United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R06-88/034
June1988
Superfund
Record of Decision
North Cavalcade, TX
*AILAS
UBMi
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50372-101 .
1 REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R06-88/034
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
North Cavalcade, TX
,cst Remedial Action - Final
Juthor(s)
3. Recipient's Accession No.
5. Report Date
06/28/88
8. Performing Organization Rept. No
9. Performing Organization Name and Address
10. Proiect/Task/Work Unit No.
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
11. ContracUC) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
1C. Abstract (Limit: 200 words)
The 21-acre North Cavalcade site is located in northeast Houston, Texas. The
surrounding areas are a mixture of residential, commercial, and industrial properties.
Surface water is drained by three stormwater drainage ditches, one of which flows into
Hunting Bayou, a limited aquatic habitat as classified by Texas Water Quality
Standards. The site was developed in 1946 when Houston Creosoting Company, Inc. (HCCI)
^tablished creosote wood preserving operations. Around 1955, HCCI added
tachlorophenol (PCP) wood preservation services and other support facilities. Wood
^serving operations ceased in 1961, and the property was sold in 1964. Subsequent
property owners divided the site into smaller tracts and sold them to a succession of
owners. There has been no industrial activity at this site since 1964. Between
September 1985 and November 1987, EPA sampled all environmental media and found PAHs,
VOCs, and components of creosote in soil, ground water, and sediments. The area of soil
contamination corresponds to where creosote was historically stored, and the point of
entry for the contaminants into the ground water. The plume of contamination currently
covers approximately 4 acres. Creosote components were found in drainage ditch
sediments probably as a result of rainfall runoff during the time of historical
operations. The primary contaminants of concerning affecting the ground water, soils,
and sediments include: VOCs, benzene, toluene, xylene, and PAHs.
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
North Cavalcade, TX
First Remedial Action - Final
Contaminated Media: gw, sediments, soil
' VOCs (benzene, toluene, xylene)
c. COSATI Field/Group
liability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
51
22. Price
(S«« ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R06-88/034
North Cavalcade, TX
First Remedial Action - Final
16. ABSTRACT (continued)
The selected remedial action for this site includes: in-situ biological treatment of
22,300 yd^ of soil (optimum method will be determined after pilot testing); ground
water pump and treatment of 5,600,000 gallons using oil/water separation and carbon
adsorption with re-injection into the aquifer or, if necessary to maintain the water
balance, discharge into an onsite drainage ditch which discharges into Hunting Bayou;
and offsite incineration of all non-aqueous phase liquids (NAPLs) separated out from the
ground water. The estimated present worth cost for this remedial action is $4,210,000.
There is no O&M associated with this remedy.
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3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
v
\ _S REGION VI
*' *"0" 1445 ROSS AVENUE, SUITE 1200
DALLAS,TEXAS 75202
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
North Cavalcade Street site, Houston, Texas
STATEMENT OF PURPOSE
This decision document presents the selected remedial action for the North
Cavalcade Street site in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980, as amended by the Superfund
Amendments and Reauthorization Act of 1986 and, the National Oil and Hazardous
Substances Pollution Contingency Plan, 40 CFR Part 300, November 20, 1985.
The State of Texas (through the Texas Water Commission) has been briefed.on
the methods of technology and degree of treatment stated-by the Record of
decision.
STATEMENT OF BASIS
This decision is based upon the administrative record for the North Cavalcade
Street site. The attached index identifies the items which comprise the
administrative record.
DESCRIPTION OF THE REMEDY
The selected remedy will treat the health- and environment-threatening
contamination resulting from historical wood preserving operations at the
site. Upon review of the information contained in the administrative
record, EPA has decided that oil/water separation and carbon absorption
of groundwater and biological treatment of contaminated soils best fulfills
the statutory selection criteria. The following is a brief summary of the
proposed remedy:
Contaminated surficial soils - Treat onsite using biological treatment to
a level of 1 ppm of carcinogenic polynuclear aromatic hydrocarbons. In-
place treatment is preferred, hut the actual method will be selected from
the results of pilot testing during the Remedial Design.
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Contaminated groundwater - Extract and treat onsite using oil/water
separation and carbon absorption until all non-aqueous phase liquids
(NAPLs) are completely removed and benzene concentrations do not exceed
5 ug/1; incinerate the NAPLs offsite.
EPA will later decide the optimal means for remediating contamination from
polychlorinated biphenyls in the drainage ditch on the eastern boundary of
the site.
DECLARATION
The selected remedy is protective of human health and the environment, .
attains Federal and State requirements that are applicable or relevant and
appropriate, and is cost-effective. This remedy satisfies the preference
for treatment that reduces toxicity, mobility or volume as a principal
element. Finally, it is determined that this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent
praticable.
Date Robert E. Layton Jr., P.E.
Regional Administrator
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NORTH CAVALCADE STREET
Record of Decision Concurrences
The North Cavalcade Street Record of Decision has been reviewed and I concur;
ATTyn M. Dtvis, Director
Hazardous Waste Management Division (6H)
Robert E. Hannesschla
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
NORTH CAVALCADE STREET SITE
HOUSTON, TEXAS
JUNE 1988
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION VI, DALLAS, TEXAS
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TABLE Q£ CONTENTS
Ease
1. SITE LOCATION AND DESCRIPTION , 1
2. SITE HISTORY
2. l Previous Site Use 1
2.2 Geology and Hydrogeology 4
2.3 Remedial Investigation Results 4
2.4 Potential Impacts on Human Health
and Environment 8
3. ENFORCEMENT 10
4. COMMUNITY RELATIONS HISTORY 10
5. ALTERNATIVES EVALUATION
5.1 Evaluation Criteria 13
5.2 Description of Alternatives 16
5.3 Evaluation of Alternatives 18
6. SELECTED REMEDY
6.1 Description of the Remedy 23
6.2 Statuatory Determinations 24
6. 3 Future Actions 27
7. APPENDICES
A Responsiveness Summary
B Applicable or Relevant and Appropriate Requirements
C State of Texas Concurrence
D Index to the Administrative Record
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LIST OF FIGURES
Page
1 Site Location Map 2
2 Composite of Historical and Current Site Features 3
3 Generalized soil Profile 5
4 Surficial Soils Requiring Remediation 11
5 Ground Water Requiring Remediation 12
LIST QF TABLES
Page
1 Soil Contaminant Concentrations 6
2 Ground Water Contaminant Concentrations 7
3 Comparison of Remedial Alternatives 19
4 summary of Remedial Alternative costs 22
11
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1. SITE LOCATION AND DESCRIPTION
The North Cavalcade Street site is located in northeast Houston,
Texas about one mile southwest of the intersection of Interstate
Loop 610 and U.S. Route 59 (Figure 1). The site boundaries are
Loop 610 to the north, Cavalcade Street to the south, and the
Missouri and Pacific railroad lines to the east and west. The
site is triangular in shape with a base of approximately 600
feet, an apex of 3,000 feet, and an area of 21 acres.
