg
Structural Inspection - Ore Storage Bldg
Asoestos Abatement: Pipe Insulation
Asbestos Abatement: Asbestos Containing Materials
Asbestos Abatement: Asbestos Containing Materials
Asbestos Abatement: Building Siding & Roofing
Vacuum Dust in Interiors of Buildings
Pressure Wash Interior Walls of Buildings
Packaging & Handling
Demolish Roasting & Leaching Bldg.
Demolish Maintenance Bldg
| Demolish Warehouse No. 1
Demolish Warehouse No. 2
Demolish Warehouse No. 3
Demolish Smelter
Demolish Smelter Stack
Demolish Lab & Office Building
Demolish General Engineering Office
Demolish Change Room
Demolish Ore Storage Bldg.
Demolish Kaldo Furnace
Demolish Kaldo Works
Demolish Water Tower
Excavation and Transportation of Soil Under Structures
In-Situ Stabilization
Backfill Using Non-Hazardous Soil from the Site
Load debris in trucks, transport across site
Construct and close RCRA landfill
General Equipment Mobilization and Demobilization (6%)
Quantity
48
48
48
48
48
4,100
6,200
17,800
356,000
1
1
4,421
1,176,000
318,780
491,400
249,600
220,000
3,021,525
250
123,904
58,080
66,429.
1,848,000
168,480
78,00
1
16,133
4,840
16,133
102
113,000
.06
Unit
HRS
HRS
HRS
Cost/Unit Cost*
$100.00
$100.00
$100.00
HRS 1 $100.00
HRS 1 $100.00
LF
CF
SF
SF
LS
LS
CY
CF
CF
CF
CF
CF
CF
LF
CF
CF
CF
CF
CF
CF
LS
CY
CY
CY
day
SF
%
$10.00
$7.00
$6.80
$6.80
$74,555.00
$154,008.00
$50.00
$0.25
$0.25
$0.25
$0.25
$0.25
$0.25
$1,000.00
$0.25
$0.25
$0.25
$0.25
«$0.25
$0.25
$65,920.00
$6.00
$35.00
$5.00
$3,666.95
$8.00
$6,995,707.0
0
Subtotal Direct Capital Costs
Overhead and Profit (25%)
Total Direct Capital Costs (Rounded to Nearest S10,000)
$4,800
$4,800
$4,800
$4,800
$4,800 |
$41,000
$43,400
$121,040
$2,420,800
$74,555
$154,008
$221,046
$294,000
$79,695
$122,850
$62,400
$55,000
$755,381 1
$250,000
$30,976
$14,520 j
$16,607
$462,000
. $42,120
$19,500
$65,920
$96,798
$169,397
$80,665
$374,029
$904,000
$419,742
$7,415,450
$1,853,862 (
$9,270,000 |
-------
Table 3.11.1.9.
Cost Estimate, Remedial Alternative BLD4
Dust Removed, Friable and Non-friable Asbestos Remediated and Landfilled On-site, Structures*
Demolished
Item Description
Indirect Capital Costs
Quantity
Unit
Cost/Unit
Cost*
Engineering and Design (7%)
Legal Fees
and License/Permit Costs (5%)
Total Indirect Capital Costs
.
Subtotal
Capital Costs
Contingency Allowance (15%)
Total Capital Costs (rounded to the nearest $10,000)
$648,900
$463,500
$1,112,400
$10,382,400
$1,557,360
$11,940,000
O&M Costs
Annual Maintenance, present value
1
LS
$678
Subtotal Direct Annual O&M Costs
Overhead and Profit (25%)
Total O&M Costs
(Rounded to Nearest $1,000)
Administration (5%)
Insurance, Taxes, Licenses (2.5%)
Subtotal
Capital Costs
Contingency Allowance (15%)
Total
O&M Costs (rounded to the nearest $1,000)
30 year cost projection at an assumed 8%
discount rate.
Present Worth of O&M (rounded to nearest $1,000)
Total Alternative Cost (Capital Cost plus O&M) to nearest $10,000
$678
$678
$170
$1,000
50
$25
$1,075
$161
$1,000
$11,158
$11,000
$11,950,000
* Due to rounding, the amount in the Cost column may be slightly different than the product.
** Capital Costs may be reduced if during the remedial design EPA determines some buildings do not meet the
demolition criteria stated in section 3.1 1.3.5.
-------
Common Features of Each Remedial Alternative.
3.11.1.10 Operation and Maintenance. The NORM
Slag and Building Debris landfills, covered soils, and
filled ponds will require long term inspection and
maintenance as an O&M measure. Annual O&M
inspections would look for breaches in the landfllbover.
Additional inspections would occur after severe weather
events (i.e., hurricanes) to ensure there is no erosion
damage to the cover. O&M measures would also include
groundwater monitoring to ensure contaminants do not
continue leaching into the groundwater.
3.11.1.11 Stabilization. Remedial Alternatives AP3,
DR3, SS2, NSL3 and SL4 will require stabilizing
contaminant sources to eliminate a principal threat.
Detailed design studies would be requiredto design the
optimum stabilizing reagents mixture. The optimal mix
design would produce the most cost effective
homogeneous stable mixture that would alter the
chemical or physical com position ofthe contaminants to
prevent them from leaching contaminants in
concentrations exceeding the leachate concentrations
shown in Table 3.11.3.1.
3.11.1.12 Impermeable Cover. An impermeable
cover is required to cover stabilized contaminants for
AP3 and NSL3. Once the stabilization is complete the
mix would be covered with an impermeable clay or
HDPE cover designed to prevent direct contact by
humans or wildlife. Thecover would also be designed to
ensure sediment toxicity and mobility is permanently
reduced and rainfall infiltration is mininized. In the case
of a cover for NORM slag the cover would be designed
to comply with radiation ARARs at the surface.
Therefore, radiation modeling will be necessary to
determine the cover design necessary to reduce the
expected radiation dosage at the fence line. Should site
development be considered in the future, the thickness
and composition of the cover would need to be
reevaluated based upon the proposed development.
3.11.1.13 Institutional Controls. Because
contaminants and debris would remain buried on site, tre
Site Wide Alternative SW3 would also include a deed
record as an institutional control to limitthe potential for
future human exposure to contaminants. The deed recoil
would describe the locations of the buried contaminants,
low-level radionuclide landfill and debris and provide
notice to potential buyers that excavations in those
locations may cause a release of hazardous substances.
3.11.1.14 Clay Cover. Remedial Alternatives WP2,
SS2 and SL4 require a clay cover to contain low level
threat waste. The intent is to cover the areas that exceed
the remedial action cleanup levels with a minimum cf 24
inches of clean compacted clay. If a minimum of two feet
of clean fill is used to backfi lithe ponds to grade, then an
additional 24-inch clay cover will notbe required. If this
can be accomplished in backfilling the ponds to grade,
then the addition of a clay cover is rot needed. The clay
cover would be topped with six inches of topsoil seeded
with native grass chosen for long-term erosion control.
Should site development be considered in the future, the
thickness and composition ofthe cover would needto be
reevaluated based upon the proposed development.
3.11.2 Summary of the EstimatedRemedy Costs.
The estimated remedy costs are summarized in the
following table. As previously discussed, EPA believes
Site Wide Alternative SW3 can be designed and
constructed in less than 36 months.
Table 3.1 1.2
Summary ofthe Estimated Remedy Costs
Site Alternatives
AP3
WP2
GW2
DR3
AST2
SS2
NSL3
SL4
BLD4
Geomembrane wall, filter
press/GAC treatment system,
sediment stabilization
NPDES discharge pond
water, 24-inch clay cover
Long-term monitoring of
groundwater
Stabilization of drum
contents on site
Off-Site disposal of organic
AST contents
24-inch clay cover on non-
hazardous soils, stabilize and
cover hazardous soil
Stabilization of NORM slag
Stabilization and covering
hazardous non-NORM slag,
backfill and cover remaining
non-NORM slag
Asbestos removal, building
demolition, on-site disposal
TOTAL
$6,570,000
$2,700,000
$330,000
$450,000
$400,000
$3,970,000
$970,000
$1,300,000
$11,950,000
$ 28,640,000
-------
3.11.3 Expected Outcomes of the Selected
Remedy. The purpose of this response action is to
control carcinogenic risks and non-carcinogenic hazards
posed to current construction workers and future
construction and industrial workers through: accidental
ingestion of contaminated soil, drummed catalyst and
ground water; inhalation of radon gas or asbestos fibers;
external radiation from NORM slag piles; and direct
contact with acid pond water or above ground storage
tank sludge. Upon completion of the remedy the site is
expected to be available for any industrial uses that
would not disturb any of the buried contaminants or use
any untreated groundwater. The results of the baseline
risk assessment indicate that existing conditions at the
site pose an excess lifetime carcinogenic risk greater thai
1 in 10,000 (l.OE-04)or a non-carcinogenic hazard with
a Hazard Index greater than 1, as shown on Table
3.7.1.4.7, "Carcinogenic Risk or Chronic Hazards
Justifying Remedial Action." Therefore, EPA will take
remedial action in those areas of the site where the
contaminant concentrations exceed the remedial action
cleanup levels in Tables, 3.11.3.1 and 3.11.3.4.
3.11.3.1 Soil, Sediment, Slag or Sludge. Since no
Federal or State ARARs define specific soil, sediment,
slag or sludge cleanup levels, EPA developedthe cleanup
levels shown in Table 3.11.3.1, "Remedial Action
Cleanup Levels," through a site specific risk analysis as
explained in Section 3.7, "Site Carcinogenic Risk and
Non-Carcinogenic Hazard." EPA and TNRCC
determined the appropriate cleanup standard for arsenic
to be 200 ppm.58 The "Identification and Listing of
Hazardous Waste, SubpartB - Criteriafdr Identifyingthe
Characteristics of Hazardous Waste and for Listing
Hazardous Waste, Toxicity Characteristic," 40 C.F.R.
§261.22 defines the action level for the AST sludge.
3.11.3.2 Leachate. To protect human health and the
environment from the primary, secondary and tertiary
contaminant sources leaching contaminants, EPA
established the leachate levels in Table 3.11.3.1,
"Remedial Action Cleanup Levels," based upon the Safe
Drinking Water Act Maximum Contaminant Levels
(MCLs) to ensure that the leachate will not add
unacceptable amounts of contamination to the
groundwater. EPA will use EPA SW-846 Method 1312,
"Synthetic Precipitation Leaching Procedure" (SPLP) to
determine the contaminant concentrations in leachate.
Table 3.1 1.3.1
Remedial Action Cleanup Levels
Chemical / Waste
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Zinc
1.1.2-Trichloroclhane
1 ,2-Dichloroc thane
Benzene
Chloroform
Acid Pond Water and Above Ground
Storage Tanks
Basis Cleanup Level
Risk Assessment
Risk Assessment
MCL**
MCL
Risk Assessment
Risk Assessment
Risk Assessment
Risk Assessment
Risk Assessment
Risk Assessment
MCL
Risk Assessment
MCL
MCL
MCL
MCL
Cleanup Levels
Soil, Sediment, Slag and Sludge
(mg / kg)
194
2,044
1,577
75,628
2.000
613
40.880
613,200
Leachate*
-------
3.11.3.3 Surface Water. Remedial alternatives AP3
and WP2 require dischargingsurface water which mete
the discharge requirements of the NPDES permit for the
facility. Those requirements are listed in table 3.11.3.3,
"NPDES' Pollutant Discharge Limits, NPDES Permit
Number TX0004855 9.11.2."
3.11.3.4 Groundwater. The groundwater action
levels in Table 3.11.3.4, "Groundwater Remedial Action
Levels" were based upon Safe Drinking Water Act
MCLs for the Deep Transmissive Zone and alternate
concentration limits (ACLs) for theShallowand Medium
Transmissive Zones. EPA determined that since on-site
groundwater will most likely not be used as a drinking
water source and that the likelihood of a down gradient
receptor is minimal (see Section 3.6 "Current and
Potential Site and Resource Uses"), site specific ACLs
for industrial use would be an appropriate action level
since background wells up gradient from the site indicate
the groundwater up gradient exceeds secondary MCL
concentrations.59 The site specific ACL calculations are
discussed in the Feasibility Study Report, Tex Tin Site,
Operable Unit No. I, Appendix D.
3.11.3.5 Building Demolition. During the remedial
design EPA will further evaluate the buildings on site.
EPA will require building demolition when :
There are no long term building
maintenance plans to prevent building
deterioration, which may present a release or
threat of release of a hazardous substance to
the environment;
The building presents a safety hazard to
response workers;
The building components are so
contaminated that decontamination is
impracticable;
The building components are so corroded or
otherwise compromised that
decontamination is inpracticable; or
Building demolition is necessary to facilitate
implementing other components of the
remedial action.
Table 3.1 1.3.3
NPDES Pollutant Discharge Limits
NPDES Permit Number TX0004855
Parameter
Chemical Oxygen
Demand
Total Suspended
Solids
Biological Oxygen
Demand, Five Day
pH Minimum
pH Maximum
Oil and Grease
Arsenic, Total
Copper, Total
Manganese, Total
Nickel, Total
Tin, Total
Zinc, Total
Sample
Type
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Concentration
125.0
120.0
40.0
mg/L
mg/L
mg/L
6.0
9.0
15.0
0.20
0.133
3.0
2.0
1.0
1.051
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
-------
Table 3.1 1.3.4
Groundwater Remedial Action Levels
Contaminant of Concern
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Mercury
Nickel
Selenium
Benzene
Chloroform
1.2'Dichloroc thane
Radium 226 and Radium
228. combined
Gross alpha particle
radioactivity
(excluding radon and
uranium)
Deep Zone
MCLs (mg/L)
0.006
0.05
2.0
0.004
0.005
0.1
1.3
0.02
0.1
0.05
0.005
0.1
0.005
5pC/L
15 pC/L
Shallow and
Medium Zones
ACLs (mg/L)
7.05
0.05
1,230.00
0.011
8.81
17,600.00
652.00
5.29
352.00
88.10
0.08!
0.909
0.102
5pC/L
15pC/L
3.12 Statutory Determinations. This section
provides a brief, site-specific description of how the
selected remedy satisfies the statutory requirements of
CERCLA Section 121 and explains the five-year review
requirements for the selected remedy. Table 3.12 below
provides a comparison of the selected remedy to the
others considered.
3.12.1 Protection of Human Health and the
Environment. The selected remedy will provide
adequate protection to human health andthe environment
through treatment, engineering controls, and / or
institutional controls. Box 3.12.1, "Protection ofHuman
Health and the Environment,"explains how the remedy
will reduce the carcinogenic risks to less than 1 in
10,000 and reduce the non-carcinogenic hazards to a
Hazard Index less than one by eliminating the pathways
to the receptors from each contaminant source.
3.12.2 Compliance with Applicable or Relevant
and AppropriateRequirements(ARARS). Applicable
or relevant and appropriate requirements include
substantive provisions of any promulgated Federal or
more stringent State environmental standards,
requirements, criteria or limitations that are determined
to be legally applicable or relevant and appropriate
requirements for CERCLA site or action. Applicable
requirements are those requirements promulgated under
Federal or State law that specifically address a hazadous
substance, pollutant, contaminant, remedial action,
location or other circumstance found at a CERCLA site.
Relevant and appropriate requirements are those
requirements that although not legally applicable, addres
problems or situation sufficiently similar to those
encountered at the CERCLA site so that their use is well
suited to the circumstances found at the site. The
ARARs EPA selected for this site are listed in Table
3.12.2. - 1, "Action Specific ARARs," Table 3.12.2-2,
"Chemical Specific ARARs," and Table 3.12.2 - 3,
"Location Specific ARARs."
3.12.3 Cost Effectiveness. It is EPA's judgement
that the selected remedy SW3 is cost-effective and
represents a reasonable value for the money to be spent.
In making this determination, the following definition
was used: "A remedy shall be cost-effective if its costs
are proportional to its overall effectiveness." (40 C.F.R.
300.430(f)(l)(ii)(D). This was accomplished by
evaluating the "overall effectiveness" of those
alternatives that satisfied the theshold criteria (i.e., were
both protective of human health andthe environmentand
ARAR-compliant). Overall effectiveness was evaluated
by assessing the relationship between long-term
effectiveness and permanence as well as reduction in
toxicity, mobility, and volume through treatment and
short term effectiveness. Overall effectiveness was then
compared to costs to detarnine cost-effectiveness. EPA
determined the relationshipof the overall effectivenesscf
Site Wide Alternative SW3 to be proportional to its cost
and hence represents a reasonable value for the money fc
be spent. SW1 and SW6 were not taken into
consideration as cost effective remedies since they did
not comply with ARARs. SW2 was not considered cost
effective because it did not offer acceptable long-term
effectiveness and permanence nor did it reduce toxicity,
mobility or volume through treatment. While
alternatives SW3, SW4 and SW5 offered acceptable or
better long-term effectivenessand permanence, reductioi
of toxicity, mobility and volume as well as short-term
effectiveness, the cost to achieve those standards throigh
alternatives SW4 and SW5 B almost triple and therefore
less cost effective than remedial alternative SW3.
-------
Table 3.12 - Qualitative Comparison
Evaluation Criteria
Protection of human
health
Compliance with
ARARs
Long-term effectiveness
and permanence
Reduction of toxicity,
mobility and volume
Short-term
effectiveness
Implementability
Cost (Present Worth)
SW1
—
—
—
—
+
+
$0
SW2
+
O
—
—
O
+
$15,580,000
SW3
+
+
+
0
0
+
$28,610,000
SW4
+
+
+
O
O
+
$88,280,000
SW5
+
+
+
0
O
+
$112,060,000
Legend:
- Unacceptable
O Acceptable
+ Best Fix
SW6
O
—
+
O
O
O
$36,930,000
-------
Box 3.12.1 Protection of Human Health and the Environment
Drummed Materials (spent catalyst) in Areas B, E, J, and L are identified in the site conceptual model as primary
contaminant sources. Exposed drum materials (spent catalyst) provide a pathway to industrial and construction
workers through exposure routes such as accidental tngestion or dermal contact during work activities. Stabilization
will provide treatment to reduce toxicity and mobility and using stabilized material fill the Acid Pond is an
engineering control that will also reduce mobility.
