United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-88/032
March 1988
Superfund
Record of Decision
Dixie Oil, TX
DALLAS, TEXAS
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30277-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R06-88/032
3. Recipient's Accession No.
4. Title and Subtitlt
SUPERFUND RECORD OF DECISION
5. Report 0
03^1/88
Oil, TX
'First Remedial Action
7. Authorfs)
8. Performing Organization Rept. No
,9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(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 A Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The 26.6-acre Dixie Oil Processors (DOP) site is located in Harris County, Texas,
approximately 20 miles southeast of Houston. The site is broken into two parcels,
19-acre DOP North and 7.6-acre DOP South, separated by Dixie Farm Road. The site is
bordered by Mud Gully, a flood control ditch that flows into Clear Creek, Friendswood .
Oil Field, the Brio Oil Refining NPL site, and various athletic fields. Between
969 and 1978, the DOP North parcel operated as a copper recovery and hydrocarbon
asning facility. Six surface impoundments were used to store copper wastewater and
wastewater from the hydrocarbon washing operation prior to recovery and treatment. In
1977 the impoundments were closed and decommissioned and the property sold to DOP. In
1978, DOP began operations on the South parcel of the site. These activities included
the following: regeneration of cuprous chloride catalyst; hydrocarbon washing to produce
ethylbenzene, toluene, aromatic solvents and styrene pitch; oil recovery; and blending
and distilling chemical residues to produce fuel oil, creosote extender and molybdenum
concentrate catalyst. The North parcel was not used in these operations. All site
activities ceased in 1986. Wastes were disposed of onsite in tanks, drums, and waste
pits. Sampling indicates contamination of surface and subsurface soils and shallow
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Dixie Oil, TX
First Remedial Action
Contaminated Media:-gw, soil
Key, Contaminants: copper, organics, VOCs
b.-1dentTfiers/6pen.Ended Terms *^
c. COSATI Field/Group
'Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
86
22. Price
(See ANSI-Z39.18)
See Instructions on Reverie
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R06-88/032
Dixie Oil, TX
First Remedial Action
16. ABSTRACT (continued)
ground water. The primary contaminants of concern affecting soil and ground water are
ethylbenzene, hexachlorobenzene, copper, 1,1,2-trichloroethane and methylene chloride.
The selected remedial action for the Dixie Oil Processors site is a limited action
alternative consisting of: site controls including, but not limited to, fencing and
deed restrictions to prevent site access; excavation and removal of contaminated offsite
soils to background levels, the extent of removal to be determined during remedial
design; consolidation and disposal of onsite debris and rubble, disposal method to be
determined during design; remediation of Mud Gully, details to be determined during
design; operation of the existing wastewater treatment system during implementation of
remedial action, then dismantling and removal upon completion; removal and disposal of
tank contents and drums, and dismantling, decontamination, and either selling or offsite
disposal of tanks; dismantling and disposal of all process equipment; ambient air
sampling; control of air emissions from treatment processes, if necessary; sampling and
monitoring of Mud Gully sediments and ground water to determine effectiveness of remedy;
and regrading and vegetation of the entire OOP site. The estimated present worth costs
of this remedy is $241,000.
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DIXIE OIL PROCESSORS
RECORD OF DECISION
MARCH 31, 1988
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
ALLIED BANK TOWER AT FOUNTAIN PLACE
1445 ROSS AVENUE
DALLAS. TEXAS 75202
DECLARATION FOR THE RECORD QF. DECISION
SITE NAME AND LOCATION
Dixie Oil Processors Site, Harris County, Texas
STATEMENT Q£ PURPOSE
This decision document outlines the selected remedial action for
the Dixie Oil Processors site 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 to the-extent
practicable, the National Oil and Hazardous Substance Pollution
Contingency Plan, 40 CFR Part 300, November 20, 1985.
The State of Texas (through the Texas Water Commission) has been
provided an opportunity to comment on the technology and degree
of treatment proposed by the Record of Decision and has no
objection to the selected remedy (See Appendix F).
STATEMENT Q_F_ BASIS
This decision is based on the administrative record for the Brio
Refining site (See Appendix D). The attached index identifies
the items which comprise the administrative record.
DESCRIPTION QJE Effi REMEDY
Upon review of the information contained in the administrative
record, it is EPA's judgement that limited action and monitoring
as described in the No Action alternative of the Brio
Refining/Dixie Oil Processors Feasibility Study appears to best
serve both statutory and selection criteria in relation to the
other solutions evaluated. A detailed description of this remedy
and an explanation of how it meets statutory requirements is
contained in the attached "Summary of Remedial Alternative
Selection."
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This action would include:
Affected materials and soils - The Brio/DOP Endangerment
Assessment identified action levels based on limited exposure to
site contaminants. This exposure scenario relied heavily on the
use of site controls to ensure a limited probability of exposure
to these contaminants. The term site controls shall be defined
below, but shall include restricted access through the use of a
site security fence. The endangerment assessment did not
identify any contaminated soils on the DOP site that exceed the
action levels discussed above. Therefore, excavation and
treatment of contaminated soils is not necessary as long as the
site controls are enforced. However, if proper site controls
are not ensured and greater exposure results from any future
activities, then the action levels identified above no longer would
apply and treatment of contaminated soils may be necessary.
Surface contamination - The site investigations identified
surface staining throughout the DOP property. These areas will
be addressed in the site management plan discussed below.
Off-site soil contamination - Any off-site soil contamination
found during the remedial investigation or during the excavation
of affected materials and soils shall be removed to background
levels. This may require that special detection limits be used
for sampling efforts at the site boundaries during the remedial
action. This activity will have to be further defined in the
remedial design.
Debris and rubble - There is much inert debris and rubble
remaining on the site from past operations. This material may be
consolidated and the ultimate disposition of the material
determined during the remedial design.
Mud Gully - Contaminants observed in this flood control ditch
and the "bottle neck" that exists as it passes the Brio and DOP
sites has been a noted concern of the EPA as well as local
residents and the Harris County Flood Control District. It is
apparent that these problems will have to be corrected as part of
any remedy that is instituted at the site. Initial thoughts
would suggest a low-maintenance approach to resolving this
problem where some type of performance standard would be set in
cooperation with the Harris County Flood Control District. Such
actions shall be further defined in the remedial design.
Wastewater treatment system - The existing wastewater treatment
system may be used during remedial action but will be
dismantled and removed from the site by the completion of
remedial action.
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Storage tanks and drums - Remove tank contents, decontaminate
tanks, dismantle tanks; sell or transport dismantled tanks to an
EPA approved disposal facility; transport tank contents and
drums to an EPA approved off-site disposal facility. If tanks
are used during remedial activities, they will be dismantled upon
completion.
Process equipment - The entire process facility will be
dismantled to the extent that some of the existing facility nay
be used during remedial activities. If they are used during
remedial action, the structures will be dismantled upon
completion of these activities.
Monitoring and control of migration pathways - Ambient air
sampling on a semi-annual basis; control air emissions from
treatment processes (if necessary); excavate in enclosures (if
necessary) and vent the enclosure to an emission control device;
eliminate or control rainfall on construction areas; sample and
monitor Mud Gully sediments; monitor the groundwater in the
Numerous Sand Channel Zone and Fifty-Foot Sand for a timeframe to
be defined in the remedial design; and monitoring activities will
be utilized to determine the effectiveness of the actions to be
•implemented and shall be detailed in the operation and
maintenance plan of the remedial design. This same data will be
evaluated during the Agency's 5-year review, in accordance with
SARA Section 121(c), to determine if any corrective action is
necessary.
Site management plan - The entire DOP site will be regraded and
vegetated to promote drainage and minimize infiltration. All
regraded areas will be covered with 6 inches of topsoil, if
necessary, to promote vegetative growth. To the maximum extent
practicable, the aesthetics of the site (upon completion of the
remedy) shall be enhanced by utilizing creative design and
landscaping techniques with input from the local residents.
Site control - This remedial action is based on permanent site
control, imposition of necessary deed notices and restrictions (if
possible), and restriction of access to the site by use of a fence or
similar barrier.
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DECLARATION
The remedy described above is protective of human health and the
environment, attains Federal and State requirements applicable or
relevant and appropriate and is cost-effective compared to
equally protective alternatives. This remedy satisfies the
preference for treatment that reduces toxicity, mobility, or
volume; and uses permanent solutions and alternative technologies
to the maximum extent practicable.
i
Date
obert E/Layton
P.E.
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
DIXIE OIL PROCESSORS SITE
SOUTHEAST HARRIS COUNTY, TEXAS
MARCH 31, 1988
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TABLE Q_E CONTENTS
I. SITE LOCATION AND DESCRIPTION Page
1.1 Site History 1
1.2 Site Geology 1
1.3 Site Hydrogeology 5
1.4 Remedial And Supplemental
Investigation Results 7
1.6 Potential Impacts of Site on Human Health
and Environment 11
II. ENFORCEMENT 12
III. COMMUNITY RELATIONS HISTORY 12
IV. ALTERNATIVES EVALUATION
4.1 Evaluation Criteria 13
4.2 Descriptions of Alternatives 16
4.3 Evaluation of Alternatives 25
4.4 Operation and Maintenance 29
V.' SELECTED REMEDY '. .• 29
VI. APPENDICES
A. Community Relations Responsiveness Summary
B. Vessel Inventory
C. Site ARARs Evaluation
D. Administrative Record
E. Process Facility Dismantling Cost Estimate
F. State Response to Record of Decision
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LIST QI TABLES ^
TABLE NO. TITLE
1 Highest Compound Concentrations For Pit Soil
and Subsoil Samples
2 Organic Compound Concentrations in the Numerous
Sand Channel Zone
3-8 Remedial Action Line Item Costs
9 Comparison of Remedial Alternatives
11
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LISX QE FIGURES
FIGURE NO. II1LE
1 Site Location Map
2 Site Location Map
3 Generalized Stratigraphic Column
4 Site Lithologic Units
5 Site Plan
111
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1.0 SITE LOCATION AND DESCRIPTION
The Dixie Oil Processors (DOP) site is located approximately 20
miles southeast of Houston, Texas in Harris County (Figure 1).
The site occupies approximately 26.6 acres. Portions of the site
occur both north and south of Dixie Farm Road and are designated
as DOP North and DOP South. DOP North covers 19.0 acres and DOP
South covers 7.6 acres.
Mud Gully, a flood control ditch and local tributary of Clear
Creek, runs along the eastern boundary of DOP North and the
western boundary of DOP South. The Brio Refinery site borders
DOP to the northeast and an athletic field borders DOP North to
the Southwest. The Friendswood Oil Field borders the remaining
areas (Figure 2).
1.1 SITE HISTORY
Intercoastal Chemical Company (ICC) operated a copper recovery
and hydrocarbon washing facility on the DOP North site from 1969
to 1978. A total of six surface impoundments were used by ICC to
store wastewater containing copper prior to recovery and to treat
wastewater prior to discharge. Wastewaters from the hydrocarbon
washing operations were also discharged into one of the
impoundments. During a two year period between 1975 and 1977,,
the .impoundments were closed and decommissioned.