The site is generally flat with several small mounds and
depressions. It is drained by three stormwater drainage ditches.
Two of these flank the site on the east and west sides, and drain
water to the third ditch which bisects the site into northern and
southern sections. The third ditch drains into a flood control
ditch which discharges into Hunting Bayou, a tributary of the
Houston Ship Channel. Hunting Bayou is currently classified in
the Texas water quality standards as a limited .aquatic habitat.
The site is now used by two commercial enterprises which have
erected two buildings on the southern part of the site. The
remainder of the site is not currently used. The surrounding
areas are residential, commercial, and industrial properties.
The nearest residential area, an old low-income neighborhood, is
directly to the west. Commercial properties are located along
the major thoroughfares as well as onsite.
2. SITE HISTORY
2.1 PREVIOUS SITE USE
The North Cavalcade Street site was not developed until Mr. Leon
Aron acquired the site in 1946 and established on it a small wood
preserving business, Houston Creosoting Company, Inc. (HCCI).
The HCCI business initially included creosote wood preserving
operations. In about 1955, HCCI added pentachlorophenol (PCP)
wood preservation services and other support facilities.
In 1961, the East End Bank of Houston foreclosed on the property
and wood preserving operations ceased. In 1964, the bank sold
the property to the Monroe Ferrell Concrete Pipe company. There
has been no industrial activity since 1964.
Subsequent property owners divided the site into smaller tracts
and sold them to a succession of owners. The property is now
owned by two companies and two individuals. The Great Southern
Life Insurance Company owns 1.6 acres in the southwest corner of
the site and has constructed a building. The Coastal Casting
Company owns two tracts consisting of 4.7 acres in the southern
area of the site; the company built a building used for engine
repair upon the westernmost tract. These tracts encompass the
operations and waste pit areas of the old wood preserving facil-
ity. Two other tracts are owned by R. D. Eichenour (3.9 acres)
and A. D. Dover :. ) acres), and represent the remainder of the
site. Figure 2 shows the current and historical site features.
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NORTH
CAVALCADE
SITE
lCOLLINGSWORTH
\WCODY
PARK
MAJOR
BUSINESS
DISTRICT
DRAINAGE
SITE LOCATION MAP
CAMP DRESSER & MCKEE INC.
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2,2 GEOLOGY AND HYDRQGEQLOGY
The North Cavalcade Street site is in the southeast Texas Coastal
Plain. This region is underlain with Holocene and Pleistocene
deposits to a depth of roughly 2400 feet. The aquifers used to
supply water for domestic, industrial and agricultural purposes
are the Lower Chicot and Evangeline, both confined aquifers iso-
lated from surface recharge. Public water supply wells are
screened in the Evangeline Aquifer at depths greater than 600
feet. Industrial water users have wells screened in both aqui-
fers at depths ranging from 50 to 576 feet.
The site-specific geology of the upper 50 feet is shown in
Figure 3. It consists of four distinct layers:
Stratum Depth (ft) Description
I 0-5 Sandy silt and sandy clay
II 5-12 Soft to very stiff sandy clay and
clayey sand
III 12-26 Medium dense to dense fine sand
IV 26-80 Very stiff to hard clay and silty clay
with sand and silt layers
The fine sand in Stratum II is the principal water bearing unit
at the North Cavalcade Street site. This unit is not currently
used as a source of water within Houston because the water yield
is low. The potentiometric surface developed during the Remedial
Investigation shows that the groundwater flow is toward the west
and is recharged by the ditches crossing the site.
2.3 REMEDIAL INVESTIGATION RESULTS
The U. S. Environmental Protection Agency (USEPA) sampled five
different types of environmental media at the North Cavalcade
Street site between September 1985 and November 1987. These
included air, surface water, sediments, soils, and groundwater.
The samples collected during this period were analyzed for toxic
substances characteristic of wood preserving sites.
The USEPA found polynuclear aromatic hydrocarbons (PAHs) and
volatiles (benzene, toluene, and xylenes) in soils, groundwater,
and sediments at levels above those natural to this area on the
southern 10 acres of the site. These compounds are components of
creosote, one of the wood preserving mixtures used at the site.
The other wood preserving chemical used at this site, pentachlor-
ophenol, was not found. Inorganic metals were infrequently found
at levels above background. Tables 1 and 2 show the maximum
concentrations of analyzed compounds in soils and groundwater and
their frequency of detection above background levels.
