Superfund Record Of Decision Sol Lynn TX First Remedial Action


              United States
              Environmental Protection
              Agency
Office of
Emergency and
Remedial Response
•iEPA    Superfund
              Record  of Decision

               Sol Lynn, TX
EPA/ROD/R06-88/029
March 1968
                      SNVIRQNMENTAI
                       PROTECTION
                        AGENCY

                      DALLAS, TEXAS

                        LIBRARY

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50272-101
REPORT DOCUMENTATION '• REPORT NO-
PAGE
EPA/ROD/R06-88/029
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Sol Lynn, TX
rst Remedial Action
3. Recipient's Accession No
5. Report Date
03/25/88
'. Author(s)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.

(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered

800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The Sol Lynn site, also known as Industrial Transformers site, is located in Houston,
Texas. The area around the three-quarter acre site is a mix of residential, commercial,
and light industrial facilities. The residential population is about 2,000 and a
maximum daily traffic of 100,000 people may move within a one-mile radius due to
recreational activities associated with the area. The site operated as an electrical
transformer salvage and recycling company between 1971 and 1978, and as a chemical
cycling and supply company from 1979 through 1980. The first documented investigation
this site took place during the fall of 1971 when the City of Houston Water Pollution
(Control Division noted that workers at Industrial Transformers poured oil out of
electrical transformers onto the ground during transformer dismantling. In 1981, strong
odors originating from the site were brought to the attention of the Texas Department of
Water Resources, the predecessor agency of the Texas Water Commission (TWO. Upon
inspection, approximately 75 drums were found scattered about the property. Most of the
drums, labeled "tnchloroethylene", were empty and had puncture holes. A technical
assessment of the site, commencing in January 1986, indicated the presence of PCB
contamination. PCB contamination has been confined to the top two feet of soil. The
iighest concentrations of PCBs were found in the middle of the site. TCE has migrated
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
5ol Lynn, TX
First Remedial Action
Contaminated Media: soil
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EPA/ROD/R06-88/029
Sol Lynn, TX
First Remedial Action

16. ABSTRACT (continued)

deeper than PCB and away from the site. Residual TCE remaining in the surface soil will
be remediated along with the PCB contaminated soils. Any TCE that has migrated into the
deeper ground water will be addressed in the second operable unit. The primary
contaminant of concern affecting the soil is PCB.

The selected remedial action for this site includes: excavation of approximately
2,400 yd^ of PCB-contaminated soil and treatment using alkali metal polyethylene
glycolate (APEG) complex dechlorination with onsite disposal of treatment residuals;
effectiveness verification of the dechlorination process through treatability studies;
and if necessary, pretreatment of liquid byproducts with discharge into a publicly owned
treatment works facility. The estimated present worth cost for this remedial action is
$2,200,000.
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Declaration for the Record of Decision
Site Name and Location

Sol Lynn Site is located in Houston, Harris County, Texas

Statement of Purpose

This decision document represents the selected remedial action for the
Sol Lynn site, developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA) as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA), and the
National Contingency Plan (40 CFR Part 300).

Statement of Basis

This decision is based on the administrative record for the Sol Lynn
site. The attached index (Attachment A) identifies the items which
comprise the administrative record upon which the selection of the
remedial action is based.

Description of the Selected Remedy

This Record of Decision for the Sol Lynn site requires the following
actions to address the polychlorinated biphenyls contaminated soil:

o excavate the soil ;
o treat the soil with alkali metal polyethylene glycolate (APEG);
o backfill treated soil .

Declaration

The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable, or relevant
and appropriate, and is cost-effective. This remedy satisfies the
statutory preference for remedies that employ treatment technologies
which permanently and significantly reduce the toxicity, mobility or volume
of hazardous substances.

The State of Texas has been consulted and agrees with the approved remedy.
DATE Robert E. Layton Jr/,
Regional Administrator
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Sol Lynn
Record of Decision Concurrences
The Sol Lynn Record of Decision has been reviewed ancpl concur:
Allyn M.1 Davis, Director
Hazardous Waste Management Division
Jen he 11 Stokes, Chi e f
Solid Waste & Emergency Response
Branch
Office of Regional Counsel
Carl E. Edlund, Chief
Superfund Program Branch
Hazardous Waste Management Division
Stanley G. Hitt, Chief
Texas Remedial Section
Superfund Program Branch
Hazardous Waste Management.
Jonnie J./OeVos,Chief
State Prop/ams Section
Superfund Program Branch
Hazardous Waste Management Division
Robert E. HannesscbTager, Chief
Superfund Enforcement>6ranch
Hazardous Waste/Manajrement Division
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Surrmary of Remedial Alternatives Selection for the Contaminated Soils ^^
at the Sol Lynn/Industrial Transformer Site, Operable Unit I
Houston, Texas

I. SITE LOCATION AND DESCRIPTION

The Sol Lynn Superfund site (also known as Industrial Transformers (IT))
is located in Houston, Texas, As shown in Figure 1, the site is located
just south of 1-610 and west of Highway 288. The Sol Lynn site encompasses
approximately three quarters of an acre.

Surface drainage around the site includes shallow ditches that border the
site along Knight and Mansard Streets. These two ditches carry surface
runoff by slightly different routes to Braes Bayou which empties into
Buffalo Bayou then into the San Jacinto River Basin, which ultimately
flows into Galveston Bay. The site is outside the 100-year flood plain.

The area around the site is a mix of residential, commercial and
light industrial facilities. The light industrial, commercial business
area is located directly to the east and south of the site, Astroworld
and Astrodome are approximately 4,000 feet to the north of the site, and
finally a mix of private, single and multi-family dwellings are approximately
3,000 feet to the west. The residential population is about 2,000 and a
maximum daily traffic of 100,000 persons may move within a one-mile
radius due to recreational activities associated with the Astrodome and
Astroworld.

Site History

The Sol Lynn site is the location of a former electrical transformer salvage
and recycler company which operated between 1971 and 1978. A chemical re-
cycling and supply company subsequently operated at the same location from
1979 through 1980.

The first docuniented investigation of this site took place during the
fall of 1971 when the City of Houston Water Pollution Control Division
noted that workers at the Industrial Transformer Company poured oil out
of electrical transformers onto the ground as they were being dismantled.
In 1981, strong odors originating from the site were brought to the
attention of the Texas Department of Water Resources, the predecessor
agency of the Texas Water Commission (IMC). Upon inspection it was
revealed that approximately 75 drums were scattered about the property.
Most of the drums, labeled "trichloroethylene", were empty and had
puncture holes.

In October 1984 the site was proposed for inclusion on the National
Priorities List. In September 1985, the TWC entered into a Cooperative
Agreement with the EPA to conduct the Remedial Investigation/ Feasibility
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INDUSTRIAL TRANSFORMER

HOUSTON, TEXAS
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Study (RI/FS) at the site. Utilizing funds from this cooperative agreement,
the TWC contracted with Radian Corporation on June 30, 1986, for a technical
assessment of the site. Field work began January 14, 1987.

In an effort to address the obvious contamination in an expeditious manner,
the site was broken down into parts called operable units. There is a
soil operable unit and a groundwater operable unit. This suitttiary only
examines potential remedial alternatives for the soil operable unit.
The groundwater operable unit will be addressed in the
second, or "Phase II" Feasibility Study.

Geology

Surface soils at the site and in the vicinity are of the Lake Charles series,
These soils are characterized by somewhat poor drainage and high available
water capacity. When the soil is dry, deep, wide cracks form on the
surface where water can enter rapidly. When the soil is wet the cracks
are sealed and water infiltrates slowly.

Below the surface soil is Beaumont Clay, which is of Pleistocene
age. The lithology of the Beaumont Clay is comprised of unconsolidated
clays and muds or deposits of clayey sands and silts. The clays and muds
were deposited as interdistributary, abandoned channel fill, overbank
fluvial or mud-filled coastal lake or tidal creek muds. The sands and
silts represent alluvium, levee and crevasse splays.