In 1978, DOP began operations on the DOP South site. Activities
which occurred on the site are as follows:
o Regeneration of cuprous chloride catalyst;
o hydrocarbon washing to produce ethylbenzene, toluene,
aromatic solvents, styrene pitch; '
o oil recovery; and
o blending and distilling residues from local chemical
plants and refineries (mainly phenolic tank bottom tars
and glycol cutter stock) to produce various petroleum
products including fuel oil, creosote extender, and a
molybdenum concentrate catalyst.
Active operations on the DOP site stopped in 1986. Previously
closed surface impoundments located on DOP North were not
utilized during DOP operations.
1.2 SITE GEOLOGY
The Dixie Oil Processors site is located within the Pleistocene
Deltaic Plain of the Brazos River, known as the Alameda Delta.
The site is underlain with Pleistocene and Pliocene deposits to a
depth of approximately 2400.0 feet as shown on Figure 3. The
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»&*.(
VICINITY MAP
LOCATOR
NOTE INFORMATION OBTAINED FROM THE
IT CORPORATION SUMMARY REPORT
DIXIE COPROCESSORS
RECORD OF D6CSION
SITE LOCATION MAP
PROJECT NO.
TC3621-22
DATE
2-18-88
FIGURE NO,
1
"ft
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NOTE. INFORMATION OBTAINED FROM THE
IT CORPORATION SUMMARY REPORT
DIX€OL PROCESSORS
REOORD OF DECISION
SITE LOCATION MAP
TC3621-22
DATE
2-18-88
2
"ft
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NOTES
I.
2
3
SYSTEM
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SERIES
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FORMAT. CN
MONTGOMERY
FORMATION
SENTLEY
FORMATION
WILL'S
FORMATION
GOLIAO
SAND
FLEMING
FORMATION
APMOXIMAT
ELEVATION
FT. .N«VO
160'-
550'
2500'-
2700'-
UPPER CHICOT
AQUIFER
LOWER CHICOT
AQUITER
EVANGELISE
"AQUIFER
DRAWING NOT TO SCALE
MODIFIED FROM GA8RYSCH, i960
NGVD P£F£RS TO NATIONAL GEODETIC
VERTICAL DATUM
NOTE. INFORMATION OBTAINED FROM THE
fT CORPORATION SUMMARY REPORT
OOOEO*. PROCESSORS
RECORD OF DEC6CN
GENERALIZED STRATCRAPHIC COLUMN
PROJECT NO.
TC3621-22
DATE
2-18- SS
FIGURE NO,
3
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aquifers used to supply water for domestic, industrial and
agricultural purposes are the Lower Chicot and Evangeline, which
are confined aquifers isolated from surface recharge. The
groundwater flow in the Lower Chicot and the Evangeline is to the
southeast.
The Friendswood Oil Field borders the site and is an extensively
explored oil and gas field. The Oligocene Age Brio Formation of
the Texas Gulf Coast Region is the oil producing zone with wells
from 4000.0 to 7000.0 feet deep.
The site specific geology that was under investigation during the
Remedial investigation/Feasibility Study (RI/FS) was the Beaumont
Formation as shown in Figure 4. The results from the Feasibility
Study and Summary Report are given in the following paragraphs.
The Beaumont Formation is separated into five major units (Figure
4). The Upper Clay Unit is composed of clay and silty clay. The
unit is continuous across the site and ranges in depth from 14.0
to 32.0 feet. The Numerous Sand Channels Zone (NSCZ) is the next
unit and is comprised of interbedded sands, sandy silts, silty
sands, clayey silts and silty clays. The thickness of the NSCZ
varies across the site from 3.8 to 26.6 feet.' The NSCZ is the
upper water bearing unit with well yields less than 10 gpm. The
Middle Clay Unit is next and is composed of silty clay/clayey
silt. The thickness ranges from 8.0 to 20.0 feet. The Middle__
Clay separates the NSCZ from the lower aquifer and forms a
confining layer over the lower unit. The Fifty-Foot Sand is the
fourth unit and occurs between 52.0 and 61.5 feet below ground
surface. The thickness varies from 35.0 to 45.0 feet. The
Fifty-Foot Sand Unit has a reasonably high well yield. The fifth
and last unit is the Lower Clay Unit, a silty clay approximately
100.0 to 120.0 feet thick. The unit extends to at least 200.0
feet below ground surface.
A salt dome fault is located in the western part of the DOP site.
According to Dr. Carl Norman of the University of Houston, the
ground movement north of the fault has been downward in relation
to the ground south of the fault. The fault could cause a slight
reduction in lateral groundwater flow for various units across
the fault. At this time, there is no evidence to support a
vertical hydraulic connection between the units along the fault.
1.3 SITE HYDROGEQLOGY
The NSCZ and the Fifty-Foot Sand are the two water bearing units
investigated at the DOP site. The NSCZ potentiometric surface
indicates that the groundwater flow is towards Mud Gully and will
either run parallel to the gully or discharge into the gully.
The groundwater flow volumes range from 6.6 to 102.0 gallons per
year per square foot of cross-sectional area. The velocity of
the groundwater ranged from 2.9 to 68.0 feet per year.
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LIT«OS*«A* 38*»H>:
US *S
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*C«MATiCN
L'SS'E
fO'WA'iON
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SiTE HVOftOlOGiC UNtT$
SEM. -CONFINING LAVEN
U^^EK WATER-BEAMING ZONE
AOUlTAHQ
LOWE* WATCM-iCAMlNG ZONE
AOUlTAHO
NOTE. INFORMATION OBTAINED FROM THE
IT CORPORATION SUMMARY REPORT
OIXE OIL PROCESSORS
RECORD OF DECSJON
SITE UTHOLOGIC UNITS
PROJECT NO. DATE
TC3621-22 2-18-88
•ft
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The potentiometric surface of the Fifty-Foot Sand showed a
hydraulic gradient of 0.0001 in the south-southeast direction.
Flow would be towards the Gulf Coast. Lateral groundwater flow
volumes range from 1.2 to 12.0 gallons per year per sq. ft. of
cross sectional area. The average groundwater velocities were
3.9 to 58.0 feet per year.
The Middle Clay Unit has an upward hydraulic gradient thereby
minimizing the potential for groundwater movement between the
NSCZ and the Fifty-Foot Sand over most of the site.
1.4 REMEDIAL AND SUPPLEMENTAL RflMFflTAL. INVESTIGATION RESULTS
Three different types of wastes were sampled at the Dixie Oil
Processors Superfund Site. The three were the contents of the
drums, tanks and vessels onsite, surface and subsurface soils
associated with the on-site waste pits, and contaminated
groundwater.
Various sludges and liquids are stored in vessels and tanks on
the site (See Appendix B for vessel inventory). All the tanks
are within earthen or concrete berms. Drums containing drilling
spoils, created during the Remedial and Supplemental Remedial
Investigations have been staged on the Brio site.
The major sources of contamination on the site are the closed
impoundments (pits) and the contamination to the shallowest
aquifer these pits may have caused.
There are approximately 107,351 cubic yards of contaminated soils
and subsoils on the site, associated with six different pits.
The pits are identified as AA to EE (See Figure 5). Numerous
discrete interval and composite samples were collected from each
pit and the subsurface soil around each pit. The analyses-of
these samples indicates that the pits are sources of groundwater
contamination. Table l shows the compounds with the highest
concentrations detected in the pit and subsoil samples.
For the pit samples, ethylbenzene had the highest concentration
(6.40 mg/kg) of volatile organic compounds; hexachlorbbenzene had
the highest concentration (674 mg/kg) of base neutral organic
compounds; and copper had the highest concentration (72,860
mg/kg) of inorganic compounds. No organic compounds were found
in any subsoil samples.
Ten wells were installed in the shallowest aquifer (known as the
NSCZ) to test for contamination, and four more were drilled into
the next aquifer (known as the Fifty-Foot Sand aquifer). Table 2
shows the highest concentrations of organic contaminants detected
in the groundwater samples from the site.
In the groundwater samples of the NSCZ, 1,1,2-trichloroethane had
the highest concentration (16.4 mg/kg) of organic compounds and
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rat*
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TABLE 1
HIGHEST COMPOUND CONCENTRATIONS FOR PIT AND SOIL SAMPLES
£11
Highest
Concentration
Volatile Organic
Compounds (mg/kg)
Compound
Pit Soil
Highest
Concentration
Base Neutral Organic
Compounds (mg/kg)
Compound
Pit Soil
AA Methylene Chloride 3.11
BB 1.1,2 Trichloro-
ethane
3.37
CC 1,1,2 Trichloro- 0.79
ethane
ND Di-n-octyl 1.45 ND
phthalate
ND Phenanthrene 9.47 ND
Hexachlorobenzene 4.97 ND
ND Di-n-octyl 1.63 ND
phthalate
DD None Detected
Phenanthrene
1.10
ND
EE Ethylhexzene
6.40
ND Hexachlorobenzene 674
ND
FF Methylene Chloride 0.2
ND Di-n-octyl
phthalate
5.10
ND
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TABLE 2
ORGANIC COMPOUND CONCENTRATIONS IN THE NSCZ
Well Concentration (mg/h
DMW5A 9.5
DMW19A ND
DMW 20A ND
DMW21A ND
DMW 22A 0.63
DMW23A 0.01
DMW24A * ND
DMW 25A 0,041
DMW33A 0.24
DMW34A 24
DMW « Dixie Monitoring Well
A - Weil monitors the NSCZ aquifer.
Concentration is the sum of
the concentrations of : Vinyl Chloride
Dichloroethane
Trichloroethane
Methylene Chloride
Bis (2 chloroethyl) ether
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copper had the highest concentration (110 mg/1) of inorganic
compounds. No contamination was detected in the groundwater from
the Fifty-Foot Sand aquifer. The most frequently detected
volatile organic compound in the pit samples was methylene
chloride. Phenanthrene was the most frequently detected base
neutral organic compound found in the pit samples. Copper was
the most common inorganic compound found in the pit samples.
1.5 POTENTIAL IMPACTS QF_ THE SITE QN. HUMAN HEALTH AND THE
ENVIRONMENT
The assessment of risk posed by the Dixie Oil Processors site was
evaluated in the Brio Refining/Dixie Oil Processors Endangerment
Assessment. This assessment examined the amount, concentration,
properties, and environmental fate and transport of chemical
found at the site; the populations and environments potentially
at risk; exposure pathways; and potential exposure events.
EPA has concluded that the site potentially poses four major
risks to human health and the environment. These risks would
result from:
o Ingestion of on-site soils;
.o direct contact with on-site soils;
o inhalation of dust from the site; and
o ingestion of shallow groundwater from the site.
However, these risks are only possible should the restrictions to
site access and use be violated.
Many of the chemicals found on the site are carcinogens (1,1,2
trichloroethane and methylene chloride) or toxic to the central
nervous system, liver, or respiratory system (toluene and
chlorobenzene).
The populations identified as being potentially at risk are
several subdivisions, including Southbend, a junior college,
an elementary school, and a hospital. Each is located within
one-half mile of the site. The 1985 population residing within
one mile is estimated at 5,751. Approximately 71,000 people
reside within a four-mile radius.