Soil in Areas A through F, J, and L through N are identified on the site conceptual model as secondary as well as
tertiary contaminant sources. Exposure to soils provide a pathway to industrial and construction workers through
exposure routes such as accidental ingestion, inhalation of radon gas released from the soil* or dermal contact. In
addition, workers in these areas may come into contact with surface soil or subsurface soil (which may be brought to
the surface via soil excavation activities) through maintenance or construction activities. Stabilizing soils that leach
contaminants in leachateconcentrationsgreater than the cleanup levels in Table 3.11.3.1, "Remedial Action Cleanup
Levels," will provide treatment to reduce toxicity and mobility of the principal threat. Using this soil to fill the Acid
Pond is an engineering control that will also reduce mobility.
Waste piles in Areas A through F, and J, are identified in the site conceptual model as primary contaminant sources.
Exposure to these piles provides a pathway to industrial and construction workers through exposure routes such as
accidental ingestion, inhalation of radon gas released from the soil or dermal contact during work activities.
Stabilization will provide treatment to reduce toxicity and mobility and using stabilized material fill the Acid Pond
is an engineering control that will also reduce mobility.
Sediments in Areas G and K, are identified in the site conceptual model as secondary as well as tertiary contaminant
sources. Exposure to sediments provides a pathway to industrial and construction workers through exposure routes
such as accidental ingestion and dermal contact. Workers in these areas may come into contact with sediments
through maintenance or construction activities. Stabilization will provide treatment to reduce toxicity and mobility
and using stabilized material fill the Acid Pond is an engineering control that will also reduce mobility.
Surface water in Areas G & K. Exposure to contaminants in surface water associated with on-site drainage ditches
and on-site ponds was evaluated through dermal contact with surface water. The Acid Pond in Area K is a primary
contaminant source. Area G becomes a secondary or tertiary source dependent upon the release mechanism shown
on Figure 2.4.7(b). Workers may be exposed to surface waters during work activities. Water treatment to neutralize
the pH will reduce the toxicity. GAC treatment will also reduce toxicity by removing heavy metals from the waste
stream. The NPDES discharge limits provide action levels to reduce toxicity.
Groundwater, Areas Shallow, Medium and Deep Transmissive Zones were each evaluated through ingestion and
noningestion exposure routes (i.e., dermal contact while showering, and inhalation of volatiles through showering).
These exposure routes were selected because future on-site industrial workers may use on-site groundwater for
showering and / or drinking. A deed record as an institutional control will prevent the use of untreated groundwater
thus eliminating the exposure route.
* As the NORM slag piles erode, fine slag particles become mixed with the soil on site. These particles then decay
to form radon gas.
-------
Remedial Alternative
BLD4, SL4, NSL3
BLD4
BLD4.AP3
BLD4, AP3
All alternatives
AP3, WP2
AP3
SL4, NSL3
All alternatives
AST2, AP3, GW2, DR3
DR3. SS2. NSL3, SL4
WP2, DR3, SS2. SL4
WP2. DR3. SS2. SL4
Table 3.12.2 - 1
Action Specific ARARs
Synopsis of Citation
Clean Air Act (CAA) § 1 12, 40 C.F.R. § 61
National Emission Standards for Hazardous
Air Pollutants (NESHAPs)-Asbestos
Standards for Demolition and Renovation. 40
C.F.R. §61.145
Prevention of Significant Deterioration of Air
Quality, 40 C.F.R. §52.21
Non-Attainment Areas-LAER. 42 USC §
172(b)(6)and§ 173
Stormwater Regulations, 40 C.F.R. § 122, 125
Concentration limits for liquid effluents from
facilities that extract and process uranium.
radium, and vanadium ores, 40 C.F.R. § 440
Subpart C
Water Quality Criteria: Report of the National
Technical Advisory Committee to the
Secretary of the Interior; April 1, 1968
Characteristics of Nonhazardous Slag. 40
C.F.R. §261.3(c)(2)(ii)(C)(l)
Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and
Disposal Facilities
40 C.F.R. § 264 Subparts B, C, D and G
Standards for Container and Tank Storage of
Hazardous Waste, 40 C.F.R. § 264 Subparts I
andJ
Standards for Waste Piles and Landfills, 40
C.F.R. § 264 Subparts L and N
Corrective Action Management Units
(CAMU), 40 C.F.R. § 264 Subpan S
Corrective Action Management Units
(CAMU) (Miscellaneous Units). 40 C.F.R.
§264 Subpart X
Action to be Taken to Attain
Requirement
Remediation in compliance with
regulation
Asbestos remediation
Building demolition and water treatment
systems will comply with these
regulations, and will not constitute a
major stationary source of air pollution
Building demolition and water treatment
systems will comply with these
regulations, and will not constitute a
major stationary source of air pollution
All selected alternatives must comply
with Stormwater issues during
implementation through a pollution
prevention plan.
Water treatment via carbon filtration,
direct NPDES discharge from
wastewater ponds
Water treatment via carbon filtration,
direct NPDES discharge from
wastewater ponds
Determines classification of hazardous
vs. non-hazardous slag for disposal
classification
Off-Site disposal or on-site placement
under an impermeable cap
Off-Site disposal or capped on-site
placement of hazardous wastes
On-site placement must comply with
these standards.
If temporary storage units are
implemented during remedial action,
they should comply with this subpart.
If temporary storage units are
implemented during remedial action,
they should comply with this subpart.
Status
Applicable
Applicable
Relevant
and
Appropriate
Relevant
and
Appropriate
Applicable.
Applicable
To Be Considered"
Applicable
Applicable""
Applicable""
Relevant
and
Appropriate
Relevant
and
Appropriate
Relevant
and
Appropriate
Based on discharge to off-site ponds from Wah Chang ditch 40 C.F.R. 300.430(d)
Applicable for off-site disposal, Relevant and Appropriate for on-site placement
Applicable for off-site disposal. Relevant and Appropriate for on-site placement
-------
Table 3.12.2 - 1
Action Specific ARARs
Remedial Alternative
SS2. AST2
AP3.DR3.SS2.NSL3,
SL4. BLD4
BLD4. SS2
BLD4
AP3
AST2. AP3
AP3. DR3. NSL3, SL4.
BLD4. SS2
BLD4
BLD4
AP3. WP2
APS, WP2
AP3. WP2
AP3. WP2. GW2
AP3. WP2
AP3. WP2
AP2. AP3. AP4, WP2.
j WP3.GW3
AP3. WP2
AP3. WP2
All remedial alternatives
BLD4
Synopsis or Citation
PCB Disposal, 40 C.F.R. § 761.60
Land Disposal Restrictions, 40 C.F.R. §
268.l(c)(4)(iv), "Purpose. Scope and
Applicability"
Specific Air Emission Requirements for
Hazardous or Solid Waste Management
Facilities, 30 TAC Subchapter L §335.367
Asbestos Notification Fees, 30 TAC § 101.28
Emissions Specifications. 30 TAC §115.131
Industrial Wastewater Emissions. 30 TAC §
115.140-115.149
Control of Air Pollution by Permits for New
Construction or Modification, 30 TAC § 1 16
Requirements for Specified Sources, 30 TAC
§ 111.111
Control Requirements for Surfaces with
Coatings Containing Lead. 30 TAC §111.135
Consolidated Permits Subchapter O,
Additional Conditions and Procedures for
Wastewater Discharge Permits and Sewage
Sludge Permits
Pollution Prohibition, Texas Water Code if
26.121
Surface Water Quality Standards -
Determination of Attainment, 30 TAC § 307.9
Acute Toxicity. 30 TAC § 307.6(b)( 1 )
Chronic Toxicity, 30 TAC § 307.6(b)(2)
Human Toxicity, 30 TAC § 307.6(b)(3)
Water Quality Certification, 30 TAC § 279
Site-Specific Uses and Criteria, 30 TAC
§307.7(b)(5)
Oyster Waters
30 TAC § 307.7(b)(3)(B)(iii)
Texas Water Quality Act. TCA. Water Code,
Title 2-State Water Commission
Disposal of Special Wastes, 30 TAC
-------
Table 3.12.2 - 1
Action Specific ARARs
Remedial Alternative
NSL3
NSL3
AST2
All alternatives
AST2
AST2
AP3, WP2, GW2
AST2
AST2
AP3, WP2, GW2, SL4,
NSL3, AST2. DR3,
BLD4.
AST2
AST2
GW2
GW2
AP3, AST2. SS2, SL4.
NSL3. BLD4
AP3. AST2, SS2, SL4.
NSL3. DR3. BLD4
AP3. WP2. SS2. NSL3,
SL4
AP3, AST2, SS2, SL4,
NSL3, DR3, BLD4
Synopsis of Citation
Exemptions, General Licenses, and General
License Agreements, 2STAC§m251
Radiation Rules for Licensing of Radioactive
Waste Disposal
30TAC §336.
Above-Ground Storage Tanks (AST), 30 TAC
§ 334 Subpart F
Exposure to Toxic and Hazardous Substances,
25 TAC §295. 102
Permanent Removal from Service, 30 TAC
§ 334.55 (pertains to USTs)
Free Product Removal. 30 TAC § 334.79
Closure and Remediation, 30 TAC Subchapter
A § 335.8
Shipping and Reporting Procedures
Applicable to Generators of Hazardous Waste
or Class I Waste and Primary Exporters of
Hazardous Waste, 30 TAC Subchapter A §
335.10
Requirements for Recyclable Materials and
Nonhazardous Recyclable Materials, 30 TAC
Subchapter A § 335.24
Adoption of Appendices by Reference, 30
TAC Subchapter A § 335.29
Hazardous Waste Management General
Provisions, 30 TAC Subchapter B § 335.41
Standards Applicable to Generators of
Hazardous Wastes, 30 TAC Subchapter C (j
335.61, §§ 335.65-335.70
Applicability of Groundwater Monitoring and
Response, 30 TAC Subchapter F § 335.156
Required Programs. 30 TAC Subchapter F
§335.157
Interim Standards for Owners and Operators
of Hazardous Waste Storage, Processing, or
Disposal Facilities, 30 TAC Subchapter E
§335.111
Interim Standards for Owners and Operators
of Hazardous Waste Storage. Processing, or
Disposal Facilities-Standards, 30 TAC
Subchapter £§335.112
Containment for Waste Piles, 30 TAC
Subchapter E§335.120
Permitting Standards for Owners and
Operators of Hazardous Waste Storage
Processing or Disposal Facilities, 30 TAC
Subchapter F§ 335. 151
Action to be Taken to Attain
Requirement
NORM waste remediation
Substantive requirements for licensing of
the radionuclide landfill (if required)
Removal of AST contents and off-site
disposal
Health and Safety Plan composed and
requirements implemented during
remediation
If USTs are located, the wastes will be
disposed off site or deep well injected in
a similar fashion to ASTs
Free product removed and disposed off
site
Carbon Filtration, Extraction and
treatment, direct NPDES discharge
Off-Site waste disposal for hazardous
slag, storage tank wastes, drum wastes.
and building demolition materials
Off-Site waste disposal for hazardous
slag, storage tank wastes, drum wastes.
and building demolition materials
Sampling and Analysis Plan should
comply with the requirements of these
regulations
Transportation and disposal for storage
tank wastes
Storage, transportation and disposal for
storage tank wastes
Perimeter well sampling and monitoring
Perimeter well sampling and monitoring
Storage, transportation and disposal for
hazardous slag, storage tank wastes;
drum wastes, and building demolition
materials
Storage, transportation and disposal for
hazardous slag, storage tank wastes.
drum wastes, and building demolition
materials
Impermeable cover over waste materials.
geomembrane wall in Acid Pond
Storage, transportation and disposal for
hazardous slag, storage tank wastes.
drum wastes, and building demolition
materials
Status
Relevant
and
Appropriate
Relevant
and
Appropriate
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Relevant
and
Appropriate
Relevant
and
Appropriate
Relevant
and
Appropriate
Relevant
and
Appropriate
Applicable
Relevant
and
Appropriate
-------
Table 3.12.2 - 1 ,
Action Specific ARARs
Remedial Alternative
APS, AST2, SS2, SL4,
NSL3, DR3, BUM
AP3, WP2. SS2, NSL3,
SL4
SL4.NSL3
All alternatives
AP3. WP2. SS2.NSL3,
SL4
APS. WP2, SS2. NSL3,
SL4. DR3, AST2
AP3, WP2. SS2, NSL3,
SL3.DR3.AST2,
AP3. WP2. SS2, NSL3,
SL4, DR3,. AST2
APS. WP2. SS2. NSL3,
SL4, DR3.. AST2
APS. WP2, SS2. NSL3.
SL4. DR3.. AST2
APS. WP2. SS2. NSL3.
SL4. DR3,. AST2
NSL3
APS. BLD4
APS. BLD4
APS. WP2. SS2. NSL3,
SL4. DR3. AST2,
Synopsis of Citation
Standards, 30 TAC Subchapter F § 335.152
Design and Operating Requirements (Waste
Piles)
30 TAC Subchapter F § 335. 1 70
Prohibition on Open Dumps, 30 TAC
Subchapter I §335.302
Hazardous Substance Facilities Assessment
and Rededication. 30 TAC Subchapter K,
§335.34 1 (b)(4)
Warning Signs for Contaminated Areas, 30
TAC Subchapter P§ 335.441
Waste Classification and Waste Coding
Required, 30 TAC Subchapler R § 335.503
Hazardous Waste Determination, 30 TAC
Subchapter R § 335.504
Class 1 Waste Determination, 30 TAC
Subchapter R § 335.505
Class 2 Waste Determination. 30 TAC
Subchapter R § 335.506
Class 3 Waste Determination, 30 TAC
Subchapter R§ 335.507
Classification of Specific Industrial Solid
Wastes, 30 TAC Subchapter R § 335.508(1)
Radiation Rules, 30 TAC §336
25 TAC §289.259
Clean Air Act (CAA)
National Primary and Secondary Air Quality
Standards (NAAQS) 40 CFR. § 50
TNRCC Historically Contaminated Sites:
Industrial Versus Municipal Solid Waste, July
12, 1994
Action to be Taken to Attain
Requirement
Storage, transportation and disposal for
hazardous slag, storage tank wastes,
drum wastes, and building demolition
materials
Impermeable cover over waste materials,
geomembrane wall in Acid Pond
On-site placement of NORM and non-
NORM slag currently piled on-site.
Compliance with Federal CERCLA
standards
Warning signs to be placed in areas of
waste consolidation such as the Acid
Pond and Area C
Waste will be classified in accordance
with these regulations
Wastes will be classified in accordance
with these regulations
Wastes will be classified in accordance
with these regulations
Wastes will be classified in accordance
with these regulations
Wastes will be classified in accordance
with these regulations
Wastes will be classified in accordance
with these regulations
On site disposal of NORM slag
Treatment systems and building
demolition/asbestos removal
Treatment systems and building
demolition/asbestos removal will comply
to these regulations
These procedures would be considered
prior to waste disposal.
Status
Relevant
and
Appropriate
Relevant
and
Appropriate
Relevant
and
Appropriate
Relevant
and
Appropriate
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
To Be
Considered
Key:
CFR - Code of Federal Regulations
LAER - Lowest Achievable Emission
RCRA = Resource Conservation and Recovery Act
USC = United States Code
TAC = Texas Administrative Code
TRCR - Texas Regulations for Control of Radiation
TNRCC = Texas Natural Resource Conservation Commission
-------
Remedial
Alternative
GW2
AP3, WP2
GW2
GW2
AP3, WP2
AP3. WP2
AP3. DR3, AST2,
NSL3, SL4, BLD4
NSL3
All alternatives
All alternatives
NSL3
SS2
SS2. BLD4
BLD4, SIS2. SS3
BLD4, SS2, AP3
BLD4, SS2. AP3
AP3, WP2
Table 3.12.2 - 2
Chemical Specific ARARs
Synopsis of Citation
Safe Drinking Water Act
Primary Drinking Water Standards (Maximum
Contaminants Level [MCL]), 40 CFR, § 141
Toxic Pollutant Effluent Standards, 40 CFR, § 129
Secondary Drinking Water Standards, 40 CFR, §
143
Maximum Contaminant Level Goals
(MCLG), 40 C.F.R. § 141,50
Federal Clean Water Act
Water Quality Criteria, 40 CFR, § 131
Hazardous substances. 40 C.F.R.
-------
Remedial
Alternative
AP3. WP2
AP3, WP2
AP3, WP2
NSL3
NSL3
AP3, WP2. GW2.
DR3. AST2.SS2
Table 3.12.2 - 2
Chemical Specific ARARs
Synopsis of Citation
Antidegradation, 30 TAC § 307.5
Application of Surface Water Standards, 30 TAC
§ 307.8
Numerical Criteria for Toxics, 30 TAC § 307.6{c)
Regulation of NORM Slag, 25 TAC §289.127
46TRCR§46.4(a)(l)(a)
Standards for Radiation Control, 25 TAC §289.202
Class 1 Waste Determination
Subchapter R , 30 TAC § 335.554
Action to be Taken to Attain Requirement
NPDES discharge to Wah Chang ditch
NPDES discharge to Wah Chang ditch, storm
water runoff
NPDES discharge to Wah Chang ditch
On-site placement under an impermeable cap
On-site placement under an impermeable cap
Excavation, drum and storage tank waste
disposal, soil disposal. Acid Pond and Wah
Chang ditch sediment disposal
Key:
CFR = Code ofFederal Regulations
LAER « Lowest Achievable Emission
RCRA = Resource Conservation and Recovery Act
USC = United States Code
TAC = Texas Administrative Code
TRCR = Texas Regulations for Control of Radiation
TNRCC = Texas Natural Resource Conservation Commission
Status
Relevant
and
Appropriate
Applicable
Applicable
Applicable
Applicable
Applicable
Remedial Alternative
AP3. WP2
AP3. WP2
AP3, WP2, SS2
SS2. SL4. AST2. DR3,
AP3. WP2
AP3. WP2. SS2,
NSL3, SL4. DR3.
