SEP A
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-87/018
March 1987
Superfund
Record of Decision:
»
V
ct
Petro-Chemical Systems, TX
I
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
NO.
RCPORi
EPA/ROD/R06-87/018
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Petro-Chemical Systems, TX
First Remedial Action
5. REPORT DATE
March 27. 1987
«. PERFORMING ORGANIZATION CODE
7. AUTHORtS)
i. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
I. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
IS. SUPPLEMENTARY NOTES
10. ABSTRACT ~~——'——————————
The Petro-Chemical Systems site is a 296-acre tract of land located in Liberty
County, Texas. It is in a sparsely populated area seven miles north of 1-10 off
Frontier Park Road. Waste oils were stored onsite prior to their use, in several pits
on approximately four to six acres of the site. Records indicate that waste oils were
spread on Frontier Park Road at the site as a method of dust control. In June 1970, all
waste oil disposal operations were discontinued and in 1974, the site's commercial
disposal facility permit was withdrawn. The Texas Water Commission (TWC) and EPA
conducted preliminary investigations of the site in 1982 and 1984. Elevated
concentrations of polyaromatic hydrocarbons (PAHs) were found in the former disposal
pits. At the end of 1984, the site was placed on the NPL. The primary contaminants of
concern include: VOCs, PAHs, benzene and napthalene. Benzene contamination was found
up to a maximum concentration of 2100 ppm and napthalene up to a maximum concentration
of 700 ppm. Contaminated media includes soil along Frontier Park Road.
The selected remedial alternative includes: excavating contaminated soil to below
100 ppm PAHs; disposing contaminated soils temporarily in a RCRA storage facility;
constructing a road over the excavated areas and existing roadway; and relocating onsite
residents temporarily during construction. The estimated capital cost for the remedial
action is $1,232,785. Annual O&M costs are estimated to be $3,000 for the road and
fel.750 for the leachate collection system.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Petro-Chemical Systems, TX
First Remedial Action
Contaminated Media: soil
Key contaminants: volatiles, PAHs, benzene,
napthalene
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (Tilts Report/
None
21. NO. OF PAGES
36
20. SECURITY CLASS (This page>
None
22. PRICE
EPA Perm 7220-1 (!!•*• 4-77) PREVIOUS COITION is OVSOLCTC
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1 1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
ALLIED BANK TOWER AT FOUNTAIN PLACE
1445 ROSS AVENUE
DALLAS, TEXAS 75202
RECORD OF DECISION
Remedial Alternative Selection
Site: Petro-Chemical Systems, Inc., Phase I, Frontier Park Road
DOCUMENTS REVIEWED
I have reviewed the following documents describing the analysis of cost-
effectiveness remedial alternatives for the Petro-Chemical Systems, Inc.
site, Phase I- Frontier Park Road.
o Petro-Chemical Systems, Inc., Remedial Investigation/Feasibility
Study (Lockwood, Andrews, and Newnam, November 1986);
o Responsiveness Summary;
o Staff Summaries and Recommendations.
DESCRIPTION OF SELECTED REMEDY
o Excavate contaminated soil to below 100 ppm Polyaromatic Hydrocarbons.
o Temporary disposal of contaminated soils in a RCRA storage facility.
o Construct a road over excavated areas and existing roadway.
o Temporarily relocate on-site residents during construction.
DECLARATION
Consistent with the Comprehensive Environmental Response, Compensation and
Liability Act"of 1980 (CERCLA), the Superfund Amendments and Reauthorization
Act of 1986 (SARA), and the National Contingency Plan (40 CFR Part 300),
I have determined that the selected remedy for the Petro-Chemical Systems,
Inc., site is a cost-effective remedy, provides adequate protection of
public health, welfare and the environment, and meets all applicable,
relevant, and appropriate State and Federal regulations. The State of
Texas has been consulted and agrees with the approved remedy. The activities
associated with the temporary RCRA storage facility is an interim measure
which is compatible with the long term remedy for the site. This remedial
action will be conducted as an expedited response action under the auspices
of the Emergency Response Branch.
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I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites. In addition, excavation and on-site RCRA storage of contaminated
soils with temporary relocation of residents is the most cost-effective
remedial action, since it provides the best protection to human health,
welfare, and the environment.
Date Robert E. Lay ton Jr, P.E.
Regional Administrator
Environmental Protection Agency
Region VI
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PETRO-CHEMICAL SYSTEMS, INC., RECORD OF DECISION CONCURRENCES
Allyn M. avis, Director
Hazardous Waste Management Division
hief
Superfund Program Branch-
Stanley G. Hitt, Chief
Texas Remedial Section
Superfund Program Branch
'Bonnie J. Dqybs, Chief
State Programs Section
Superfund Program Branch
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TABLE OF CONTENTS
Page
1. Site Location and Description 1
2. Site History 1
3. Current Site Status 3
4. Migration Pathways 5
5. Target Receptors 5
6. Enforcement Analysis 6
7. Alternatives Evaluation 6
8. Consistency with other Environmental Laws 11
9. Recommended Alternative 11
10. Operation and Maintenance 20
11. Schedule 21
12. Community Relations 21
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
PETRO-CHEMICAL SYSTEMS INC.,
LIBERTY, TEXAS
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Record of Decision Remedial Alternative Selection
Petro-Chemical Systems, Inc., Phase I, Road
Liberty, Texas
Site Location and Description
The Retro-Chemical site 1s a 296-acre tract of land located in Liberty
County. This site is south of Liberty, Texas, in a sparsley populated
area approximately one mile east of FM 563 and seven miles north of 1-10
(see Figure 1) off of Frontier Park Road. The Petro-Chemical site has
often been called the Turtle Bayou site because of Its proximity to Turtle
Bayou, a tributary of the Trinity River.