Using a trespass exposure scenario, which assumed that the site
would remain a secured industrial facility, target removal and
treatment levels for selected chemicals were developed. These
target levels were based on a 10~6 increased cancer risk for
carcinogens and on an acceptable chronic daily intake for non-
carcinogens. The endangerment assessment also examined an
unrestricted access exposure scenario which indicated that
greater volumes of affected materials and soil would have to be
11
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treated should exposure to the site increase. Reference the Brio
Refining/Dixie Oil Processors Endangerment Assessment for a more
detailed discussion and analysis of this subject.
II. ENFORCEMENT
Approximately 17 potentially responsible parties (PRPs) have been
identified. To this group, 104(e) information requests were
sent, with 2 follow-up letters. EPA received 11 responses (many
of the companies identified are no longer in business). The
Agency did not send any Notice Letters to these parties.
EPA will continue its enforcement activities and send Special
Notice Letters to PRPs prior to the initiation of the remedial
design. Should the PRPs decline to conduct future remedial
activities, EPA will provide funding for such activities, but
will retain its right to seek cost recovery for all EPA-funded
response actions from the above referenced PRPs.
III. COMMUNITY RELATIONS
Dixie Oil Processors (DOP) was referred to EPA in 1985 by the
Texas Water Commission for inclusion to the National Priorities
List. Due to its location next to the Brio Refining site, its
past history with the site and the fact that many of the same
PRPs at Brio were potentially involved at DOP, the Brio
Administrative Order on Consent was amended on April 23, 1986, to
include the DOP site. This agreement between EPA and the Brio
Site Task Force provided for investigations at the DOP site and
for the Task Force to conduct a comprehensive community relations
program on DOP with EPA oversight.
On September 4, 1986, a community meeting was held to discuss any
issues or concerns the local residents may have regarding the
site studies, status reports were also provided through
newsletters.
On February 2, 1987, the Task Force held a community meeting on
various treatment techniques that may be employed during remedial
action at a typical Superfund site. A community leaders meeting
was held on April 2, 1987, to provide an update on site
activities. A meeting to discuss the preliminary results of the
Endangerment Assessment was held with the community leaders on
June 18, 1987.
On January 21, 1988, EPA announced through a press release that
studies were completed on the DOP site. The announcement also
advised the public that EPA would be accepting comments on the
proposed remedy for the site from February 1 to March 1, 1988,
and that the Agency would hold a public meeting on February 9,
1988. An EPA prepared fact sheet describing various alternatives|
evaluated was mailed to interested citizens. EPA held a
community leaders meeting on January 25, 1988, to brief the
1.2
-------
members of the group on the solutions proposed for the site. On
the following night, January 26, 1988, the Brio Site Task Force
held a community meeting to discuss the overall results of the
site investigations, the findings of the Endangerment Assessment.
An EPA representative announced the scheduled public meeting to
discuss remedial alternatives. EPA's public meeting was held on
February 9, 1988, at the Weber Elementary School. Approximately
350 people attended the meeting. The community expressed great
concern that the remedial action would only address partial
remediation. A summary of the public response to the solutions
proposed by EPA at this meeting, can be found in the
Responsiveness Summary (Appendix A). On February 22, EPA met
with the Friendswood City Council to discuss the proposed
alternative solutions that the Agency had outlined in its public
meeting on February 9.
Again, It should be noted that EPA was an active participant in
all of the community or community leaders meetings discussed
above. These activities were carried-out in cooperation with the
Brio Site Task Force in accordance with the terms outlined in the
above mentioned Brio Refining/Dixie Oil Processors Administrative
Order on Consent.
IV. ALTERNATIVES EVALUATION
4.1 EVALUATION CRITERIA
Section 121 (a), (b), and (d) of the Superfund Amendments and
Reauthorization Act (SARA) contains nine factors which EPA must
consider in selecting a remedy for a Superfund site. These items
are summarized below:
1. Consistency with Other Environmental Laws
i
In determining appropriate remedial actions at Superfund
sites, consideration must be given to the requirements of
other Federal and State environmental laws, in addition
to CERCLA, as amended by SARA. Primary consideration is
given to attaining applicable or relevant and appropriate
Federal and State public health and environmental laws
and regulations and standards. Not all Federal and State
environmental laws and regulations are applicable to each
Superfund response action. The compliance of each
remedial alternative with all applicable or relevant and
appropriate environmental laws is discussed in
Appendix c.
2. Reduction of Toxicitv. Mobility or Volume
The degree to which alternatives employ treatment that
reduces toxicity, mobility or volume must be assessed.
Relevant factors include:
13
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o The treatment processes the proposed solutions
employed and materials they treat;
o the amount of contaminated materials that will
be destroyed or treated;
o the degree of expected reduction in toxicity,
mobility, or volume;
o the degree to which the treatment is irreversible; and
o the residuals that will remain following treatment,
considering the persistence, toxicity, mobility, and
propensity for bio-accumulation of such hazardous
substances and their constituents.
3. Short-term Effectiveness
The short-term effectiveness of an a].-ernative must be
assessed considering the following:
o Magnitude of reduction of existing risks; and
o short-term risks that might be .posed to the community,
workers, or the environment during the implementation
of an alternative including potential threats to human
health or the environment associated with excavation,
transportation, and redisposal or containment.
4. 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:
o Magnitude of residual risks in terms of amounts and
concentrations of wastes remaining following
implementation of a remedial action, considering the
persistence, toxicity, mobility, and propensity for
bio-accumulation of such hazardous substances and
their constituents;
o type and degree of long-term management required,
including monitoring and operation and maintenance;
o potential for exposure of human and environmental
receptors to remaining waste considering the potential
threat to human health and the environment associated
with excavation, transportation, redisposal, or
containment;
o long-term reliability of the engineering and
14
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institutional controls, including uncertainties
associated with the land disposal of untreated wastes
and residuals; and
o potential need for replacement of the remedy.
The ease or difficulty of implementing the alternatives
are assessed by considering the following factors:
o Degree of difficulty associated with constructing
the solution;
o expected operational reliability of the treatment
technology;
o need to coordinate with and obtain -necessary approvals
and permits (or meet the intent of any permit in the
case of Superfund actions);
o availability of necessary equipment and specialists;
and
o available capacity and location of needed treatment,
storage, and disposal services.
Costs
•
The types of costs that should be assessed include the
following:
o Capital costs;
o operation and maintenance costs;
o net present value of capital and operation and
maintenance cost; and
o potential future remedial action costs.
Community Acceptance
This assessment should evaluate:
o Components of remedial alternatives that the community
supports ;
o features of the alternatives about which the community
has reservations; and
o elements of the alternatives which the community
15
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strongly opposes.
8. State Acceptance (through the Texas Water Commission)
Evaluation includes assessment of:
o Components of remedial alternatives that the State
supports;
o features of the alternatives about which the State has
reservations; and
o elements of the alternatives which the State strongly
opposes.
9- Overall Protection of Human Health and the Environment
Following the analysis of the remedial options against
individual evaluation criteria, the alternatives are
assessed from the standpoint of whether they provide
adequate protection of human health and the environment.
EPA is also directed by Superfund law. (SARA) to give
preference to solutions that utilize treatment to remove
contaminants from the environment% Offsite transport and
disposal without treatment is the least preferred option
where practicable treatment technologies are available.
4.2 DESCRIPTION p_F_ ALTERNATIVES
In conformance with the National Contingency Plan, initial
remedial approaches were screened to determine which might be
appropriate for this site (see the Brio refining/Dixie Oil
Processors Feasibility Study for details of this evaluation).
From these possible remedies, four were chosen for more detailed
evaluation and comparison with the remedy selection criteria
outlined above. Two other alternatives, No Action and Off-site
Disposal, were also evaluated to comply with the requirements of
the NCP. Each remedy is summarized below, common elements of
all the plans include:
o Implementing the Site Management Plan. Areas of the site
which are not treated would be regraded and revegetated
to promote rainwater drainage into Mud Gully and to
minimize infiltration.
o Monitoring of the existing wells on the site.
o Monitoring Mud Gully in three locations for any
increased contamination in runoff.
o All tank contents win be removed and properly
disposed.
16
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o There will be semi-annual air monitoring of the site.
o Site controls through the use of the existing security
fence and imposing a deed notice and restrictions (if
possible) .
The Brio/DOP Endangerment Assessment (EA) identified the action
levels (or those affected material and soil that required
treatment based on a trespass exposure scenario) for each site.
This provided the information necessary to determine the volume
of affected material and soil requiring treatment. In the
case of the Dixie Oil Processors site, there were no affected
materials and soils found to exist above the EA action levels.
Therefore, each of the alternatives evaluated in the Brio/DOP
Feasibility Study assumed that all treatment of affected
materials and soils would occur at the Brio site (being
the only site with affected materials and soils above the
referenced action levels). Furthermore, the costs
associated with each of the remedies evaluated below
accounts only for the monitoring and site management plan
activities that would occur in conjunction with the
selected remedy selected for the Brio Refining' site (as
outlined in the. Brio Refining/Dixie Oil Processors
Feasibility Study). Examination of the line item costs
for both the Brio and Dixie Oil Processors sites may
clarify this point (Table 3 - 8).
It must also be' noted that the estimated cost of the alternative
actions at DOP (listed below) do not include the costs associated
with dismantling the process facility. Appendix E contains an
the information to support an estimated cost of $100,000 for
flushing and dismantling the facility.
Alternative ij. £jo_ Action This remedy consists mainly of the
common elements listed above. The site management plan will be
implemented, all drums on the site properly disposed," and the
various monitoring plans initiated. Access to the site would be
controlled with the existing security fence. Deed restrictions
on the property would be imposed. If any contaminated soils are
found to be above the action levels, they will be properly
disposed. The estimated cost of this alternative is $141,000
(plus $100,000 to dismantle the facility).
Alternative 2_L Cap and Cover Under conditions where affected
materials and soils were to exist above the action levels
specified in the Brio Refining/Dixie Oil Processors Endangennent
Assessment this remedy would consist of three main phases.
First, all on-site liquids and flowable organics will be
stabilized in place. Any work which might release VOC fumes will
be done inside portable buildings connected to a fume
incinerator/scrubber. The pits would then be closed by
constructing compacted clay caps over them. These caps would
1.7
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TABLE 3
NO ACTION
REMEDIAL ACTION PLAN
BRIO, OOP LINE ITEM COST
(*K)
BRIO OOP TOTAL
SOURCES AND PATHWAYS COST COST COST
1. Affected Soils and Material 0 0 0
2. Wastewater Treatment System 310 0 310
3. Storage Tanks and Drums 680 0 680
4. Air Migration 120 20 1MO
5. Runoff to Mud Gully 0 0 0
6. Mud Gully Sediments 0 0 0
7. Ground water (NSC2) 600 MO 6MO
8. Ground water*(Fifty-Foot Sand) 86 21 107
9. Site Management Plan M70 60 1,530
TOTAL COST 3,266 1M1 3.M07
NET PRESENT COST 1,350 80 1,«30
VOLUME: 62,000 C.Y.
DURATION: 30 Years
COST BASIS: -30% to +50%
BRO/TABLES
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TABLE 4
VAULT
REMEDIAL ACTION PLAN
BRIO, OOP LINE ITEM COST
(*K)
BRIO OOP TOTAL
SOURCES AND PATHWAYS COST COST COST
1. Affected Soils and Material 12,870 0 12,870
2. Wastewater Treatment System 800 0 800
3. Storage Tanks and Drums 700 0 700
M. Air Migration 2,695 25 2,720
5. Runoff to Mud Gully 000
6. Mud Gully Sediments 270 0 270
7. Ground water (NSCZ) 1,832 U2 1,871
*
8. Ground water (Fifty-Foot Sand) 86 21 107
9. Site Management Plan 1.U70 60 1,530
TOTAL COST 20,723 1*»8 20,871
NET PRESENT COST 17,180 120 17,300
VOLUME: 62,000 C.Y.