AST2.
Table 3.12.2 - 3
Location Specific ARARs
Synopsis of Citation
Executive Order on Flood plain Management,
Order No. 11988
Fish and Wildlife Coordination Act, 16 USC
§ 661 et seo.
16 USC §742 a
16 USC §2901
Protection of Wetlands Executive Order No.
1 1990, 40 C.F.R. § 6.302(a) and Appendix A
General Application;
Proximity of New Construction to Schools. 30
TAC§ 116.111
TNRCC Historically Contaminated Sites:
Industrial Versus Municipal Solid Waste, July
12. 1994
Action to be Taken to Attain Requirement
NPDES discharges to Flood plain areas.
Modification of off-site drainages for NPDES
discharges not likely to occur.
Excavation, on-site placement
On-site placement. Acid Pond construction, deep
well construction
These procedures would be considered prior to
waste disposal.
Key;
CFR = Code of Federal Regulations LAER = Lowest Achievable Emission
RCRA = Resource Conservation and Recovery Act TAC = Texas Administrative Code
USC =• United States Code TRCR = Texas Regulations for Control of Radiation
TNRCC « Texas Natural Resource Conservation Commission
Status
To Be
Considered.
To Be
Considered
Relevant
and
Appropriate
Relevant
and
Appropriate
To Be
Considered
-------
3.12.4 Utilization of Permanent Solutions to the
Maximum Extent Possible. EPA has determined that
remedial alternativeSWS represents the maximum extert
to which permanent solutions and treatment technologic
can be utilized in a practicable manner at the site. Of
those remedial alternatives thatare protective of human
health and the environment and comply with ARARs,
EPA selected remedial alternative SW3 because it
provided the best balance of trade-offs amongthe other
remedial alternatives with respect to the five balancing
criteria explained in Section 3.9.9, "Summary of
Comparative Analysis of Site Wide Alternatives." Site
Wide Alternative SW3 represents the maximumextent to
which permanence and treatment can be practically
utilized at this site with consideration to State and
community acceptance. Remedial Alternative SW3
utilizes stabilization and water treatment to providea
long-term effective and permanent reduction of toxicity
and mobility for principal threats. Short-term
effectiveness and implementability were not considered
factors in selecting the remedy since the construction
methods and duration for each site wide remedy is
essentially the same for each alternative. Consequently,
cost effectiveness became the decisive factor. While
SW3 did not provide treatment for all contaminated
materials as did SW4 and SW5, SW3 recognizes that
some of the contaminants in the soil and slag are not
mobile and would not require stabilization to reduce
mobility. Consequently, additional stabilization would
be ineffective.
a preference for treatment as a principal element.
3.12.6 Five Year Review Requirements. Since
hazardous substances, pollutants or contam'nants remain
at the site above levels that would allow for unlimited us
and unrestricted exposure, EPA will Eview the remedial
action no less than once every five years after remedial
action was initiated. This review is to assure the
community that the remedial alternative continues to
protect human health and the environment.
3.12.7 No significant changes. There were no
significant changes made to the proposed plan in this
ROD. However, there was a minor change to SW3.
EPA substituted alternative AST2 for alternative AST3.
This substitution assures proper management of RCRA
K0052 listed waste.
3.12.5 Preference for Treatment as a Principal
Element. In accordance with CERCLA, EPA's
preference for treatment of principal threats is the
principle element of the remedial alternative. The
principal threats on site were identified in Section 3.5.29
"Contaminant Sources" and the preferred treatment for
each principal threat is identified in Section 3.10.4,
"Protection of Human Health and the Environment."
EPA believes that through the use of stabilization,*
neutralization and granulated activated carbon filtration,
treatment has been used to the maximum extent
practicableas discussed in Section 3.10.7, "Utilizatiorof
Permanent Solutions to the Maximum Extent Possible,"
above. Consequently this remedial alternative provides
In so far as stabilization alters the composition of the
hazardous substance through a chemical or physical means, it
is considered treatment technology as defined in the NCP
§300.5, "Definitions."
-------
4 RESPONSIVENESS SUMMARY. The
United States Environmental Protection Agency (EPA)
has prepared this Responsiveness Summary for the Tex
Tin Corporation Superfund Site (Tex Tin Site), as part cf
the process for making final remedialaction decisions for
Operable Unit No. 1 (OUNo. 1). This Responsiveness
Summary documents, for the Administrative Record,
public comments and issues raised during the public
comment period on EPA's recommendationspresented h
the Proposed Plan for the contaminated areas of the Tex
Tin Site, OU No. 1, and provides EPA's responses to
those comments. EPA's actual decisions for OU No. 1
are detailed in the Record of Decision (ROD)for OU No.
1. Pursuant to Section 117 of the Comprehensive
Environmental Response, Compensation, and Liability
Act(CERCLA),42 U.S.C. § 9617, EPA has considered
all comments received duringthe public comment period
in making the final decision contained in the ROD for
OUNo. 1.
4.1 Overview of Public Comment Period. EPA
issued its Proposed Plan detailing remedial action
recommendations for OU No. 1 for public review and
comment on September 9, 1998. Documents and
information EPA relied on in making its
recommendations in the Proposed Plan were made
available to the public on or before September9, 1998in
three AdministrativeRecord File locations, includng the
Moore Public Library located in Texas City. EPA
provided thirty days for public comment. At the request
of the public, EPA extended the comment period an
additional thirty daysand it closed on November 9, 1998.
EPA held a public meeting to receive comments and
answer questions on October 6, 1998, at City Hall in
Texas City, Texas. All written comments as well as the
transcript of oral comments received during the public
comment period are included in the Administrative
Record for OU No. 1 and are available at the three
Administrative Record repositories.
4.2 Comments and Issues Raised During the
Comment Period
Public Meeting, October 6, 1998, Texas City, City
Hall - Comments received at the Public Meeting.
COMMENT: Mayor Doyle: Good evening, lades and
gentlemen, and -welcome to this most important hearing
that's before us here this evening in our community of
Texas City and our neighboring community of La
Marque. I think it's very important that we put this
project in proper perspective. First, I'm sorry to hear
that we had a written request for a 30-day delay. If
someone hasn't found out all they need to know about
this project by now, they must havebeen living on Mars.
We have had this project before us twice. Most of these
kind of funds, when you're talking about placing a site en
a Superfund location, happens once. In our case it
started-- the first listing occurrel after extensive studies
and announcements and plans result back in August of
1990. I had just been elected Mayor in Mayofl990, and
the NPL listing was remanded in June of 1991 after legd
and other hearings, administrative hecrings. And it was
ordered deleted from the NPL in May of 1993.
Frustrated by that, the City filed suit against Tex-Tin
because since the Federalgovernment coudn't do it and
the State couldn't do it, we thought, well, at least we have
the power of— of legislation in the home rule city, we as
a city will try to do something about this. Andyoumight
ask, well, why was the City so frustrated over something
like this? Well, to find out that frustration, you have to
go back to 1939, the beginning of World War II. Of
course you know we were not involved in it in 1939. It
was not until 1941 that we became engaged in the war.
But I want to tell you about a little story about this
community. And I think it's very important the Federal
government learn this story. And I went to Washington
to tell them about it. So I'm going to kind of divergefran
the routine of a hearing like this proposed plan that
we 're going to be discussing tcnight. The Defense Plant
Corporation, called DPC, was operated by the Federal
Loan Agency and established on February the 24th,
1942. The DPC was dissolved and the function
transferred to the Reconstruction Finance Corporation
after the war was over on July the 1st, 1945. Well,
during that period of time when the war broke out, we
had no tin manufactured in — on this northern
hemisphere. It was a critical material that weneededfor
the war. And the construction of the tin smelter was not
at the request of this community. It was as a part of a
-------
national plan. The Federal government brought it here,
United States Government. And consequently after 1945
the R - RFC was abolished on June 30th, 1957. And
those functions were transferred to the Housing and
Home Finance Agency, which later, in September of
1965, became the Department of Housing and Urban
Development. In addition, other agencies assumed
responsibilityfor this site: The General Services Agency,
the Small Business Administration, and the Department
of the Treasury. Now those are all PRP's of this site.
There's 130 of them. My contention and our contention
has been the United States Government brought this
plant here. They allowed thisplant to stay here, and they
have a responsibility to clean it up as soon as possible.
Now that is a — the underlying program for this hearing
tonight and for what actions are taken in the future. On
September the 8th of this year I went to Washington. I
met with the Department of Justice at 1425 New York
Avenue Northwest in Washington D. C. I met with Joel
Gross, chief environmental enforcement of the
Department of Justice. And John Gregory. Lettie
Grisham, chief environmental defense; and Eric
Hosteller from the Department of Justice. And only in
the United States Government can we do that sort of
thing where you have on the one hand the defense
attorneys lined up working for the government and on
the right handthe prosecuting attorneys lined'up. It was
a very interesting meeting to come there and to talk to
our Federal government, who are going to represent part
of the United States Government that enforces and the
other part of the United States Government that is going
to try to defend those agencies. Now, the purpose of my
meeting was to address a GAO report, general
accounting office report of the United States Government
on the time required for the completion and assessment
clean-up of hazardous waste sites in this country. Non-
Federal sites listed on the NPL in 1966 took EPA 9.4
years from the time of discovery of the site. The clean-up
at the sites - that's for the listing. The clean-upafter the
listing of the sites averaged 10.6 years by 1996,
compared to 3.9 years during 1986 to 1989. You'd ask:
Why did it increase from 3.9 in '89, in that period to
1996? The number. That's why. There's a lot of them.
Now, my mission before that group and tonight, as an
opening statement, is that we need a fast-track
performance here. In the past one of the methods used
by the EPA for the clean-up of the site has been to bring
all 130 principal responsible parties, the PRP's, and
bring lawsuits if they cannot reach agreement — to put
the money on the table to start thzjob. My contention is
United States Government is the deep pocket that needs
to start the job. And then after theyfhish with that, they
can sue whomever they wish to recover the funds
necessary to clean up this site. In my statement to Mr.
Gross in a letter dated May 28th, 1999, I stated the
following -following: We understand that these and
other agencies - I've identified the agencies for you -
may not follow that approach based on the general belief
that they may not have specific statutory authority to
allocate funds - I'm talking about the Treasury
Department and all the list of other agencies — for
clean-ups like this and that the money for the clean-up
must come from a certain, quote, "judgment fund,"
closed quote, that can only be assessed after a lawsuit is
filed and a consent decree with the other PRP's is
negotiated. This runs counter to the view that Congress
articulated of Federal agencies' responsibilities under
the Comprehensive Environmental Response
Compensation and Liability Act, called CERCLA, and
EPA'spolicies relating to enforcement against Federal
agencies that have incurred CERCLA liability, which
clearly they've incurred the liability. It's documented in
the halls of the Congress, Library of Congress. All of
this is there. The EPA holds Federal facilities
accountable for environmental clean-up andwillproceed
with enforcementactions at Federal facilities in the sane
way that it would proceed against private facilities.
Now, today I faxed to our senators and our congressmen
a request that they ensure that these agencies are
budgetingfunds so that they will clean up andrmet their
responsibilities on this site just as other private
corporations are being asked to do. One of the things
that brings all of this importance to home in Texas City
is the fact this is not our first dealing with the United
States Federal Government due to the war. Every
community was impacted by the war. Every family was
impacted by the loss of a loved one or someone injured.
But no community in the United States was impacted by
the war like Texas City, Texas because in April 1947, on
April 24 the 16th and on April the 17th, two liberty ships
blew up in our harbor and they killed over 380 some-odJ
people. They injured almost 4,000 people, and this
community has suffered from that ever since. Lawsuits
were filed. On June the 8th, 1953, the United States
Supreme Court held that the United States Government
was not liable. But I think it's interesting to read from
the book that was written on this disaster where it says,
"The Coast Guard's failure to enforce dangerous cargo
regulations came to light in the Dalehite and — versus
United States, consolidated 273 suits for damages
relating to the explosion filed under the Federal Tort
Claims Act of 1946 on behalf of 8,487 persons. The
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claim by Elizabeth Dalehite and her son for the wrongful
death of her husband and his father went on trial in 1949
before Judge T. M. Kennerly in the U.S. District Court,
Southern Division of Texas. Millions of dollars were at
issue, including substantial claims insurance conpanies,
blaming almost every one else, including the
municipality — that's Texas City — stevedore firms,
longshoremen unions, and shipping. The United States
Government denied having any responsibility for the
deaths and injuries. Approximately 20,000 pages of
testimony and exhibits have been generated by the time
Judge Kennerly rendered his verdict just prior to the
third anniversary of these explosions. He found for the
plaintiffs, holding the United States atfaulton some 80
specific points. The appeal of this decision was
overturned by the Fifth Circuit court and confirmed on
a four-to-three vote by the United States Supreme Court
in 1953. Both the Court of Appeals and the Supreme
Court reached their decisions on the basis of the
meaning of culpability in Federal Tort Claims Act of
1946; that is, the Supreme Court majority thought that
the plaintiffs were not entitled to sue because the act
confined liability to specific acts of negligence and not to
tortious conduct. So, as you can tell, those of you who
represent the government in this case, there is a feeling
in (his communitythat we shared our part of the battle h
the war that we won in World War II. But we also paid
a big price for it that most communities did not have to
pay. I submit to you that Tex-Tin is an additional price
that we have had to pay. We have lived with that. We
live with it day in and day out, and when we were
frustrated by it being removed in May of1993, we took
them to our municipal court for failure to maintain their
building in a safe and sanitary condition. The reason
was the boiler was falling down and you could literally
see, drifting from it, all sorts of materials that could be
dangerous to those who passed by. On August 2nd in
1993 a plea bargain agreementwas reachedwherein the
defendants agreed to demolish certain structures and
provide some certain for landscaping — some funds for
that. The demolition was completed on January 1994.
On September the J 7th, 1996, without permission, some
parts of the plant were being removed. The — our fire
department responded, not knowing what they were also
engaged in entering that site, to the Tex-Tin site, fora
fire. The security company in charge of the property wa
cited for failure to provide fire watch. I guess you can
say we've had it. And so we went to the Governor. I
have letters here from the Governor, from both of our
senators, and from our congressmen to get this back on
track. And I do appreciate the EPA and the TNRCC, and
particularly Ralph Marques, who, at the time I was
elected in 1990, was appointed as the head of our
environmental committee, the first this dty has ever had.
And he has since been appointed by the Governor as ore
of the commissioners— three commissioners of TNRCC.
EPA, Myron Knudson. I couldn 't ask for more help than
we have had out of Region VI. We cannot allow
bureaucracy to stand in the way of this clean-up. We
cannot do things in the old, usual, customary way in this
clean-up. The Federal Government's hands are not
clean in this clean-up, and we want that message to be
loud and clear in Washington D.C. and the office of the
EPA and also with the attorney -- our -- general of the
United States and the justice department. Our objective
are to promote the commencement of the actual clean-ip
as soon as possible, and we support this plan. There will
be — should be no delay in the clean-up based on the
source of funds. United States Government stands
behind this, and they should be -- they weretalking about
how — what we're going to do with the surplus in
Washington now. I submit to you there is no lack of
funds. If Superfund money is not really available,
Federal PRP should stand and find for — and fund the
clean-up. Federal PRP's are held accountable by law.
I read that part of the law. Federal PRP's should
budget funds as appropriate for their Superfund site
exposure. And I have asked our Congress to do that.
Department of Justice should treat Federal PRP's at
least like private PRP's. Federal PRP's should lead the
clean-up effort at appropriate sites where funds are not
otherwise available. And if that happens to be the case
here, then we expect them to lead. Thank you.
EPA RESPONSE: We at EPA Region 6 also want to
expedite activities for the Tex Tin site. While EPA
cannot make up for harm that private corporations or
Federal may have caused to the communities of Texas
City and LaMarque EPA is working to ensure that the
public and the environment is protected from the
contaminants on site. As you stated, we too have been
working to list the site on the NPL since the early 1990's
to begin cleanup activities. Bit as you are aware, listing
this site has been challenged many times by the
companies that owned, operated or had dealings with the
Tex Tin facility. Some of these companies continue
opposing remedial activities suchas building demolition
and stabilizing contaminated waste materials. So the
delay to list the site has not been caused by EPAor other
Federal agencies. With respectto Federal agencies that
are liable for contamination at the Tex Tin siteJEPA will
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pursue their involvement in funding the remediation.
However, EPA cannot use its funding to pay for a
cleanup that may have been caused by another Federal
Agency, just as one city department cannot pay costs
incurred by another department. With respect to viable
potentially responsible parties (PRPs) for a site, EPA is
required to follow an enforcement process t> commit the
PRPs to conduct the cleanup. We continue topursue the
enforcement process to obtain commitments from those
responsible parties.
COMMENT: I've been real concerned about the
situation we have at — at the tin smelter. Having
experienced some of the things that we encountered on
the Motco clean-up, I'd Uketo pass these points on to this
group and for your consideration. First, thse of us that
have dealt with the contractors in the past — which I've
dealt with many of them down through the years - when
you get contractors, they will bid jobs and sometimes bit
them low in order to get the job. Now, there's several
reasons for doing that, and our first encounter with a
contractor at the Motco Trust site was that IT was given
the contract, being the low bidder. We fmaly found out
that their reason for getting the job was to use it as a
stepping stone — they're an international company — to
get other jobs throughout the world for neutralizing
hazardous waste sites. So I would caution any
contractors that are bidding this job, be sure that you get
a good bid on the thing, that they can make money on it.