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TABLE 1
SOIL CONTAMINANT CONCENTRATIONS
Contaminant
Number of Detections*"*
Above Below
10 feet 10 feet
Arsenic 0
Cadmium 0
Chromium 0
Copper 0
Lead 0
Zinc 0
Benzene
Toleune
Xylenes
Pentachlorophenol
2-Methylnaphthalene
Naphthalene 16
Acenaphthylene 7
Acenaphthene
Fluorene
Phenanthrene 19
Anthracene
Fluoranthene 18
Pyrene
Benzo(a)anthracene 12
Chrysene 13
Benzo(b)fluoranthene 12
Benzo(k)fluoranthene
Benzo(a)pyrene 7
Idenod ,2,3-cd)pyrene 4
Total PAHs
Total Carcinogenic PAHs
0
0
2
3
4
1
4
27
7
0
18
19
3
14
16
14
13
14
10
9
8
8
7
2
Maximum Concentration^2'
Above
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4
2
5
feet
nd<3)
nd
nd
nd
nd
nd
na<4)
na
na
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na
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38
na
na
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na
830
na
95
112
201
na
34
88
,563
407
Below
10 feet
nd
nd
70
41
27
132
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TABLE 2
GROUNDWATER CONTAMINANT CONCENTRATIONS
Contaminant
Arsenic
Cadmium
Chromium
Copper
Lead
Zinc
Benzene
Ethylbenzene
Toluene
Xylenes
Pentachlorophenol
Number of
Detections1
1
0
0
0
0
0
4
2
3
3
0
'
Maximum
Concentration
Federal and
2) State Standards(3
2-Methylnaphthalene 2
Dibenzofuran 3
Naphthalene 4
Acenaphthylene 4
Acenaphthene 6
Fluorene 4
Phenanthrene 3
Anthracene 3
Fluoranthene 3
Pyrene 4
Benzo(g,h,ijperylene 0
Benzo(a)anthracene 2
Chrysene 2
Benzo(b)fluoranthene 2
Benzo(k) fluoranthene 2
Benzo(a)pyrene 2
Idenod ,2,3-cd)pyrene 0
Dibenzo(a,h)anthracene 0
Total PAHs
Total Carcinogenic PAHs
nd
nd
nd
nd
79
79
620
280
nd
14,000
8,900
39,000
460
18,000
14,000
32,000
5,000
16,000
7,300
nd
2,300
2,000
2,000
730
560
nd
nd
147,800
4,960
50
10
50
1000
50
5000
5
680
2000
440
220
0.03
(1)
18 total wells
( 2 \
1 ' units of micrograms per liter (ug/1)
lowest of final and proposed drinking water and ambient water
quality standards (10 5 risk level), units of ug/1
*4) nd = not detected above background concentration,
Background = the 95th percentile of groundwater in the
northern part of the site and off-site
beyond the extent of the contaminant plume.
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The contamination in soil and the upper groundwater unit
describes the way in which historical operations contributed to
the contamination. USEPA first found creosote-type contaminants
in surficial soil in two areas corresponding to the historical
operation area and creosote lagoon; these areas cover approxi-
mately l acre. These data show that creosote stored in these
areas was allowed to seep into the soil and thereby became the
source of further contamination, The surficial soil is a sandy
clay which allows a pathway for vertical migration. The creosote
became adsorbed onto the soils until they were saturated. At
that point, the creosote entered the groundwater in the surface
aquifer.
The'surface aquifer is a layer of sand which provides a pathway
for further migration. As in the surficial soil, the creosote
became adsorbed onto the sand until the sand was saturated. The
creosote then encountered a hard clay below the aquifer. Also,
the compounds which comprise creosote became partially dissolved
and were transported westward with the groundwater flow. The
volatile compounds such as benzene are the more soluble; these
traveled the farthest. The dissolved contaminants in the ground-
water now form a plume covering approximately 4 acres.
As stated above, the creosote encountered a layer of hard clay
below the surface aquifer and spread along the top of the clay to
cover an area of approximately 6 acres. The contamination
in this clay layer consists of both soil with adsorbed PAHs and a
non-aqueous phase liquid (NAPL) characteristic of denatured creo-
sote. The clay layer in general retards further vertical migra-
tion. The permeability of this layer is reportedin other geo-
logical investigations of this area as roughly 10~9 cm/sec.
USEPA also found creosote-type contaminants in the sediments of
ditches draining the site. The concentrations of PAH compounds
in the sediments ranged from undetected to 93 ppm. This contami-
nation probably resulted from rainfall runoff during the time of
historical operations or oil spills along the railroad tracks.
In addition, sediment samples in one isolated area near the rail-
road track on the east side of the site showed contamination from
polychlorinated biphenyls (PCBs). PCBs are not used in wood
preserving operations. The cause of this contamination appears
to be a spill resulting from railroad activity. USEPA has re-
cently gathered data to better define the area, and will address
remediation of the PCBs later.
The analyses of air and £:.ainage ditch water showed no measurable
contamination.
2.4 POTENTIAL IMPACTS QN. HUMAN HEALTH AND ENVIRONMENT
Based on the information gathered from the site, USEPA has found
no current exposure to local residents or onsite workers. The
principal exposure pathways through which humans might poten-
tially become exposed to contaminants in the future are:
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o inadvertent ingestion and direct contact with surficial
soils, and inhalation of dust and volatile chemicals by
utility workers in trenches or construction workers in
excavations;
o inadvertent ingestion and direct contact with surficial
soils by children if the site is ever developed for
residential purposes;
o direct contact with drainage ditch sediments by utility
workers; and
o ingestion of shallow groundwater if water supply wells are
ever installed onsite.
The exposure to site contaminants is of concern because many of
the chemicals are carcinogens (ie. benzene and benzo(a)pyrene) or
are otherwise toxic to humans (xylenes and toluene). For ground-
water, arsenic, benzene, and carcinogenic PAHs concentrations
exceed Federal regulations and criteria for drinking water (see
Table 2). USEPA assessed the above pathways and contaminant con-
centrations with relation to risks to human health if no remedial
action is taken. These risks are shown below as the aggregate
risk to each receptor group from all site contaminants. The
first three receptor groups are exposed to direct contact with
soils; the last group with groundwater. These riskr, are upper
bound estimates of effects on human health; the true risks are
most likely lower and may be zero.
Receptor Group
Utility Workers
Construction Workers
Future Residents
Groundwater Users
Noncarcinpgenic
Hazard Index
(Target = 1)
Average Maximum
0.04 18
0.01 8
<0.001 <0.001
0.06
Additional
Risk of Cancer
Average Maximum
3xlO~6 7xlO~4
2xlO~6 3xlO~4
2xlO~5 lxlO~4
9x10
-5
USEPA concluded from the risk assessment that adverse public
health or environmental hazards could result if no action was
taken to prevent exposure to contaminants found at the site. The
principal exposure pathways leading to these riskr are those
involving surficial soils and groundwater; sediments posed an
additional risk of cancer of only 1x10" . USEPA determined that
to protect the public from adverse effects to health, surficial
soil and groundwater will be cleaned as follows:
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Surficial Ground
Contaminant goils Water
Carcinogenic PAHs i ppm not detected
Benzene 0.04 ppm 5 ug/1
The remedial level for soils was selected to prevent againct an
additional risk of cancer from exposure to soils of greater than
1 in 100,000 (10_^) and also ensure against any non-carcinogenic
hazards. The 10 5 cancer risk level was selected as appropriate
for a commercial site where only a few people may ever become
exposed. The remedial level will also assure that creosote based
compounds will not continue to leach into the groundwater.