The site was subdivided Into smaller acre tracts ranging from 5-15 acres,
in 1974. As many as 11 families have lived on the site since 1974;
however, only two families remain as of August 1986.
The objective of this study and remedial action 1s Frontier Park Road,
which lies within the site boundry. Records Indicate that waste, oils
were spread on the road at the site as a method of dust control. This
road 1s the only access to the various waste areas, as well as the only
access for residents living there.
Site History
The Petro-Chemical Systems, Inc., site was originally discovered in 1970.
The waste oils were stored prior to their use, in several pits on approximately
4 to 6 acres in the northwest corner of the site. All waste oil disposal
operations were discontinued in June 1970. The State granted a commercial
disposal facility permit to Petro-Chemical Systems 1n 1971, but the permit
application was subsequently withdrawn in 1974.
Preliminary sampling conducting in 1982 and 1984 by the Texas Water Commission
(TWC), formerly the Texas Department of Water Resources (TDWR) and the
Environmental Protection Agency (EPA) Indicated elevated concentrations
of several polyaromatic hydrocarbons in the former disposal pits. The
documentation of the presence of hazardous constituents on-site lead to
the site being placed on the National Priority List in late 1984.
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In March 1985, the TDWR contracted with Lockwood, Andrews and Newnam,
Inc., In association with Harding Lawson Associates to conduct a remedial
investigation and feasibility study for the Petro-Chenrical Systems, Inc.
hazardous waste site. Remedial investigation activities on the road were
conducted in February and June 1986.
Following completion of the Remedial Investigation (RI) activities
work began on the Feasibility Study (FS). The Initial FS was received-
in October 1986 and the public review copy was received in November 1986.
Current Site Status
The Remedial Investigation Phase I road sampling efforts 1n February and
June 1986, performed at the Petro-Chemical Inc., site, (Frontier Park
Road) were used to describe the nature and extent of contamination.
Several areas of contamination have been identified on the road. About
4,000 cubic yards of highly contaminated soils were found over the first
third of a mile of Frontier Park Road, and 22,000 cubic yards of moderately
contaminated soils were found up to 2 miles along the road (Table 1).
Highly contaminiated soils were defined as those with greater than 100 ppm
polyaromatic hydrocarbons (PAH) or volatlles, and moderately contaminated
soils are those between 10-100 ppm PAHs or volatiles. These criteria are
based on a direct contact threat established by the Agency for Toxic
Substances and Disease Reglstery.
Due to the volume of data generated during the sampling effort, two marker
compounds were chosen to represent classes of compounds. Benzene and
napthalene were the most prevalent contaminants in the samples collected
along Frontier Park Road. Therefore, benzene was used to indicate the
presence of other volatile contaminants found at the site and napthalene
was used to Indicate the presence of other base neutral contaminants
(primarily PAHs). In general, the benzene contamination was found up to
a maximum concentration of 2100 ppm and napthalene up to a maximum
concentration of 700 ppm in the roadway.
The first 3600 feet of Frontier Park Road appears to be the most heavily
contaminated with significant concentrations of volatiles and base
neutral extractable compounds. Within the first 3600 feet, the length of
road between 1200 and 1600 feet from FM 563 appears to be the most highly
contaminated. Benzene and napthalene concentrations in this area were
generally between 100 and 1000 ppm within the upper two feet of the
roadway. In addition to the first 3600 feet, two more areas of Frontier
Park Road appear to be significantly contaminated. Between 5500 feet and
6300 feet from FM 563, and between 9500 feet and 10,000 feet from FM 563,
concentrations of individual contaminants ranged between 10 and 100 ppm.
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TABLE 1
VOLUME OF MODERATELY CONTAMINATED AND HIGHLY
CONTAMINATED SOILS AT THE FRONTIER PARK ROAD SITE
Volume Volume
Distance from Greater Than Between 100 ppm
FM 563, 100 ppm, and 10 ppm,
FT. CY CY
0 to 1800 4,000 5,400
1800 to 3670 - 10,700
5200 to 6600 - 5,100
9600 to 10,060 - 960
TOTAL . 4,000 . 22,100
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Because the Frontier Park Road has significant quantities of contaminated
soils at or near the surface and because provides the primary access to
to persons living on the site, the risk of exposure to contaminants 1s
high. Furthermore, access to the various waste areas throughout the site
1s limited as a result of the poor condition of the road. Because of
these problems TWC and EPA decided to address the remedial Investigation/
feasibility study activities relating to the road separate from the total
site.