Make money, but we want a good job. And come in
ready to do the work. We ran in to quite a few
difficulties, holdups on the job, in that we were dealing
with a Government Agency and we didn't have
cooperation in several instances where we weie hung up
to get clearance of some — one of the major things was
approval of the cap that we put on the thing. And EPA
did not give us a final answer on that. It cost us a lot of
money and a lot of time to work around that thing until
we got it finished. But now we've got it cleanedup. It is
a beautiful site. We had to put a retainingwall around
it to keep it from migrating contaminants to the
surrounding area. We don't have that problem here. But
it is a possibility, needs to be explored. We hope we will
be able to streamline EPA 's outdated laws where we cat
get to work on the thing and get it cleaned up properly.
So those of us that have dealt with it from a practical
standpoint can — going along with the Mayor's comment
we feel like the time is here, that we need to get the thing
done and get on with the work.
EPA RESPONSE: If EPA conducts the cleanup, we
will evaluate all companies that submit bids and hire the
most capable and responsive company at the lowest bid.
Consequently, the work may not necessarily be awardd
to the lowest bidder. We understand that companies in
business to make a profit should be afforded the
opportunity to make a profit by producing a good
product at a reasonable cost. Regarding the placement
of a retaining wall (slurry wall) at the Tex Tin site, we
investigated the contaminated ground water at the site
and concluded that a slurry wall or retainingwall was net
warranted. The Motco site has different contaminants
than those found at the Tex Tin siteand therefore a direct
comparison cannot be made between the Motcoand Tex-
Tin sites.
COMMENT: I'm a lawyer practicing here in Texas
City. I'm also the chairman of the Environmental
Protection Emergency Response Advisory Board for the
city of Texas City. I'm the chairman of the EPER board
for the city of Texas City. Our committee is comprised
of about 20 members. Our board is assigned the
responsibility to ^- to monitor and be aware of the
environmental circumstances within our city, whether it&
a matter ofaSuperfundsite or — or a matter of any otha-
environmental matter that — that might affect our
citizens. I want the EPA to know that we, as a committee
of citizens will be available to act as a — as a conduit
between the official operation of the city of Texas City.
I encourage EPA and TNRCC to take every action to
move this project forward. And if there's anything that
we can do within the city and through our EPER board
to facilitate the — the quick response at the ite, and then
we invite you to contact any one of us, either with me
directly or through Mayor Doyle.
EPA RESPONSE: We appreciate your offer to help and
welcome the opportunity to work with the EPER board
and find the pro-active initiatives the Mayor and the
community have taken to expedite the cleanup process
encouraging. EPA will be happy to work with the City
and the community to move the cleanup activities
forward. We appreciate the City's and community's
support and will work to address your concerns. We
know that the City has waited a long time for cleanup
activities to get started and understand its frustration, so
we ask the city and community to bear with us a little
longer as we proceed with the enforcement process
which we are required, by law, to follow. So while
construction site activities may not be going on, we are
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completing lots of legal, engineering and administrative
activities to get the field work started.
COMMENT: My concern — or two or three concerns
with the site, one of them being that both 519 and
highway — State Highway 146, which border the plants
on the -- 519 on the north side and 146 on the west side,
are both hurricane evacuation routes. And during high
winds there's a history of material blowing from there
and making it a hazard. Also in the past two years weve
had ten calls to the site for where public safety officers a-
police officers or firemen had to respond and had fair
fires and different other types of calls, such as suspicous
vehicles and stuff like that. So it's a danger. And plus
any child that might wander into that place.
EPA RESPONSE: EPA has placed a high priority in
addressing the contaminated site buildings to prevent
them from obstructing these roadways in case of an
emergency situation and causing a release of hazardous
substances. We are aware that some buildings are
seriously deteriorated and we believe that deterioration
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preferred alterative for the site. ,
COMMENT: Okay. And I would presume the - that
the City and the Mayor's office, they -would get reportsof
this monitoring system. I would presume the Mayor's
office in Texas City, City Council, every year or two
years would get a copy of the reports, because I — it's
just hard for me - it's hard for me not tounderstand how
come there hasn't been some migration there, possibly
the chemical makeup or whatever, because I knowon the
hazardous waste site at the Motco site, which he had
mentioned also up at Crosby, there was — there was
migration of chemicals that were way over the Old
Central Freight Yard at that time when they put the
slurry wall in. I just --1 just wondered— hopefully this
is not a quick fix for a long-range set of circumstances.
EPA RESPONSE: EPA will continue to place site
reports and site information at the Moore Public Library
to make information available to the public. If Texas
City officials would like to receive certain types of
reports, that can be arranged through our Community
Involvement Coordinator. Perimeter wells indicate that
site contaminants may have migrated beyond the
operable unit boundary in the Shallow and Medium
transmissive zones. However, these zones are not used
for drinking water sources in the down gradient directon
of the site. In the surrounding area, the shallow and
medium transmissive zones are used for industrial
purposes. Current perimeter wells do not exceed
industrial use concentrations for site contaminants and
therefore do not currently warrant a responseaction. The
contaminants at the Motco site are different than those
present at the Tex Tin site and a direct comparison of the
two site cannot be made.
COMMENT: If the remedy was not working, then
would funds be available for you to remedy a situation
immediately or in a — in a timely manner?
EPA RESPONSE: We believe that funds can be
procured in a timely manner to address the areas that
pose a risk to human health and the environment. The
cleanup that we are proposing for the site will not bea
quick fix remedy but a long term remedy that will reman
protective of human health and the environment fora
long time. That, in part, is why the cleanup will be
expensive; we want it to be as permanent as possible.
We will re-evaluate the effectivenessof the remedy evey
five years. If for some reason the remedy is not
performing as designed, corrective measures will be
taken so that the remedy remains protective.
COMMENT: You're the project manager. From the
EPA are you going to be the general contractor on the
site, or are you going to contract everything out?
EPA RESPONSE: The majority of the work at this site
will contracted to EPA or the responsible parties'
contractors. The current EPA site contractor is CH2M
Hill, an environmental firm known worldwide. If EPA
conducts the cleanup, CH2M Hill, through competitive
bidding, would hire the appropriate contractors or
subcontractors with the properspecialtiesto complete th;
work. The EPA project manager who will be overseeiig
that phase of the work is Carlos Sanchez.
COMMENT: Then I would presume that you would
also strongly recommend that when they come into our
city, that we do have local area people around here that
are very good subcontractors. And there are two or
three in the area that have 40-hour trained people. And
they have participated in the clean-up of sites in this
area. And I would hope that you would certainly
recommend that — that they solicit subcontract work
from the local area and from the Texas City and La
Marque area and not bring in from Dallas or Houston or
Oregon if we have qualified people in the area to take
care of their needs. I would hope that — I would ask thd
if— if you would do that. I'm glad we're going to get it
cleaned up.
EPA RESPONSE: EPA always encourages its
contractors to hire local workers and subcontractors and
we will do likewise for this site, and contractors
generally do so to keep their bids lower. Many of them
also understand the need to hire local workers and
subcontractors. It has been our experience at other
Superfund sites is that contractors do hire local workers
and subcontractors. So we would expect a similar
situation for the work at the Tex Tin site.
COMMENT: Well, I would hope that you would
possibly leave the project manager's name and so forth,
if nothing else, with Commissioner Carl Sulivan here or
the Mayor, and there might be some people that would
like — would possibly like to send themresumes or also
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send them qualifications to do the type of work that may
be necessary out there, because if there's no contractors
in Texas City that's on their bid list at the present time
and they already have contractors, then they will bring
contractors from —from Dallas, from Houston. And
there's people here that are qualified to do that -work.
So, like I said, I would certainly Ike for somebody in the
Texas City, City Council to have the contractor's name
and address and whoever their project manager or —
and/or contract administrator would be.
EPA RESPONSE: Carlos Sanchez (214) 665-8507 and
Glenn Celerier (214) 665-8523 are the two principal
project managers on the site. Please feel free to contact
them to ask questions. However neither project mamger
has the authority to directly hire contractors. EPA is
required to follow Federal acquisition processes to hire
its contractors. With regard to subcontractors EPA
cannot require the general contractor to hire specific
subcontractors. However, once a contractor is selected,
we would be glad to pass on that information to the city
council or whomever asks for it, so resumes or
qualifications could then be sent directly to the
contractor.
COMMENT: / had some concerns about what the
definition of— of fast track is. And so lalso am not sure
which remediation was chosen. Was it SW3 or SW6?
I'm not sure what the difference is between SW3 and 6,
other than injection of materials with SW6. Could you
explain a little bit more the differencesbetween those two
remediationsand exactly what the definition of fast tack
— the Mayor made a good case for the Federal
Government to pursue immediate clean-up. And
certainly hope that's what happens. But I would like to
have a forum understanding about the difference
between those fivo.
EPA RESPONSE: Fast track is used by different
people in different ways. But what we mean, is that we
we continually look for innovative ways to move the
remedial process along faster. In addressing SW3 and
SW6, essentially the only difference is the underground
injection component. In the proposed plan we
specifically asked for comments regarding underground
injection because we thought that disposing of the
contaminants deep underground would allow for more
surface area to become available for development.
Conversely landfilling and covering contaminants on
site, would restrict future development in thoseareas to
uses that would not require extensive excavation that
could disturb the contaminants beneath the cover.
However, there is a drawback, underground injection is
expensive. So we solicited comments from the general
public to learn ifthepublicbelieves deep-well injection,
is worth the added cost. In this case publiccomment did
not present any convincing arguments or supply
additional information to support deep well injection;
therefore, we determined that SW3 remained the
preferred alternative.
COMMENT: So the reason is just to free up more
area; it's not for any concern about leaching of that
material or that material being airborne? It's — it's all
— all industrial development? I mean that — that seems
to be — there's no concern about restoration of— of the
natural quality. It's all industrial level clean-up.
EPA RESPONSE: The deep well injection alternative
is a more permanent remedy that removes hazardous
materials from the surface environment and results in
more surface area being available for redevelopment.
Under the deep-well injection alternative, hazardous
materials would be injected into a deep zone that would
never be used for drinking water. The deep well
injection zone is about 5,000 feet below ground surface.
On the other hand, while stabilizing and covering
contaminantsis a safe remedy, it does have a limitation.
That limitation is there can not be any excavation
through the cover, and we believe that may limit
redevelopment of this site. Consequently, any
excavation would require additional specific
requirements to prevent the release of contain inants. If
the material was completely removed from the surface
through deep-well injection, then more surface area coufl
be redeveloped.
COMMENT: But you do realize there's other drilling
going on and from the past and future that there could be
dry holes that have not been plugged that could cause tte
site clean-up to back up, too. A lot of deep injection veil
on it.
EPA RESPONSE: If EPA were to have chosen
deep-well injection as a remedy it would ensure there
were no other holes and perforations in the confining
formations above and below the injection zone. The
injection process would also be carefully monitored to
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ensure that the confining formations are not fractured in
such a manner that material could not migrate out of the
injection zone.
COMMENT: S. J. Manuel, La Marque Mayor Pro
Tern. And in speaking for the citizens of La Marque, I
would like to thank Mayor Doyle for his time and effort
to return Tex-Tin to the Superfund list. I think this is
something that we've needed for a long time. Shouldn't
have been taken off of the list. I've got several quetions.
What happens to the material removed and how is it
handled in the final disposal? What happens to the
material that you remove until its final disposal, and
where does it go? Talking about the carbon and rock
and whatever we have on the surface that's
contaminated. We won't be moving it to another state or
anything?
EPA RESPONSE: The contaminated materials will be
treated and covered as described in the record of
decision. Once we begin the cleanup this material woud
most likely be moved only once to be placed in its
permanent resting place. The site materials will be
handled as little as possible to minimize cost. However,
specific materials handling and field activities will be
determined by the contractor. With regards to an out of
state shipment, there are no plans to move site materials
to another state. Under the preferred alternative, there
are some liquid waste materials that require off site
disposal, but there are permitted facilities within Texas
able to handle those materials. However, the site
contractor may elect to dispose of some material in
another state. In that case, EPA has to approve the
disposal facility and the state to which the material is
being shipped has to be notified.
COMMENT: What distance from the contaminated site
does the EPA test, and what process does it use to
correct the problem for the underground water and the
underground soil? The underground water, what we're
— we're looking at is there's some wells over here. I'm
not for certain as to what contaminantlevels we've found
in those wells, but they haven't shown us that there's any
— any problem right now. And what we're looking at is
using this ground-water and potential this groundwater
use would be for some industrial use, not for drinking
water use. Will you dril any kind of test well across the
highway to see if it has moved toward La Marque ? My
concern is we have some citizensin La Marque that have
wells that they still use to water their grass, their
gardens, and flower beds. What are the chances these
wells could be affected? Could they contact the EPA to
have those wells tested if they so desire? Well, there's
some people in the Lee addition and some on Shady Lane
— are the closest ones that havewells that are still being
used. And I was wondering if the underground water
could contaminate those wells.
EPA RESPONSE: The nature and extent of known
contamination was determined by detailed field
investigation of the site and surrounding areas.
Typically, the scope of site investigation depends on the
facility's operational history and information received
from the community. As the site invesfgation proceeds,
the site boundaries as determined by the presence of
contamination may either increase or decrease. Areas
requiring response actions will be based on areas with
site related contaminants that exceed regulatory oihealth
based levels. To date at this site we do not think drilliig
wells west of the siteor across Highway 146 is necessary
since numerous site studies and local hydrogeological
information shows groundwater movement towards a
south, south-easterly direction, away from the city of La
Marque. Therefore, wells that could potentially be
affected by site related contaminants would be located
down gradient of the site, towards Swan Lake and away
from La Marque. If any citizen has a concern with their
well water, they can report it to the Texas Department of
Health or the TNRCC.
COMMENT: / have experience during the early 1940s
at the tin smelter as a process operator. That is a mean
bugger; I can tell you that. But thankfully I got away
from that mess in the early years of my growing up.
Became an employee of Amoco Corporation. I've got
one question. I want to make a couple more comments,
too. In looking around and see how the industry
operates in all facets of chemical and oil refinery and
such, I see that there's a lot of expense involved. But for
the life of me and in the terms of all good judgment and
honest assessment and good decision-making, why in
Christ's world is it going to cost so much money to get
that thing wiped out? We do that all the time at Amoco.
We don't — it doesn 't cost that much money. I can't see
the 86 million. We wipe units away. They — they're
poisonous, too, but we don't have that much money
involved. And I just want to know why it costs so dogged
much. We 've torn down units much larger than that wih
a lot less money. I can tell you that. Like the Mayor
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said, the Government's money, and they're supposed to
have deep pockets, too. Well, I'm very thankful to God
and to all the members of Texas City hat seeing this has
possibly righted along the time used before and after.
I'm proud to see that you guys are in, taking good steps
towards the fact of getting that dad gummed thing wiped
clean. And I do mean clean in every respect.
EPA RESPONSE: EPA's remedy involves more than
tearing down the buildings. The Tex Tin site is a large
site with different contaminated components. We have
to address extensive site contamination and treat
contaminated materials to ensure they ro longer threaten
human health or the environment. The estimated cost of
EPA's preferred alternative is $28.6 million. It is
expensive but unfortunately, many environmental
cleanup costs are high. We evaluated numerous cleanup
alternatives that provided different levels ofprotection at
varying costs and determined Site WideAlternative#3 to
offer the best level of protection at a reasonable cost.
Site cost are considered when selecting cleanup
alternatives for the sie. However, the main criteria is to
protect human health and the environment. We believe
the preferred alternative meets these goals and is cost
effective. Comparisons of the work that Amoco
conducts to the selected Tex Tin cleanup are not valid
since the circumstances at this site are different than
those at Amoco.
COMMENT: I'm a physician in La Marque, and also,
for a time, developer here in Texas City and theSanta Fe
area. The — I want to offer my sympathies to the Mayor
about the delays. And I might state to you that in some
of the sites that I have worked with Jor example, the case
site, it took me 14 years to get the thing stopped. Many
times with EPA and solid waste people, TNRCC in
Austin, everything is in aider for a clean-up. I have met
all the criteria of the RCRA and clean air and clean
water. Yet nothing happens and I — and so I can
appreciate the frustration of our Mayor in looking at ths
Tex-Tm thing. The other thing that I'd like to briefly go
over with you is the overall health pictures of parts of
Texas City. This is a study that was done by the
University of Texas and was authorized by EPA. And the
date on this study was 1975. What it is looking at is it
stated air samples in vacuum bottles that had normal
saline in them. And those studies were done at several
sites here in the industrial area of Texas City, Anahuac,
across the bay, Corpus Christi, San Antonio, Odessa,
and one other city. At any rate, the findings are — are
frightening, to say the least. The amount of cancer in
this county alone is enough to spur on action by any of
the agencies. How it's goingto go, I don't know. But the
national average on lung cancer — is just one of the
cancers - is 37 per 100,000. State of Texas has 38.52.
Calves ton County has 55.2. The relevance to the
Tex-Tin site is it's only one of the problems here. I
certainly agree it needs to go. And some of the things,
the other areas you might look at, is the industrial canal
which is the main outlet today for the runoff from the
Tex-Tin. And 1 have here astudy that was ordered by the
US Fish and Wildlife. And it's a frightening study. I
mean there's 35 highly toxic agents there, hydiocarbons.
Hydrocarbon, mercury, and selenium. The rest are in
the benzene category. Now I hope that this study tktt all
— currently that's underway wouldinvolve the industrial
canal because it is really the major outlet of the entire
Texas City industrial system. Now whether these
contaminants are coming in from water or air that's
contaminating it, who knows. But the — all the bad
actors are here. And I would submit these copiesto you.