The remedial level for volatiles in groundwater was selected to
comply with the Federal drinking water standard for benzene which
is a relevant and appropriate requirement (see Appendix B for the
list of ARARs). The remedial level for carcinogenic PAHs was
selected to assure that, in conjunction with the level for vola-
tiles, the overall risk to potential consumers of groundwater
will be less than 10 5. A remedial level for arsenic was not
developed because arsenic was only found with the free phase
creosote in one well. Collection and treatment of groundwater
to attain the benzene level would collect the free phase and
remove the arsenic.
From the Remedial Investigation results, approximately 22,300
cubic yards of soil above 10 feet in depth and 5.6 million
gallons of groundwater in the upper aquifer exceed these levels.
Figures 4 and 5 show the areas of surficial soil and groundwater
where remedial levels are exceeded.
3.
USEPA identified four potentially responsible parties (PP.Ps) in
the initial stages of the Remedial Investigation. USEP? 11
continue its enforcement activities and send a Special Nc .:ce
letter to the PRPs before the initiation of the remedial design.
Should the PRPs decline to conduct future remedial activities,
USEPA will provide funding for these activities, but will retain
its right to seek cost recovery for all USEPA-funded response
actions from the PRPs. USEPA will also investigate the liability
of other parties who may have contributed to the contamination
during the time when the Houston creosoting Company was oper-
ating.
4. COMMUNITY RELATIONS HISTORY
In October 1984, USEPA proposed to add the North Cavalcade Street
site to the National Priorities List. USEPA approved funds in the
spring of 1985 to conduct a Remedial Investigation and Feasibil-
ity Study at the site.
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USEPA held the first community meeting on September 11, 1985, to
discuss the reasons for listing the site on the NPL and to pre-
sent the schedule for the site investigation. Fact sheets were
periodically mailed to local residents and interested parties to
describe the field activities.
On April 18, 1988, USEPA announced, through a press release, the
completion of the site investigation studies on the North
Cavalcade site. The announcement also advised the public that
USEPA would accept comments on the proposed remedy for the site
from Kay 1 through May 31, 1988, and that the Agency would hold a
public meeting on May 11, 1988. USEPA prepared a fact sheet
describing various alternatives evaluated and the proposed remed-
ial plan; this was mailed to interested citizens on April 15,
1988. USEPA also met informally on May 5, 1988, with the local
city councilman's staff and representatives of onsite businesses.
The public meeting was held on May 11, 1988, at the Lindale Park
Civic Club in Houston, Texas. Approximately 15 people attended.
The Responsiveness Summary in Appendix A lists the public
response to the alternatives proposed by USEPA at this meeting.
5. ALTERNATIVE EVALUATION
5.1 EVALUATION CRITERIA
OSWER Directive 9355.0-21 prescribes nine factors which USEPA
must consider in selecting a remedy for a Superfund site. These
factors address the specific requirements of Section I21(b)(l) of
SARA. These nine factors are listed below:
1. Consistency with Other Environmental Laws
In determining appropriate remedial actions at Superfund
sites, USEPA must consider the requirements of other Fed-
eral and State environmental laws, as well as CERCLA as
amended by SARA. Primary consideration is given to attain-
ing applicable or relevant and appropriate Federal and
State public health and environmental laws, regulations and
standards (ARARs). Not all Federal and State environmental
laws and regulations are applicable to each Superfund
remedial action.
2. Reduction of Toxicitv. Mobility or Volume
USEPA must assesc the degree to which remedial alternatives
employ treatment that reduces toxicity, mobility or vol-
ume. The relevant factors include:
o The treatment processes the proposed solutions use and
the materials they treat;
o the amount of contaminated materials destroyed or
treated;
13
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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 after
considering the persistence, toxicity, mobility, =md
propensity for bioaccumulation of such hazardous
substances and their constituents.
3. Short-term Effectiveness
USEPA must assess the short-term effectiveness of an alter-
native by considering the following:
o Magnitude of reduction of existing risks; and
o probable short-term risks to the community, workers, or
the environment during the implementation of an alter-
native, including potential threats associated with exca-
vation, transportation, and redisposal or containment.
4. Long-term Effectiveness and Permanence
USEPA must assess for each alternative the long-term effec-
tiveness and permanence it affords along with the degree
of certainty that the remedy will prove succtcsxul. The
relevant factors include:
o Magnitude of residual risks in terms of amounts and
concentrations of wastes remaining following implemen-
tation of a remedial action, considering the persis-
tence, toxicity, mobility and propensity for bioaccum-
ulation of such hazardous substances and their consti-
tuents ;
o type and degree of long-term management required,
including monitoring and operation and maintenance;
o potential for exposure of human and environmental recep-
tors 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 institu-
tional controls, including uncertainties associated with
the land disposal of untreated wastes and residuals; and
o potential need for replacement of the remedy.
5. Implementabilitv
USEPA must assess the ease or difficulty of implementing
the alternatives by considering the following factors:
14
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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 a permit for
Superfund actions);
o availability of necessary equipment and specialists; and
o available capacity and location of needed treatment,
storage and disposal services.
6. Costs
USEPA must assess the following types of costs:
o Capital costs;
o operation and maintenance costs;
o net present value of capital and operation and mainte-
nance costs; and
o potential future remedial action costs.
7. Community Acceptance
USEPA must assess the concerns of the community including:
o Components of remedial alternatives that the community
supports;
o features of the alternatives about which the coirinity
has reservations; and
o elements of the alternatives which the community
strongly opposes.
8. State Acceptance
USEPA must assess the concerns of the State government
which, for this site, is represented by the Texas Water
Commission. This assessment includes:
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.
15
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9. Overall Protection of Human Health and the Environment
Following the analysis of the remedial options against
individual evaluation criteria, USEPA must also assess
whether the remedial alternatives provide adequate protec-
tion of human health and the environment. USEPA is also
directed by the Superfund law (SARA) to prefer solutions
that use treatment to permanently remove contaminants from
the environment. Offsite transport and disposal without
treatment is the least-preferred option when practicable
treatment technologies are available.