The uppermost aquifer is encountered at a depth of 30-34 feet below ground
surface. This particular aquifer is a water-bearing sand that varies in
thickness from 2 feet to 6 feet, averaging 4 1/2 feet. Sand content
increases from west to east across the site, from 50% to 70%. This
aquifer is not used as a drinking water supply. The groundwater flows to
the northwest.

The uppermost water-bearing sand is separated from the next lower, "inter-
mediate" water-bearing sand by a stiff clay, approximately 45 to 52 feet
in thickness. The intermediate water-bearing sand is underlain by clay.

The major aquifers in the Houston area are the Chicot and Evangeline.
These aquifers supplement surface water in supplying the City
with drinking water. In the vicinity of the site the shallowest well
for the City of Houston is at 670 feet below the surface. During the
groundwater investigation of the site an evaluation of the extent of the
contamination and its impacts on these wells will be determined.

Remedial Investigation Results

During the RI samples were collected from soil, stormwater, and
air to determine the nature and extent of contamination.
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Because information collected previously by WC indicates the primary
contaminants at the site are polychlorinated biphenyls (PCBs) and
triohloroethylene the emphasis for the analytical testing was placed
on determining vertical and areal extent of these two contaminants.

In the samples collected from the upper two feet of soil, concentrations
of PCBs varied from 350 ppm at the middle of the site, to 118 ppm at the
eastarn edge of the site, to not detected in the western part of the site.
samples collected at the 2 to 4 foot depth indicated PCBs of less than
5 ppm.

Seven stormwater samples were collected from "ponded" areas onsite
and from the offsite drainage ditch areas. All samples were analyzed
for PCBs. Only one sample of "ponded" water at the site near a contami-
nated area showed PCBs (0.0011 ppm). Two of the sa.npT.es were analyzed
for TCE. Only one sample of "ponded" water shows the presence of TCE at
.0026 ppm.

Sediment samples were collected from the same location as the stormwater
samples. The results of the sediment sampling showed that only one
sample collected in a drainage ditch south of the site exceeded the
cleanup criterion. Air samples were also taken. The analysis of the
air samples did not detect TCE or PCBs.

In conclusion, analytical results of all samples collected at the site
indicate that the PCS contamination is confined to the top two feet of
soil and is within the area shown on Figure 2. This constitutes a
volume of approximately 2400 cubic yards of contaminated PCB soils
that exceed the cleanup criterion. The TCE which is a highly mobile
and volatile compound, has migrated much deeper and farther away from
the site. Very little TCE remains near the surface because it has
either volatilized or moved with the groundwater into the deeper aqu-
ifers. The TCE that does remain at the surface will be remediated
along with the PCB contaminated soils. Any TCE that has migrated
into the deeper groundwater is beyond the scope of this cleanup will
be addressed as part of the groundwater operable unit.

Potential Impacts of the Site on Human Health and the Environment

As part of the remedial investigation, an assessment of the health threat
created by the current site conditions was conducted. Factors included
in this risk assessment were the identified target receptors, the maximum
concentrations of PCBs onsite, and the degree of exposure to the hazards
from the site. Target receptors identified in the assessment included the
workers, trespassers, and clientele of the business which currently
operate at the site.

The results of the risk assessment indicate that the highest concentrations
of PCBs found onsite present a 10 (one thousand in one million) lifetime
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cancer risk. The major pathways of exposure are dermal and ingestion.
This level represents the threat that would be posed by the site
conditions if no remedy was implemented.

The extent of remedial action necessary is based on a comparison of the
contaminant concentrations found at the site to either 1) existing health-
based standards or criteria; or 2) concentrations that would represent a
10"4 to 10"' lifetime cancer risk. A health-based criterion for PCB
contaminated soil is available (Toxic Substances Control Act Spill
Cleanup Policy, Fed. Register, April 2, 1987). This criterion, 25 ppm,
which assumes a worker is exposed to the site of eight hours per
day for a 40 year period was chosen as the cleanup standard.

II. Enforcement

The goal of the EPA is to have those parties responsible for contamination
of the site perform the cleanup. There are three identified potentially
responsible parties (PRPs) for the IT site. These parties will be
given the opportunity to conduct or participate in the remedial action
selected for the site. If they refuse, EPA will proceed with funding
the remedial design and implementation.

III. Community Relations History

The Industrial Transformer Superfund site was proposed for the National
Priorities List (NPL) in October 1984. In February 1985 the U.S.
Environmental Protection Agency (EPA) and the Texas Water Commission (TWC)
held a public meeting in Houston for residents near the site to discuss site
conditions and the Superfund Program/Process. Approximately 15 people
attended the meeting. On October 3, 1985, EPA issued a news release
announcing that funds to study the site had been awarded to the TWC.

Initiation of studies on Industrial Transformer was announced by TWC at a
public meeting in Houston on September 24, 1986. Evaluation of the site
was divided into two separate studies: 1) surface soil contamination;
2) groundwater contamination. The study addressing surface soil
contamination was completed in December 1987. On January 21, 1988, EPA
announced to the public via a news release that a public meeting would be
held on February 2, 1988, to discuss the proposed remedy for surface
contamination at the site. The groundwater study is expected to be
completed in 1989.

An EPA prepared fact sheet which described alternative remedial actions
for the soil contamination along with the EPA preferred alternative was
sent to the interested and affected public shortly after the public
meeting was announced. EPA and TWC conducted the 7:00 pm public meeting
at the Astro Village Hotel on February 2, 1988. Approximately 35 people
attended the public meeting.
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Further details on community relations are contained in Attachment B.

IV. Alternatives Evaluation

The requirements, procedures and preferences that the EPA follows in
selection of a Superfund remedy are outlined in the Comprehensive
Environmental Response Compensation and Liability Act, (CERCLA) as
a-rended by the Superfund Amendments and Reauthorize ton Act (SARA),
the National Contingency Plan (40 CFR Part 300) and various applicable
guidelines. The following describes the evaluation criteria used in
selection of a remedy for the IT site.

A. Evaluation Criteria

1. SARA Requirements-Section 121(a) through (f) of SARA contains three
factors which EPA must consider in selecting a remedy.

a. Protection of Human Health and the Environment.

The alternative must provide adequate protection of human health
and the environment.

b. Cost Effective

Cost effectiveness includes an evaluation of the following criterion:

i. Long-term Effectiveness and Permanence '

Alternatives are assessed for the long-term effectiveness and
permanence they afford along with the degree of certainty
that the remedy will prove successful. Factors considered
are:

• magnitude of residual risks in terms of amounts and concen-
trations of waste remaining following implementation of a
remedial action, considering the persistence, toxicity,
mobility, and propensity to bioaccumulate of such hazardous
substances and their constituents;

• type and degree of long-term management required, including
monitoring and operation and maintenance;

• long-term reliability of the engineering and institutional
controls, including uncertainties associated with land
disposal of untreated wastes and residuals;

ii. Short-term Effectiveness

The short-term effectiveness of alternatives must be assessed;
considering appropriate factors among the following:
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• magnitude of reduction of existing risks;

• short-tern risks that might be posed to the community, workers,
or the environment during implementation of an alternative
including potential threats to human health and the environment
associated with evacuation, transportation, and redisposal or
containment;;

• time until full protection is achieved.

• potential need for replacement remedy.

• potential for exposure of human and the environmental
receptors to remaining waste considering the potential threat
to human health and the environment associated with
excavation, transportation, redisposal or containment.

iii. Implementability

The ease or difficulty of implementing the alternatives are
assessed by considering the following types of factors:

• degree of difficulty associated with constructing the
technology;

• expected operational reliability of the technology;

• need to coordinate with and obtain necessary approvals and
permits (e.g. NPDES, Dredge and Fill Permits for off-site
actions) from other offices and agencies;

• availability of necessary equipment and specialists;

• available capacity and location of needed treatment,
storage, and disposal services.