EPA RESPONSE: This proposed plan only addresses
the Tex Tin site. If you have information related to other
health problems, it can be provided to the Texas
Department of Health or the Agency for Toxic
Substances and Diseases Registry. TNRCC may want to
look at some of the other areas that you mentioned if yoi
provide whatever information you have. TNRCC can
then take action or request EPA's involvement.
COMMENT: / wish I could help the Mayor in urging
— in the urgency. If I knew how to help him, I'd help,
myself. I've been involved certainly initially with the
Motco site. I've had several that I did get closed down h
the Corpus Christi area, south coast The advantage we
have right now is that the Tex-Tin is the highly visible
thing. And I felt that's the only reason I was ever to
make any headway at Motco, whereby a Superfund— get
Superfund, if it's visible to thousands of people. And
Tex-Tin, with its horrible looking buildings has that
visibility. And I think with the heat on, I think we -- some
way if we could speed up these agencies, I'm here to
receive all the advice that lean get, including EPA and
the State of Texas, the — I've been with the State in
arguments beginning with water quality board, then the
department of water resources, and next is back to the
Texas Water Commission. And finally, thanks to our
woman in Austin, we've got a new one there and a very
fine man — sorry to the commission -finally after 14
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years went along -with me, went with me on stopping the
beginning site. At this point all they did is the materials
in the child. They just went down to Brazoria County
about 40, 45 miles and did the same thing here. I hope
that doesn't happen here. If-we're going to remove all
that stuff off site, we need to know wheie that site is. My
recommendation is at least 100 miles from the Gulf of
Mexico. I would like to see some of this material, if we
have to, hauled out to some of the counties in West
Texas, like Loving County. I think you cannot find a
water table. Give them everything they need. They
accept a lot of this stuff. I don't see how it could do any
harm. And I will be giving a lot of this material to you.
If there are any questions, I'd be glad to comment on
them. I haven't done justice to this report on cancer. It's
extensive, and it needs to be repeated and certainly
Tex-Tin is contributing to it. There's no doubt about
that. But you can't have the contaminants listed at
Tex-Tin standing alone. They're going to have to be
considered as apart of the entire picture.
EPA RESPONSE: EPA will work with Mayor Doyle
and the citizens of Texas City and La Marque to move
the cleanup of the Tex Tin site forward as fast as
possible. One of the main components of the selected
alternative for the site requires on-site treatment of
hazardous materials and on-site disposal. We believe
that this remedy will provideprotection to human health
and the environment and that it is cost effective. We do
not believe that disposing of site materials from the Tex
Tin site to another location will address EPA's goals of
providing protection to all areas of the country. We
don't think the communities in West Texas would be
receptive to hazardous materials being disposed of in
their community. As far as the Tex Tin site contributing
to more cancers cases in thecommunity, we cannot make
that determination. However, we do have information
that site contaminants can pose a potential health risk to
humans and that is the basis for the proposed remedial
action for the site.
COMMENT: I'm the president of Texas City and La
Marque Chamber of Commerce. Along with some
1,000-plus members, I would like to urge that the EPA
move forward with this project and fast-track it because
it is something that we have lived with for many years.
I've been here 57years and at one time my wife worked
a tin smelter. So I know a little bit about it. But one of
the things, too, that we would like to urge and just show
you, I think when you came into the city, Texas City —
and our citizens spend a lot of time and money andeffo*
to have a beautiful city. We have done a lot of
beautification, being one of the All American cities in tte
last two years. And one of the things that we'd like to
say, too, is we — we appreciate what the city has done
and we need some help cleaning up something that's
bigger than we can do. So we ask the Government to
help us out.
EPA RESPONSE: We appreciate your comments and
welcome the interest from the ciizens of Texas City and
La Marque in voicing their support of the cleanup effort
at the Tex Tin site We can see that the citizens of these
two cities are proud of ther cities and have worked hard
in the beautification campaign and we will do all we can
to expedite the cleanup process at the Tex Tin site.
COMMENT: It's been the policy of the EPA to go afia-
the — that's been involved in these sites,and usually they
wind up going after the ones with deep pockets and so
forth. And a lot ofthese companies declare bankruptcy
and it's drug out, takes a long time, takes a long time to
find them, and people claim that, I'm not responsible, the
one is responsible, back and forth, and these things is
drug out. And I think part of the frustration that the
Mayor was pointing out, that he's tired of fooling with at
this and he wants the Government to — to assume
responsibility. Now it's unclear in my mind as I leave
here tonight whether the Government has accepted this
responsibility or are they still on this old program, the
same program that they have, looking up these
companies that they've been looking for the last, you
know, 20 years or so. And the second thought was that
nobody has mentioned the eye sore. You know, we all
criticize the Federal Government. And I'm — I'm
included. But there's a lot of things that theGovernment
does that benefits us all and they do a lot of things
around here in Texas City. The ship channel, interstate
highways, flood controls, and so forth. And they're
really taking a bad rap on this thing right here. I mean
if there wasn't even any pollution, that's one of the
gateways to this city. You go over that overpass, and it
looks terrible. It's a disgrace. Union Carbide tried to
plant some plants out there. Now there might notbe any
contamination, but you look, there's no grass that grows
in the back of that thing. There's a bunch of pine trees
all dead. They won't grow. And it's a shame that as
much good as the Federal Government does in this
community that they take a beating. I mean everything
-- every time that thing comes up in the local
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newspapers, the Federal Government gets — gets
mentioned. But I wish you would answer my — the first
part of that question, whether y'all have accepted this
responsibility and— aid ready to move on with it, or do
we still continue this fight with the - our Congressmen
and everyone else?
EPA RESPONSE: EPA has an "enforcement first"
policy, which provides that if there areviable potentially
responsibleparties (PRPs) connected with the site, EPA
pursues those PRPs to conduct the cleanup activities
before spending taxpayer money on a remedial action.
While there are exceptions, this is the general policy
applicableto all Superfund sites. We deal with PRPs in
a fair manner and attempt to negotiate a settlement with
each one. It is true that this process takes a long time,
but we are required todo so. However, we attempt to try
settle with cooperative PRPs as soon as possible.
However, realize some PRPs do not want to enter into
agreements with EPA and such recalcitrant action may
lengthen the settlement process. So any delays starting
cleanup cannot be placed solely on the Government. Tre
Mayor and others are aware that just listing the site on
the NPL took many years because companies were
contesting the listing. The Federal Government is
negotiating its fair share of cleanup reponsibility for the
site, and EPA treats the Federal responsible parties the
same as we would treat private companies that are
responsible for the contaminatbn. As previously stated,
EPA can not assume the site liability for other Federal
agencies.
COMMENT: If we leave this meeting here tonight with
enthusiasm, if you go through the same program you've
been going through, we can expect some action
somewhere several years down the road. Let me aska
second question. Is there any way that it can be done in
two stages, to at least remove the eye sore first? I mean
that wouldn't be quite as bad. It would still have the
contamination. But at least we wouldn't have an eye
sore.
EPA RESPONSE: EPA appreciates the effort from the
citizens of TexasCity and La Marque to get the cleanup
of the Tex Tin site started. All we can promise is that ve
will work hard to move this process forward. We will
also explore ways of getting all or part of the cleanup
activities started at the site as early as posible. We have
had discussions with a group of PRPs and we think it
may be possible to use their contribution to commence
addressing the buildings.
COMMENT: I have a couple of questions. First of all
I'd like to say that I appreciate — I've been waiting for
one of these since — well, actually '90. My question has
to do with the pond across 146 that's not been mentions!
yet. Is this part of the site oris it not? The pond west of
146. A few years ago there were signs saying "arsenic h
the water," and that's why I was concerned. I didn 't see
anything mentioned about it here. Unless that part has
been backfilled, I was wondering if you were also —
getting back on the plans, 135, [sic] when you take the
water out, what will you do with the soil? Are you g)ing
to bury it or are you going to go through some of the
process?
EPA RESPONSE: The pond west of Highway 146 was
sampled as part of the investigations conducted for the
Tex Tin site. Areas outside the Tex Tin site boundary
become part of the site if site related contamination is
found in those areas. Based on the sampling data
collected from this pond, risk assessments were
conducted to determine the need for a response action
relating to Pond 22. Based on the risk assessment result,
we are proposing no response action for Pond 22. EPA
is unaware of warning signs being placed around Pond
22. If there is a health issue reated to fish consumption,
the Texas Department of Health (TDH) will make the
determination on the placement ofwarning signs around
Pond 22 to prevent fishing. The ponds within the Tex
Tin site will be drained and backfilled. A minimum of
24 inches of clean soil will be used to cover the site
ponds.
COMMENT: The ponds inside the plant where you 're
going to remove the water, you said you would take the
water and treat it or whatever. What about the soil
underneath that water? You won't remove the soil or
anything?
EPA RESPONSE: Except for the Acid Pond, sediment
contamination in the other ponds does not exceed
concentrations that would warrant stabilization or some
type of treatment. However, cortaminant levels in these
ponds exceed health based levels that require a response
action to prevent exposure to humans. Therefore, the
preferred alternative recommends covering those ponds
with 24 inches of clean soil materials to prevent exposue
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of those contaminants.
COMMENT: What about the foundations? Will you
remove those from the site when you take the structure
down, or will they remain thereand cap over? There are
pretty good size foundations in there. And then asecond
question along those lines, would you remove the
buildings— is it your proposal to come in withsome sort
of mechanical device and cut them down, or will you
actually be removing them with acetylene torch, et
cetera? Will you require that those individuals that are
going to work out there on the asbestos have the
required, trained as specified.
EPA RESPONSE: The site foundations will be
removed to the extent required to clean up the site
contamination. In some cases, not all of the building
foundations will be removed. Remaining foundations
will be covered with clean soil. The buildingdemolition
will be conducted in a controlled manner to prevent
release of site contaminants to the environment. The
demolition contractor, with EPA approval, will
determine demolition methods. Site workers are reqiired
to meet specific training standards for the work they do.
Workers involved with the asbestos cleanup will be
required to meet the asbestos abatement training
requirements.
COMMENT: Hive in Houston, Texas, Harris County,
the home of 17 state and Federal Superfund sites. My
Ph.D. is in geology. I am a registered professional
geologist in the state of Kentucky, No. 446. I'm a
certified professional geologist, No. 4485, with the
American Institute of Professional Geologist, No. 2445,
with the Society of Independent Professional Earth
Scientists. I'm a Certified Fraud Examiner, No. 2285,
the Association of Certified Fraud Examiners. I am an
independent geoscientist consultant that has applied
geology and geophysical methods to oil, gas, and
environmental problems for more than 20 years. My
clients are risk averse. My opinion is that the best — tbt
the applied geology and geophysical methods used at
Tex-Tin were in fact not the best availatie or state of the
art, leaving the public at an unacceptable risk. You
propose SW No. 3 alternative actions for 28.6 million
dollars. I recommend that the EPA safely demolish the
buildings at this site at its own expense and provide the
28.6 million dollars directly to Texas dp for reparation
and restitution for damages to Texas City'senvironment.
That's the air, water, and land, its cilmns and residents.
It is unconscionable thct both US EPA and the State of
Texas have provided insufficient dati to support that the
location and that the monitor wells are placed
appropriately to protect the public drinking water supp^
even if the pits and ponds were capped. I have three
technical areas of concern: One, the first, did you
accurately outline the area of contamination; secondly,
did you accurately determine thedepth of contamination;
thirdly, allowable levels of chemical exposure. First, the
area for Operable Unit 1 appears to be inconsistmt with
historical best available or acceptable engineering waste
disposal practices. Let me briefly explain. The area
outlined for Operable Unit 1 is defined by surface
political boundaries, such as roads, railroad tracks, and
ditches. Historical engineering practices for waste
disposal placed landfills in waste disposal pits at or necr
moving water. The solution to pollution was dilution.
This was in films in the training sessions I had. Waste
fluids could migrate vertically and laterally away from
the landfill and independent of political boundaries.
Professional engineerswho 1 service and I want to know,
do you have the authority to waive liability to third
parties outside Operable Unit 1? Secondly, regarding
depth of contamination, the depth of contamination is
influenced by two things: The depth of the pits with
buried tanks, drums, wastewater and radioactive waste
with respect to the underground drinking water supply;
and, secondly, the depth of the waste that was injected
from the underground injection control well, which was
about I mile below the public drinking water supply.
The samples from core holes seem to be limited towithin
Operable Unit I's outline in less than 80 feet deep. Yet
did heavy chemicals from the pits and ponds wide rank
deeper than 80 feet as alMotco where the contamination
was at 300 feet below ground level? Is waste from the
underground injection control well moving upward
along fracture zones and contaminating the drinking
water supply? In my professional opinion, today's best
available, state-of-the-artgeophysicd technology that is
critical to delineatingthe areaand depth of underground
fluid pathways and barriers for Tex-Tin includes the
three-dimensional, high-resolution seismic reflection
survey. The surveyed area would include but not be
restricted to the 2-and-a-half-mile area of review
required for underground injection control wells. This
is important if the 10,000 year non migration clause is to
be enforceable and to protect the long-term drinking
water supply, at least lower the risk of contamination
from the bottom up. A well-designed, three-dimensional
high-resolution seismic reflection survey delineates
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buried, inactive faults. Faults control the oil and gas
production in this area, faults that couldbe reactivated
by groundwaterwithdra\val. Butdoesnl Texas City still
use groundwater for its public water supply?
Appropriate, wel!-designed,3-D, high-resolutionseismt
surveys document the continuity of underground harries
between wells more accwatdy than the well data alone,
the continuity of underground conduits to flow more
accurately than well data alone and provides more
accurate geological and engineering groundwater
models. You did not use available, appropriate
nonintrusive geophysical methods to help delineate the
area and depth of contamination prior to placing
monitor wells. Lastly, allowable levels of chemical
exposure out of Operable Unit 1 also appear to be
politically defined. According to the sections of the wojk
I read, either no background data was available for
certain chemicals, no samples were collected, no
historical environmental baseline wasset, and threshold
values ignored. And where the state and Federal levels
differ, the higher value to health was ag-eed to. I agree,
do you have the authority to waive liability to third
parties outside Operable Unit 1? You propose — in
summary, you propose — that I repeat — SW No. 3
alternative actions for 28.6 million dollars. I think it is
unconscionable that both the state and Federal
environmental regulatory agencies have failed to
practice safety first in Superfund sites, leavingthe public
exposed to hazardous chemicals. The Mitral
Management Service, United States Geological Survey,
the Department of Defense, and Department of Energy's
national and regional research and development labs,
and Amoco Corp., and the Texas geological survey have
used high-resolution seismic reflection programs for
decades. Therefore, EPA should safely demolish the
buildings at this site at its own expense and provide the
28.6 million dollars directly to Texas Ctyfor reparation
and restitution for damages to the city's environment,
citizens, and residents. What you did is legal, probably,
strictly speaking. What it is not appropriate or the best
available technology, even whenyouhave in your agreed
order resistivity, the resistivity meantthat it may not have
been appropriate for what you're doing. So I'm very
disappointed, but — and I know I'm an outsider, but thats
my opinion.
EPA RESPONSE: EPA cannot provide compensation
or reparations to Texas City or the community for
damages that may have been caused by other Federal
Agencies or private companies. EPA can provide
funding for the cleanup of contamination if viable
potential responsible parties are not found for a site. As
far as waiving third party liability determinations are
handled that will be determined by EPA in consultation
with the U. S. Department of Justice on a case by case
basis, based on the facts of a party's involvement with
the site and whether it contributed to the site
contamination. EPA uses highly trained personnel to
determine the appropriatesampl ing methods and samples
that are collected at Superfund site. We rely on the
expertise of professional engineers, toxicologists with
Ph. D. degrees, geologists with advanced degrees and
other highly skilled, practical andexperienced personnel
to make the decisions at Superfund sites. We want to
emphasize that the geotechnicalinvestigationsconducted
for the Tex Tin site are appropriate for the goals of
identifying contaminated areas that may pose a risk to
human health and the environment and feasible, effective
response action under Superfund, particularly the
National Contingency Plan. The goal of these studies is
to generate site specific information which isappropriate
for use in the administrative process of remedy seledon.
The studies on site were not to identify potential
geological formations for oil or gas exploration or other
purposes as would be used by oil companies. We used
proven, EPA approved sampling and analytical
techniques at the site to determine the nature and extent
of the contaminants of concern. As a matter of fact, the
most extensive investigations conducted at the site were
conducted by a contractor hired by Amoco Corporation,
an oil company. Although modeling isan excellent way
of predicting what may be found in the field, only actual
sampling and analysis can estimate the true nature and
extent of contaminant distribution on site and this was
done at the Tex Tin site. Samples were also analyzed fcr
radiological content. We believe that the sampling
techniques and analytical methods used at the Tex Tin
are reliable and have accuratelyestimated the nature and
extent of contamination necessary to select a remedy for
the site. Therefore; we are confident that by using the
results obtained from the site investigations,acleanup of
site contaminants can be conducted which will provide
long term protection of human health and the
environment. Risk assessment methods based on
national criteria were conducted for the Tex Tin site
using site specific data to determine the risk that site
contaminants pose to human health and the environment
These risk assessments are conservative estimates based
on various exposure scenarios. We believe that the risk
estimates identify areas that require response actions to
address site contaminants.
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COMMENT: I have a genuine concern about the
actual work that's going to be done. What's the
methodology of the material removal for, like, ponds,the
dirt, remediation stuff? Is there any method disclosed
yet?
EPA RESPONSE: Specific remedial action methods
have not been determined at this time and will not be
determined until the remedial design and work plan
stage, after the site remedy has been selected. We have
some ideas, but we want -the cleanup contractors to
propose methods that they would use to conduct the
cleanup. If those methods achieve the cleanup goals for
the site, we would have no objections. To some extent,
we want to give contractors a choice on cleanup method
that are used; we want them to be innovative. Different
contractors have different ways of conducting site work.