5.2 DESCRIPTION Q£ ALTERNATIVES
In conformance with the National Contingency Plan (NCP), USEPA
screened initial remedial approaches to determine which might be
appropriate for this site. The Feasibility Study describes the
details of this evaluation. From these possible remedies, four
were chosen for detailed evaluation under the remedy selection
criteria outlined above. One other alternative. No Action, was
also evaluated to comply with the requirements of the NCP.
Except for the No Action alternative, all alternatives require
collection and treatment of contaminants in groundwater. Ground-
water will be collected and treated. A maximum of 38 collection
wells and 44 recharge wells will be installed in the surface
aquifer to the depth where the non-aqueous phase liquids (NAPLs)
reside. The extracted groundwater will be treated by an oil-
water separator to remove the non-aqueous phase liquids followed
by a carbon adsorption system to remove trace organics. Part of
the treated groundwater will then be re-injected into the forma-
tion to aid groundwater recovery; the remaining treated ground-
water will be disposed of directly into Hunting Bayou to the east
of the site. The recovered NAPLs will be sent offsite to be
burned; the spent activated carbon will be regenerated offsite.
Alternative 1 - J}o_ Action; This alternative consists of long-
term groundwater monitoring and deed restrictions. Five site
monitoring wells will be monitored. In addition, the deeds for
the property will be amended to restrict any future land use from
those activities which would disturb the soil. The approximate
cost of this action is $307,000.
Alternative 2. - Onsite Landfill; This remedy represents con-
tainment of contaminated surficial soil in an onsite landfill.
A landfill will be designed in accordance with Federal require-
ments and constructed in the south end of the site. Clean soil
removed during the construction will be stockpiled for later use
as fill. After the landfill has been constructed, the surficial
soil will be excavated, mixed with fly ash if wet, and placed
into the landfii: , T^e stockpiled clean soil will be used to
fill in the excavation. After all contaminated soil has been
removed, the landfill will be capped according to Federal
requirements, and the disturbed site areas will be revegetated.
16
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A fence will be erected to prevent access to the landfill area.
In addition, the deeds for the property will be amended to
restrict any future land use to those activities which do not
disturb the soil. Finally, four monitoring wells will be
installed and monitored to ensure that the landfill remains
intact. The estimated cost of tnis alternative is $4.0 million;
it will require about 2 years to complete.
Alternative 2. Onsite Incineration; This remedy represents
complete treatment of contaminated surficial soil by incinera-
tion. The soils will be thermally treated in a mobile inciner-
ator equipped with appropriate air pollution control devices.
The components of the incinerator will be shipped to the site and
erected adjacent to the contaminated soil area. The incinerator
will then be tested with small volumes of soil to ensure that the
incineration will comply with Federal and State requirements.
When the incinerator is ready for full operation, the soil will
be excavated and fed into the incinerator. After incineration,
the treated soil will be stockpiled temporarily and returned to
the excavation if it can be delisted. Otherwise, the treated
soil will be disposed of in a hazardous waste landfill. Finally,
disturbed areas will be revegetated. The estimated cost of this
is $10.5 million; it will require about 2 years to complete.
Alternative 4 - In-situ Soil Flushing; This remedy represents
complete treatment of contaminated surficial soil by remobilizing
the organic contaminants and treating them in the groundwater.
Surfactants will be added to the treated groundwater and re-
injected into the formation to desorb the contaminants from soil
and allow them to migrate into the- groundwater. The groundwater
treatment system would then remove the contaminants from the
groundwater. The surfactants will continue to be added until
test borings show no residual contamination in the soil and the
groundwater is completely remediated. The estimated cost for
this alternative is $4.8 million; it will require approximately 3
to 5 years to complete.
Alternative 5. - Biological Treatment; This remedy represents
complete treatment of contaminated surficial soil by accelerating
the natural biological degradation of the organic contaminants.
Nutrients and oxygen will be added to treated groundwater and
mixed with the contaminated soils. Mixing will be accomplished
either through percolating the water through perforated pipes,
injecting the water into the soil, or by mechanically mixing the
water with the soil. This approach enhances growth of indigenous
microorganisms in the soil and increases the rate of bacterial
degradation. The nutrients and oxygen w"11 continue to be added
until soil samples show no residual contamination and the ground-
water is completely remediated. The estimated cost for this
alternative is $4.2 million; it will require about 3 years to
complete.
17
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5.3 EVALUATION OF ALTERNATIVES
USEPA has assessed the degree to which each remedial alternative
meets the nine selection criteria; Table 3 summarizes this
assessment. The following values were used to compare the remedy
selection criteria:
«+ Alternative would greatly exceed a selection criterion
compared to other alternatives.
* Alternative would exceed a criterion compared to other
alternatives.
0 Alternative can meet the selection criterion.
Special efforts will be necessary in the design of the
remedy to meet the selection criterion.
Great difficulty would result in achieving a selection
criterion as compared to other alternatives.
The rationale for the ratings assigned in this table follows:
1. Consistency ffitfr Other Environmenta3, Laws (i.e. meets or
exceeds applicable, or relevant and appropriate Federal and
State requirements). Appendix B discusses the compliance
of each remedial alternative with all applicable or rele-
vant and appropriate environmental laws.
No Action is rated as "" because it violates the intent
of SARA Section 121 regarding the selection of a remedy and
does not comply with the National Contingency Plan provi-
sions to respond to a threat of release.
Onsite Landfill is rated as "-" because it cannot comply
with the proposed requirements for PAHs in creosote sludge
under the Land Disposal Restrictions (40 CFR Part 268).
The contaminated soil originated from creosote sludge.
These proposed regulations require treatment of individual
PAHs to 3 ppm. Existing PAH concentrations exceed this
level; therefore, treatment of the contaminated soil is
required before disposal. The regulations are not yet
promulgated, but should be by November 1988.
Onsite Incineration, Soil FLushing, and Biological Treat-
ment are rated as "0" since they can be designed to meet
any ARARs. Specifically, for the Land Disposal Restric-
tions, these three alternatives include treatment methods
which provide sufficient performance to meet the proposed
requirements for PAHs in creosote sludge.