• compatibility with existing future land use.

• need to respond to other sites

iv. Cost

The types of costs that should be assessed include the
following:

• capitol cost;

• operational and maintenance costs;
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7

• cost of five-year reviews, where required

• net present value of capital and O&M costs;

• potential future remedial action costs.

c. Compliance with applicable or relevant and appropriate Federal
and State regulations

In determining appropriate remedial actions at Superfund sites,
consideration must be given to the requirements of other Federal
and State laws. Alternatives should be assessed as to whether
they attain legally applicable or relevant and appropriate require-
ment of other Federal and State public health and environmental
laws. Requirement under Federal and State laws that specifically
address the circumstances at a Superfund site are considered
applicable. Relevant and appropriate requirements, While not
applicable to a Superfund site, address situations which are
sufficiently similar to those existing at the site.

2. SARA Preferences. The EPA is also directed by SARA to give
preference to remedial actions which reduce the toxicity, mobility or
volume of the waste. Relevant factors are:

• the treatment processes the remedies employ and materials
they will treat;

• the anount of hazardous materials that will be destroyed or
treated;

• the degree of expected reduction in toxicity, mobility, or volume;

• the degree to which the treatment is irreversible;

• the residuals that will remain following treatment, considering
the persistence, toxicity, mobility, and propensity for
bioaccumulation of such hazardous substances and their
constituents.

3. EPA Guidelines-It is EPA policy is to consider other factors in
factors in selection of a remedy. These are:

a. Community Acceptance

This assessment should look at:

• components of the alternatives which the community supports;
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8

• features of the alternatives about which the community has
reservations;

• elements of the alternatives which the community strongly
opposes.

b. State Acceptance

Evaluation factors include assessments of:

• components of the alternatives the State supports;

• features of the alternatives about which the State has reser-
vations;

• elements of the alternatives under consideration that the
State strongly opposes.

B. Description of Alternatives

In conformance with the NCP, an initial set of remedial approaches
were screened to determine whether they might be appropriate for
this site. From these possible remedies, eight alternatives were
chosen for more detailed evaluation and comparison with the remedy
selection criteria outlined above. Each is summarized below:

Alternative 1, No Action - For this remedy, no new or additional remedial
actions will be conducted. There are some costs associated with closing
out the site, which include plugging monitoring wells, dismantling remedial
investigation equipment and the decontamination pad.

In addition, long term monitoring activities would be required.
Groundwater, soil sediment, and air samples will be taken at an
approximate cost of $10,000 per year. The present worth of this
alternative costs is estimated to be $450,200 for 30 years.

Alternative 2, Off Site Landfill - In the off site landfill alternative,
PCBs above 25 ppm in the soil would be excavated, transported, and
disposed at an off site PCB landfill. Approximately 2500 cubic yards
of soil will require excavation and transport several hundred miles
to an appropriate facility, necessitating over 168 dump trailer loads.
The off site landfill will be specifically permitted for the disposal
of PCBs and in compliance with the Resource Conservation and Recovery
Act and TSCA. The estimated cost of this alternative is 2.3 million.
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Alternative 3, Stabilization and Off Site Landfill - This alternative is
the same as Alternative 2, except prior to disposal the excavated soils
will be stabilized with a cement-type mixture to enhance binding of the
toxic substances to the soil. The estimated cost of this alternative is
$3.5 million.

Alternative 4, In-Situ Classification - This is an innovative technology
which uses an electric current passed between electrodes in the ground to
convert the soils into a stable glass material resembling natural obsidian.

Implementation of this process would require power in the form of locally
supplied electricity. A square array of four electrodes is placed in
the soil to the desired treatment depth, at lest two feet in this
case. A mixture of graphite and glass frit is spread between the
electrodes to act as a starter path for the electric current established by
the potential applied to the electrodes. The current heats the starter
path and adjacent soils to 3630°F, well above normal melting temperatures of
most soils. The molten soils incorporate the inorganic constituents
and pyrolysis the organic ones. The pyrolysis byproducts migrate to the
surface and combust in the presence of oxygen. A hood placed over the
treatment area collects the gases for treatment. Following glassification
more topsoil will be added and revegetated. This alternative may require
a pilot scale test to determine the most effective electrode spacing and
depth of soil treatment. The estimated cost for this alternative is
$1.5 million.

Alternative 5, On Site Incineration - This alternative consists of
excavating contaminated soils and incinerating them onsite using the
most suitable of several types of mobile or transportable thermal
destruction units.

After excavation the soils will be stored temporarily in waste piles
then fed into an on site incinerator. The incinerator exhaust gases
will be scrubbed prior to venting to the atmosphere. If the ash is
hazardous it will be disposed of in a RCRA approved off site landfill
(as described in Alt. 2). If not it would be disposed on site. Follow-
ing excavation the topsoil will be replaced and revegetated. The es
timated cost for this alternative is $2.5 million.

Alternative 6, Off Site Incineration

This remedy would require the excavation and transportation or two
feet of soil in bulk to an off site commercial incineration facility
that complies with RCRA.

Transport and regrading will be as described for Alternative 2. The
soils'will be transported in bulk to an off site commercial incin-
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10

cineration facility in compliance with Section 121 (d) of CERCLA as
amended by SARA. The cost of this alternative is estimated at $6.1
million.

Alternative ~1, Chemical Treatment - This is a new technology which results
in the dechlorinization of PCBs by mixing soils with alkali metal poly-
ethylene glycolate complex (APEG) in a batch reactor. This treat-rent
changes the chemical composition of the PBCs by chemically reacting
with the chlorine atoms occur until they are completely dechlorinized.
This process yields polyglycol byproducts that are non-toxic. This
technique would be proven effective by implementing treatability testing.
This alternative is estimated to cost $2.2 million.

Alternative 8, Biological Treatment - This is a new technology in in
the hazardous waste field. Wastes are used as a food source for the
microorganisms in a slurry medium with mechanical or diffused air
supplying oxygen to the microbes. For this alternative the soil will be
excavated and treated in a batch system on site. The estimated cost is
$3.3 million.

Evaluation of Alternatives

An evaluation of the alternatives is shown on Table 1. The following values
were assigned to compare remedial selection criteria:

+ Alternative would exceed a criterion in comparison to other alternatives.
0 Alternative can be designed to meet the selection criterion.
- In comparison to other remedies, this alternative will present difficulty
in achieving a selection criterion.

1. Complies with ARARs (meets or exceeds Applicable, or Relevant and Appro-
priate Federal and State Requirements).

Table 2 delineates the Federal and State statutes which are applicable or
relevant and appropriate (ARARs). In all instances where the regulation
is considered applicable or relevant and appropriate, those requirements
will be met.