Some of the work could be performance based, as long
as cleanup goals are met. More specific details on
construction activities, cleanup methods^nd monitoring
will be included in the remedial design document.
COMMENT: My concern is with the removal of
material. I've seen a lot of material used with backhoes
and OSHA approved suits, and there's a lot of airborne
contamination. There's a lot of people hurt on the job.
There's a lot of new, modern techniques and technologies
back there — not only my company, there's a lot of other
companies. I think that it should be addressd or looked
at. It should be done in a new, state-of-the-art type of
equipment so that it does not affect the residents around
Texas City and also the workers who are going to be
working there, from wherever they come from.
EPA RESPONSE: Methods or plans and specification;
regarding site cleanup activities will be developed as pat
of the remedial design for the site. TheEPA requires that
the contractors safely handle hazardous materials such
that contaminants are not released to the surrounding
community, and that site workers are protected and not
put in an unsafe situation. We require contractors to
comply with all OSHA regulations in conductingcleamp
activities. Worker safety for chemical and physical
hazards is one of the major priorities at Superfund sites.
Materials are tested before determining the safest and
best methods to handle and dispose of hazardous
materials. All of these precautions are also taken with
the surrounding community in mind. Wedo not want to
cause an on-site release that may inpact the surrounding
community. We require extensive monitoring to ensure
that site activities do not result in releases of hazardous
materials to the community. Trigger levels will be
specified for air monitoring which would stop site
activities or signal the need for modified work practices
before reaching hazardous levels which could potentidly
affect the surrounding community. The EPA is not
opposed to contractors using new modern construction
techniques and technologies. Again, construction
activities will be further defined in the remedial design.
COMMENT: When will the ROD be ready.
EPA RESPONSE: After the Public Comment period
has ended, EPA will evaluate all comments before
selecting the remedial action for the site. Depending on
the number of comments submitted and if additional
analyses are needed to address comments, the process fir
signing the ROD usually takes three to four months.
This includes preparing the ROD documentwhich details
the selected remedy for the site, responding to public
comments, and involvingthe Stateand other agencies in
reviewing the ROD before the final document is signed
by EPA's Regional Administrator, hopefully in early
1999.
COMMENT: / own the 10 acres on Highway 146 due
west of the tin smelter and own a steel company that
operates out of that location. Early Nineties I believe it
was the Texas National Resource Conservation
Commission was doing testing at these sites on my place,
on -- on the lake that's west of— of the tin smelter, and
y 'all keep referring to the fact they haven't ben tested or
you don't have reports on that? Are you aware of the
tests that were done, the soil samples and the well
samples and the testing in the lake? And in La Marque
also. But no one is referring to those tess or the results.
And you sound like you 're going to retest again.
EPA RESPONSE: We are aware of the investigations
conducted at those areas. Sampling and testing have been
conducted for Pond 22 located on the west side of
Highway 146 and in some residential areas of La
Marque. The EPA is not recommending additional
testing for Pond 22. However, there are some concerns
related to the consumption of fish from Pond 22. The
Texas Department of Health may decide to test fifa from
Pond 22 to determine if there is a need topost a fishing
advisory or ban. The residential areas of La Marqie will
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be addressed as Operable Unit No. 3. The need for
additional sampling or a response action for those areas
is currently being evaluated.
COMMENT: What was in that lake? The water, the
sediments in the bayou that were sampled in '92. It's in
the remedial investigation report.
EPA RESPONSE: You can find the results of the pond
sampling and other sampling conducted in 1992 are
included in Remedial Investigation reports prepared for
the site which are part of the Administrative Record for
the site. This information is available at the Moore
Public Library in Texas City. Results from the
investigations conducted were used determine if the
ponds pose a risk to human health and to prepare the
Ecological Risk Assessment (ERA) for the site. The
results of the risk assessment and ERA did not indicate
a need for a response action. Fish samples were
inconclusive. However, indications are that follow up
testing of the fish edibb parts are needed to determine if
a fish consumption advisory is warranted.
COMMENT: So you don't have to go back and do
everything again. I'm Just — I'm more concerned becave
what my understanding was when the initial testing was
done that there wasn't anything harmful except minor
traces of arsenic — is what I was told. Now since this
time we had the collapse of the furnace that the Mayor
was talking about. And I mean it was awful. We had a
tremendous cloud, gas that came over us, or dust or
whatever it was. In addition to Chief Purdon was saying
about every time the wind blows, we get a tremendous
amount of dust, debris. No telling what blows in on us.
And this fast track that you keep talking about sounds
like it's an unknown. And I wish that y'all could give us
a little better time schedule as far as what the
Government is going to do and how fast they're going to
do it because every day I've got my employees out there.
And we're at risk, and we need to move on it. And I just
think it's awful that we keep getting caught up in the
gridlock that goes on that we all hear about all the time.
And I respectfully request that the EPA and the State of
Texas resources go after it and get it done.
EPA/TNRCC RESPONSE: Several investigationshave
already been conducted in and around the Tex-Tin Site,
including these ponds. Therefore, we do not beleve that
additional soil, sediment, or water sampling is needed.
The EPA and the TNRCC have discussed what is in the
pond, what they are used for, i.e. fishhg, and whether or
not consumption of fish from the ponds poses a health
risk. The Texas Department of Health (TDH) evaluates
the risk of exposure to contaminants through fish
consumption, and we defer to the TDH in this matter.
COMMENT: / was wondering what the time line was
on the proposed object 1 activity. Is number— is it yeas
or months, or just what kind of time line is that? The
other is, is if you finish this proposal by the end of
December, as you — as you think you will, when would
you expect to get started?
EPA RESPONSE: The public comment period for the
Proposed Plan ended on November 9, 1998. EPA will
evaluate all comments before selecting the remedial
action for the site. Depending on the number of
comments submitted and if additional analyses are
needed to address comments, the process for signing the
ROD generally takes three tofour months. This includes
preparingthe ROD document which details the selected
remedy for the site, respondingto public comments, and
involving the State and other agencies in reviewing the
ROD before EPA's Regional Administrator signs the
final document. If we enter into an agreement with the
PRPs soon after the ROD is signed, it will probably be
about a year before the actual site cleanup will start. The
first step will be to complete the remedial design and
prepare the plans and specifications for the site. Second,
contractors have to be selected. Consequently, as you
can see, two substantial components of work must be
completed before field activities start.
COMMENT: I'm a little concerned that some of our
citizens out here might go away from here thinking that
the environment in this city is — is extremely dangerous
for them to be in and is liable to cause them to be ill in
some way. And I want to emphasize to you, do a little bi
of a commercial on the community advisory (CAP) thing
I don't know how many of you know that our city has a
community advisory panel that's made up ofciizens that
attend these meetings once a month. They are facilitated
by a person that does an outstanding job. They're
attended by industrial representatives that bring us
information all the time about what's being done to
improve the environment n our city. And so it's open to
citizens. If you're not aware of it, you'd like to attend,
visitors can come into that meeting. I don't doubt thatas
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this project gets underway, there yvillbe reports made to
the CAP on a regular basis and so -- so that committee
in all likelihood will be monitoring what goes on at this
site just as will the Environmental Protection Emergeny
Response Advisory Board for the city. One of the things
that — one example of the type of information that we are
brought every month, we got — only last monh we had a
toxic release inventory data that is prepared by Global
Industry and submitted to EPA. It won't come out in any
of the EPA publications for probably a year, but we got
this last month. And in all — it looks better every year.
That is, it shows every year a reduction in the — in the
emissions into the atmosphere from local industry.
Another thing that we got just recently is the data that is
produced by the Texas City-La Marque community air
monitoring network. I don't know how many of you are
aware we do have an air monitoring network that
measures continuously about 500 differentchemicals and
substances that might be in our air. And I want t> say to
you, my interpretation of that data that we've received
only last month is that the air in this city is better than
many cities that you might go to on your vacations. So,
I say to you, don't go away from here thinking that the
air you're breathing here every day is going to give you
a 55 percent better chance of having cancer than some
other city that you might live in.
EPA RESPONSE: The Toxic Release Inventory (TRI)
information is available to the public through EPA's
Region 6 Internet Website. Additional information
regarding the City's air quality can be obtained by callitg
EPA's office in Dallas, and I believe the TNRCC also
has air quality information available for the public.
COMMENT: Can I make one brief comment along
Charlie's line, I don't know if you was on that committee
at that time or not, but several years ago, seemed like it
was in the time of two or three years, the EPA officials
come before this committee and they — one of the reason*
why they told us that this site was taken off the Superjuid
list was that there wasn't any significant contamination
off site. Now, this is their words, not mine. But they
assured us, they assured the officials of Texas City, that
the contamination off site was — was not of any danger
to, you know, human beings. They said it was minimal.
So only thing I'm trying to say is that they said at that
time that the surrounding people wasn't in any great
danger. Now I share this, gentlemen, I share the fact
that it should be cleaned up and there is a potential for
this — and it's not my words. It's their words. But I'm
just trying to echo the fact that it's not a great danger in
the La Marque area from — according to the EPA. But
I hope that they check it again and get the thing cleaned
up.
EPA RESPONSE: There is contamination at the site
that warrants action on site andin the surrounding areas.
EPA has investigated the residential areas of La Marque
that are closest to the smelter which could have been
impacted by air deposition from the smelter operations.
We have designated the potentially affected residential
areas of La Marque as Operable Unit No. 3 for the Tex
Tin site. By doing this, we are tying the arsenic
contaminated areas of La Marque to the Tex Tin site.
The residential areas of La Marque will soon be
addressed as OU No. 3
COMMENT: I would just like to know what we can do
besides writing our Congressmen and our Senators to
make sure that you all stay on this very fast track hat we
think is so important and that there not be more 30-day
extensions. I mean how do you stop 30-day extensions
and keep this process rolling? What else do we need to
do?
EPA RESPONSE: The 30-day time extension to the
comment period was requested by those involved with
the site, and if requested, EPA is required by law to grart
such an extension. At this point, there is nothingthat can
be done to stop the time extension. Beyond that, you cai
get involved by attending meetings such as this and
participating in the Superfund process. There is a
Technical Assistance Grant (TAG) available for his site.
We believe TAG's are an excellent way for citizens to
become involved in the Superfund decision making
process. That will help. Forming a Community
Advisory Group for the site can also help move the
action along.
COMMENT: I'm still concerned about your contractor
You say you have a contractor. Is he on a cost-plus basis
just as an advisor to get this plan detailed, formulated?
Or where do you stand as far as getting the work done?
EPA RESPONSE: EPA has not selected a contractor to
conduct the cleanup work for the Tex Tin site. We are
now in the process of selecting a remedy for the site.
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EPA's contractor prepared the feasibility study for the
site and provided technical assistance; that contractor wil
continue in that role until we begin the next phase of site
work. At that time, EPA's contractor will either oversee
the cleanup activitiesif these activities are conducted by
the PRPs or the contractors that conduct theconstruction
or manage the cleanup activities if EPA conducts the
cleanup. EPA's contractor is paid on a level of effort
basis. EPA controls the work assignment for the work
that the contractor conducts for the site.
EPA RESPONSE: Community participation is an
important of part of the Superfund process. We do trust
the communities of Texas City and La Marque and we
hope that you will continue to trust us. We will be
honest in the responses we give to you and in the
information we provide to you. Sometimes youmay not
like what we say, but we will try to give you the right
information. We hope you do not lose your patience
with us and continue to work with us in getting the site
cleaned up.
COMMENT: We found in the Motco site that a public
relationsfirm was concerned with the thing and kpt our
community well informed as to the activity of the site.
Worked out real well until we wound the thing downand
we had some upsets on the thing that kind ofcdored our
final clean-up on ths thing. But would you mind having
a group that will keep our general public advised to the
detail as you go along and include local citizens' input to
this thing?
EPA RESPONSE: EPA's community involvement
branch will handle the release of public information and
conduct other public involvement activities. If you are
interested in having information mailed directlyto you,
you can ask Donn Walters to place your name on the ste
mailing list. Additionally, as activities proceed, we will
be conducting open house meetings to keep the
community informed regarding ste activities. There are
two other meetings that are typically planned for all sites
after signing the ROD. When we complete the design,
we have an open house in whichthe public can come and
take a look at the design and we can again listen to
concerns and comments. When we start the remedial
action, before the contractor begins work on site,we will
visit the community and explain to the community whafs
going to happen. Additionally, EPA would encourage
the community to form a Community Advisory Group s>
that there can be better interaction between the
community and EPA.
COMMENT: I want to see, for this lady here and
Sheqffer, about what do we need to do. What do we have
to do to get it done? That's what these people are trying
to find from you. Now do we need to go and get some
light petitions, or you guys goingto trust us like we trust
you? It's like Brother Reagan said when he kissed
against that wall withKruschev. "Yes, we trust you, sir,
but sign here," when he went to kick that wall down.
COMMENT: I'm probably the only member here save
the tin smelter tonight. But in he process of tearing this
thing down, can you maneuver this stuff around and put
you a membrane in there before you cap it off? And the
second thing is, you're talking about building a big
shipyard down here along Snake Island. Can we use
some of that fill there possibly or can this thing be
converted for an area, assembly area, for this dock? In
the process of chewing your problem in one place, you
might be creating another one. But you 're gong to need
a marsh land area for the material thatcomes in on these
ships. Can this building possibly be salvaged to use for
steel storage or whatever have you in the process of
moving it off of ships and all? I know right now your big
problem is you want to get rid of the thing. But to me
there's a salvage value there and this thing could
possibly be used for other things rather than just tear it
down and putting it on the end of the property here.
EPA RESPONSE: As far as using a membrane, the
landfill design for the site materials will be based on the
materials being disposed of inthe landfill. That will be
addressed in the remedial design. One of the plans was
to leave the buildings intact. However, many of the
structural connections in the buildings are badly corroded
and there would be a lot of work required to shore upthe
buildings. In addition the buildings have to be
completely decontaminated from the contaminated dust
that's accumulated over the years. It's our opinion that
for some buildings the best thing to do is to just take
them down and landfill them on the site. However, if
some parts of a building can be adequately
decontaminated, they can be sold as salvage materials.
The conservation assumption in the proposed plan was
that all building materials and debriswould be landfilled
on site. As far as using fill materials from other
locations, that is acceptable as long as the fill materials
meet the site requirements. Those requirements will be
specified in the remedial design. Activities being
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conducted at Snake Island are not part of EPA's
construction for the Tex Tin site. But, if the timing can
be worked out and the materials meet the specifications,
we would not object to the use of fill materials from that
location.
COMMENT: If you mentioned Swan Lake, this stuff ha;
been running off for 40, 50 years, 60 years into Swan
Lake. Do we have a total contamination down there, or
are we going to have to tackle Swan Lake next after this?
Possible it was their whole idea onthis scene here is not
to disturb more contamination, to spreadcontaminaion.
If Swan Lake is okay like it is, I say leave it alone; don't
disturb it.
EPA RESPONSE: EPA has conducted an investigation
in the Swan Lake salt marsh area. Preliminary
indications are that some small areas of the Swan Lake
marsh may require a response action. The contaminafcd
areas tend to be Ihiited where the historical Wah Chang
ditch emptied into Swan Lake. The Swan Lake reports
are being finalized to determine the full extent of
contamination and what areas may need a response
action. We have designated the Swan Lake Salt Marsh
as Operable Unit No. 4 of the Tex Tin site so that we
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bid conferences, prebid conferences: We do that real
well here in Texas City because we've had over —
between 300 and 400 million dollars in new expansion in
our industries since 1990. We have never had abatement
used before I became Mayor. But we have had six
projects now. We know how to bring in all of the local
people, the suppliers, fie contractors, and sit down with
the general contractors and talk to the subcontractors
and bring in our o\vn subcontractors and get them
talking. And we have good rules and also oversight
techniques under our abatement project to make sure
that our local people are put to work. I would strongly
encourage you to allow us to participate in that with
your general contractor. We will make sure they use
local labor. We will not run your costs up and they will
use local businesses and local materials that can be
bought here. Training: We have a safety council on
Sixth Street. They restored one of our old action — that
we didn 't tear down and they can teach your people good
safety techniques that are goingto work on this job. We
have a College of the Mainland that can teach people to
properly handle these materials if you need to train them
I'm glad to hear that December '98 will still be the ROD
date that you're going to shoot for because I was really
concerned that was going to be pushed back. I would
like for somebody to tell us the day work will start in
1999. And until I hear that, I'm going to keep asking
Senator Kay Bailey Hutchison and I'm going to keep
asking Senator Gramm and your staffs, if you're here
tonight, and Congressman Lampson, to find that out for
us. I can assure you the citizens of Texas City won't let
me duck a question like that, and I'm not going tolet you
duck it either. Funding made available to the Federal
Government by those agencies who are the successors to
the Defense Plant Corporation. Again I want to mentiai
them because I don't think you were here when I
mentioned them earlier. General Services
Administration: well-knownname in Washington, inside
the beltway. Small Business Administration: another
well-known name. Department of Housing and Urban
Development, HUD. We also have the Department of
Treasury. Now, if there's not funds therefor this, you're
just trying to put us on. And we are not going to accept
"no funds available" as an answer. Department of
Justice. I've met with them. They should enforce on the
Federal agencies who are PRPs with the same rules, the
same enthusiasmthat they enforce on private PRP Is. Th
US Supreme Court, in closing, in 1953 told our people
no after six years of trying to get some money out of the
explosion of the
Grand Camp. // took Congressman Thompson to get the
bureaucracy to move. And on August 12th, 1955
President Dwight Eisenhower signed the bill and about
17 million dollars were paid to 1,394 persons in Texas
City. Nine years. That's too long. We need to have
some action immediately here. Again, thank all of you
for coming tonight. And I assume we're adjourned:
Comments submitted by Terralog Technologies USA,
Inc. by report dated November 2,1998.