18
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TABLE 3
COMPARISON OF REMEDIAL ALTERATIVES
NORTH CAVALCADE STREET SITE
1
COMPLY WITH OTHER
ENVIRONMENTAL LAWS
REDUCES TOXICITY
REDUCES MOBILITY
REDUCES VOLUME
SHORT-TERM
EFFECTIVENESS
LONG-TERM
EFFECTIVENESS
IMPLEMENTABILITY
COST(1)
PROTECTION OF HUMAN
^^ HEALTH AND THE
^P ENVI RONMENT
NO
ACTION
I J
r i
_
-
-
-
+
0.3
ONSITE
LANDFILL
L _
|- -
_
0
-
-
+
4.0
ONSITE
INCIN-
ERATOR
L
r
0
+
+
+
+
10.5
IN-SITU
SOIL
FLUSHING
I J
r A
0
0
o
o
+
0
4.8
- I 0 0
ONSITE
BIOLOGICAL
TREATMENT
i
r
0
0
o
0
0
o
-
4.2
0
I
\ ~* ~ ~ /
Symbols:
++ = Compared to others, alternative greatly exceeds criterion.
+ = Compared to others, alternative exceeds criterion.
0 = Alternative can be designed to meet the criterion.
Notes:
Compared to others, alternative will need special efforts
to meet the criterion.
Compired to others, alternative would have the most
difficulty in meeting the criterion.
Present worth in units of million dollars, includes anticipated
replacement costs, see Table 4 for cost breakdown.
19
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2. Reduction of Toxicityf Mobility and} Volume
No Action is rated as "-" because it does not reduce toxic-
ity, mobility or volume. However, natural biodegradation
will eventually reduce some contamination.
Onsite Landfill is rated as "-" for toxicity and volume for
the same reasons as for No Action, and as "0" for mobility
since the leachate from the contaminated surficial soils
would be contained.
Soil Flushing and Biological Treatment are rated as "0"
because the organic contaminants would be removed from the
soil down to the remedial action level, but probably not
any further.
Onsite Incineration is rated as "+" since it would com-
pletely destroy the organic compounds.
3. Short-Term Effectiveness
All action alternatives would complete the remediation
within 3 years. Therefore, there is no difference between
the alternatives on the basis of completion time.
No Action is rated as "-" because the health threat would
not be abated.
Onsite Landfill and Onsite Incineration are rated as "-"
because excavation and materials handling could pose addi-
tional risks to the health of workers at onsite businesses
through inhalation of volatilized contaminants.
Biological Treatment is rated as "0" because workers at
onsite businesses would not be exposed to volatil d con-
taminants during installation if in-situ treatment -s shown
to be possible during the design. In the event that the
pilot tests show that mechanical mixing by augering or
partial excavation is needed, the open soil area could be
covered with an inflatable dome.
Soil Flushing is rated as "+" because the in-situ design
would prevent workers at onsite businesses from being
exposed to volatilized contaminants during installation of
the remedy.
4. Long-Term Effectiveness and permanence
No Action is rated as "" because the potential human
health and environmental risks, as previously stated, would
not be abated.
Onsite Landfill is rated as "-" because it would involve
long-term monitoring, maintenance, and possible replacement
of monitoring wells, fence, or liner.
20
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Soil Flushing and Biological Treatment are rated as "0"
since these remedies would destroy health-threatening con-
tamination at the site.
Onsite Incineration is rated as "+" because it would remove
all contamination at the site.
5. ImplementrgM ]"»t-Y
Onsite Incineration, Soil Flushing, and Biological Treat-
ment are rated as "-" because they require a significant
amount of testing and coordination with State agencies
before startup. Pilot studies of all three alternatives
would be required to optimize the performance. In addi-
tion, the Texas Air Control Board would need to be con-
sulted in the design and operation of an incerator.
No Action and Onsite Landfill are rated as "+" because
they can be easily -implemented.
6. Cost
Table 4 lists the estimated costs for each remedial action
alternative. This table includes capital, operation and
maintenance, present worth, and replacement costs. The No
Action alternative has the lowest present worth cost of all
alternatives followed by Onsite Landfill, Biological
Treatment, Soil Flushing, and Onsite Incineration in
increasing order of cost. The three treatment alternatives
(Biological Treatment, Soil Flushing, and Onsite Incinera-
tion) have no long-term operation and maintenance costs
beyond 5 years.
Replacement costs are those for replacing elements needed
for long-term operation. This cost is greatest for the
Onsite Landfill because the integrity of the landfill liner
cannot be guaranteed beyond 30 years. The three treatment
alternatives require no replacement costs because there is
no long-term operation.
7. Community Acceptance
The public at the public meeting demonstrated a preference
for remediation of the site. The people attending the
meeting had no preference for any alternative other than to
note some concern about risks to health of local residents
during remediation. USEPA explained that the proposed
remedy, Biological Treatment, would be designed to minimize
any air emission which could adversely affect human health.
21
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TABLE 4
SUMMARY OF REMEDIAL ALTERNATIVE COSTS
NORTH CAVALCADE STREET SITE
(1)
i
ILINE ITEM
1 - - - -i
(CAPITAL
I Soil Treatment
I Groundwater Treat.
1 Site Overhead
j Total Capital Cost
j
| OPERATION/MAINTENANCE
I Annual
Present Worth*2'
REPLACEMENT
Total
Present Worth*2'
TOTAL PRESENT WORTH* 5)
NO
ACTION
i
r
0
25
*&
25
25
279
'
25(3)
3
307
ONSITE
LANDFILL
i j
r J
1,024
971
1.342
3,337
53
584
1,000(4)
99
4,020
ONSITE
INCIN-
ERATOR
i j
r 1
6,090
971
.3.479
10,540
0
0
0
0
10,540
IN-SITU
SOIL
FLUSHING
I j
r
1,915
971
Ir924
4,810
0
o
0
0
4,810
\
ONSITE
BIOLOGICAL
TREATMENT
L _
1,475
971
1.764
4,210
0
0
0
0
4,210
(1* Units of thousand dollars; uncertainty of -30% to +50%
*2^ 30 years at 8% interest
*3^ Based on 5 wells, 30 year life
*4) Based on 4 wells and a landfill liner, 30 year life
(5) Sum of capital, present worth 0/M, and present worth replacement.