Migration Pathways
The contamination present in the Frontier Park Road soil samples could
potentially be affecting groundwater and surface water quality 1n the
immediate vicinity. However, issues Involving these pathways for migration
will be deferred to later investigation studies Involving Impacts from the
total site.
Results of the remedial investigation indicate that during dry periods air
quality has not been adversely affected by the contamination associated with
the road. However, volatilization of these contaminants may be possible
during wet weather when ruts caused by vehicular traffic serves to disturb
the deeper buried waste.
Target Receptors
If contaminated soils are left in place, current and future residents of the
area, as well as occasional travelers of Frontier Park Road, will be exposed
to the contaminants contained in the road in a variety of ways. During
wet weather periods, ruts in the road and mud from vehicular traffic
significantly Increase the potential for contact with contaminants.
Because the road provides the only access to their homes, the on-site
residents may potentially be exposed several times daily. During dry
periods, vehicular traffic raises dust particles contaminated with PAHs
and volatiles. Onsite residents may then be exposed through inhalation of
dust particles. Dust particles may also be ingested or deposited on skin
and other body tissues.
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Enforcement Analysis
Four potentially responsible parties (PRPs) have been identified for the
Petro-Chemical site. The PRPs include three landowners and one transporter
of the waste.
An Administrative Order was issued to the PRPs for a removal action at
the site. This removal action consisted of installing a fence around
the main disposal area. The PRPs chose not to comply with this order and
to date none of the PRPs has Indicated any responsibility or willingness
to fund any portion of the cleanup.
All identified PRPs will be offered the opportunity to voluntarily
implement the preferred remedy. If- anticipated negotiations are
unsuccessful, the fund will be utilized for cleanup of the site. However,
no negotiations have been initiated to date. If the PRPs decline to
implement the remedy, EPA will seek appropriate enforcement action.
Alternatives Evaluation
The Feasibility Study for the Frontier Park Road was performed to determine
what actions, if any, would be appropriate as part of a permanent remedy
for the site. Several alternative remedial methods were developed to
mitigate damage to, and provide adequate protection of public health,
welfare, and the environment from past and future releases of contaminants
on the road.
The National Contingency Plan (NCP), 40 CFR Part 300.68(c)(l) states that
"Response actions may be separated into operable units consistent with
achieving a permenent remedy. These operable units may include removal
actions pursuant to 300.65(5) and/or remedial actions involving source
controls, and/or management of migration." In accordance with the NCP,
and based on the conclusions of the Remedial Investigation, a response
action operable unit is necessary at the Retro-Chemical Systems, Inc.,
Phase I, Frontier Park Road.
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The Remedial Investigation and Feasibility Study performed by Lockwood,
Andrews, and Newnam, Inc., in November 1986, developed the following
objectives and criteria based on the results of the Remedial Investigation:
o Objective: Prevent direct contact with highly contaminated soils.
Criterion: 100 ppm total polyaromatlc hydrocarbons (PAH's), or 100
ppm Total Volatiles (TVs), (for the purpose of this study total
volatiles will be defined as benzene, ethylbenzene, toluene, 2-butanone,
4-methyl, 2-pentanone, styrene, and xylene).
o Objective: Minimize direct contact with moderately contaminated soils.
Criterion: Between 10 and 100 ppm total PAH's or 10 and 100 ppm TVs.
o Objective: Improve access to site for heavy equipment to facilitate
remedial investigation sampling and monitoring and future remedial
actions.
Criterion: Meets or exceeds minimum Liberty County Road standards.
Initial Screening of Alternatives and Identification of Potential Remedial
TechnbTogTes
Section 300.68(h) of the National Contingency Plan states that the
following broad criteria should be used in the initial screening of
alternatives and technologies:
1. Cost. For each alternative, the cost of installing or Implementing
the remedial action must be considered, including operation and maintenance
costs. An alternative that far exceeds the costs of other alternatives
and does not provide substantially greater public health or environmental
benefits should usually be excluded from further consideration.
2. Effects of the Alternative. The effects of each alternative should
be evaluated as to whether the alternative itself or its implementation
has any adverse environmental effects, and whether the alternative is
likely to effectively mitigate and minimize the threat of harm to
public health, welfare or the environment. If an alternative has
significant adverse effects, it should be excluded from further
.consideration.
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8
3.. Acceptable Engineering Practices. Alternatives must be feasible for the
location and conditions of the release, applicable to the problem,
and represent a reliable means of addressing the problem.
Identification of Response Actions and Applicable Technologies
In the screening process, only technologies applicable to the following
response actions were considered:
1. Removing and disposing of highly contaminated soils;
2. Surface barrier over moderately contaminated soils and other portions
of road to provide access; and
3. Temporary detour or temporary relocation.
Development of Site Remedial Alternatives
From the screening process seven alternatives plus the no-action alternative
were retained and analyzed for mitigating the problems associated with the
Frontier Park Road. The following is a description of each alternative and
its respective cost.