2. Reduces Toxicity, Mobility, and Volume

a. No Action was rated "-" for reducing mobility and toxicity because
it does nothing to reduce these parameters. The volume will not
change so it was rated a "0".
Off Site Landfill was rated a "0" for mobility because the landfill
encapsulate the waste from the environment as long as all the
containment features remain intact. Because of the risk of future
leakage from a landfill, total immobilization can not be assured. The
toxicity will not change so it was rated "-" and the volume will stay
the same.
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-------
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c. Stabilization with Off Site landfill was rated a "+" for mobility.
Stabilization before landfilling will iirmobilize the waste before
containment. The toxicity will not change so it was rated "-" and
the volume will greatly increase due to the fixatives added to
stabilize the waste so it was rated a "-".

d. in-Situ Classification was rated with a "+" for mobility because
this method convert the soils into a stable material resembling natural
obsidian. It was rated a "+" in toxicity reduction because it would be
expected to destroy PCBs in the soil with a greater than 99.9999%
destruction efficiency. Classification will reduce the volume of
toxic substances substantially/ therefore it is rated a "+".

e. On Site and Off Site Incineration were given a "+" for reducing toxicity,
and mobility because thermal destruction destroy organics in the
soil. Soil will not burn, therefore the volume of soil will not be
substantially reduced, however, since the volume of contaminants
will be reduced these are rated a "+" on volume reduction.

f. Chemical Dechlorinization was given a "+" for reducing mobility and
toxicity because studies show that PCBs will be eliminate. After
treatment the volume of remaining material is relatively unchanged
because the material treated is soil. However, since the volume of
contaminants will be reduced this rated a "+" on volume reduction.

g. Biological Treatment was given a "+" for reduction in mobility and
toxicity because studies show that PCBs can be biodegraded. The
volume of toxic substances will be reduced therefore this alternative
was rated a "+" for this criterion.

3. Short Term Effectiveness

a. No Action does nothing to reduce the existing risks. However,
because there are no construction activities that will occur there is
no potential for increased exposure to workers or the community.
Therefore, the overall risks tend to balance each other out for this
criterion giving an overall "0" ranking.

b. Off Site Landfill and Stabilization with Off Site Landfill these
alternatives do involve construction activities so there is an
increased potential for exposure to the workers. These risks include
possible spillage during transportation and the increased contact
with the soil the workers experience during excavation. The construction
activities are expected to take only a couple of months. For these
reasons the landfill alternatives rated a "-".

c. In-Situ Classification has the advantage of no excavation, however
gases are produced as the soil is melted. The gases produced will
be treated and rendered non-hazardous. Therefore it was graded
a "0" for short-term effectiveness.
-------

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-------
11

c. Stabilization with Off Site Landfill was rated a "+" for mobility.
Stabilization before landfilling will immobilize the waste before
containment. The toxicity will not change so it was rated "-" and
the volume will greatly increase due to the fixatives added to
stabilize the waste so it was rated a "-".

d. In-Situ Classification was rated with a "+" for mobility because
this method convert the soils into a stable material resembling natural
obsidian. It was rated a "+" in toxicity reduction because it would be
expected to destroy PCBs in the soil with a greater than 99.9999%
destruction efficiency. Classification will reduce the volume of
toxic substances substantially, therefore it is rated a "+".

f. Chemical Dechlorinization was given a "+" for reducing mobility and
toxicity because studies show that PCBs will be eliminated. After
treatment the volume of remaining material is relatively unchanged
because the material treated is soil. However, since the volume of
contaminants will be reduced this rated a "+" on volume reduction.

3. Short Term Effectiveness

d. On Site Incineration received a "-" for short-term effectiveness.
As previously stated excavation poses a short-term potential health
hazard to the workers. Although there will be gases produced from
the incineration these gases are primarily non-hazardous and will not
impose any significant increased health risks to the community. Air
monitoring will be concurrent with any incineration. Time requirements
should be approximately two months for the test burn treatability
study and another four months for the treatment itself.

e. Off Site Incineration received a "-" for short-term effectiveness
because the soil must be excavated, as well as transported, increasing
exposure to the workers and the community. Due to scheduling problems
with incinerators, implementation of this alternative may take several
years.
. f. Chemical Dechlorinization and Biological Treatment were given "0"
for short term effectiveness. Although the worker will be wearing
protective gear excavating the contaminants will expose the workers
to the contaminants more than an insitu process will.

4. Long-term Effectiveness and Permanence

a. No Action allows for further migration of the contaminants in the
environment and therefore this alternative received a "-".

b. Off Site Landfill was given "-" because a landfill may allow for the
potential of migration if the liner is not maintained and is therefore,
the least preferred alternative under SARA.

c. Stabilization with Off Site Landfill was given a "0" for long-term
effectiveness because it offers a more permanent solution than
landfilling alone but the wastes are not destroyed as in the other treatment
alternatives.

d. in-Situ Classification, Chemical Dechlorinization, Off and On Site
Incineration and Biological Treatment were given a "+" because they
eliminate the contaminant thereby rendering both long-term and permanent
solutions. Little to no maintenance is required for these alternatives.
Classification, chemical dechlorinization and biological treatment are
all innovative technologies, therefore, there is a degree of uncertainty
associated with these methods not associated with off or on site
incineration.

5. Implementability

a. No Action is very simple to implement therefore, it rated a "+".
There are no construction activities, only setting up monitoring
systems.
-------
14

protect human health and the environment more than the "no action" alternative,
however, all require excavation and transportation which increases the
exposure of the workers and the community to the PCBs. Classification
does not require excavation or transportation and does provide protection
to human health and the environment. It destroys the contaminant and
therefore eliminates the threat of dermal contact and ingestion. However,
because buildings are located on site it is not technically feasible.
Chemical Dechlorinization, Biological Treatment and On site Incineration
all require excavation for treatment. These treatments processes do meet
the TSCA Spill Cleanup Policy recommendation for the protection of human
health and the environment. They destroy the contaminant and thereby
eliminate the threat of dermal contact and ingestion, and they are SARA
preferred remedies.

Selected Remedy: Dechlorinization

Rationale

As previously stated, based on the information available to evaluate the
eight remedial options against these nine criteria, EPA has concluded
that Alternative 7, Chemical Dechlorinization, is the Agency's selected
alternative. This alternative is protective of human health and the
environment, attains all applicable or relevant and appropriate Federal
and State requirements and is cost effective. This alternative satifies
SARA's preference for a remedy which employs treatment as the principal
element to reduce toxicity, mobility or volume.

Treatability studies will be conducted during the design phase of the project.
The contaminated soils will be excavated and an alkali metal polyethylene
glycolate reagent (APEG) will be applied. This reagent dechlorinates the
PCBs, rendering them harmless. After treating the soil to or below a
PCB concentration of 25 ppm, the liquid byproducts of this treatment may
be pretreated if necessary and discharged into a public owned treatment
works facility.

Operation and Maintenance (O&M)

The need for future operation and maintenance will be minimized since the
contamination will be removed. Site operation and maintenance will include
a shallow groundwater sampling and analysis program which will be included
with the remedy for the groundwater. Additional site maintenance will
entail the inspection and care of the surface vegetation.
-------
13

b. Off Site Landfill, Stabilization with Off Site landfill and Off Site
Incineration were given a "+" because of the minimum amount of
difficulty that would be expected from simply excavating the waste
and taking them off site for disposal. These alternatives are very
compatible with both existing and future land uses.

c. In-Situ Classification was given a "-" because there will be some
difficulty associated with the construction of this process. It is a
new technology and there will be a need for special equipment and
specialists. Furthermore, this method causes the soil to contract
which may cause structural problems with the existing buildings
located on the site.

d. On Site Incineration was rated a "+". This technology is new. There
is some difficulty associated with the construction setup and trial
test burn, however this technology has proven to be reliable in the
past. Ample room exists at the site to set up and operate an on
site incinerator.
e. Biological Treatment and Chemical Dechlorinization were both given a
"0" because they are innovative technologies. Excellent results have
been obtained in field tests on both processes which are being considered
and implemented on other Superfund sites. There is ample available
space at the site for both of these technologies. They are compatible
with current and future land uses.

6. Cost

Estimated costs for each remedial action alternative are summarized in
Table 1. A breakdown of this cost may be found in Appendix A of the
Feasibility Study.

7. Community Acceptance

The public comment period began January 25, 1988 and ended February 24,
1988. The public meeting was held Febuary 2. One comment was received
during the public comment period objecting to the recommended alternate
from a vendor of a different technology.

8. State Acceptance

The State of Texas (Texas Water Commission) has concurred with chemical
dechlorinization as the treatment alternative.