DURATION: 3 Years
COST BASIS: -30% to +50*
BRO/TABLES
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TABLE. 5
CAP AND COVER
REMEDIAL ACTION PLAN
BRIO, OOP LINE ITEM COST
BRIO DOP TOTAL
SOURCES AND PATHWAYS COST COST COST
1. Affected Soils and Material 6,770 0 6,770
2. Wastewater Treatment System 510 0 510
3. Storage Tanks and Drums 620 0 620
U. Air Migration 1,775 25 1,800
5. Runoff to Mud Gully 000
6. Mud Gully Sediments 270 0 270
7. Ground water (NSCZ) 1,832 U2 1.87U
8. Ground water (Fifty-Foot Sand) 86 * 21 107
9. Site Management Plan 1,U70 60 1,530
TOTAL COST 13,333 1*8 13,
NET PRESENT COST 11,570 130 11,700
VOLUME: 62,000 C.Y.
DURATION: 2 Years
COST BASIS: -30* to
BRO/TABLES
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TABLE 6
BIOLOGICAL TREATMENT ACTION PLAN
BRIO, OOP LINE ITEM COST
UK)
BRIO OOP TOTAL
SOURCES AND PATHWAYS COST COST COST
1. Affected Soils and Material
a. Aqueous Phase 14,335 0 14,335
b. Solid Phase 11,360 0 14,360
2. Hastewater Treatment System 1,350 0 1,350
3. Storage Tanks and Drums 770 0 770
4. Air Migration 2,695 "25 2,720
5. Runoff to Mud Gully 000
6. Mud Gully Sediments 270 0 270
7. Ground water (NSCZ) 1,832 42 1,87*
8. Ground water (Fifty-Foot Sand) 86 21 107
9. Site Management Plan 1,470 60 1,530
TOTAL COST
a. Aqueous Phase 22,808 148 22,956
b. Solid Phase 22,833 148 22,981
NET PRESENT COST
a. Aqueous Phase 19,790 130 19,920
b. Solid Phase 19,800 130 19,930
VOLUME: 62,000 C.Y.
DURATION: 30 Months
COST BASIS: -30* to +50*
BRO/TABLES
-------
TABLE 7
INCINERATION REMEDIAL ACTION PLAN
BRIO, OOP LINE ITEM COST
($K)
BRIO OOP TOTAL
SOURCES AND PATHWAYS COST COST COST
1. Affected Soils and Material
a. Rotary Kiln 19,260 0 19,260
b. Infrared 15,120 0 15,120
2. Wastewater Treatment System 775 25 800
3. Storage Tanks and Drums 700 0 700
4. Air Migration 1,705 25 1,730
5. Runoff to Mud Gully 000
6. Mud Gully Sediments 270 " 0" 270
7. Ground water (NSCZ) ' 1,832 M2 1.87M
8. Ground water (Fifty-Foot Sand) 86 21 107
9. Site Management Plan 1.U70 60 1,530
TOTAL COST
a. Rotary Kiln 26,098 173 26,271
b. Infrared 21,958 173 22,131
NET PRESENT COST
a. Rotary Kiln 21.6MO 1MO 21,780
b. Infrared 17.M30 110 17,540
VOLUME: 62,000 C.Y.
DURATION: a. 3 Years
b. U Years
COST BASIS: -30* to +50*
rirv^ /•?>« m PC
-------
TABLE 8
OFF SITE DISPOSAL
REMEDIAL ACTION PLAN
BRIO, OOP LINE ITEM COST
(*K)
BRIO OOP TOTAL
SOURCES AND PATHWAYS COST COST COST
1. Affected Soils and Material 76,710 0 76,710
2. Wastewater Treatment System 800 0 800
3. Storage Tanks and Drums 700 0 700
U. Air Migration 2.M15 25 2.UMO
5. Runoff to Mud Gully 000
6. Mud Gully Sediments 270 0 270
7. Ground water (NSCZ) 1,832 «2 1.87M
8. Ground water (Fifty-Foot Sand) 86 21 107
9. Site Management. Plan 1,170 60 1,530
TOTAL COST W.283 1H8 84.U31
NET PRESENT COST 66,060 130 66,190
VOLUME: 62,000 C.Y.
DURATION: U Years
COST BASIS: -30% to +50*
BRO/TABLES
-------
have a venting system to trap any volatile organic compound (VOC)
fumes released later by the unstabilized materials (soils) in the
pits. The vents will be connected to carbon canisters to control
any VOC emissions, if necessary. All drums and tanks will be
disposed of off site. The estimated cost of this alternative is
$148,000 (plus $100,000 to dismantle the facility).
Alternative .3_L Vault Under conditions where affected materials
and soils were to exist above the action levels specified in the
Brio Refining/Dixie Oil Processors Endangerment Assessment this
remedy would place all affected materials in an on-site vault.
Affected materials would include drum contents, soil and subsoil
contaminated at or above action levels, and any liquids and
flowable solids. Any liquids or flowable solids will be
stabilized first, and then put in the vault. Any work which
might release VOC fumes would be done in a portable building, the
fumes collected and incinerated. After the vault was filled it
would be capped and covered. As in the Cap and Cover
alternative, a venting system for VOC fumes would "be installed.
Tank liquids and drums with liquids would be disposed of off
site. All tanks but one would be dismantled and buried in the
vault along with all drums of solids. One tank would be used to
equalize the flow to a wastewater treatment plant. This plant
would treat the leachate from the vault. The estimated cost of
this alternative is $148,000 (plus $100,000 to dismantle the
facility).
Alternative 4; •Biological Treatment Under conditions where
affected materials and soils were to exist above the action
levels specified in the Brio Refining/Dixie Oil Processors
Endangerment Assessment this remedy would use either a solid
phase or aqueous biological system to treat all affected
materials and soils. After treatment, the solid residues from
either process would be sufficiently decontaminated for use as
direct backfill of the areas from which they were removed. All
excavation would be enclosed in a portable structure which would
vent to a fume incinerator/scrubber system. Tank residues, drums
and decontaminated, dismantled tanks would be transported off
site and disposed. The estimated cost of this alternative is
$148,000 (plus $100,000 to dismantle the facility).
Alternative 5; Qn Site Incineration Under conditions where
affected materials and soils were to exist above the action
levels specified in the Brio Refining/Dixie Oil Processors
Endangerment Assessment, the only difference between this remedy
and Alternative 4 is that the affected materials would be
incinerated. The decontaminated ash would be used to backfill
the excavations. The estimated cost of this alternative is
$173,000 (plus $100,000 to dismantle the facility).
Alternative £_L Off-site Disposal Under conditions where affected
materials and soils were to exist above the action levels
specified in the Brio Refining/Dixie Oil Processors Endangerment
24
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Assessment this solution would include excavation inside portable
buildings connected to a fume incinerator/scrubber. The pits
would then be backfilled with clean soil. The excavated material
would be placed in trucks, specially equipped for hauling
hazardous substances, and transported to an off-site disposal
facility. The estimated cost of this alternative is $148,000
(plus $100,000 to dismantle the facility).
4.3 EVALUATION Q£ ALTERNATIVES
It should be noted, as discussed in Section 4.2 above, that the
Brio Refining/Dixie Oil Processors Endangerment Assessment
indicated that under a trespass exposure scenario (that assumed
use of a site security fence to restrict access, thus limiting
potential exposure to site contaminants) there were no affected
material and soil above the action levels which would trigger the
need for treatment. Therefore, only monitoring activities and
the site management plan of each alternative would be applicable
to the Dixie Oil Processors site.
The degree to which the remedial alternatives meet the nine
selection criteria is contained in Table 9. The following values
were assigned to compare remedy selection criteria:
++ Alternative would greatly exceed a selection criterion
when compared to other alternatives.
+ Alternative would exceed a criterion in comparison
to other alternatives.
0 Alternative can be designed to meet the selection
criterion.
Special efforts will be necessary in the design of
the remedy to meet the selection criterion.
In comparison to the other remedies, these
alternatives would present most difficulty in
achieving a selection criterion.
The rationale for the ratings assigned in this table is as follows;
1. Complies with ARARS (i.e. meets or exceeds
Applicable, or Relevant and Appropriate Federal and
State Requirements).
All alternatives are assigned a "0" because they can
be designed to meet the selection criterion.
2. Reduces: Toxicitv. Mobility, and Volume
All alternatives were rated "-" because they do not
reduce any of these parameters. However, they all
25
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are protective of public helath and the environment
and provide permanence to the maximum extent
practicable.
3. Short-Term Effectiveness
All the alternatives were rated "0", as long as site
access is restricted and the potential for direct
contact with site contaminants is significantly
reduced.
4. Long-Term Effectiveness and Permanence
All alternatives were rated "+" based on the low
level of contamination left on the site, the low
mobility of the waste and the site controls
which will be enforced to reduce potential
exposure. All alternatives provide permanence to the
maximum extent practicable.
5. Implem^n^^bilitv
All alternatives were rated "0" because of the ease
in implementing the monitoring activities, a site
management plan, and any necessary dismantling.
6. Cost
Estimated costs for each remedial action alternative
are summarized in Table 4. Included in this table
are total capital and present worth costs. Operation
and maintenance costs were factored into each line
item. The only foreseen cause for failure of the
remedy is a change in the land use which would
result an increase in exposure to site contaminants.
In this case, further treatment of affected soils and
materials may be necessary. If you were to increase
exposure to levels which required treatment to
background conditions (naturally occurring),
it is estimated that in excess of 100,000
cubic yards of soil would have to be treated
at a cost of $30 to $40 million.
The No Action alternative has the lowest present
worth cost of the various alternatives followed by
Biological Treatment, Off-Site Disposal, Cap and
Cover, Vault, and Incineration. The line items were
essentially the same except for the differing costs
associated with air monitoring and the wastewater
treatment system. Line item accounting costs include
air emissions controls and monitoring, groundwater
monitoring and the site management plan.
26
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7. Community Acceptance
Comments from local residents received at the public
meeting on February 9, 1988, and during the public
comment period have one central theme, there is
general agreement among local residents that all
measurable amounts of affected materials and soils
found on the site should be treated. EPA has
proposed to treat only affected materials and
soils that would pose a human health or environmental
health threat. Thus, some measurable amounts of
contaminants will remain on site, however, deed
restrictions will be imposed and site access will be
controlled. Another major concern of the public is
the potential adverse impact that this Superfund site
will have on their property values and on the
economic development of the area.
Community members have also expr-=*5sed concern over
the need to widen Mud Gully (a flood control ditch
located on the western boundary of the site) to
prevent a "bottle neck" in the ditch. Additionally,
they would like to see the tanks and process
equipment dismantled as part of any remedy.
Off-site Disposal was the only solution which the
public appeared to favor, but they wanted all
contaminants excavated and disposed off-site.