Alternative 1: On-Site Storage with Relocation
Remove/excavate contaminated soil to below 100 ppm PAHs and/or TVs and
dispose of them in an on-site RCRA storage facility. Backfill as necessary
with natural soils. Construct a road so that access is provided to all
areas of the site. Construct the road so that all soils on the road,
contaminated with greater than 10 ppm PAHs and/or TVs are covered.
Temporarily relocate on-site residents and maintain their property until
their return. The cost of this alternative is $1,266,524.
Alternative 2: On-Site Storage with Detours
Remove/excavate contaminated soil to below 100 ppm PAHs and/or TVs and
dispose of them in an on-site RCRA storage facility. Backfill as necessary
with natural soils. Construct a road so that access is provided to all
areas of the site. Construct the road so that all soils on the road,
contaminated with greater than 10 ppm PAHs and/or TVs are covered.
Provide temporary construction detours to allow on-site residents access
to their property during remedial actions. The cost of this alternative
is $1,489,106.
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Alternative 3: Off-Site Disposal with Relocation
Remove/excavate contaminated soil to below 100 ppm PAHs and/or TVs and
dispose of them in an off-site RCRA facility. Construct a road so that
access is provided to all areas of the site. Construct the road so that
all soils on the road, contaminated with greater than 10 ppm PAHs and/or
TVs are covered. Temporarily relocate on-site residents and maintain
their property until their return. The cost of this alternative is
$3,353,162.
Alternative 4: Off-Site Disposal with Detours
Remove/excavate contaminated soil to below 100 ppm PAHs and/or TVs and
dispose of them in an off-site RCRA facility. Construct a road so that
access is provided to all areas of the site. Construct the road so that
all soils on the road, contaminated with greater than 10 ppm PAHs and/or
TVs are covered. Provide temporary construction detours to allow onsite
residents access to their property during remedial actions. The cost of
this alternative is $3,575,744.
Alterntive 5: Alternative Access
Provide temporary alternate access around portions of Frontier Park Road
contaminated with greater than 100 ppm PAHs and/or TVs. Fence the
perimeter of the contaminated areas to prevent access. Construct a road
so that access is provided to all areas of the site. Construct the road
so that all soils with greater than 10 ppm PAHs and/or TVs are covered.
Provide temporary construction detours to allow on-site residents access
to their property during remedial actions. Postpone further remedial
action until remediation occurs at the remainder of the site. The cost
of this alternative is $1,018,578.
Alternative 6: Remove to Background
Remove/excavate contaminated soils to background levels and dispose of
them in an off-site RCRA facility. Backfill as necessary with natural
soils. Construct a road so that access is provided to all areas of the
site. Provide temporary construction detours to allow on-site residents
access to their property during remedial actions. The cost of this
alternative is $25,796,534.
Alternative 7: Construction of Surface Barrier
Construct a road so that access is provided to all areas of the site,
and all contaminated soils on the road are covered by pavement. Provide
temporary construction detours to allow on-site residents access to their
property. The cost of this alternative is $1,039,451.
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Alternative 8: No Action
Do nothing to remedy the contamination problem on the road. There 1s
no cost associated with this alternative.
Detailed Analysis of Alternatives
Each one of the preceeding remedial alternatives was evaluated, and then,
rated with respect to the following specific criteria.
o Performance
o Reliability
o Engineering Implementabllity/Constructability
o Environmental Impacts
o Institutional Factors
o Costs
Rating Symbol Definition
Extremely negative effects, even with mitigating
measures. Alternative not worth further
consideration in this category.
Negative or moderately negative effects, but
not strong enough to be sole justification for
eliminating an alternative.
o Has very little positive or negative
effects, but inclusion can be justified for
special reasons, or no change from existing
conditions.
+ A positive or moderately positive benefit.
•H- An extremely positive benefit.
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11
Table 2 summarizes the results of this evaluation process.
Consistency with Other Environmental Laws
It 1s EPA policy to give primary consideration to remedial actions that
attain or exceed applicable and relevant standards of other Federal and
State public health and environmental laws. Environmental laws which will
have an Impact on the proposed remedies for the Petro-Chemical Systems, Inc.,
Phase I Frontier Park Road are summarized in Table 3. Provisions of the
applicable and relevant or appropriate requirements of these laws are
summarized 1n Table 4.
Recommended Alternative
Section 300.68(1) of the National Contingency Plan states that "the
appropriate extent of remedy, shall be determined by the lead agency's
selection of a cost-effective remedial alternative that effectively
mitigates and minimizes threats to and provides adequate protection of
public health and welfare and the environment."
Alternative 1 is the recommended alternative for Petro-Chemical Systems,
Inc., Phase I, Frontier Park Road. Costs for this alternative are summarized
in Table 5. This alternative consists of:
- Excavation and removal of 4,000 cubic yards of highly contaminated
soil. Backfill with clean soil.
- Temporarily store the contaminated soil onslte in a facility meeting
RCRA requirements until permanent remedy is selected.
- Construct a road over excavated areas and existing roadway to
provide access to site areas.
- Temporarily relocate on-site residents during excavation.