9. Overall Protection of Human Health and the Environment

"No Action" does not protect human health and the environment. Off Site
Landfill, Stabilization with Off Site Landfill and Off Site Incineration,
-------
15
Future Actions
No future actions are anticipated for the soil. The selected remedial
action will afford a high degree of permanence.

Remedial Action Schedule
Approve Remedial Action (sign ROD)

Complete Enforcement Negotiation
Award Cooperative Agreement Amendment
for Design of approved Remedy

Start Design

Complete Design

Award Remedial Action Cooperative
Agreement Amendment for Construction
of approved Remedy

Start Construction

Complete Remediation
March 1988

Sept. 1988
Sept. 1988
Oct. 1988

Dec. 1989

June 1990

June 1991
-------
ATTACHMENT A
-------
ADMINISTRATIVE RECORD INDEX
-------
ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
April 16, 1984
Correspondence
Charles E. Nemir
Texas Department of Water Resources
Dick Whittington
U.S. EPA - Region VI
Re: Hazardous Ranking System Submittals
1
1
Document Date
Document Type

Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 13, 1973
Worksheet Picture Log A Water Control
System
Jerry R. Kahl
Texas Water Pollution Control
Files
U.S. EPA - Region VI
3
2
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
June 14, 1984
Hazardous Ranking Systems Package
U.S. EPA - Region VI
Files
U.S. EPA
Document
15
3
- Region VI
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
Enforcement Notice
File
U.S. EPA - Region VI
Enforcement Notice
3
4
-------
ADMINISTRATIVE RECORD INDEX
Job Name: Industrial Transformer
Job Number: T327

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
April 12, 1982
Interoffice Memorandum
Fred C. Dal by
Texas Department of Water Resources
Gary Schroeder
Texas Department of Water Resources
TCE & PCB Contamination
21
13
August 18, 1983
Interoffice Memorandum
Fred C. Dal by
Texas Department of Water Resources
Gary Schroeder
Texas Department of Water Resources
Enforcement Action
2
14
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Number of Pages
Document Number Sequences
April 26, 1984
Worksheet
Steve Gil rein
U.S. EPA - Region VI
File
U.S. EPA - Region VI
Potential Hazardous Waste Site
Identification
1
15
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
April 12, 1984
Worksheet
Fred C. Dal by
Texas Department of Water Resources
File
U.S. EPA - Region VI
Site Inspection Report
10
16
-------
ADMINISTRATIVE RECORD INDEX
Job Nane: Industrial
Job Number; T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
August 12, 1983
Document
Fred C. Oalby
Texas Department of Water Resources
File
U.S. EPA - Region VI
Investigation Report
4
17
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
July 5, 1982
Interoffice Memorandum
Merton J. Coloton
Texas Department of Uater Resources
Gary D. Schroeder
Texas Department of Water Resources
Enforcement Action
1
18
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
July 5, 1982
Document
Fred C. Dal by
Texas Department of Water Resources
File
U.S. EPA - Region VI
Site Investigation Report
3
19
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
March 22, 1982
Document
File
U.S. EPA - Region VI
Clean-up by Owner
1
20
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Nunber: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
September 14, 1981
B. McDonald-Buyton
File
U.S. EPA - Region VI
Health Compliants
2
21
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
Worksheet
Fred C. Dal by
Texas Department of Water Resources
File
U.S. EPA - Region VI
Compliant Report
1
22
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
May 15, 1984
Interoffice Memo
Gail Corrigan
Texas Department of Water Resources
Bryan Dixon
Texas Department of Water Resources
Sol Lynn Property
2
23
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
January 31, 1985
Correspondence
Sammy Russo
Roy F. Weston
Michael Warner

Lab Results
31
24
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ADMINISTRATE RECORD INDEX
Job Name: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
June 27, 1985
Memo
Kendall Young
U.S. EPA - Region VI
Charles Gazda
U.S. EPA - Region VI
Analytical Data
15
25
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
August 27, 1984
Record of Communication
George Buynoski
Center of Disease Control
John Cochran
U.S. EPA - Region VI
Immediate Health Hazard From Site
1
26
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
September 25, 1984
Record of Communication
John Cochran
U.S. EPA - Region VI
Tom Goddard
Texas Attorney Generals Office
Sol Lynn Law Suit
1
27
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
October 31, 1984
Document
File
U.S. EPA - Region VI
Planning Activities and RI/FS
2
28
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
February 6, 1985
Newspaper Article
Bill Dawson
The Houston Chronide
Public

Fall Study of Toxic Cleanup Planned
1
29
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Number of Pages
Document Number Sequences
February 6, 1985
Newspaper Article
Harold Scarlett
The Houston Post
Public

EPA Evaluating Cleanup Steps for
Uaste Site
1
29
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 13, 1973
Worksheet
Jerry R. Kahl
Texas Water Pollution Control
File
U.S. EPA - Region VI
Comments of Visual Contaminants
1
30
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
February 4, 1985
Correspondence
Uarren Zehner
Weston - Sper
Gerald Fontenot
U.S. EPA - Region VI
Industrial Transformer Site Inspection
11
31
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ADMINISTRATIVE RECORD INDEX
Job Nane: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
June 11, 1985
Correspondence
Susan K. Siege!
Ueston Sper
Gerald Fontenot
U.S. EPA - Region VI
Well Sampling
1
32
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
October 2, 1985
Inteoffice Memorandum
Karen Solari
U.S. EPA - Region VI
Gerald Fontenot
U.S. EPA - Region VI
Review of Data
2
33
Document Date
Document Type
Ori ginator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
December 1985
Report
U.S. EPA - Region VI

File
U.S. EPA - Region VI
Community Relatins Plan
22
34
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
February 11, 1985
Correspondence
Rosemary Henderson
U.S. EPA - Region VI
Charles Gazda
U.S. EPA - Region VI
Trip Report
3
35
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Nunber: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient-
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 10, 1985
Newspaper Article
Harold Scarlett
The Houston Post
Public

Waste Site Owner Objects to Cleanup
1
36
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
October 28, 1985
Correspondence
Charles R. Fauld
Texas Water Commission
Bonnie DeVos
U.S. EPA - Region VI
Justification for RI/FS
2
37
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
March 7, 1983
Correspondence
Charles Nemir
Texas Department of Water Resources
Jim Mattox
Attorney General of Texas
Legal Action Against Sol Lynn
2
38
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
June 11, 1982
Interoffice Correspondence
Lew Turnock
City of Houston
John R. Whittington
City of Houston
TCE Health Hazard
1
39
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
March 4, 1985
Record of Communication
Drew Puffer
U.S. EPA - Region VI
Tom Goddard
Texas Attorney General's Office
Civil Penalty Trial in July
1
40
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
August 27, 1984
Record of Communication
John Cochran
U.S. EPA - Region VI
George Buynoski
Center for Disease Control
Health Hazard at Site
1
41
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
April 24, 1985
Memorandum
Samuel L. Nott
U.S. EPA - Region VI
William Hathaway
U.S. EPA - Region VI
Industrial Transformers
3
42
Document Date
Document Type
Originator
Originator -Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
January 15, 1987
Correspondence
John Bins
ERT Company
Arthur Talley
Texas Water Commission
Sampling
10
43
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ADMINISTRATIVE RECORD INDEX
Job Nane: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
June 27, 1985
Document
File
U.S. EPA - Region VI
Final Report Laboratory Report
41
44
March 17, 1986
Document
TUC

File
U.S. EPA - Region VI
Work Scope for RI/FS Studies
20
45
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
October 13, 1986
Report
Radian Corporation

Texas Water Commission

Project Sampling Plan
71
46
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
October 13, 1986
Report
Radian Corporation

Texas Water Commission

Project Health & Safety Plan
34
47
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ADMINISTRATIVE RECORD INDEX
Job Nane: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
June 30, 1986
Document
Texas Water Commission