Therefore, Off-Site Disposal was rated " + " while all
other alternatives evaluated in this Record of
Decision were rated "-" due to the lack of support
community support.
To address the concerns mentioned above, EPA will
request that any settling party (as part of the
selected remedy) investigate creative design and
landscaping ideas, in cooperation with the local
residents, that might reduce any adverse economic
impact the site might have on the area and enhance
the aesthetics of the site. Additionally, any remedy
will have to address the problem associated with Mud
Gully to the satisfaction of the local Flood Control
District and include dismantling the above ground
storage tanks and process equipment. For further
detail refer to Section V, entitled "Selected
Remedy." Furthermore, reference the "Community
Relations Responsiveness Summary" (Appendix A) for
EPA's response to public comments.
8. State Acceptance
The State (through the Texas Water Commission) was
provided an opportunity to comment on the Record of
27
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Decision. They had no objection to EPA's proposed
alternative (See Appendix F).
Therefore, limited action and monitoring as described
in the No Action alternative in the Feasibility Study
was rated "+", while all other alternatives were
rated "0".
9. Overall Protection of Human Health and the Environment
All alternatives rated "0" because they can all be
designed to provide adequate protection from the
potential risks involved with leaving low level
contamination in an untreated state on the site.
Additionally, this rating is based on the results of
the Endangerment Assessment which under the trespass
exposure scenario indicated that the site would not
pose a public health threat as long as site controls
are maintained (i.e., a security fence to restrict
access, deed notice and restrictions, and a
restriction on site activities to ensure limited
exposure).
4.4 OPERATION AND MAINTENANCE
Site operation and maintenance will include a monitoring program
for sampling groundwater wells, ambient air, and Mud Gully
sediments. This sampling program will monitor the effectiveness
of the selected remedy and provide the data necessary to trigger
future corrective action, if necessary. Additional site
maintenance will include, but not necessarily be limited to,
inspections of surface vegetation, ensure proper drainage, and
periodic fence (or barrier) repair. The details of this activity
will be defined in the Operation and Maintenance Plan of the
remedial design.
V. SELECTED REMEDY
Based on the information provided in the administrative record
and the results of the evaluation of alternatives (Section 4.3),
the final remedy has been selected.
It is EPA's judgement that limited action and monitoring as
described under the No Action alternative in the Brio
Refining/Dixie Oil Processors Feasibility Study Study best serves
both statuatory and selection criteria in relation to the other
solutions evaluated in this document.
The final remedy is summarized as follows:
Affected materials and soils - The Brio/DOP Endangerment
Assessment identified action levels based on limited exposure to
site contaminants. This exposure scenario relied heavily on the
29
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use of site controls to ensure a limited probability of exposure
to these contaminants. The term site controls shall be defined
below, but shall include restricted access through the use of a
site security fence. The endangerment assessment did not
identify any contaminated soils on *-he DOP site that exceed the
action levels discussed above. Therefore, excavation and
treatment of contaminated soils is not necessary as long as the
site controls are enforced. However, if proper site controls
are not ensured and greater exposure results from any future
activities, then the action levels identified above no longer would
apply and treatment of contaminated soils may be necessary.
Surface contamination - The site investigations identified
surface staining throughout the DOP property. These areas will
be addressed in the site management plan discussed below.
Off-site soil contamination - Any off-site soil contamination
found during the remedial investigation or during the excavation
of affected materials and soils shall be removed to background
levels. This may require that special detection limits be used
for sampling efforts at the site boundaries during the remedial
action. This activity will have to be further defined in the
remedial design.
Debris and. rubble - There is much inert debris and rubble
remaining on the site from past operations. This material may be
consolidated and the ultimate disposition of the material
determined during the remedial design.
Mud Gullv - Contaminants observed in this flood control ditch
and the "bottle neck" that exists as it passes the Brio and DOP
sites has been a noted concern of the EPA as well as local
residents and the Harris County Flood Control District. It is
apparent that these problems will have to be corrected as part of
any remedy that is instituted at the site. Initial thoughts
would suggest a low-maintenance approach to resolving this
problem where some type of performance standard would be set in
cooperation with the Harris County Flood Control District. Such
actions shall be further defined in the remedial design.
Wastewater treatment system - The existing wastewater treatment
system may be used during remedial action but will be
dismantled and removed from the site by the completion of
remedial action.
Storage tanks and drums - Remove tank contents, decontaminate
tanks, dismantle tanks; sell or transport dismantled tanks to an
EPA approved disposal facility; transport tank contents and
drums to an EPA approved off-site disposal facility. If tanks
are used during remedial activities, they will be dismantled upon
completion.
30
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Process equipment - The entire process facility will be
dismantled to the extent that some of the existing facility may
be used during remedial activities. If they are used during
remedial action, the structures will be dismantled upon
completion of these activities.
Monitoring and. control o_f migration pathways - Ambient air
sampling on a semi-annual basis; control air emissions from
treatment processes (if necessary); excavate in enclosures (if
necessary) and vent the enclosure to an emission control device;
eliminate or control rainfall on construction areas; sample and
monitor Mud Gully sediments; monitor the groundwater in the
Numerous Sand Channel Zone and Fifty-Foot Sand for a timeframe to
be defined in the remedial design; and monitoring activities will
be utilized to determine the effectiveness of the actions to be
implemented and shall be detailed in the operation and
maintenance plan of the remedial design. This same data will be
evaluated during the Agency's 5-year review, in accordance with
SARA Section 121(c), to determine if any corrective action is
necessary.
Site management plan - The entire DOP site will be regraded and
vegetated to promote drainage and minimize infiltration. All
regraded areas will be covered with 6 inches of topsoil, if
necessary, to promote vegetative growth. To the maximum extent
practicable, the aesthetics of the site (upon completion of the
remedy) shall be enhanced by utilizing creative design and
landscaping techniques with input from the local residents.
Site control - This remedial action is based on permanent site
control, imposition of necessary deed notices and restrictions (if
possible), and restriction of access to the site by use of a fence or
similar barrier.
/
Estimated Cost - The estimated cost of the remedy is $241,000.
31
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APPENDIX A
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DIXIE OIL PROCESSORS SITE
SOUTHEAST HARRIS COUNTY, TEXAS
RESPONSIVENESS SUMMARY
This community relations responsiveness summary is divided into
two sections:
SECTION I: BACKGROUND QH COMMUNITY INVOLVEMENT AND CONCERN
This section provides a brief history of community
interest and concern raised during the planning
activities at the Dixie Oil Processors Superfund site.
Section II: SUMMARY QF_ MAJOR COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND THE EPA'S RESPONSE JQ THE COMMENTS
Both written and oral comments are presented. EPA's
responses to these relevant topic* are also
presented.
I. BACKGROUND QN, COMMUNITY INVOLVEMENT
Dixie Oil Processors (DOP) was referred to EPA in 1985 by the
Texas Water Commission for inclusion to the National Priorities
List. Due to its location next to the Brio Refining site, its
past history with the site and the fact that many of the same
PRPs at Brio were potentially involved at DOP, the Brio
Administrative Order on Consent was amended on April 23, 1986, to
include the DOP site. This agreement between EPA and the Brio
Site Task Force provided for investigations at the DOP site and
for the Task Force to conduct a comprehensive community relations
program on DOP with EPA oversight.
On September 4, 1986, a community meeting was held to discuss any
issues or concerns the local residents may have regarding the
site studies. Status reports were also provided through
newsletters.
On February 2, 1987, the Task Force held a community meeting on
various treatment techniques that may be employed during remedial
action at a typical Superfund site. A community leaders meeting
was held on April 2, 1987, to provide an update on site
activities. A meeting to discuss the preliminary results of the
Endangerment Assessment was held with the community leaders on
June 18, 1987.
On January 21, 1988, EPA announced through a press release that
studies were completed on the DOP site. The announcement also
advised the public that EPA would be accepting comments on the
proposed remedy for the site from February 1 to March 1, 19.88,
and that the Agency would hold a public meeting on February 9,
1988. An EPA prepared fact sheet describing various alternatives
evaluated was mailed to interested citizens. EPA held a
-------
community leaders meeting on January 25, 1988, to brief the
members of the group on the solutions proposed for the site. On
the following night, January 26, 1988, the Brio Site Task Force
held a community meeting to discuss the overall results of the
site investigations, the findings of the Endangerment Assessment.
An EPA representative announced the scheduled public meeting to
discuss remedial alternatives. EPA's public meeting was held on
February 9, 1988, at the Weber Elementary School. Approximately
350 people attended the meeting. The community expressed great
concern that the remedial action would only address partial
remediation. A summary of the public response to the solutions
proposed by EPA at this meeting, can be found in the
Responsiveness Summary (Appendix A). On February 22, EPA met
with the Friendswood City Council to discuss the proposed
alternative solutions that the Agency had outlined in its public
meeting on February 9.
Again, It should be noted that EPA was an active participant in
all of the community or community leaders meetings discussed
above. These activities were carried-out in cooperation with the
Brio Site Task Force in accordance with the terms outlined in the
above mentioned Brio Refining/Dixie Oil Processors Administrative
Order on Consent.
II. SUMMARY QE PUBLIC COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND AGENCY RESPONSES
The public comment period on the Feasibility Study for the Dixie
Oil Processors Superfund site opened on February 1, 1988 and
closed on March l, 1988. A public meeting was held February 9,
1988, at the Weber Elementary School with approximately 350
people in attendance. The EPA received many comments regarding
all aspects of the Superfund actions taken at this site. This
Responsiveness Summary is written to summarize the publics
response to EPA's proposal for remediation at the Brio Refining
and Dixie Oil Processors sites. Therefore, the Agency has
focused its attention on summarizing and responding only comments
concerning the Brio Refining and Dixie Oil Processors Feasibility
Study and the remedial alternatives being evaluated. This
summary is provided below:
Comment 1
EPA misrepresented what was meant by "cleanup" of the site (i.e.,
partial versus complete treatment).
EPA Response to Comment 1
The EPA agrees that, in general, the term "cleanup" is misused in
certain situations. However, the Agency's representatives for
this particular site have been very careful as to not mislead the1
local residents during the many public meetings that have been
held throughout the past few years. Experience has shown us that
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very few sites are ever returned to a naturally "clean" state;
therefore, we are very careful about the message that we
communicate to the public. It is our opinion that this
misconception is a result of the publics own belief that an
eventual remedial action would mean treating all measurable
amounts of contaminated materials and soils enabling the site to
be used for commercial or recreational purposes.
Comment: 2.
The proposed remedy does not provide maximum health protection to
nearby residences, schools, and hospitals.
EPA Response to Comment 2.
It is EPA's opinion that the proposed remedy provides what EPA
considers to be adequate protection of human health and the
environment. This message is discussed in great detail in the
Brio Refining and Dixie Oil Processors Endangerment Assessment.
This document provided EPA with the information necessary to make
this determination. Additionally, the calculations made in the
assessment are very conservative thus providing the Agency with
added certainty for protection of public health.
EPA has proposed to excavate and treat all affected materials and
soils that have a potential for creating an unacceptable risk to
human health or the environment. Once this activity is
completed, site controls will be enforced to restrict access to
the site thus reducing the probability of exposure to any low
level contaminants that may remain upon completion of
remediation.