The rationale for selection of Alternative 1 is as follows:
Alternative 2 is essentially the same as Alternative 1, except that
temporary detours would be constructed. The cost for providing temporary
detours rather than temporary relocation is $225,000 more than
Alternative 1. Also, by leaving people onsite during excavation
there is a potential risk of exposure, which would be eliminated if
they were relocated. Therefore, Alternative 2 was eliminated.
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TABLE 4
PROVISIONS OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Page 1 of 3
RCRA Part 264
Subpart B - General Facilities Standards
Requires that facilities located 1n the 100-year
floodplain be designed, constructed, operated and
maintained to prevent washout of any hazardous
waste by a 100-year flood.
o Could be applied to any on-s1te landfill which would
be constructed 1n the future to dispose of wastes.
Subpart E - Manifest system, recordkeeping, and reporting
o Hazardous waste manifesting procedures would be required
If any waste 1s transported to an off-site TSO facility.
Subpart F - Groundwater Protection
o Requires that levels of hazardous constituents (40 CFR,
Part 261 Appendix VIII) In the uppermost aquifer at the
point of compliance (generally site boundary) meet
limits set by U.S. EPA as:
1) Background, or
2) Maximum Contaminant Levels (MCLs), or
3) An alternate concentration limit (ACL) posing no
present or future hazard to human health or the
environment.
o Will be fully addressed in Petro-Chemical Systems, Inc.
Remedial Investigation and Feasibility Study.
Subpart 6 - Closure and Post-Closure
Requires closure in a manner that minimizes the need for
further maintenance and prevents future'release of
contaminants.
o Could be applied to 1n-p1ace capping of wastes or closure
of any on-s1te landfills constructed as part of the
remedial action.
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TABLE 4 (Continued)
PROVISIONS OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Page 2 of 3
Subpart N - Landfills
Requires that RCRA compliant landfills be double-lined
and contain leachate collection and leak detection
systems; does not allow placement of liquid, ignitable,
or reactive wastes in landfill; also provides specific
closure requirements.
o Could be applied to any on-site landfill which would be
constructed In the future to dispose of wastes.
Occupational Safety and Health Standards; 29 CFR 1910
OSHA sets standards for protection of workers.
o Would be applied to site workers during any remedial
action; some standards may be considered in developing
safe exposure levels (in air for example) for near
site residents.
Clean Air Act: 42 U.S.C. 7401
Regulates primary air pollutants; does not address volatile
organics or most toxics in air.
o Application to site limited, possibly applies during
remedial actions Involving waste excavation.
0.0.T. Rules for the Transportation of Hazardous Materials: 49 CFR
Parts 107. 171.11 - 171.500
Regulates the transport of hazardous wastes through licensing
of qualified transporters.
Regulates hazardous waste manifesting system.
Regulates transport placarding.
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TABLE 4 (Continued)
PROVISIONS OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Page 3 of 3
EPA Groundwater Protection Strategy
Ranks aquifers In the order to be protected:
Class I - sole source aquifer
Class II - usable aquifer, other supplies available
Class III - water unfit for consumption (due to high salt
content for example), or aquifer has low yield.
o Deferred to Petro-Chemical Systems, Inc. Remedial Investi-
gation and Feasibility Study.
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Table 5 Estiiated Capital Costs for Rnedial Action
Cleanup Alternative 1 for Frontier Park Road
ALTERNATIVE 1 - On-site RCRA Storage Facility
Hith Tetporary Relocation
UNIT
DESCRIPTION QUANTITY UNIT COST TOTAL
1.
2.
3.
4.
5.
6.
Eicavate Contaminated Soils and
Transport to on-site RCRA
Facility
Backfill H/Natural Soils
Construction of on-site RCRA
Storage Facility
a. Liw Stabilized Subgrade
b. Oiled Sand Pad
c. 40 nl Synthetic Liner
d. 12* Leak-Detection Systei
USand
ii.) 4* PVC Drain Pipe
e. 40 il Synthetic Liner
f. 12* Leachate Collection Sys.
i.)Sand
ii.) 4' PVC Drain Pipe
g. 40 il Synthetic Liner
h. 12* Clay Layer
i. 6' Top Soil
j. Seeding
k. Backfill Contaainated Soil
Construction of Asphalt Road
a. Earthmrk (Ditches) -
(ll,100')(2)(7.S')(2.0')/27il.;
b. 6* Line Stabilized Subgrade
c. 4.5" Limestone Base
d. 2* Asphalt Top
e. Seeding (Shoulders ( Ditches)
Permanent Bayou Crossing
Temporary Relocation
(4 Families/16 People)
a. Housing (4 unitsll600/month)
b. Moving Expenses
i.) In
ii.) Out
c. Maintenance and Security
d. Misc. Eitraordinary Eip.
CONSTRUCTION SUB-TOTAL
OVERHEAD f PROFIT (10!)