File
U.S. EPA - Region VI
Contract with Radian
78
48
December 22, 1986
Correspondence
Arthur Talley
TWC
Sol Lynn
Remedial
14
49
Investigation
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
January 15, 1987

John Bins
ERT
Arthur Talley
Texas Water Commission
Industrial Transformers
3
50
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequences
January 16, 1987
Record of Communication
Robie Hirt
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
Industrial Transformer Progress
1
51
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Nunber: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
Janauary 29, 1987
Memorandum
Steve Muse
U.S. EPA - Region VI
File
U.S. EPA - Region VI
Report on Field Audit of RI
1
52
June 17, 1987
Correspondence
Sharron Oppel
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
RI/FS Information
1
53
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
July 15, 1987
Correspondence
Arthur Talley
Texas Water Commission
Sol Lynn
Remedial
1
54
Investigation
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation

Description
Number of Pages
Document Number Sequences
July 28, 1987
Memorandum
Sherry Fuerst
U.S. EPA - Region VI
Carl Hickam
Agency for Toxic Substance Control
A Disease Registry
1
55
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
July 29, 1987
Correspondence
Sherry Fuerst
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
Comments on Draft RI
3
56
August 26, 1987
Interoffice Memorandum
John DuPont
Texas Water Commission
Arthur Talley
Texas Water Commission
Review of Data Package for Sol
3
57
September 8, 1987
Correspondence
Donald H. Williams
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
TCE Cleanup Criteria
1
58
Lynn
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
September 1987
Correspondence
Sherry Fuerst
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
Phase II RI Scope of Services
2
59
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ADMINISTRATIVE RECORD INDEX
Job Nane: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
Sequences
September 10, 1987
Memorandum
Don Williams
U.S. EPA - Region VI
Carl Hickam
Agency for Toxic Substance &
Disease Registry

2
60
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
September 11, 1987
Correspondence
Sherry Fuerst
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
Comments on Preliminary Technologies
1
61
September 17, 1987
Correspondence
Thomas W. Hoskins
Radian Corporation
Sherry Fuerst
U.S. EPA - Region VI
TCE Action Level
4
62
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
September 24, 1987
Memorandum
Sharon Fuerst
U.S. EPA - Region VI
File
U.S. EPA - Region VI
Action Level for TCE
3
63
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ADMINISTRATIVE RECORD INDEX
Job Nane: Industrial Transformer
Job Nunber: T327

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation

Description
Number of Pages
Document Nunber Sequences
September 30, 1987
Correspondence
Sherry Fuerst
U.S. EPA - Region VI
Arthur Talley
Texas Uater Commission
Compliant Disposal Facilities
1
64
October 7, 1987
Memorandum
Sharon Fuerst
U.S. EPA - Region VI
Carl Hickam
Agency for Toxic Substance
Disease Control
TCE Contamination
3
65
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
October 10, 1987
Correspondence
Sharon Fuerst
U.S. EPA - Region VI
Mary McGi11
Radian Corporation
Decontamination Water
1
66
October 12, 1987
Correspondence
Arthur Talley
Texas Water Commission
Rlaz Anmend
Radian Corporation
Draft Feasibility Comments
13
67
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
October 13, 1987
Correspondence
Sharon Fuerst
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
Review of Preliminary Technologies
2
68
Document Date
Document Type
Originator
Originator - Affiliation

Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 5, 1987
Memorandum
George Petti grew
Agency for Toxic Substance &
Disease Control
Sharon Fuerst
U.S. EPA - Region VI
Health Consultation
3
69
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 6, 1987
Correspondence
David Sorrells
Texas Water Commission
Robin Gelston-Walls
U.S. EPA - Region VI
Identifying Federal ARARs
1
70
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 9, 1987
Correspondence
David Sorrel!s
Texas Water Commission
Pauline Krueger Trust
Moody National Bank
Access Agreement
2
71
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Nunber; T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 19, 1987
Correspondence
Sherry Fuerst
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
Comments on RI Report
2
76
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 19, 1987
Correspondence
Stanley G. Hitt
U.S. EPA - Region VI
Greg Tipple
Texas Water Commission
Cleanup Levels for TCE
1
77
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
December 16, 1987
Correspondence
Sherry Fuerst
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
Comments on Draft FS
9
78
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
December 23, 1987
Memorandum
Sherry Fuerst
U.S. EPA - Region VI
File
U.S. EPA - Region VI
Alternative Selection
2
79
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 9, 1987
Correspondence
David Sorrel Is
Texas Water Commission
Lavanne P. Mclaughlin

Access Agreement
2
72
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 9, 1987
Correspondence
David Sorrells
Texas Water Commission
Maury Ruberstein

Access Agreement
2
73
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 9, 1987
Correspondence
David Sorrells
Texas Water Commission
Lawrence Kagen
Kagen-Edelman Enterprizes
Access Agreement
2
74
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 10, 1987
Correspondence
Sherry Fuerst
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
Comments on Draft RI Report
7
75
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
December 23, 1987
Correspondence
Sherry Fuerst
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
Phase II Draft Project Plan Comments
1
80
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
February 29, 1984
Interoffice Memo
Mike Dick
Texas Department of Uater Resources
Rod Kimbro
Texas Department of Water Resources
Contamination at Site
2
81
November 29, 1985
Correspondence
Carlene Chambers
U.S. EPA - Region VI
Charles Faulds
Texas Water Commission
Schedules
1
82
September 5, 1985
Record of Communication
Steve Muse
U.S. EPA - Region VI
File
U.S. EPA - Region VI
Workplan Schedule

83
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ADMINISTRATIVE RECORD INDEX
Job fiane: Industrial
Job Nunber: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
May 23, 1985
Worksheet
S&6 labs

File
U.S. EPA - Region VI
Uater Analysis Results
1
84
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
April 2, 1985
Correspondence
Linda Graham
Chromaspec
Sol Lynn

Lab Results
3
85
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Number of Pages
Document Number Sequences
March 17, 1986
Document
File
U.S. EPA - Region VI
Texas Water Commission Request
for Proposals
13
86
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
May 5, 1986
Interoffice Memorandum
David Sorrells
Texas Water Cc.jnission
Larry Soward
Texas Water Commission
Executive Summary Review
2
87
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial Transformer
Job Number; T327

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
April 10, 1986
Correspondence
Nancy E. Olinger
Texas Attorney General's Office
Barry Berger
Newton B. Schwartz
State of Texas V. Sol Lynn
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number Sequences
April 8, 1988
Interoffice Memo
Arthur Talley
Texas Water Commission
Greg Tipple
Texas Water Commission
Consultant's Site Visit
1
89
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
March 31, 1986
Correspondence
Barry S. Berger
Newton B. Schwartz
David H. Sorrel Is
Texas Water Commission
State of Texas vs. Sol Lynn
2
90
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
March 18, 1986
Correspondence
David Sorrel Is
Texas Water Commission
Sol Lynn
Site
2
91
Visit
-------
ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Nunber; T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
March 11, 1986
Correspondence
David Sorrel Is
Texas Water Commission
Sol Lynn
Site
2
92
Visit
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
July 21, 1986
Correspondence
David Sorrel Is
Texas Water Commission
H.E. Finger

Access Agreement
4
93
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
July 21, 1986
Correspondence
David Sorrells
Texas Water Commission
Kagen Edelman Enterprises

Access Agreement
4
94

July 21, 1986
Correspondence
David Sorrells
Texas Water Commission
LMNCO

Access Agreement
4
95
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ADMINISTRATIVE RECORD INDEX
Job Nane: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
July 21, 1986
Correspondence
David Sorrells
Texas Water Commission
PDC Partnership