Comment 1
The deed restrictions and restricted access associated with the
proposed remedy will promote a negative perception of the
community and will adversely affect property values.
EPA Response to Comment J3.
EPA in conducting its environmental mandate, must balance a large
number of factors before determining the best approach to
addressing problems at Superfund sites. The Superfund Amendments
and Reauthorization Act (SARA) specifies that EPA shall
"... select a remedial action that is protective of human health
and the environment ..." The statute also states that EPA shall
"... select appropriate remedial actions determined to be
necessary to be carried out ... which provide for cost-effective
response." These laws are developed by our governmental leaders
and EPA must use them as a guide in conducting its business.
EPA believes that the proposed plan of action at the Brio and
Dixie Oil Processors (DOP) sites comply to the maximum extent
-------
practicable, with the provisions of SARA. The first priority of
the Agency is the protection of human health and the environment
and the proposed solutions serve this purpose very well. An
increased degree of treatment at either site would result in very
little added protection relative to the incremental increase in
cost that would result. Furthermore, the appearance of the sites
upon completion of the remedial action is a consideration of the
final Record of Decision. Appearance will also be a factor in
all discussions on conducting and funding of remedial actions by
potentially responsible parties. It is believed that the parties
win be interested in investigating, in concert with local
homeowners, various creative landscaping ideas that will result
in an acceptable solution.
Implementing solutions which account for local property values
and economic development is outside the jurisdiction of EPA.
Local residents have the state courts available to them to
resolve these issues or they can request that their State
government intervene on their behalf. State governments have the
opportunity to request for and pay the additional costs
attributed to meeting any such standard they may deem necessary.
This would include a request for treating all measurable
quantities of waste at a Superfund site. Additionally, the State
would then become a signatory to the Consent Decree and actively
participate in negotiations, the remedial design, and remedial
action.
Comment 4.
Bioremediation should be evaluated further as a potential remedy
at the site.
EPA Response to Comment 4.
It is EPA's judgment that on-site incineration of wastes would
best serve both statutory and selection criteria in relation to
the other solutions evaluated. On the other hand, the Brio
Site Task Force has proposed the use of on-site aqueous-phase
biological treatment. The EPA had some concerns over the lack
of demonstrated performance of this technique on the wastes at
the site. However, this will not prevent EPA from favorably
considering the proposal of the Task Force if they can
demonstrate that biological treatment can provide the same
level of treatment deemed necessary by the Agency. Pass/fail
criteria for use of biological treatment rather than
incineration will be developed prior to the start of remedial
action. If biological treatment cannot meet the pass/fail
criteria, then on-site incineration will be implemented.
Comment £
On-site incineration is not a practical alternative given the
-------
Based on the public response to this situation, as part of any
remedy, all storage tanks, surface vessels, drums, and process
equipment will be dismantled and either sold (after proper
decontamination) or disposed according to EPA regulations.
Comment 2.
The ash from the incinerator is going to be harmful to our
health.
EPA Response to Comment 1
If incineration is used for treatment of affected materials and
soils all of the ash resulting from the thermal treatment
operations will have to pass specific tests before it would be
allowed to be placed back into the ground. These tests will
provide EPA with the confidence that this material will not
result in a future problem. Additionally, this material will
remain onsite and site access will be restricted.
Additionally, our incineration tests showed us that we could
achieve a 99.997% reduction in contaminants. .These results
suggest that minimal amounts of contamination, if any, will
remain after treatment.
Comment 10
Identify the methods of control for odors in the incineration
process.
EPA Response to Comment 10
The most likely cause of odors during the remedial action would
result from volatile contaminants being released during
excavation activities. As outlined in the Brio Refining and
Dixie Oil Processors Feasibility Study, all excavations (during
the construction of the solution) will be performed in portable
enclosures. The enclosures will trap the volatile compounds.
The air in the enclosures will then be treated to remove these
compounds. This practice should reduce, to the maximum extent
practicable, any odors resulting from soil disturbance
activities.
Comment 11
Describe the regulations and standards that will be in place
after the cleanup is completed that will ensure the protection of
the publics health and safety.
EPA Response to Comment
This remedial action is based on permanent site controls. This
-------
will include the imposition of deed notices and restrictions to
ensure that the site is never used in such a way as to increase
exposure to contaminants that will remain on site and a security
fence or similar barrier will be maintained to prevent trespass
and potential exposure to contaminants left onsite.
In addition to these activities, the ambient air, groundwater and
Mud Gully sediments will be sampled and monitored to provide
information for evaluation of the effectiveness of the solution.
This program will be conducted indefinitely or until such time
that EPA feels that such efforts are no longer necessary. Also
any remedial action where EPA leaves contaminants at the site
(upon completion of the remedy), the Agency must review such
actions no less than five years after the initiation of such
remedial action to assure that human health and the environment
are being protected.
Comment 12
In screening the remedial alternatives, the offsite disposal
option was quickly dismissed in the Feasibility Study. This
conclusion is not reached in a logical and well documented
manner.
EPA Response fro Comment 12
The Superfund law, specifically SARA Section 121 (b) state that
"... offsite transport and disposal of hazardous substances or
contaminated materials without such treatment should be the least
favored alternative remedial action where practicable* treatment
technologies are available ... shall conduct an assessment of
permanent solutions and alternative technologies ... that, in
whole or in part, will result in a permanent and significant
decrease in toxicity, mobility, or volume of hazardous substances
dismissal of Offsite Disposal as a viable alternative.
Comment 13
It was suggested that the estimates in the Feasibility Study for
waste volumes of the on-site pits were ball-park figures; heavily
contaminated areas could have been missed by soil borings; the
shallow groundwater contamination was not well defined; and the
cost analysis lacked sufficient support.
EPA Response to Comment 13
The EPA feels that the field work conducted as part of the
Remedial Investigation and Supplemental Investigation was more
than sufficient to characterize the magnitude and extent of
contamination. This effort will be further refined during the
actual remedial action where all'contaminated sludges and liquids
will be excavated and treated. The Feasibility Study identified
pits B, J, Q, R, H/v, and E as needing remediation based on the
-------
findings of the Endangerment Assessment. As part of the Record
of Decision pits F, G, I, K, L, and M will require examination
during remedial action for removal of all sludges and liquids.
Additionally, all surface contamination (in the form of tars)
will be scraped and consolidated for treatment. Regarding the
comment on cost estimates, the Feasibility Study contained
sufficient information to evaluate each conceptual design.
Comment J.4
Some comments were received concerning the question of off-site
contamination which originated from the Brio Refining site.
EPA Response to Comment 14
This information has been turned over to EPA's Site Assessment
section for further investigation. Those individuals who have
commented in this fashion will be contacted by this group
following their evaluation of the matter.
Comment 15
Explain what pits will be excavated.
EPA Response to Comment 15 • .
See EPA's response to Comment #13.
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APPENDIX B
-------
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-------
TABIZ 3-9
HI GiJOATED WASTES
DRUM INVENTORY
Origin
OW-5A
EMW-19A
HW-19B
EMW-20A
OW-20B
EMW-21A
DW-22A
EMW-23A
EMW-24A
DMW-24B
HW-25A
HW-27A
EMW-283
Dixie Totals
Clothing
4
2
1
3
6
0
1
0
1
2
0
2
_0
22
Drilling
Fluid
32
24
36
8
80
3
26
5
22
38
20
14
45
353
Drill
Cuttings
2
5
0
1
3
0
0
4
0
1
1
1
18
Monitor
Well
Hrtar
0
3
3
3
7
4
2
3
0
12
4
0
41
DRJM IDCATIONS
Storage
Location
Storage Areas on Brio
On-Site Dixie
Total Drums
Palletized
Yes
No
Total
38
34
40
15
96
7
29
12
23
53
25
17
45
434
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APPENDIX C
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k.l REGULATORY COMPLIANCE
^.7.1 General Background
Section 121(d) of CERCLA, as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), describes the types of standards that a
remedial action is required to meet. Those standards mist be met by any
remedial action proposed by this Feasibility Study for the Brio site. Section
121(d) mandates that the remedial action selected must be protective of public
health and the environment and the types of control in place and the levels of
the hazardous substances, pollutants, or contaminants at the site must meet
those standards, requirements, criteria, or limitations under any Federal
environmental law, or any more stringent state standard, that are "legally
applicable" OJT "relevant and appropriate". To obtain compliance with this
general standard, and in recognition of the USEPA's July 9. 1987 memorandum
"Interim Guidance on Compliance with Applicable and Relevant and Appropriate—*
Requirements", all remedial action plans were evaluated to determine what
standard and appropriate technologies would be adequately protective of public
health and the environment.
The universe of environmental standards and controls was reviewed to determine
which of them had a bearing on remedial action at the site, Table U-8. The
results of that evaluation are summarized in Table M-9 which specifies
controls and standards deemed appropriate during remediation on the basis of a
best engineering Judgement evaluation.
At the completion of remediation the only standards that mist be complied with
are those that describe the level at which a hazardous substance, pollutant or
contaminant should be found in the environment or those standards that specify .
a means of controlling releases of hazardous substances, pollutants or
contaminants.
For those standards that describe a level or type of control, th«a«
requirements need only be met if they are "legally applicable" or "relevant
and appropriate". These terms are not defined in the amended CERCLA. Th«
EPA's Interim Guidance defines "applicable requirements" as "those cleanup
standards, standards of control, and other substantive environmental
u-m
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TABLE 4-8
STANDARDS, REQUIREMENTS, CRITERIA, OR LIMITATIONS EVALUATED
FOR ARARs DETERMINATION
Safe Drinking Water Act
Clean Water Act
Solid Waste Disposal Act
Occupational Safety and Health Act
Hazardous Materials Transportation Act
National Historic Preservation Act
Archeoiogical and Historical Preservation Act
Historic Sites, Buildings and Antiquities Act
Fish and Wildlife Coordination Act
Endangered Species Act
Rivers and Harbors Act of 1899
Wilderness Act
Scenic River Act
Coastal Zone Management Act
Texas Clean Air Act
Texas Solid Waste Disposal Act
Texas Water Code
BRO/FS-FN-S4TrO6)
BRO/FS-FN-S4Tr(l6)
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TABLE U-9
STANDARDS AND CONTROL TECHNOLOGY
UTILIZED DURING REMEDIATION AS
SPECIFIED BY BEST ENGINEERING
JUDGEMENT TO PROTECT PUBLIC HEALTH
AND THE ENVIRONMENT
A. AIR EMISSIONS
1. Excavation/stabilization performed in enclosure and air Missions
collected and routed to fume Incinerator with scrubber (all
remedial options).
2. Any stockpiles of feedstock for treatment (biological or
incineration) maintained in enclosure with air emissions collected
and routed to scrubber equipped fume incinerator.
*
3. Biological treatment (solid or aqueous) performed in an enclosure
with air emissions collected and routed to a scrubber equipped fume
incinerator.
4. Incinerator equipped with high-temperature secondary combustion
chamber-and wet scrubber designed to meet particulate, HC1 and
destruction removal efficiency limitations specified in 40 CFR Part
264, Sutjpart 0.
B. SURFACE AND GROUNDUATER
1. Process water and potentially contaminated stormwater1 collected
and routed to a package activated sludge treatment system equipped
with carbon polishing and discharged to Hud Gully or routed to a
POTW for treatment (all remedial options).