22
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8. State Acceptance
The Texas Water Commission (TWO, the State regulatory
agency for CERCLA sites, was briefed on the remedial
alternatives on May 4, 1988. The TWC notified USEPA by
letter that the TWC had no objections to the selected rem-
edy (see Appendix C).
9. Overall Protection of Human Health and the Environment
No Action is rated as "" because it does not provide
adequate protection from the potential risks involved with
leaving untreated wastes onsite.
Onsite Landfill is rated as "-" because it only protects
health by containing the soils. There is some potential
for exposure to soil or release to groundwater in the
future if the landfill fails and, most importantly, it is
the least-preferred alternative where practicable treatment
technologies are available. However, the ground collection
and treatment part of the alternative will provide full
protection in this, and all action alternatives, by
removing and treating the groundwater contaminants.
Onsite Incineration, Soil Flushing, and Biological Treat-
ment are rated as "0" because they destroy the organics,
and they provide protection of human health and the envir-
onment .
6. SELECTED REMEDY
6.1 DESCRIPTION QF_ TJLE REMEDY
USEPA believes that carbon adsorption of groundwater with bio-
logical treatment of contaminated surficial soil (Alternative 5)
best fulfills the statuatory and selection criteria as compared
to other solutions. The optimum method for implementing this
alternative will be determined after pilot testing during the
Remedial Design phase. USEPA prefers that in-situ application of
nutrients and oxygen to contaminated soils be used if found to be
practicable.
Soils contaminated with carcinogenic PAHs in excess of 1 ppm will
be treated to this level using biological treatment. The 1 ppm
level was selected to prevent an additional risk of cancer of 10"
from direct contact witv. soils and also to prevent continued leach-
ing of creosote compounds into the groundwater. There are approx-
imately 22,300 cubic yards of surficial soils above 10 feet of
depth needing remediation. The remediation should be complete
approximately 3 years after construction. After treatment, the
soils will remain onsite.
23
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Groundwater contaminated with benzene in excess of 5 ug/1 and
detectable carcinogenic PAHs will be treated to these levels
using oil/water separation and activated carbon filtration. The
benzene level is the Federal drinking water standard (MCL); both
levels together prevent an additional risk of cancer of 10~5 from
ingestion of groundwater. There are approximately 5.6 million
gallons of groundwater in the upper aquifer needing rsmediation.
The remediation should be complete approximately 2 years after
construction due to the number of wells to be installed. After
treatment, the groundwater will be re-injected into the aquifer,
or, if necessary to maintain the water balance, some may be dis-
charged into an onsite drainage ditch which, in turn, discharges
into Hunting Bayou.
6.2 STATUATQRY DETERMINATIQNS
Section 121 of SARA requires the selected remedy to be protective
of human health and the environment, be cost effective, use per-
manent solutions and alternative treatment or resource recovery
technologies to the maximum extent possible, be consistent with
other environmental laws, and have a preference for treatment
which significantly reduces the toxicity or mobility of the haz-
ardous substances as a principle element. USEPA believes that
the selected remedy best fulfills the statuatory and selection
criteria as compared to the other solutions evaluated herein.
1. Protective of Human Health and Environment
The selected remedy will reduce soil and groundwater con-
taminations to prevent an additional risk .of cancer of 10~ ,
prevent any non-carcinogenic hazards, and prevent continued
leaching of creosote compounds from soils into groundwater.
It does this by treatment; therefore, the risks will not
increase in the future due to a failure of the remedy.
2. Cost Effective
The selected remedy offers the lowest cost of all the
treatment alternatives. Compared to other treatment al-
ternatives, it is equally effective in removing contami-
nants and is also equally implementable. It can offer
little short-term risk to onsite workers during remedia-
tion by minimizing excavation and thereby the potential for
volatile emissions.
3. Permanent Solutions to Maximum Extent Pp5sib1<3
The selected remedy permanently removes contaminants from
soil by biological degradation and from groundwater by
activated carbon adsorption. As a result, no long term
monitoring or maintenance will be necessary.
24
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4. Consistent with Other Environmental Laws
The selected remedy can be designed to attain other envir-
onmental laws. The laws applicable or relevant and appro-
priate to CERCLA activities are called ARARs. Appendix B
lists all the ARARs which were initially identified for
this site in the Feasibility Study. The specific ARARs for
the selected remedy are described below:
National Primary Drinking Water Standards; Groundwater
treatment performance will attain all final Maximum Con-
taminant Levels (MCL). Table 2 listed the MCLs for contam-
inants- found on the site.
National Secondary Drinking Water Standards: Groundwater
treatment performance will attain all final secondary
drinking water standards. Table 2 listed these for contam-
inants found on the site.
Maximum Contaminant Level Goals (MCLGs); This is not an
ARAR, but is another factor to be considered. Groundwater
treatment performance will attain the MCLGs for those con-
taminants where the MCLs have yet to be promulgated.
Underground Injection Control Regulations: The wells
through which treated groundwater will be re-injected into
the aquifer will be designed to comply with the Class V
well regulations.
Ambient Water Quality Criteria; Groundwater treatment
performance will comply with these criteria if, to maintain
a proper water balance, treated water needs to be dis-
charged to the drainage ditch leading into Hunting Bayou.
National Pollutant Discharge Elimination System; Gr^und-
water treatment performance will comply with Best £- iable
Technology and water quality standards if treated water
needs to be discharged to the drainage ditch leading into
Hunting Bayou. A permit will not be required because the
point of discharge will be onsite.
Occupational Safety and Health Act; Remedial action will
be conducted consistent with the OSHA regulations for
personnel protection and safety.
Hazardous Materials Transportation Act; Transport of
recovered creosote offsite will require handling in a
manner consistent with this act.
RCRA Standards Applicable to Generators of Hazardous Waste;
Transport of recovered creosote offsite for incineration
will require manifesting.
25
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RCRA Standards Applicable to Transporters of Hazardous Waste:
Transport of recovered creosote offsite for incineration
will require manifesting and handling consistent with this
regulation.
Releases from Solid Waste Managsment Units (40 CFR 264(F));
Groundwater not recovered will comply with the levels
required by this regulation.