Access Agreement
4
96
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
July 21, 1986
Correspondence
David Sorrells
Texas Water Commission
Darlena Jones
Gilbralter Savings Association
Access Agreement
4
97
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
July 22, 1986
Correspondence
David Sorrells
Texas Water Commission
Barry S. Berger

Access Agreement
6
98
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
Document
Radian Corporation

Files
U.S. EPA - Region VI
Scope of Work
29
99
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ADMINISTRATIVE RECORD IrtDEX
Job Nane: Industrial Transformer
Job Nunber: T327
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
August 4, 1986
Correspondence
Arthur Talley
Texas Water Commission
Paul Sieminski
U.S. EPA - Region VI
Cooperative Agreement Schedules

100
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
August 15, 1986
Correspondence
David Sorrells
Texas Water Commission
Darlene Jones
Gilbralter Savings Association
Access Agreement
4
101
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber Sequences

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
August 27, 1986
Correspondence
Paul Sieminski
U.S. EPA - Region VI
David Sorrells
Texas Water Commission
Comments on Health & Safety Plan
2
102
August 29, 1986
Correspondence
James F. Haley
Texas Water Commission
Sol Lynn

Access Agreement
1
103
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
September 3, 1986
Record of Communication
Robie Hirt
U.S. EPA - Region VI
Bonnie Devos
U.S. EPA - Region VI
Site Schedule Update
1
104
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
September 8, 1986
Interoffice Memorandum
Arthur Talley
Texas Water Commission
David Sorrells
Texas Water Commission
Status Report
1
105
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
October 6, 1986
Interoffice Memorandum
Arthur Talley
Texas Water Commission
David Sorrells
Texas Water Commission
Status Report
1
106
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
November 3, 1986
Interoffice Memorandum
Arthur Talley
Texas Water Commission
David Sorrells
Texas Water Commission
Status Report
1
107
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Number: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
December 1, 1986
Interoffice Memorandum
Arthur Talley
Texas Water Commission
David Sorrells
Texas Water Commission
Status Report
1
108
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
September 29, 1986
Record of Communication
Cindy Aduddell
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
Access Agreements
1
109
Document Date
Document Type
Ori ginator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
October 3, 1986
Record of Communication
Cindy Aduddell
U.S. EPA - Region VI
Arthur Talley
Texas Water Commission
Schedule Revisions
1
110
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
October 6, 1986
Correspondence
Arthur Talley
Texas Water Commission
Calvin Spencer
Radian Corporation
Comments on Draft Project Plan
18
111
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ADMINISTRATIVE RECORD INDEX
Job Name: Industrial
Job Nunber: T327
Transformer
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber Sequences
December 11, 1986
Memorandum
Steve Muse
U.S. EPA - Region VI
File
U.S. EPA - Region VI
Trip Report
1
116
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number Sequences
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Sol Lynn
Houston, Texas
Responsiveness Summary

This contnunity relations responsiveness summary is divided into two sections:

Section I: Background on Conmunity Involvement and Concern
This section provides a brief history of community interest and
concerns raised during the remedial planning activities at the Sol Lynn
Superfund site.

Section II: Summary of Public Comments Received During the Public Comment
Period and the EPA Responses to Comments
Both the written and spoken comments are categorized by topics.
EPA responses to these relevant major topics are also presented.

I. Background on Contnunity Involvement

Initiation of studies on Industrial Transformer was announced by TWC at a
public meeting in Houston on September 24, 1986. Evaluation of the site
was divided into two separate studies: 1) surface soil contamination; 2)
groundwater contamination. The study addressing surface soil contamination
was completed in December 1987. On January 21, 1988, a news release
that a public meeting would be held on February 2, 1988, to discuss the
proposed remedy for surface contamination at the site was issued. The
groundwater study is expected to be completed in 1989.

An EPA prepared fact sheet which described alternative remedial actions
for the soil contamination along with the EPA preferred alternative was
sent to the interested and affected public shortly after the public
meeting was announced. EPA and TW3 conducted the 7:00 pm public meeting
at the Astro Village Hotel on February 2, 1988. Approximately 35 people
attended the public meeting.

II. Surmiary of Public Comment Received During Public Comment Period and
Agency Responses

This section gives the EPA's responses to the comments during the public
comment period. There was only one verbal statement made at the public
meeting which was a letter from Ira E. Tobolowski and read by Mr. Sol Lynn.
This letter was received by EPA and is addressed along with all the
other written comments received during the public comment period in the
following sanmary.

A. Comments from Ira E. Tobolowski on behalf of Mr. Sol Lynn, a
responsible party

Comment #1

The results of EPA done by the EPA, TWC and Mr. Sol Lynn indicate
there is no contamination hazardous to human health and the
environment at the site. This is supported by Exhibits B, D, E, F,
J, K, L, M, and N which were attached to the letter.
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Response

The EPA disagrees. Exhibits B, D, and E (soil and water sample
results dated May 15, 1985 and January 31, 1985) show low level
PCB contamination. These sampling points are outside the con-
taminated zone. The data concerning TCE in the groundwater is
not applicable to this particular study but will be considered in
the Phase II results.

Exhibits F and G (sample results dated March 6, 1985 and April 12,
1985) also show PCB contamination above the established 25 ppm
cleanup level. These tests were not funded by the TWC or the
EPA and no data quality documentation was presented with the
results. Therefore, this data is unacceptable.

Exhibits K, L, and M are results of water samples which containing
TCE. These results pertain again to the Phase II study in which the
groundwater will be considered.

Exhibit J is a memo dated April 17, 1985, stating low levels of PCB
and TCE exist at the site. This memo refers to a map and historical
summary of soil and water sampling at the site which was not attached
to the memo, therefore, no comments can be made about level or
or the location of the contamination referred to in this memo.

Comment 12

The data obtained by Radian Corporation for the Texas Water Commission is
not accurate. There are serious quality assurance, quality control problems
as supported by Exhibits S and T.

Response

The EPA disagrees. Exhibits S and T are memos from ERT dated March 4, 1987,
and April 20, 1987, discussing the installation of monitoring wells at
the site. This again relates to the Phase II study. However, it can
be stated that all field laboratory data analyses were performed
according to standard EPA protocol. These procedures were outlined
in a site specific quality assurance/quality control plan. There
were no significant deviations from this plan, such as to cause
serious problems or questions with any of the data collected for the
remedial investigation.

Comment #3

Mr. Sol Lynn has been harassed by the Texas Water Commission, the
Texas Attorney General and the Environmental Protection Agency.
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Response

EPA disagrees. In dealing with Mr. Lynn who is a potentially responsible
party under CERCLA, the EPA simply carried out those procedures
outlined in the National Contingency Plan for the identification,
notification and participation of responsible parties in the re-
mediation ol Superfund sites.

Comment 14

Exhibit R indicates that the EPA has wasted the tax payers money on
this site.

Response

Exhibit R is a copy of the Project Sampling Plan for the Remedial
Investigation and Feasibility Study at Industrial Transformer site
prepared by Radian Corporation for the Texas Water Commission dated
October 13, 1986. This report does not document EPA cost expenditures.
Funds expended at the site are justified because of the threat to
human health and environment.

Comment 15

Exhibit C and 0 are secret memos indicating the EPA considered dropping
the site from Superfund.

Response

The EPA disagrees. These are not secret memos but rather records of
telephone conversations. The EPA has never considered dropping the
site from the National Priority List. Exhibit C dated September 25, 1985,
is a memo stating the Texas Attorney General did not want to file against
Mr. Lynn for the clean up of the site. Exhibit 0 is the record of a
phone conversation in which an employee of the Texas Department of
Water Resources inquired if the EPA planned to remove the Sol Lynn site
from the National Priorities List.

B. Comments from Detox Industries, a bioremediation vendor.

Comment tl

A review of the detailed cost breakdown for the recommended
alternative indicates an error in addition.