4,800.00
4,800.00
2,952.00
1,180.00
30,625.00
935.00
2,934.00
24,964.00
871.00
2,320.00
29,929.00
1,280.00
658.00
29.00
4,800.00
; 14,800.00
27,134.00
27,134.00
24,667.00
433.00
1,040.00
6.00
4.00
4.00
6.00
6.00
CY
CY
SY
CY
Sfl.FT
CY
LF
SO.FT
CY
LF
SO.FT
CY
CY
MSF
CY
CY
SY
SY
SY
MSF
SO.FT
MO
EA
EA
NO
NO
5.00
8.00
3.20
8.00
0.50
8.00
15.76
0.50
8.00
15.76
0.50
8.00
8.00
19.25
8.00
5.00
1.60
5.50
4.40
19.25
38.00
2400.00
500.00
500.00
800.00
400.00
24,000.00
38,400.00
9,446.40
9,440.00
15,312.50
7,480.00
46,239.84
12,482.00
6,968.00
36,563.20
14,964.50
10,240.00
5,264.00
558.25
38,400.00
74,000.00
43,414.40
149,237.00
108,534.80
8,335.25
39,520.00
14,400.00
2,000.00
2,000.00
4,000.00
2,400.00
724,400.14
72,440.01
TOTAL 796,840.15
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Table 5 (continued)
A. CONSTRUCTION Stf-TOTAL * OVERHEAD I PROFIT 796,840.15
I. IID CONTINGENCIES 119,526.02
C. SLOPE CONTINGENCIES 0.00
0. CONSTRUCTION TOTAL 916,366.18
E. R.O.V AND EASEMENT ACQUISITION 0.00
F. BONDING t INSURANCE 91,636.62
6. SERVICES DURING CONSTRUCTION 64,145.63
N. HISCELLANEOUS LAI TESTING,
COMMUNITY RELATIONS.ETC. 69,000.00
I. TOTAL INPLEHENTATION COST 1,141,148.43
J. ENGINEERING DESIGN 71,636.62
I. TOTAL CAPITAL COST 1,232,785.04
L. OPERATION AND MAINTENANCE PRESENT WORTH 33,739.36
N. TOTAL PRESENT VORTH COST 1,266,524.40
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20
Alternative 3 and 4 were eliminated because transport and off-site
disposal of soils increases the cost of this alternative to over 2
million dollars more than Alternative 1 with no increase in protection
to human health and the environment. Furthermore, there is the risk of
a transportation incident since the material would be removed off-site.
Alternative 5 and 8 were eliminated because the road would essentially
remain the same as it is now. The road would persist in posing a risk
to human and the environment, by continuing to threaten ground and
surface water.
Alternative 6 was eliminated due to an additional 24 million dollars
required to perform excavation to background and off-site disposal.
Furthermore, this alternative does not meet the intent of the Super-
fund Amendments and Reauthorization Act of 1986 (SARA) which encourages
permanent remedies versus land disposal with no treatment
**
Consequently, Alternative 1 complies with all applicable and relevant
Federal and State environmental laws and regulations. Furthermore,
Alternative 1 is the lowest cost remedy that mitigates short and
long term threats to public health and the environment.
Operation and Maintenance
Operation and Maintenance will consist of surficial maintenance of the
road once the construction is complete.
EPA will be responsible for operation and maintenance of the road through
the Phase II, site remedial action, since the road will be used for access
by heavy equipment. The State of Texas or Liberty County will assume
responsibility for operation and maintenance of the road, commencing at the
close of Phase II, site remedial action.
Annual operation and maintenance costs for the road are estimated to
be $3,000.00.
Operation and maintenance will also be required for the onsite RCRA
storage area. This will consist of maintaining and operating the
leachate collection system.
EPA will consider the first years operation and maintenance of the
leachate collection system as part of the remedial'action. The
State of Texas will assume full responsiblity for the operation and
maintenance after this time. It is estimated that the system will
be in operation for a 5 year period until such time that the site
remedy can be implemented.
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21
Annual operation and maintenance costs for the leachate collection system
1s estimated to be $1,750 and the present worth for 5 years Is estimated
to be $6,600.
Schedule
Approve Remedial Action December 1986
Emergency Response Branch take-over January 1987
for Design of Road
Emergency Response Branch take-over January 1987
for Construction of Road
Agency coordination of Relocation with January 1987
FEMA
Community Relations
Public interest 1n Petro-Chemical Systems, Inc. was very high. Citizen
involvement resulted in the relocation of a State permit in 1974. Public
interest since that time has become moderate. In November, 1985, an
informational meeting was held 1n Liberty, after the site was placed on the NPL,
Approximately 30 people attended this meeting.
The public notice regarding the feasibility study and public meeting was
released on October 29, 1986. This was followed by the public comment
period which began November 12 and ended December 3. Approximately 45
people attended the public meeting held November 20, 1986, in Liberty.
There was no opposition to the temporary relocation effort and planned
roadway excavation and construction. The citizens did express concern that
the site might be used for future disposal of waste from other Superfund
sites. They also expressed an opinion regarding the drainage problems in
the area. Specific concerns and EPA's responses to all comments/questions
are outlined in the "Community Relations Responsiveness Summary" attached
to this Record of Decision.