2. Discharge from package treatment system consistent with NPDES
permit limitations, and UO CFR Part 125.
3. Any groundwater subject to treatment would be treated in the
package treatment system prior to discharge.
BRO/FS-FN-S4Tr(12)
1 Since excavation/stabilization, stockpiling and any treatment will take
place in enclosures such that potentially contaminated storawater would
not be generated, the only areas subject to storawater collection would
be the transfer areas between pit excavation and stockpile and stockpile
and treatment.
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TABLE 4-9 '
(Continued)
C. AFFECTED SOIL AND MATERIAL
1. Compliance with substantive portions of 40 CFR Part 264, Subpart J,
relating to tanks (aqueous biological treatment), including:
a. 40 CFR $ 264.191 (shell strength)
b. 40 CFR $ 264.192 (prevent overfilling)
2. Compliance with substantive portions of 40 CFR Part 264, Subpart L,
relating to covered storage piles (all remedial options),
including:
a. 40 CFR 5 264.250(c) (covered waste pile)
3. Compliance with substantive portions of 40 CFR Part 264, Subpart M,
relating to land treatment (solid phase biodegradation), including:
a. 40 CFR § 264.273 (maximize degradation)
b. 40 CFR § 264.278 (unsaturated zone monitoring)
D.
1. OSHA Health and Safety Regulations as provided for in 20 CFR Part
1910, Subpart H.
BRO/FS-FN-S4Tr(13)
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protection requirements, criteria, or limitations promulgated under Federal or
State law that specifically address a hazardous substance pollutant,
contaminant, remedial action, location or other circumstance at a CERCLA
site." The guidance also notes that to be "applicable" implies that the
remedial action or circumstance satisfy all the Jurisdictional prerequisites
of a requirement.
The Interim Guidance defines "relevant and appropriate" requirements as "those
cleanup standards, standards of control, and other substantive environmental
protection requirements, criteria, or limitations promulgated under Federal
and State law that, while not 'applicable' to a hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance at a
CERCLA site, address problems or situations sufficiently similar to those
encountered at the CERCLA site that their use is well suited to the particular
site."
Section 121 also provides that onTsite remedies are not required to obtain
Federal, State, or local permits. This permit exemption covers Federal, State
or potentially responsible party response actions being taken on site under
the authority of CERCLA Sections 104, 106 or 122. Therefore, these remedies
must comply with the substantive requirements which specify a level or means
of control, but do not need to comply with administrative and procedural
requirements associated with the permitting process. "On-site" includes the
areal extent of contamination and all suitable areas in reasonable proximity
to the contamination necessary for implementation of the response action.
ARARs must be determined on a site specific basis. Therefore, with this
general understanding of the requirements of $ 121(d), the following la an
assessment by environmental media of compliance of the proposed remedial
actions with the standards found to be either "legally applicable" or
"relevant and appropriate".
M.7.2 Air Emissions
Based on a review of all potentially applicable air emission-related
regulations and standards, the only "legally applicable or relevant and
appropriate requirement" for air emissions at the completion of remediation is
-------
specified in Section 4.01 of the Texas Clean Air Act, which provides that "no
person may cause, suffer, allow or permit the emission of air contaminants or
the performance of any activity which causes or contributes to, or which will
cause or contribute to, a condition of air pollution". "Air pollution" is
defined "as the presence in the atmosphere of one or more air contaminants or
a combination thereof, in such concentration and of such duration as are of
may tend to be injurious to or to adversely affect human health or the
environment, animal life, vegetation or property, or as to interfere with the
normal use and enjoyment of animal life, vegetation, or property."
To assure compliance with this standard, each of the proposed remedial action
plans contains provisions for semiannual ambient monitoring to verify that
site conditions existing at the completion of remediation-are not causing or
contributing to a condition of air pollution. All of the remedial actions are
designed to insure .that emissions are in compliance this ARAR. Specific^*/
measures to control air emissions during remediation have been incorporated
into each remedial action plan and are outlined in Table 4-9.
U.7.3 Surface and Ground Mater
•
4.7.3-1 Discharges to Surface Water
Hud Gully runs through the site and will be impacted from both point and non-
point sources of water discharges from the site. The point sources will
consist of water generated by remedial activities as well as storm water
flows. At the completion of remediation, there will be no point source
discharge.
However, at the completion of remediation Mud Cully may be impacted by a non-
point source discharge, namely ground water flow from the NSCZ. The only
standards that could be "legally applicable or relevant and appropriate" to
discharges from the NSCZ would be state* water quality standards or federal
water quality criteria.
State water quality standards are the legally enforceable counterpart to
federal water quality criteria. In Texas, the state water quality standards
are set forth in Chapters 319 and 333, of the rules and regulations of the
4-43
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Texas Water Conrission. Those standards establish certain numerical criteria
which are legally applicable to Hud Gully. All remedial action plans satisfy
the requirements of 31 TAG $§319-21 - 29, 333.17 - .19 for the discharge of
water from the NSCZ to Hud Gully.
While these requirements are ARARs, those portions of the state's standards
and the federal water quality criteria that relate to use of surface waters as
a source of drinking water (because the surface water directly supplies water
to a public drinking water supply system or recharges an aquifer used for that
purpose) are not applicable or relevant and appropriate, because Mud Gully
does not supply water to a potable water supply system nor does it recharge an
aquifer used for that purpose.
J4.7.3.2 Ground Water
The EPA's ground water protection strategy is based on the "differential*-^
protection" of ground water (i.e., ground water protection as it relates to a
specific classification of an aquifer). Under the strategy ground waters are
classified as follows:
Class I - ground waters that are highly vulnerable and
either an irreplaceable source of drinking water or
ecologically vital;
Class II - ground water currently used or potentially
available for drinking water or other beneficial use;
and
Class III • ground waters are not a potential source of
drinking water and of limited beneficial use.
For Class I and Class II ground waters MCLs established under -The Safe
Drinking water Act would be applicable for ground water which qualifies as a
public water system or a ooanunity water system. MCLs say also be relevant
and appropriate to ground water that would not currently qualify as such
systems but could potential so qualify in the future. Similarly, where the
State has established drinking water standards are more stringent than the
Federal MCL, these may be applicable or relevant and appropriate.
U-MU
-------
There are two water-bearing zones underlying the site which appear to have
been impacted by on-site activities. The uppermost zone is the NSCZ. The
next zone, which is separated from the NSCZ by an aquitard referred to as the
Middle Clay Unit, is the Fifty- Foot Sand. As discussed in this FS, the NSCZ
is neither an existing nor potential drinking water supply because of the poor
yield of that zone and therefore is a Class III aquifer under the EPA
Groundwater Protection Strategy. As such MCLs are neither applicable nor are
they relevant and appropriate to the NSCZ. As outlined above, however, NSCZ
ground water quality will be maintained such that its discharge does not
represent a threat to aquatic life in Hud Cully.
While the Fifty-Foot Sand might be a "potential" drinking water source,
demographic data, land use, and projected water supply plans for the area
clearly indicate that this aquifer is not likely to be used for drinking water
supply purposes.
Even if it is used as a drinking water supply it is not likely to serve as a
public water system or even a community water system. Therefore, MCLs would
not be legally applicable to the Fifty-Foot sand. However, because of its
status as a potential drinking water source these standards may be considered
relevant. Given that any potential use is unlikely in the near future, and
indeed may never occur, immediate application of MCL is not appropriate.
Instead, it is more appropriate to monitor this zone and let natural
attenuation, which will eventually allow any affected ground water in the
Fifty-Foot Sand to achieve MCL levels, take its course since there is not
current or projected threat of exposure. Furthermore, any subsequent
application of MCLs would apply to concentrations at the point of use and not
at the source.
J4. 7. U Affected Material and Soils
The primary standards of criteria that could be legally applicable to the
storage, treatment or disposal of affected material and soils are those
developed under the authority of RCRA. RCRA requirements would be "legally
applicable" to "hazardous waste" which includes: (1) wastes which exhibit one
of four characteristics (ignitability, reactivity, corrosivity, or toxicity)
or (2) are listed in the RCRA regulations as hazardous waste or (3) are
-------
mixtures of solid waste and hazardous waste that are not subject to an
exclusion from regulation. In order for these RCRA requirements to be legally
applicable at a CERCLA site the waste must be: (1) RCRA characteristic or
listed hazardous waste; and (2) have been received after November 19, I960; or
the CERCLA activity at the site constitutes current treatment, storage, or
disposal as defined under RCRA.
Applying this test, the first portion is clearly not satisfied sine* all of
the material to be dealt with during remediation was received at the site
prior to November 19, 1980. Therefore, the RCRA requirements would not be
legally applicable on that basis. The remaining portion of the test concerns
whether the proposed remedial actions would constitute storage, treatment or
disposal. No storage, as defined under RCRA, is proposed. Further, no
treatment will exist at the completion of remediation. With regard to
disposal, movement of material deposited before November 19, 19flO
constitute disposal where the material is moved from within a "unit area of
contamination" and placed in another area outside the "unit area of
contamination." In the case of Brio/OOP, all proposed excavation and
treatment would be conducted within the unit area of contamination and thus,
disposal as defined in RCRA will not occur. No element of the second portion
of the test is satisfied and, consequently, the RCRA requirements are not
legally applicable.
Even thougn they are not legally applicable, certain RCRA requirements,
including the RCRA design and operating standards, may be considered relevant
and appropriate based on the fact that they address problems or situations
sufficiently similar to those encountered at the Brio/OOP sites. Table 4-10,
in addition to specifying other ARARs, lists those RCRA requirements deemed
relevant and appropriate to the various remedial actions analyzed In this
FS. These requirements are considered ARARs.
For example, in two of the remedial action plans, cap and cover and vault,
affected material and soils would be remediated on site in accordance with the
closure requirements applicable to surface impoundments and landfills,
respectively. These closure requirements are relevant and appropriate to the
remedial action technologies contained within these two remedial action plans.
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TABLE 4-10
BRIO/DOP APPLICABLE OR
RELEVANT AND APPROPRIATE REQUIREMENTS
1. Section 4.01 of Texas Clean Air Act (applicable).
2. Sections 329.X1-.49, 333.17-.19 of Chapter. 31 of Texas Administrative
Code Relating to State Water Quality Standards as applied to Mud Gully
(applicable).
3. Federal Water Quality Criteria for Fresh Water Aquatic Life Protection
as applied to Hud Gully (relevant and appropriate).
4. Safe Drinking Water Act Primary and Secondary Maximum Contaminant
Levels (MCLs) as applied to Fifty-Foot Sand (relevant and appropriate).
5. RCRA requirements contained in 40 CFR, Part 264, consisting of the
following (by remedial action plan) (relevant and appropriate).
a. Cap and Cover (40 CFR Part 264, Subpart N)
(1) Eliminate.Free Liquids.
(2) Stabilize to a bearing capacity sufficient to support final
cover.
(3) Cover designed to:
(a) provide long term minimization of migration of liquids
through closed area;
(b) function with minimum maintenance; ,
(c) promote drainage and minimize erosion;
(d) accommodate settling and subsidence so that cover
integrity maintained; and
(e) have a permeability less than or equal to permeability of
any bottom liner system or natural subsoil.