Response

EPA agrees. There was an error in the addition of the direct
activity costs for the dechlorinization alternative. The total
present worth should be 52,178,562 not $1,773,560 as indicated in
the Feasibility Study. This alternative, as corrected, is still
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$300,000 less expensive than the other technically feasible
treatment alternatives that provide an equivalent level of
protection for human health and the environment. Therefore, it
renains the most cost-effective remedy for the Industrial
Transformer site.

Comment 12

In-situ biological treatment was improperly eliminated in Chapter 3
of the Feasibility Study.

Response

The in-site treatment of contaminated soils using microbes was
screened out because it would take significantly longer than the
other technologies considered. This inordinate length of time for
cleanup would interfere with possible remedial action to be taken
for the groundwater as well as further disrupt businesses operating
at the site.

Comment #3

In-situ biodegradation is less expensive and takes only six months.

Response

Data collected at another Superfund site indicates that PCBs
adsorbed to soils cannot be biodegraded to 25 ppm in six months and
in fact it will take much longer. Therefore, it was screened out as
being technically infeasible in comparison with the other alternatives
considered, costs not a factor

C. Comnents from Gulf States Utilities a potentially responsible party

Comment II

The quality assurance project program for PCB analysis did not meet work
plan objectives; consequently, all soil PCB data is in question. A
review of the data indicates the Quality Assurance objective of <50%
relative percent difference was consistently exceeded. Therefore, the
PCB soil data is invalidated and should not be included in the Site
Investigation Report or used as a basis for selecting a remedial
alternative or determining potential public health impacts.

Response

The EPA disagrees that the PCB data is invalidated because of
consistently exceeding the <50% relative percent difference on co-
located samples. In those two instances where co-located samples
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were taken in the remedial investigation, the relative difference
was 18.5 and 85.7 percent, respectively. With respect to the first
set of co-located samples an error was made in the Site Investigation
Report text. The actual samples that were duplicated were numbers
22 and 23 not 23 and 24 as indicated. A comparison of samples 22
and 23 give 18.5 percent relative difference. In the other instance
where the relative difference was 85.7 percent, both of samples had
extremely low concentrations of PCBs where it is not unusual to find
significant differences.

Comment 12

The RI fails to state whether the "uppermost water-bearing zone" is in an
unconfined hydraulic state (water table condition) or a confined hydraulic
state (artesian pressure). Knowing this is fundamental to assessing the
potential for surface and near surface contaminants to move downward to
the "uppermost water-bearing zone." The very generalized lithologic
information in the RI implies that at least 20 feet of clay overlies the
"uppermost water-bearing zone"; other data and narrative statements
imply that the static water level of this zone ranges from about 3 to 5
feet below ground surface. If this is true, it would appear that the
"uppermost water-bearing zone" is in a confined to semiconfined hydraulic
state. Therefore, the potential for downward migration of surface
contaminants would be orders of magnitude lower than if the zone is
in an unconfined hydraulic state.

Response

We acknowledged that the hykogeology of the site was not completely
defined in the retiedial investigation, however, it was not the intent
of this study. Our main objective for the first study was to identify
the extent of PCB soil contamination on site. The groundwater and
deep soil TCE issue at the site will be covered in Phase II where a more
complete geohydrological study will be done.

Comment 13
The soil PCB contamination objective of 25 ppm was obtained from the
Toxic Substances Control Act (TSCA) PCB spill cleanup policy rule (FR,
2 APR 87), not from a site-specific risk assessment. It is unclear as
to the applicability of this TSCA policy as an Appropriate, Relevant,
and Applicable Regulation (ARAR).

Response

The Toxic Substances Control Act cleanup level of 25 ppm was considered -
relevent because it assumes an industrial setting with possible worker
exposure for eight hours per day for a 40 year period. The Industrial
Transformer site is likewise in an industrial setting with active businesses
on site. Therefore, situations were similar enough to apply the TSCA
cleanuo standard.
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gNVIRONMENTAt
PROTECTION
AGENCY
6
DALLAS, TEXAS
Comment 14
A decontamination objective of 100 ppm in the soil was
appropriate concentration at the Geneva Industries, Superfund site
in Houston as per the Record of Decision (ROD) of 9/18/86. There
was no discussion or consideration of this decision as a part of this
RI/FS. A decontamination objective of 100 pptn at the Industrial
Transformer site would have major implications as to the remedy
selection and cost.

Response

The difference in cleanup levels is the result of the conditions
which exist at the two sites. The Geneva Industries site is an
abandoned facility. In addition to the higher cleanup criterion
of 100 ppm, a RCRA compliant cap was placed over the entire
surface of the site. This cap, which must be maintained by the
State, will limit incidental exposure to the PCB contaminated
soil. A cap of this type was nor feasible at the Industrial
Transformers site because of the businesses currently operation
at the site. As was discussed in EPA's response to comment 13,
a 25 ppm cleanup level is needed to protect the health of the
workers at the site without closing the businesses.

Comment 15
I** i*""f~ jJ^-^C -_^- „ - i --
A remedy consisting of partial soirfemovaT"7 (tl foot) anoThot spot
removal^_and treatment- to soil concentrations of less than 25 ppm was not
considered. This*would drastically reduce the volume of soil to be
remediated, and consequently be a more cost-effective solution.

Response

The complexity and expense associated with excavating a hot spot,
testing, excavating, then retesting makes hot spot removal
technically impractical.
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TEXAS WATER COMMISSIOiN
Paul Hopkins. Cr.e rn-,a'-, - . "^ '/.. J. D. Head, Genera! Counsel
John O. Houchins. Cor-,rr.'ss-oner , •.. • ^-- ,;,/ Michael E. Field, Chief Examiner
B. J W^nne. III. Co:rrr.iisiori vj: "S".: • 1*7 •
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fiNVIRONMENTAk
PROTECTION
3 AGENCY

n n DALLAS. TEXAS
EPA Response to Comment #4

No. The remedial investigation found that the soils contain trivalent chromi
rather than the more toxic and mobile hexavalent form of chromium now present
in the groundwater. A site specific risk assessment conducted during the
investigation determined the present levels of chromium in the soil would not
pose a significant health threat to nearby residents or workers. In addition,
leach tests conducted during the investigation showed the chromium was tightly
bound to the soils; therefore, would not cause further degradation of the
groundwater. Since the chromium contaminated soil is neither a health threat
nor a potential source of contaminant migration, a remedial action of the
soil is^not necessary to protect human health or the environment.

Comment 15

The most logical plan for resolving the problem at the Odessa Chromium II
site would be to provide the area with city water and to take no further
action since the chromium in the groundwater will naturally dilute to below
drinking water standards within 5 to 10 years.

EPA Response to Comment #5

We disagree. Based on computer simulations of the "no action" remedy, the
chromium plumes at the Odessa II site are predicted to migrate to the southwest
at a rate of 0.1 to 0.3 feet per day. The southern plume will migrate an
estimated 600 feet and the northern plume approximately 1,600 feet within 15
years. The chromium concentrations will dissipate as the plume expands given
there are no more releases to the groundwater; however, wells within the area
are expected to still have chromium levels above the current Federal drinking
water standard even after 15 years of natural dilution.

In order to prevent potential exposure through future consumption of the
contaminated groundwater, a water supply system would require continued
extension as the plumes migrate beyond the current impacted areas. Protection
can be achieved only if all persons within the expanding impacted areas elect
to connect with the system and if effective institutional controls are
implemented. Since connection with the alternate water supply system is
voluntary and the effectiveness of institutional controls is uncertain;
protection of human health cannot be assured. The selected electrochemical
treatment system will insure protection by reducing the chromium present in
the groundwater to levels below the Federally Regulated Drinking Water Standard
within a reasonable length of time. In addition, the selected remedy satisfies
the statutory preference for remedies that employ treatment as their principal
element.
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