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Attachment A
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TEXAS WATER COMMISSION
Paul HopkiM, Chairman
Ralph Homing, CommiMtoneT
John 0. HoMchlM, CommiwiontT
Larry R. Soward, Executive Dirtctor
Mary Ann Hefner, Chief Clerk
Jamct K. Rourki, Jr., General Counsel
December 19, 1986
Dr. Allyn M. Davis
Director, Hazardous Waste Management Division
U. S. Environmental Protection Agency
Region VI (6H)
1201 Elm Street
Dallas , Texas 75 270
Raft Petro-Chemical Systems
Proposed Record of Decision
Dear Dr. Davis t
we have reviewed the proposed Record of Decision (ROD) for the
Petro-Chemical Systems, Inc. Super fund Site. We have no
objection to the selected remedy as described in the proposed
ROD. The proposed remedy is excavation of the highly
contaminated soil on the road with storage of the waste in an
on-site RCRA facility. The road will be backfilled to grade and
paved with asphalt.
Sincerely,
Larry R. Soward
Executive Director
P. 0. BOB 13067 Capital Station • Awtin, Ttxa* 78711 • Am Code 512/463-7898
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1 t
Attachment B
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Petro-Chemical System, Inc.
Frontier Park Road
Liberty, Texas
Responsiveness Summary
This community relations responsiveness summary is divided into the following
sections:
Section I. Overview - This section discusses EPA's alternatives for
remedial action of the contamination on Frontier Park Road.
Section II. Background on Community Involvement and Concerns - This
section provides a brief history of community interest and concerns raised
during the remedial planning activities at the Petro-Chem site.
Section III. Summary of Comments Received during the Public Comment
Period - The comments and/or questions received during the public comment
period are summarized and EPA's responses are provided.
I. OVERVIEW
On November 12, 1986, EPA announced seven possible alternatives for
corrective action for the Frontier Park Road and on November 20, 1986
a public meeting was held to discuss the 7 approaches and solicit comment.
The alternatives under consideration were:
Onsite Storage - An estimated 4,000 cubic yards of highly contaminated
soil would be excavated and stored in a temporary onsite facility that
meets EPA and State standards. The excavated area would be backfilled
with clean soil and a road would be constructed over existing roadway.
During the excavation the two families currently living on the site
would be temporarily relocated or a temporary access road would be provided.
The costs range from $1 - $1.3 million.
Offsite Disposal - The contaminated soils mentioned above would be
excavated and taken to an offsite disposal facility. The area would be
backfilled and a road constructed over existing roadway. Again, the
residents would be relocated or a temporary access road would be provided.
The costs range from $2.9 - $3 million.
Temporary Access - A temporary gravel road would be constructed through
an uncontaminated area. The perimeter of the contaminated areas would be
fenced to prevent access. The contaminated soil on the roadway would be
addressed in the overall remedy for the site. The cost of this temporary
measure is estimated at $700,000.
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Total Removal - All soils contaminated above background levels
would be excavated. Clean fill dirt would be added and a road constructed
over existing roadway. A temporary road would be built for access
during excavation. The estimated cost is $24 million.
Cover Contamination - All contaminated material on the road would be
covered with gravel. A" temporary road would be provided during construction,,
The cost is estimated at $900,000.
No Action - As required by federal regulations, EPA considered taking
no action to remove or cover the contamination.
EPA's preferred remedial action for Frontier Park Road was excavation of
the highly contaminated soils and storage of the soil in a temporary onsite
facility. The residents would be temporarily relocated during the excavation.,
Judging from the comments received during the public comment period, the
general public is not opposed to the proposed remedy. One family living at
the site expressed the desire to be relocated if the relocation was short-term
and if the drainage problems could be alleviated when the road is constructed.
The other family living at the site expressed opposition to the relocation if
the entire road was not going to be reconstructed.
II. BACKGROUND OF COMMUNITY INVOLVEMENT
The Petro-Chemical System, Inc. site was originally discovered in 1970
by the Texas Water Quality Board (now the Texas Water Commission). The
records indicate that waste oils were spread on roads at the site as a
dust abatement measure. In 1971, the owner filed an application for a
commercial disposal permit for the 296-acre site. A permit was granted
after a lengthy public hearing, but subsequent legal action and public
opposition resulted in the permit being revoked. The original tract was
subdivided into 5 to 15-acre tracts. As many as 11 families have lived
on the site since 1974.
Interest in the site was renewed in 1981 and the State of Texas
conducted a preliminary Investigation of the site. In 1984, the State
requested that the site be included on the National Priorities List.
Community Interviews in December 1984 Indicated that the primary
concern was Frontier Park Road, drainage, and health-problems associated
with the contamination. In November 1985, the Texas Water Commission
held a public meeting to discuss the status of the site. Thirty-six
area residents attended.
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II. SUMMARY OF PUBLIC COMMENTS
The press release announcing the public comment period and public
meeting was Issued on October 29, 1986. The comment period began on
November 12 and ended December 3, 1986. The public meeting to outline
the results of the Remedial Investigation and Feasibility Study was
held November 20, 1986, 1n the Humphreys' Cultural Center 1n Liberty.
Forty-three (43) people registered at the meeting and 6 people spoke.
One letter with comments was received.
Comments/questions raised during the public comment period are
summarized briefly:
Comment 1: What do you estimate for time of temporary relocation?