TERRALOG COMMENT: The Proposed, Plan of
Action, dated September 9, 1998, describes six site wide
remediation alternatives for the Tex Tin Corporation
Superfund Site. The EPA has identified one of these
alternatives, SW3, as a preferred option, but has noted
advantages of and solicited public comment on a second
alternative, SW6. Alternative SW3 involves on-site
stabilization and cover of most wastes at the site, with
some off-site transport and disposal of organic wastes.
Alternative SW6 involves deep well injection of
hazardous wastes at the site.
The deep well injection alternative (SW6) is in fact
superior to the on-site stabilization and cover, and off-
site disposal alternative (SW3), and should be
implemented at the Tex Tin Superfund site for the
following reasons:
- Deep well injection provided greater protection
to the environment (and ground waters in particular)
than surface stabilization and cover, and off-site landfill
disposal, and also preserves greater surface land for
future site development;
- Costs for deep well injection have declined
significantly in the past few years, so that this alternative
can now be implemented at Tex Tin at similar or lower
cost than the surface stabilizationand cover alternative;
- Deep well injection with state-of-the-art
monitoring technology has significant potential for
remediation of other Superfund and hazardous wastes
sites. Successful demonstration of this technology at the
Tex Tin Site will provide valuable data andexperience or
application to other areas.
Deep well injection of hazardous and non-hazardous
wastes from the Tex Tin site is the only remediation
option which effectively removes the waste from the
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biosphere; wastes are permanently removed from the
surface and near surface environments. Fracture
injection of wastes can be used to dispose of a wide
variety of hazardous and non-hazardous wastes in an
economic, time-efficient, and publicly acceptable
manner. There is little surface impairment from injection
operations, and future land use restrictions are
significantly reduced once wastes are permanently
entombed at depths well below groundwater.
The costs for deep well injection have recently declined
significantly, with technical advances in material
processing, injection, and monitoring technolcgy. Much
of the waste material at the Tex Tin site can be safely
injected at similar costs to the stabilization and cover
alternatives. A cost summary for deep well injection is
presented in this memorandum, detailing cost savings of
about 35% compared to the original injection costs
itemized in the Tex Tin Feasibility Study (FS) Report
(Document Control NO. 98-756) prepared by CH2M
Hill. Furthermore, significant errors in slag material
volume calculations in the Feasibility Stidy inflated cost
estimates for deep well injection by more than 100%
relative to stabilizationcover option for these materials.
Finally, deep well injection with state-of-the-art
monitoring and analysis may potentially be applied to
many other hazardous and non-hazardous wastes,
providing superior environmental protection to on-site
storage and cover or off-site transport and landfill
disposal. In addition to industrial wastes, other
applications include mining wastes, municipal
waste water treatment sludges (biosolids), and
agriculture wastes can be effectively disposed of in this
way. By applying this technology in a well documented
and controlled manner at the Tex Tin site, the EPA will
generate critical new data and experience for application
to other Superfund sites and for other waste streams.
Because deep well injection is such an appealing option
due to favorable environmental and long-term liability
factors, the option should be included in any final
remedial plan in the event that one or more of the
potentially responsible parties prefers it.
EPA RESPONSE: Thank you for your comment and
the effort you took to recalculate the site costs for
comparisons of alternatives in light of the volume error.
EPA agrees with the additional benefits that can be
derived from the deep welf injection option verses on-sfe
stabilizationand cover. Although your cost climates do
show a saving from the estimates presented in the FS
report and even if your revised costs are all correct, the
' deep well injection alternative is still about $3 million
higher than on-site stabilization and cover. While this
may only represent about a 10% cost increase verses the
preferred alternative, it is a higher cost that we cannot
justify if Federal funding is used to implement the
remedial action for the site. Also, the Deep Well
Injection alternative does not meet ARARs for the site.
In order to implement deep well injection at this site,
EPA would have to conduct additional studies to suppot
waiver of the UIC ARAR for the deep well injection of
hazardous waste material and makethat demonstration a
part of the Administrative Record for the remedial action
4.2.0.1 Comments submitted by ARCO by letter
dated November 6,1998.
ARCO COMMENT: Atlantic Richfield Corporation
(ARCO) believes that Deep Well Injection is a viable
alternative for the disposal of hazardous materials. We
have had substantial experience in the development and
use of this technology, and we recommend that the EPA
continue to consider Deep Well Injection as a candidate
technology for waste disposal for the following reasons:
- The costs to implement this technology have
declined as the technology improves and increases. This
is a trend we expect will continue;
- This technology isolates the wastes and is
therefore protective of human health and the
environment; and
-It enhances property value because it makes th
surface available for future site development.
This technology should be considered for solid waste
disposal at sites with the appropriate geologyand where
costs are competitive. The Tex Tin Corporation
Superfund Site is an ideal candidate for this technology
because it has an existing well on site and because ofthe
suitability ofthe geology. At the very least, Deep Well
Injection should be considered further at Tex Tin if the
PRPs express an interest in pursuing it as an option.
EPA RESPONSE: Thank you for your comments. EPA
agrees with your assessment ofthe Deep Well Injection
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alternative and the added benefits thetechnology offers
for the Tex Tin site. However, even with the current
reduction in costs, the Deep Well Injection alternative is
still several million dollars more expensive than tb EPA
selected alternative for the site. The other current
obstacle for the Deep Well Injection alternative is that it
does not meet ARARs for the site. A waver petition for
the deep well injection of hazardous materials ARARcai
be pursued by EPA if the PRPs express a high interest in
implementing this alternative.
Comments submitted by representatives for a group
of companies by letter dated November 6,1998.
COMPANIES COMMENT: The U.S. Environmental
Protection Agency ("EPA ") has issued a Proposed Plan
for the Tex Tin SuperfundSite (the "Site ") Operable Unit
No. 1 ("OU1") concerning the Tex TinPropertyat Texas
City, Texas. EPA requested comments on the Proposed
Plan and information contained in the Administrative
Record file. In response to EPA 's public notice, the
following companies herewith transmit and file
comments in triplicate and request that this letter and
these comments be included in and made a part of the
Administrative Record: Chevron U.S.A. Inc.; E.I. du
Pont de Nemours and Company; Elf Atochem North
America, Inc., successor to M&T Chemicals, Inc.;
General Electric Company: Rohm and Haas Texas, Inc;
Southwire Company; Union Carbide Company; and
Vulcan Materials Company (the "Companies ")
The Companies object to EPA 's preferred alternative
and object to implementation of the Proposed Plan for
the reasons summarized below. The basis of these
objections to EPA's preferred alternative are more fully
set forth in the attadied "Comments to EPA 's Proposed
Plan for Operable Unit No. I of the Tex Tin Superfitnd
Site" prepared on behalf of the Companies by
Environmental Resources Management ("ERM"). The
Companies request that EPA revise its Proposed Plan to
eliminate demolition of the buildings, stabilization of
soils, and attendant remedial action and those otherfacs
of the Proposed Plan noted in the enclosed technical
comments. The Proposed Plan includes several actions
that are inconsistent with the National Oil and
Hazardous Substances Pollution Contingency Plan
("NCP") and that are not supported by information
contained in the Administrative Record.
The Companies object to the proposed demolition of
buildings because CERCLA expressly prohibits the
proposed action, given that asbestos is a product in a
building and there is no release. See 42 U.S.C.
§9604(a) (3)(B). The NCP tracks the provisions of
CERCLA; given that the proposed remedial action is
prohibited by CERCLA, it also is inconsistent with the
NCP. Additionally, OSWER guidance enlarges upon the
NCP requirements, and EPA has failed to follow the
requirements of its own guidance as set forth in OSWER
Directive 9360.3-12 (August 12, 1993). Finally judicial
precedent, including that within the Fifth Circuit,
confirms that EPA 's proposed action is prohibited by
CERCLA.
First, asbestos removal and buildingdemolition should
be completely eliminated from the Proposed Plan
because these actions are inconsistent with the NCP.
The NCP provides as follows:
Unless the lead agency determines that a release
constitutes a public health or environmental emergency
and no other with the authority and capabilityto respond
will do so in a timely manner, a removal or remedial
action under section 104 of CERCLA shall not be
undertaken in response to a release:... [fjiom products
that are part of the structure of, and result in exposure
within, residential buildings or business or community
structures....
40 C.F.R. § 300.400(b)(2)(1997). The asbestos-
containing materials ("ACM") designated for removal
are clearly "part of the structure of eleven buildngs on
the Site. However, EPA has failed to demonstrate that
there has been a release of ACM constituting a public
health or environmental emergency.
Second, there is no evidence in the Proposed Plan, the
Remedial Investigation, the Supplemental Remedial
Investigation or the Feasibility Study or any release of
ACM from the eleven buildings on the site. No friable
ACM has been identifiedin these buildings,and EPA has
not declared that the ACM in the buildings constitutea
public health or environmental emergency. In fact,
potential exposure to the A CM in these buildings was na
even included within the Baseline Human Health Risk
Assessment ("BHHRA ")for the Site. See Proposed Plan
at 24. EPA cannot declare an emergency without
presenting any data to support it. The ACM in these
4»
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buildings has not created an emergency situation. The
risk from the ACM identified by EPA is the risk that
future workers may be exposed to ACM if the buildings
deteriorate or are demolished. See Proposed Plan at 22.
By its very definition, an emergency situation cannot
currently exist if the risk is conditioned solely on the
occurrence of future events (i.e., deterioration or
demolition of buildings).
Third, EPA inclusion of asbestos removal and building
demolition in the Proposed Plan also contravenes
several other NCP requirements. For instance, 40
C.F.R. § 300.430(d)(2) requires EPA to "characterize
the nature of and threat posed by the hazardous
substances and hazardous materials and gather data
necessary to assess the eXent to which the release poses
threat to human health or the environment or to support
the analysis and design of potential response actions.
. " As noted above, EPA has collected no data to
determine whether a release of ACM has occurred. In
fact, EPA has not taken air samples from thesebuildings
or soil samples from beneath these buildings for ACM.
In addition, the NCP requires EPA to "conduct a site-
specific baseline risk assessment to characterize the
current and potential threats to human health and the
environment that may be posed by" on-site
contaminants. 40 C.F.R. § 300.430(d)(4). EPA
conducted a BHHRA for the Site but, as noted above,
chose to exclude exposure to asbestos from this risk
assessment. Thus, EPA 's proposed $ 12 milion asbestos
remedial action is not supported by any data and is
inconsistent with the NCP.
Finally, the ACM removal and building demolition
remedial action also is contrary to clear judicial
authority establishing that CERCLA does not authorize
the removal of asbestos form buildings. See, e.g., Kane
v. United States, 15 F. 3d 87, 89-90(8"' Cir. 1994); 3550
Stevens Creek Assoc. v. BarclaysBank, 915 F.2d 1355,
1364-65 (9lh Cir. 1990), cert, denied, 500 U.S. 917
(1991); Dayton Indep. Sch. Dist. v. U.S. Mineral Prod.
Co., 906 F.2d 1059, 1066 (5lh Cir. 1990); First United
Methodist Church v. U.S. Gypsum Co., 882 F.2d 862,
868 (4th Cir. 1989), cert, denied, 493 U.S. 1070 (1990).
These courts all determined that Congress did not htend
to extend CERCLA cleanup and cost recovery to cover
ACM removal from buildings. The First United
Methodist court summarized Congress 'intent as follows:
[TJhis interpretation of CERCLA fitly comports
with the most fundamental guide to statutory
construction - common sense. To extend
CERCLA's strict liability schemeto all past and
present owners of buildings containing asbestos
as well as to all persons who manufactured,
transported, and installed asbestos products into
buildings, would be to shift literally billions of
dollars of removal costs liability based on
nothing more than an improvident interpretation
of a statute that Congress never intended to
apply in this context. Certainly, ifCongresshad
intended for CERCLA to address the
monumental asbestos problem, it would have
said so more directly when it passed SARA.
While CERCLA is unquestionably a far-reaching
remedial statute that must be interpreted with an
eye toward this nation's environmental
problems, it cannot reasonably be inteipreted to
encompass the asbestos- removal problem.
882 F.2d at 869, EPA is violating CERCLA and
applicable judicial precedentby including ACM removal
in the proposed remedial act ion for the Site.
Because EPA's Proposed Plan is prohibited by
CERCLA, is inconsistent with the NCP, violates EPA 's
own guidance, and is barred by established judicial
precedent, the Companies request that EPA withdraw
asbestos removal and building demolition from the
Proposed Plan.
EPA RESPONSE: As parties who are potentially
responsible under CERCLA for contamination^ the Tex
Tin Site, the Companies' motivation to limit the scope
and thus the cost of the remedial action as much as
possible is understandable. However, EPA disagrees
with the comment. Demolition buldings in appropriate
cases and stabilization of contaminated soils are
consistent with the National Contingency Plan's intent t>
provide for long term and permanent remedies protective
of human health and the environment. In this case
building demolition is not prevented by CERCLA's
limitations on response provision, because EPA has
jurisdiction to take a response action to abate arelease or
threat of release of hazardous substances, pollutants, or
contaminants from a site, and provide for a long term
permanent remedy.
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The condition of the buildings at this site is well-
documented. Investigations of this site have included
three building surveys: one conductedto detect potential
sources of hazardous materials insidethe buildings (e.g.,
radiation, vapors/dust, asbestos, metals, or organics) in
ten process area buildings, ("Building Survey Report,"
Appendix T, Remedial Investigation Report (Woodward-
Clyde 1993)), an asbestos inspection, ("ACBM Survey
Report," Ecology & Environment, 1996), Appendix R to
Supplemental Remedial Investigation (Ecology &
Environment, Inc. for EPA, 1997)(hereafter,"SRI'), and
a third to ascertain the integrity of twelve of the process
areastructuresthemselves("BuildingIntegrityInspecti
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of the buildings during the 1996survey could be released
to the environment.
To conclude, as noted above, the purpose for
demolishing site buildings in this action is to providea
long term permanent remedy in cases where:
There are no long term building maintenance
plans to prevent building deterioration, which
may present a release or threat of release ofa
hazardous substance to the environment;
The building presents a safetyhazard to response
workers;
The building components are so contaminated
that decontamination is impracticable;
The building components are so corroded or
otherwise compromised that decontamination is
inpracticable; or
Building demolition is necessary to facilitate
implementing other component of the remedial
action.
The NCP allows for removal, demolition, excavation,
etc., of other materials when necessary to address
hazardous substances on site. Therefore, the proposed
remedial action is authorized by CERCLA and consistent
with the NCP.
COMPANIES COMMENT: The Companies also
object to the proposed soils stabilization because EPA
failed to compare the Site-specific maximum allowable
concentration of chemical in ground-water with Toxicity
CharacteristicLeachate Procedure (TCLP) data, which
is the proper comparison to evaluate the need for a
response action. A proper comparison demonstrates thct
TCLP leachate data do not exceed the maximum
allowable on-site concentrations; thus, leachate from tk
soils, sediment, slag or drummed material will not
impermissibly degrade the groundwater. Therefore,
stabilization is not required to protect public health and
the environment, and attendant remedial actions such as
installation of a geomembrane wall also are
unnecessary.
Because EPA 's own TCLP leachate data demonstrates
no need to stabilize soils and other materials and
conduct attendant actions to protect public health and
the environment, the Companies request hat EPA delete
from the Proposed Plan the requirement to stabilize soik
and other material and to conduct attendant actions
because these proposals are inconsistent with the NCP.
EPA must select as its preferred alternative remedial
actions that are not inconsistent with the NCP and that
are not expressly prohibited by CERCLA. EPA has
failed to do that for the Tex Tin Superfund Site.
Accordingly, EPA must withdraw, revise and reissue its
Proposed Plan so that it is not inconsistent with the
NCP.
EPA RESPONSE: The proper use of TCLP data is not
for the data to be compared to the maximum allowable
concentration of chemicals in groundwater. The proper
use of TCLP data is to determine whether a material is
characteristically hazardous or not, which in turn
determines whether it warrants a response action under
CERCLA (since "hazardous wastes" are included in the
definition of "hazardous substances") and also to
determine the appropriate disposal facility. Under the
Clean Water Act, Maximum Concentration Limits
(MCLs) have been established for drinking water
sources. The MCLs are the chemical concentrations to
which allowable chemicals in ground water data are
compared, not TCLP data. Afterevaluating site specific
conditions and in agreement with TNRCC, EPA
proposed to use the Synthetic Precipitation Leaching
Procedure (SPLP) test to determine the potential of site
contaminants leaching to the ground water. Therefore,
materials that exceed the MCL concentration levels for
the contaminants of concern when subjected to the ISPLP
will be stabilized to prevent future leaching of
contaminants above MCL levels to the ground water.
While the shallow and medium transmissive zones meet
the criteria as potential future drinking water sources,
EPA evaluated the current use of these ground water
zones in the surrounding area and in particular the down
-------
gradient locations and concluded, with TNRCC's
concurrence, that the ground water use for the shallow
and medium transmissive zones would likely be for
industrial use. Therefore EPA established a perimeter
monitoring program based on alternate concentration
levels (ACLs) for industrial use. In calculating the
ACLs, further analyses were needed to determine if on-
site ground water concentrations already existed which
would exceed the perimeter ACLs. In that case, a grouid
water pump and treatment program would berequired to
prevent exceedance of the perimeter ACLs. Calculating
the maximum allowable levelson site was to determine
the need for starting pump and treatment, not to estaHish
or maintain continued on-site leaching concentrations at
levels that would even exceed the limits for
characteristically hazardous materials. Clearly
maintaining the current leaching levels would cause
further degradation of the shallow and medium
transmissive zones and could in time impact the deep
transmissive zone which is used as a drinking water
source in the surrounding area. Additionally,
maintaining the current leaching levels would not, in
time, reduce the contaminant concentrations in the
shallow and medium transmissivezones which is EPA's
goal for these groundwater zones, a reduction in
contaminant levels through natural forces.