(4) Post-Closure Designed to:
(a) maintain integrity and effectiveness of cover;
(b) maintain groundwater monitoring system;
BRO/FS-FN-S4Tr(l4)
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TABLE 4-10
(Continued)
(c) prevent run-on and run-off from eroding or otherwise
damaging final cover; and
(d) prevent disturbance of cover.
b. Vault (40 CFR Part 264, Subpart N)
(1) Constructed with two liners and a leachate collection system.
(2) Lower liner at least 3 feet thick constructed of reoompacted
clay with a permeability of no more than 1 x 10"' ca/s.
(3) Maintain a run-on control system to prevent flow into active
portion of landfill.
(M) Maintain a run-off control system to collect and control water
volume from active portions resulting from a 24-hour, 100 year
storm.
(5) ' Manage wind dispersal of particulates.
(6) Stabilize materials sufficiently such that no free liquids are
placed into vault.
(7) Cap construction consistent with 5a, above.
(8) Post-closure consistent with 5a, above.
6. RCRA requirements contained in 40 CFR Parts 262 and 263 to the extent
that a remedial alternative involves off-site transportation of
materials (applicable). Additionally, 49 CFR Parts 107, 174-177
relating to Hazardous Materials Transportation would be applicable.
7. RCRA requirements contained in 40 CFR Part 264, Subpart B, related to
general facility standards (applicable), consisting of:
a. 40 CFR f 264.14 (site security).
b. 40 CFR $ 264.17 (incompatible waste).
8. RCRA requirements contained in 40 CFR Part 265, Subpart G (relevant and
appropriate), consisting of:
a. 40 CFR S 264.114 (equipment decontamination).
b. 40 CFR S 264.117 (monitoring).
9. Executive Order 11988 - Flood Plain Management
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Additionally, all remedial action plans that involve the off site transport
for disposal would be managed in a manner consistent with 10 CFR Part 262,
including disposal at a RCRA approved facility.
4.7.5 Land Ban Requirements
Waste banned pursuant to the Hazardous and Solid Waste Amendments of 1984
(HSWA) cannot be placed in or on the land unless they have been first treated
to levels achieving by best demonstrated available technology (BDAT) for each
hazardous constituent in the waste. "Placement" triggers the land disposal
requirements and this only occurs when disposal occurs. Therefore, for
placement to occur, hazardous waste must be picked-up and moved across the
boundary of RCRA "unit area of contamination". Applying this definition to
the Brio/DOP sites, it is clear that "placement" does nst. occur when waste is
consolidated within an area of contamination, capped in place (including
grading prior to capping) or treated in-situ.
Therefore, since the Brio/DOP sites are each considered an "area of
contamination", for the reasons discussed above, "placement" does not occur
during any of the proposed remedial actions. Therefore, the land disposal
requirement is not "applicable" nor is it considered "relevant and
•
appropriate".
4.8 SUMMARY OF DETAILED ANALYSIS
4.8.1 Introduction
At this stage, remedial investigations and endangerment assessment of the
Brio/DOP site have been completed. Utilizing data developed in the RI and
SRI, the EA concluded that existing conditions at the Brio/DOP site do not in
and of themselves represent unacceptable risks to public health and the
environment. The EA further concluded that exposure scenarios reflecting
reasonably anticipated future changes to site conditions can be developed
which, were they to occur, would result in unacceptable risks to huamn health
and the environment. The identified areas containing materials that eiceed
the cleanup levels developed in the EA include materials and soils in Pits B,
E, J, Q and H/V. The exposures of concern include long term inhalation of
volatilized compound from these areas or direct ingestion of these affected
soils and materials.
4-147
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To remediate these affected areas, four surviving remedial action plans were M
refined in the beginning of this chapter (Section 1.3). Each plan was then ,
evaluated in relation to its technical feasibility (Section 4.4),
effectiveness in achieving health and environmental goals (Section 4.5), cost
(Section 4.6} and regulatory compliance (Section 4.7). The purpose of this
section is to summarize the results of these earlier analyses.
4.8.2 Cap and Cover
• Technical Evaluation - Stabilization followed by cap
and cover is a feasible and commonly practiced remedial
approach. It is applicable, practical and proven.
Some long term monitoring and maintenance of cap
conditions would be required.
• Public Health/Environmental Evaluation - Stabilization,
cap and cover and venting will isolate affected soils
from human contact. Cap and cover in combination with
the site management plan will minimize the potential
for migration via infiltration or runoff. Cap and
cover in combination with long term venting system will
eliminate potential air emissions.
• Regulatory Compliance - Cap and cover complies with all
legally applicable or relevant and appropriate federal
and state standards, requirements, criteria or
limitations.
• Cost - Total cost of cap and cover is $13,481,000. Net
present cost of cap and cover is $11,700,000. Cap and
cover is the most cost effective remedial action plan.
4-48
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H.8.3 Vault
• Technical Evaluation - The vault is a feasible and
readily constructable remedial approach. Equipment
manpower and materials for vault construction are
readily available. Some uncertainty regarding the
effectiveness of stabilization remains. Some long-term
maintenance would be required.
• Public Health/Environmental Evaluation -Stabilization
and vaulting of affected soils and materials will
isolate the materials from direct human contact. Vault
construction in combination with the site management
plan will minimize the potential for migration via
infiltration or runoff. The secure cap and cover
installed on the vault will eliminate potential air
emissions.
• Regulatory Compliance - Stabilization and vaulting of
affected soils and materials complies with all legally
applicable or relevant and appropriate federal and
state standards, requirements, criteria or limitations.
• Cost - Total vault costs are $20,871,000. Net present
costs of the vault are $17,300,000.
.8. U Biological Treatment
Technical Evaluation - Biological destruction of
organic compounds is applicable, practical, and
proven, field testing on site specific materials has
yielded further positive results for degradation of
PNAs and removal of volatiles. Basic process
configurations (solid or aqueous phase) are easily
constructable and implementable.
Public Health/Environmental Evaluation - Biological
treatment of affected soils and materials will
significantly reduce constituent concentrations for
both PNAs and volatiles. This destructive technology
will result in the production of soils that can be
backfilled to the pit areas with no need for -further
treatment effectively eliminating the ingestion and
runoff issues. Cap and cover on other site areas will
further isolate materials from potential contact or
transport.
Regulatory Compliance - Biological treatment complies
with all legally applicable or relevant and appropriate
federal and state standards, requirements, criteria or
limitations. Further substantial reductions in
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mobility, toxicity and volume of affected soils and
materials are achieved.
Cost - Total costs for biological treatment are
$22,956,000 (aqueous phase) and $22,981,000 (solid
phase). Net present costs are $19,920,000 (aqueous
phase) and $19,930,000 (solid phase).
H.8.5 Incineration
Technical Evaluation • Destruction of organic compounds
through incineration is applicable and a proven
technology for remediation of affected soils and
materials. Field testing of high temperature
incineration on site specific soils indicated
successful destruction of organic constituents.
Mobile/transportable incinerators are available from
various vendors. Application of incineration, however,
will be more complex than other alternatives.
Public Health/Environmental Evaluation - Incineration
will eliminate potential public health/environmental
impacts by elimination of organic compounds in affected
soils and materials. Air emissions would be controlled
with Conventional scrubber technology. Constituent
destruction eliminates future concerns regarding
ingestion, inhalation and off site transport. Cap and
cover on other site areas will further isolate
materials on site from potential contact or transport.
Regulatory Compliance - Incineration complies with all
legally applicable or relevant and appropriate federal
and state standards, requirements, criteria or
limitations. Further, substantial reductions in
mobility, toxicity and volume of affected soils and
materials are achieved.
Cost - Total costs for incineration are $22,271,000
(Rotary Kiln) and $22,131,000 (Infrared). Net present
costs are $21,780,000 (Rotary Kiln) and $17,510,000
(Infrared).
J4.8.6 Comparative Evaluation
All remedial action plans are technically inplenentable and construetable.
Both aqueous phase and solid phase biological treatment systems will be more
complex to implement than the containment options (cap and cover and vault)
because of the fact that complete modular units are not available. However,
<*
4-50
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the process itself is not complex. All technologies are field-proven although
certainty concerning performance is variable.
All remedial action plans achieve compliance with the specifltd remedial
objectives. The containment options isolate affected materials and soils fro*
human contact. While subject to prior stabilization, affected soils and
materials remain on site in the cap and cover and vault alternatives. The
treatment alternatives (biological and incineration) reduce or destroy organic
constituents down to trace levels to the extent that future concerns regarding
inhalation, ingestion or off site transport are eliminated.
All remedial action plans achieve compliance will all legally applicable or
relevant and appropriate federal and state standards, requirements, criteria
or limitations. Both treatment options achieve an additional reduction in
mobility, toxicity and volume of affected soils and materials. —'
Cap and cover is the most cost effective containment options. The treatment
option costs are essentially equivalent given the accuracy of the cost
estimation.
Table 4-11 summarizes this comparison of alternatives.
BRO/FS-R3-SH
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APPENDIX D
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APPENDIX E
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RIMCO DISMANTLING 1331 t-omor, Suite U59
Houston, Texas 77010
713/739-0388
August 2, 1985
Brio Task-Force
0. £. Canschinietz
c/o Monsanto Company
P.O. Box 711
Alvin, Texas 77511
Gentlemen:
The following costs are for the cleaning and dismantling of the Brio Refinery inc. site as
requested by Mr. Donald E. Gonschinietz:
*
I A. $90,000.00 Flushing and Steam Cleaning Refiner/ Area.
18. $220,000.00 Dismantle Refinery Area.
• ?.;•
2A. $40,000.00 Flushing and Steam Cleaning Dixie Chemical Area.
2B. $60,000*00 Dismantle Dixie Chemical Area.
*' >
3, $50,000.00 Dismantle Site Building.
' e >
k. $38,000.00 All Other Equipment On Site.
5. $150,000.00 Remove All Concrete.
6. Revenue Shoring Plan 70% for Contractor
s 30% for Brio Task Force
7. Decontamination Work: Cost Plus
10% Overhead
20% Profit *
Thank you for the opportunity to estimate this work. •
•
Very truly yours,
J. R. Brown
JRB:oh
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ft
APPENDIX F
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fll 4€3 5233 F.01
-• •' ~ ~ ,—
TEXAS WATER COMMISStjM*. ?G p Is
Paul Hopkins. Chairman
John O. Howthins, Commissioner
B. J. Wynn*. Ill, Commission?!
Allen H<*ink«. Fxci uiivc Dirci ice
March 29, 1988
J. D. Head, Genwol Countel
Mklwcl £. Field. Chief Examiner
Karen A. Phillip*. Chef Clerk
Allyn M. Davis, Ph.D., Director
Hazardous Waste Management Division
U.S. Environmental Protection Agency
Region Vi
1445 Ross Avenue
Dallas, Texas 75202-2733
Re: Dixie Oil Processors site
Draft Record- of Decision
Dear Dr. Davis:
We have reviewed the proposed Record of Decision (ROD) for the
Dixie Oil Processors site, we have no objection to the selected
remedy as described in the draft ROD of March 21, 1988. The
selected remedy requires a limited action/monitoring remedy as
described under the "no action" alternative.
Sincerely,
Allen P. Beinke
Executive Director
AGLM-'.Y
DALLAS, TEXAS
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