EPA Response: The feasibility report estimates that the relocation
time would be six months. However,
this 1s a conservative estimate, realistically 1t could be 4-5 months.
This projection 1s based on starting the temporary relocation when the
equipment moves in and returning the residents when the equipment
moves out.
Comment 2: With the excavation and removal to an onsite disposal
facility that meets state and federal requirements, what are the
chances of wastes from other sites being brought to this facility in
the future?
EPA Response: None, wastes from other sites will not be brought
to the Petro-Chemical Systems, Inc., site for disposal.
Comment 3: How long will the waste be stored onsite?
EPA Respone: The projection is a period of 2-5 years, until total
site remediation 1s accomplished.
Comment 4: What standards would be used for the construction of the
road?
EPA Response: We would follow minimi urn county road specifications,
which consist of the following:
a) eight inches of lime-stone sub-base
b) 4 1/2 inches of gravel
c) two inches of asphalt
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Comment 5: Who would maintain the road after Its finished?
EPA Response: EPA would maintain the road, through the total
site remediation, since one of our objectives Is to access other
parts of the site. Long-term maintenance of the road will either be
the State or the County's responslbHty.
Comment 6: What will happen 1f, during construdton, additional
contamination is found?
EPA Response: We believe the road 1s sufflcantly characterized
and the extent of contamination Is known. However, should the situation
arise, provisions could be made to allow the residents effected access
to their homes until construction activities resume.
Comment 7: What 1s the estimated date to start actual construction?
EPA Response: Money from the newly enacted Superfund Bill has yet
to be appropriated, but we project money will be available some time In
February. Actual construction 1s not expected to begin until mid-summer
1987.
Comment 8: How can a clean-up alternative be chosen if the extent
of the contamination 1s not really known?
EPA Response: We are only proposing a remedy for the road at
this time. All other aspects of this site, the actual disposal
areas, groundwater and surface water will be thoroughly Investigated
under the total site remediation plan.
Comment 9: The road on the east side of the bayou Is about
1700 feet long and 1s in as bad shape as the rest of the road. When
the bayou crossing 1s built and only a limited area east of the
bayou reconstructed, the crossing water will only find another spot
to cross the road at a point just beyond the repairs. Therefore,
we believe the entire road should be repaired.
EPA Response: There are two objectives that we are concerned
with as far as the road remediation 1s concerned. Our proposed remedy
meets these objectives, which are to prevent direct contact with the
contaminated areas on the road and to provide access for the heavy to
the many disposal areas. Since there are no waste disposal areas
east of Turtle Bayou and no contamination was identifed along this
portion of the road, it does not meet with the Agency's objectives to
repair the east portion of the road.
Comment 10: The main waste pit 1s on my property. Am I in
any danger?
EPA Response: You would only be in danger if you repeatedly
came in direct contact with waste.
-------
Comment 11: Who will pay for the clean-up of this site?
EPA Response: The responsible parties have been notified to
Indicate whether they want to participate 1n the clean-up. If they
decline or there 1s no response, then the Agency will fund the clean-up
and recoup the costs from the responsible parties 1n court.
Comment 12: How 1s 1t cheaper to build an onslte storage
facility rather than take it away?
EPA Response: The Feas1b11ty Study was based on actual cost
estimmates and It ascertained that 1t 1s Indeed cheaper to build
a temporary onslte storage facility, rather then transport the waste
to an offsite facility.
Comment 13: How will the construction contracting be handled?
EPA Response: The road remediation could be handled as a TWC
State lead project. The State would be responsible for hiring a
prime contractor who would in turn hire any subcontractors needed to
complete the construction. However, it 1s likely, that EPAs Emergency
Response Branch will, assume the design and construction of the road.
Under the Emergency Program, one of the already approved prime contractors
would be used to design and construct the road. However, these prime
contractors have the authority to hire any subcontractors needed to
complete the job.
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Appendix 1
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Attachment A
Community Relations Activities
Conducted Regarding
the Retro-Chemical Systems Site
Community relations activities conducted at the Retro-Chemical site to
date Include the following:
o TWC conducted community interviews with local officials and
interested residents in December 1984.
o TWC finalized the community relations plan in August 1985.
o Information repositories were established in Liberty at the Public
Library and the County Courthouse and the TWC office in Austin.
o TWC conducted a public meeting to explain the status of the site
in November 1985. Thirty-six (36) people attended.
o The Remedial Investigation and Feasibility Study concerning the
road was released to the public for review and comment on
November 12, 1986.
o A pre-meetlng briefing was held with the County Judge and County
Commissioner on November 20. A pre-meeting briefing was also
conducted with the two families currently living on the site.
o EPA held a public meeting in the Humphreys' Cultural Center in
Liberty to describe the results of the Remedial Investigation and
Feasibility Study on Frontier Park Road. Fourty-three (43) people
registered at the public meeting on November 20, 1986, 6 people
spoke or asked questions.
o The transcript of the public meeting was sent to the area reposi-
tories on December 3, 1986.
o This Community Relations Responsiveness Summary was mailed to area
repositories and all individuals who commented or-asked question.
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