The Companies' comment that "EPA's own TCLP
leachate data demonstrates no need to stabilize soils and
other materials..."is clearly wrong. TCLP leachate data
in the remedial investigation reports show several waste
materials that exceed TCLP levels for characteristic
hazardous materials which would trigger treatment under
the land disposal requirements. Materials exceeding
TCLP levels would require treatment (stabilization) for
on-site landfill disposal or off site disposal. Additicnally,
EPA, in consultation with the State, has determined that
stabilization of materials exceeding SPLP concertrations
is needed to protect the groundwater. Under CERCLA,
EPA can take additional action to prevent migration of
site contaminants to the ground water. This is EPA's
goal in proposing stabilization for materials that exceed
SPLP levels.
The Companies'comments ignored the risk posed by site
contaminantsto human health and the environment. Sie
risks are clearly presented and detailed in the Baseline
Human Heath Risk Assessment report included in the
Administrative Record. This report forms the basis for
the response action proposed for the site. Stabiliation is
needed for protection of ground water and required for
disposal of materials exceeding TCLP levels. The risk
assessment for the site shows that a response action to
address site contaminants that exceed human health
levels is warranted. Response actions to address these sit
materials are warranted to address the present and future
threat that site contaminants pose to him an health. EPA
believes that the best responseaction to address materiafc
that are characteristically hazardous is through
stabilization.
Installation of a geomembranewall is necessaryto isolafe
the acid pond, Pond 6, from the shallow ground water
transmissive zone as part of the in situ treatment
proposed for the Acid Pond. The geomembrane would
prevent groundwater infiltration after dewatering the
Acid Pond. The geomembrane would also help in
preventing leaching of pond con tarn inantstothe shallow
groundwater. Although stabilization of pond
contaminants would be conducted as partof the preferred
alternative for the site, the geomembrane would provide
added protection.
EPA's preferred alternative for the Tex Tin site is
consistent with the NCP in providing long term
protection to human health and the environment and
therefore is not prohibited by CERCLA. The
Companies' comments regarding asbestos removal and
stabilization of site materials are clearly inconsistent wih
EPA's long term goal of providing protection to human
health and the environment at Superfund sites and
therefore the Companies' commentsareinconsistentwith
the NCP and CERCLA. The Companies' comments do
not warrant reissuing the Proposed Plan for the Tex Tin
Site, OU No. 1. EPA has evaluated comments received
at the public meeting held at Texas City, City Hall on
October 6, 1998, and written comments submitted.
Based on the results of this evaluation, EPA has
concluded that the preferred sitewide alternative, SW-3,
presented in the Proposed Plan will be selected as the
remedy for the site that will meet EPA's long term
objectives for the site. As a result of comments received
minor revisions made to lie preferred alternative will be
noted in the Record of Decision for the site.
-------
5 END NOTES
1. The Administrative Record contains the documents that form the basis for the
selection of a response action.
2. Woodward - Clyde, Remedial Investigation Report, Volume 1 of VII, June 1993, pp.
1-3 through 1-7.
3. King, E. B. and D. N. Gibson, "Tin Smelting at the Texas City Smelter," an
unpublished general description of the Tex-Tin Site, updated.
4. The Dallas Morning News, 1990 - 91 Texas Almanac. 1989, p. 113. Average annual
rainfall for Galveston County is 40.2 inches.
5. The Dallas Morning News, 1990-91 Texas Almanac. 1989, p. 71
6. Ecology and Environment, Supplemental Remedial Investigation for the Tex Tin
Corporation Site, March 1997, page 1-6.
7. Environmental Systems Design and Management, Inc. (ESDM), Building Integrety
Inspection Report at Tex-Tin Corporation Site, Texas City, Galveston County, Texas,
November 1996.
8. Woodward Clyde, Remedial Investigation Report, June 1993.
9. Woodward-Clyde, Remedial Investigation Report, Volume 1 of VII, June 1993,
Section 3.0, "Physical Characteristics."
10. Ecology and Environment, Supplemental Remedial Investigation for the Tex Tin
Corporation Site, March 1997, Section 3, "Supplemental Remedial Investigation."
11. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Toxicological Profile For 1,2-
Dichloroethene, August, 1996, p. 4.
12. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Toxicological Profile For Antimony,
September, 1992, p. 4.
13. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Internet Web Page
http://atsdrl .atsdr.cdc.gov:8080/ToxProfiles/phs8802.html
14. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Toxicological Profile For Asbestos,
-------
August, 1995, p. 5.
15. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Toxicological Profile For Barium,
July, 1992, p. 3.
16. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Internet Web Page
http://atsdrl.atsdr.cdc.gov:8080/ToxProfiles/phs8803.html
17. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Toxicological Profile For Beryllium,
April, 1993, p. 3.
18. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Toxicological Profile For Cadmium,
September, 1997, p. 4.
19. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Toxicological Profile For Chloroform,
September, 1997, p. 4.
20. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Internet Web Page
http://atsdr 1 .atsdr.cdc.gov:8080/ToxProfiles/phs8810.html
21. U. S. Department of Health and Human Services, Public Health Service, Agency
for Toxic Substances and Disease Registry (ATSDR), Toxicological Profile For Copper,
December, 1990, p. 4.
22. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Internet Web Page
http://atsdrl .atsdr.cdc.gov:8080/ToxProfiles/phs8817.html
23. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Internet Web Page
http://atsdr 1 .atsdr.cdc.gov:8080/ToxProfiles/phs8916.html
24. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Toxicological Profile For Radium,
December 1990 p.3.
25. U. S. Department of Health and Human Services, Public Health Service, Agency
for Toxic Substances and Disease Registry (ATSDR), Toxicological Profile For
Selenium, August, 1996, p.7.
-------
26. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Toxicohgical Profile For Thorium
October, 1990,p.3.
27. U. S. Department of Health and Human Services, Public Health Service, Agency for
Toxic Substances and Disease Registry (ATSDR), Toxicohgical Profile For Uranium
September, 1997 p. 5.
28. 40 C.F.R. Part 261, "Identification and Listing of Hazardous Waste," Subpart C,
"Characteristics of Hazardous Wastes."
29. Ecology and Environment, Supplemental Remedial Investigation, March 1997, p. 3-
42.
30. (Woodward-Clyde, 1993a)
31. Woodlands Reporting Services, Transcript of Public Meeting of the U. S.
Environmental Protection Agency, October 6, 1998, 7:00pm to 10:15pm Texas City,
City Hall, Texas City, Texas, Regarding the Tex-Tin Corporation Superfund Site, p. 92.
32. Harris - Galveston Coastal Subsidence District, District Plan. April, 1992, p. 1.
33. Harris Galveston Coastal Subsidence District, District Plan, April 1992. The
HGCSD was created in 1975 by the 64th Legislature to regulate the withdrawal of
groundwater within Harris and Galveston Counties. The district was created for the
purpose of ending subsidence which contributes to or precipitates flooding, inundation, or
overflow of any area within the district, including without limitation rising waters
resulting from storms or hurricanes.
34. Roy F. Weston, Inc. Baseline Human Health Risk Assessment, March 1997, p. 3-30.
35. EPA, Risk Assessment Guidance for Superfund Volume 1, Human Health Evaluation
Manual (Part A). December 1989.
36. Roy F. Weston, March 1997, Sections 3.4 and 7.3.3
37. EPA, Supplemental Region VI Risk Assessment Guidance. May 1995. EPA. Risk
Assessment Guidance for Superfund, Volume 1, Human Health Evaluation Manual (Part
A). Interim Final. Office of Solid Waste and Emergency Response, Washington DC
EPA/540/1-89/002,1989, p. 6-22.
38. Woodward-Clyde, Inc. 1993a. Final Remedial Investigation Report, Tex-Tin RI/FS,
Texas City, Texas. June 1993 and EPA. Personal communication between Jon Rauscher,
-------
EPA Region 6 Toxicologist, and Andrew S. Kallus, Roy F. Weston, Inc., Houston, Texas,
20 August 1996.
39. Roy F. Weston, March 1997, Appendix A and Appendix Q.
40. Ecology and Environment, Supplemental Remedial Investigation, March 1997, pp. 3-
239 through 3-255.
41. Woodward-Clyde, Remedial Investigation Report, Volume 1 of VII, June 1993,
Section 4.3.17, "Site Wide Groundwater Investigation."
42. Roy F. Weston, March 1997, p. 3-1 - 3-77.
43. Roy F. Weston, March 1997, p. 4-1 - 4-30.
44. EPA. 1995a. Health Effects Assessment Summary Tables (HEAST), FY-1995
Annual. EPA540/R-95/036. PB 95-921199. May 1995.
45. Roy F. Weston, March 1997, p. 5-1 - 5-82.
46. EPA. Integrated Risk Information System. U.S. EPA Toxicological Database.
Washington, D.C., 1996.
47. ATSDR (Agency for Toxic Substances and Disease Registry), The Nature and Extent
of Lead Poisoning in Children in the United States: A Report to Congress. U.S.
Department of Health and Human Services, Public Health Service. July 1988. ATSDR,
Toxicological Profile for Lead. Final. NTIS PB 93-182475, April 1993. CDC (Centers
for Disease Control), 1991. Preventing Lead Poisoning in Young Children. A Statement
by the Centers for Disease Control, October 1991.
48. CDC 1991.
49. EPA. Adult Lead Cleanup Level. Draft Region 6 Superfund Guidance, 1996.
50. Bowers, T.S., B.D. Beck, and H.S. Karam, Assessing the Relationship between
Environmental Lead Concentrations and Adult Blood Lead Levels. Risk Analysis 14(2):
183-189, 1994.
51. EPA. Risk Assessment Guidance for Superfund, Volume 1, Human Health Evaluation
Manual (Part A). Interim Final. Office of Solid Waste and Emergency Response,
Washington, D.C. EPA/540/1-89/002, 1989.
52. EPA. Human Health Evaluation Manual, Supplemental Guidance: "Standard
Default Exposure Factors". Office of Solid Waste and Emergency Response,
-------
Washington, D.C. OSWER Directive 9285.6-03, 1991
53. EPA, David W. Charters, PhD., "Ecological Risk Assessment for Operable Unit 1 "
1997.
54. Woodward-Clyde, 1993, p. 3-49.
55. Stabilization is a treatment process that mixes or injects treatment agents into a
material contaminated with heavy metals to accomplish one or more of the following
objects:
Improve the physical characteristics of the waste, without necessarily
reducing aqueous mobility of the contaminant, by producing a solid form
liquid or semi-liquid wastes
Reduce the contaminant solubility
Decrease the exposed surface area across which mass transfer loss of
contaminants may occur
Limit the contact of transport fluids and contaminants
EPA, Contaminants and Remedial Options at Selected Metal-Contaminated Sites,
EPA/540/R-95/512, Office of Research and Development, July 1995. In so far as
stabilization alters the composition of the hazardous substance through a chemical or
physical means in accordance with the NCP §300.5, "Definitions," it is considered
treatment.
56. EPA, Denver Radium Superfund Site, Record of Decision, 1992.
57. EPA, Motecillo Superfund Site, Record of Decision, 1990.
58. TNRCC, Jeffery A. Saitas, Executive Director, Memorandum to Program Areas
Which Utilized the Risk Reduction Rules and Site-Specific Risk Analysis, September 11
1998.
59. CH2M Hill, August, Feasibility Study Report, Tex Tin Site, Operable Unit 1 August
1998. '
-------
Figure 3.1
« *-'
Site Location
\, v:: - // Galveston Island
, .,,;., ,.• 'Galveston
. :,:; ^ County
v .y
Galveston
Bay
Tex Tin
-------
COMT!T»,uI»T
CONTAMINANT
SOURCE
""'MARY
RELEASE
MECHANISM
Figure 3.5.27-1 Conceptual Site Model- Soil, Waste Pita and Croundwitar
SECONDARY
CONTAMINANT
SOURCE
SECONDARY
RELEASE
MECHANISM
TERTIARY
CONTAMINANT
SOURCE
---lit
Fugitive Duat
Generation
On-Site Exposed
Drum Material
(Areas 8. E. J. t)
~i
— i
EXPOSURE
ROUTES
RECEPTORS
RMCANDCTE
SCENARIOS
tngestion
Inhalathon of
Paniculate*
Dermal Contact
r-^moizj
(1) Curr.nt/futur. indu.lrial work.r i. a..um.d to only be e.po.ed to contaminant, in.urfac. .oil.
-------
A*
•A
A
'
-..' ^
Notes:
V-.
1. Geological Information based on Phase II Rl.
2. Zone 1 is-the shallow confining zone
3. S&M&D mdicates clustered wells representing
Figure 3.5.21
FILL
CLAYEY SAND
CLAY
SILTY SAND
SILTY/SANOY CLAY
SANDY SILT
SAND
POND SEDIMENT
INTERLAYERED SAND
AND CLAY
INDICATES A
___ TRANSMISSIVE ZONE
CLAYEY SILT
NO RECOVERY
CROSS-SECTION LOCATION MAP
REPRESENTATIVE
GEOLOGICAL
CROSS SECTION
-------
• 45S
•SS.M
6S. y. 0
•7S
' P-K).
-'**44S
C03
37S" . . . •
- MS
4IS
• S2S
« 56S
•»&« •«S;..i=£r--;.^
.:"' . 54S
• J9S
55S
• 40S, U
•S7S
'--": " " ', 8S.U-
50S • '
P-S-.
IpS
42S'
\ •-',--:
JIS.U
32S.M .
*?
, • ,• . J7S.U
' • 26S. U
•WS.K.
. ST*-2B
• STW-2*
WS.U
ST»-3
295. M
KS. H.O
• 23S. U
• 2'S. U
• 22S. U
• LOCATIONS OF MONITORING WELLS AND PIEZOMETERS
• SHALLOW TRANSMISSIVE ZONE WELL
• MEDIUM TRANSMISSIVE ZONE WELL
- DEEP TRANSMISSIVE ZONE WELL
• PIEZOMETER
LOCATIONS OF MONITORING
WELLS AND PIEZOMETERS
TSX TIN SUP^FUNO SITE
TEXAS CITY, TiXAS
Figure 3.7.1. I.I
-------
PRIMARY
I CONTAMINANT
SOURCE
PRIMARY
RELEASE
MECHANISM
Figure 3.5.27 - 2 Conceptual Site Model - Sediment »nd Surface Water
SECONDARY
CONTAMINANT
SOURCE
SECONDARY
RELEASE
MECHANISM
TERTIARY
SOURCE
PATHWAY
On-Site Drums
(Areas L. J),
On-Site waste
Oil Tanks (Areas
L, M. N). and
On-Srte Process
Units Associated
with Areas J and
M
Leaks/Spills
On-Site Soil
(Leaching To
Ground water
On-Site
Groundwater
Groundwater To
Surface Water
Discharge
(1)
On-Site Sediment
(Area K - Ponds 1- 5)
(2)
On-Site Surface Water (Area
K - Ponds 4and 5)
On-Site Sediment
(Area K - Pond 6)
' (3)
On-Site Surface Water (Area
K - Pond 6)
EXPOSURE
ROUTES
Dermal Contact I
Notes
(1) Sediment exposure in Area K occurs in Ponds 1-5.
(2) Surface water exposure in Area K occurs m Ponds 4 and 5 (Ponds 1-2 are dry and Pond 3 is mostly dry)
(3) Pond 6 was evaluated separately from Ponds 1 through 5 because it ts a waste acid pond and not a former wastewater treatment pond
RECEPTORS
RMEANDCTE
SCENARIOS
Current/
Future
Industrial Recreatonil
Worttr Tr«pa««i uj,.,
• >
On-Site
Sediment
(Area G)
On-Site Surface
Water (Area G)
I Ingestion > •
< * Dermal Contact » •
. Dermal f-nntart 1 . J •
Ingestxm
Dermal Contact
»
1 >
•
•
Off-Site Sediment
(Area 1)
*
IngestJon
Dermal Contact
fr
Off-Site Surface
Water (Area 1)
nP
*"
Ingestion .
Dermal Contact
Ingestion of Fish
»
-------
UNION CARBIDE COMPLEX
AMOCO COMPLEX
\
M
FORMER MORCHEV FACILITY
\ A TEX TIN PROCESS AREA
. - \ POND 7
\ - J 5-
-"-•;- PO^,
LAMARQUE. TEXAS
This drnvng w»» oogntty dov*top«d tor tw EPA
by Erotopy and Enwwxntnl. h: w»p*rtofUie
EnQm««nng EvtfuMon£att Ar*tr*t* Report
Figure 3.2.11
G
B
F \
H
AMOCO PROPERTY
POND 3
f\J , POND«
E V
% PO
K N
/
\
\
S
hn
NOTES:
1. SOURCE: PHASE II Rl
LEGEND:
= FENCE
= RAILROAD
= BERM OR DIRT ROAD
* LICENSED LOW-LEVEL
CLOSED RADIONUCLIDE
LANDFILL
= DITCHES AND PONDS
: BUILDINGS
: DRUMS AND TANKS
AREAS:
A NORTHWEST CORNER
B SlAG STORAGE AREA
C PONOSW-2)
D PONDS 7. Si POND 174 SURROUNDING AREA
E CATAIYST PILES AND PONDS
F NORTH SLAG STORAGE
G SURFACE DRAINAGE & DITCHES
H PONDS 9-14
I OFFSITE PONDS
J PROCESS AREA
K PONDS 1-6
L MORCHEM FACILITY
M GENERATOR HOUSE & NORTHWEST TANKS
N CATALYST TANKS
O OFF-SITE SOILS
P RADIOACTIVE LANDFILLARF-A
NOTES
1 SOURCE PHASE II Rl
SITE FEATURES
TEX TIN SUPERFUND SITE
TEXAS CITY TEXAS
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