Tanks (40 CFR 264(J)): Tanks temporarily storing recovered
creosote will be designed to comply with this regulation.
Land Disposal Restrictions; Treatment performance for
soils will comply with the proposed regulations for creo-
sote sludge (K001 waste). Recovered creosote will need to
be sent to an off-site incinerator which can achieve the
required performance.
Texas Allowable Limits of Metals in Drinking Wa^ter;
Groundwater treatment performance will attain these levels.
Texas Water Qualify Standards for Surface Waters: Ground-
water treatment performance will comply with water quality
standards if water needs to be discharged to the drainage
ditch leading into Hunting Bayou.
Texas Prohibition of Air Contaminants which Adversely
Affect Human Health; soil disturbance will be minimized
during remediation to assure compliance with these regula-
tions. If necessary, an inflatable dome can be constructed
over the soil areas to contain any release. Air will be
monitored during remediation to observe compliance.
Texas Storage of Volatile Organic Compounds; Tanks tempor-
arily storing recovered creosote will be designed to comply
with this regulation.
Texas Oil/Water Separators; The oil/water separator in the
groundwater treatment system will be designed to control
volatile emissions in accordance with this regulation.
Texas Vacuum Producing Systems; The groundwater recovery
system uses a vacuum. This system will be designed to
prevent emissions requiring incineration under this regu-
lation.
5. Preference for Treatment as a. Principle Element
The selected remedy uses treatment for the complete remedi-
ation of each contaminated medium (soils and groundwater).
Biological payment will detoxicify benzene and carcino-
genic PAHs ^ soils by bacterial degradation. Oil/water
separation and activated carbon adsorption will remove
contaminants from groundwater.
26
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Other alternatives were not selected for the following reasons:
No Action; This alternative does not protect human health
or the environment.
Onsite Landfill; This alternative does not permanently
reducs the toxicity or volume of the waste. The long-tarm
effectiveness of this alternative is not as reliable as the
selected remedy. Furthermore, this alternative may require
replacement of wells, fences, or liners in the future.
Onsite Incineration; This alternative is protective of
human health and the environment, but the costs are more
than double those of the selected remedy. Furthermore,
this alternative could result in short-term air emissions
during construction which could pose a threat to the health
of workers at onsite businesses. This was one concern
voiced by the public during the public meeting.
In-situ Soil Flushing; This alternative is also protective
of human health and the environment, but at a slightly
higher cost than the selected remedy.
6.3 FUTURE ACTIONS
The selected remedy offers a high degree of permanence; there-
fore, future remedial actions should not be necessary after com-
pletion of the remedy. The proposed schedule for remediation is
as follows:
Action Date
Approve Remedial Action by Signing the June 1988
Record of Decision
Complete Enforcement Negotiations August 1988
Obligate Funds to Begin Remedial Design September 1988
Complete Remedial Design May 1990
Obligate Funds to Begin Remedial Action June 1990
Complete Remedial Action December 1994
27
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APPENDIX A
RESPONSIVENESS SUMMARY
-------
North Cavalcade
Community Relations Responsiveness Summary
This Community Relations Responsiveness Summary has b«*en prepared
to provide written responses to comments submitted regarding the
proposed plan of action at the North Cavalcade Superfund site.
The summary is divided into two sections:
Section I: Background of Community Involvement and Concerns.
This section provides a brief history of community interest
and concerns raised during the remedial planning activities at
the North Cavalcade site.
Section II: Summary of Manor Comments Received. The comments
are summarized and USEPA's responses are provided.
I. Background of Community Involvement and Concerns
Reported citizen concern regarding this site has been minimal.
No known public interest groups have been formed, and concern
about the site is very limited. Media coverage of the site has
been scarce.
In August 1985, USEPA held a meeting to announce ^e rtdrt of the
remedial investigation. Thirty-one citizens attende'd; however,
few attendees lived in the immediate area. Progress reports were
issued in April and July of 1987.. These two updates did not
generate any comments, questions or concerns.
II. Summary of Manor Comments Received
The press release and Proposed Plan fact sheet announcing the
public comment period and public meeting were released on April
18, 1988. The comment period began on May 1 and ended on May 31,
1988. The public meeting was held with area residents and local
officicls on May 11, 1988, at the Lindale Park Civic Club. The
purpose of this meeting was to explain the results of the
Remedial Investigation and to outline the various alternatives
presented in the Feasibility Study. Fifteen citizens attended
the meeting, and four people made oral statements or asked ques-
tions. No additional written comments or questions were received
from citizens.
Overall, the residents and local officials do not oppose the
proposed plan. During the public comment period, there were
comments and questions regarding the following:
Comment »l; Will the health assessment describe the danger of
exposure to the residents?
USEPA Response: Yes, the health assessment will examine the
various pathways of exposure and the types of contaminants
involved.
A-l
-------
Comment »2; It is difficult to comment on the Proposed Plan
when the health assessment has not been completed.
USEPA Response; The Feasibility Study does address some of the
health impacts related to the proposed remedy. The principle
concern during remedial action would be air emissions from
disturbing the soil. Potential exposure during the construction
of the remedy would be virtually limited to the workers.
Specific measures to eliminate the exposure will be included in
the actual design of the remedy. In addition, the air will be
monitored during all activity on the site so that USEPA will know
if any emission occurs and can take appropriate action.
Comment #3: When will you make the decision on the remedy?
USEEA. Response; The decision will be made before June 30, 1988.
Comment *4; What other alternatives could be considered for the
groundwater? Why is there just the one remedy?
USEPA Response; There are other ways to address a groundwater
problem, but they are not feasible for this site. USEPA con-
sidered a number of technologies in the initial analysis of
alternatives in the Feasibility Study. They were eliminated
based on construction problems (need to cross railroad tracks),
or would be ten times more expensive and would not provide any
additional benefit to, or protection of, public health.
Comment t5; What is the opinion of the Texas Water Commission?
USEPA Response: The Texas Water Commission has indicated that it
supports bioremediation. However, a treatability study would be
needed to prove that the bioremediation process would be an
effective remedy.
Comment #$; When would the treatability studies begin?
USEPA Response; The treatability studies will be conducted as
part of the Remedial Design. The Remedial Design is scheduled to
begin after August 1988 and to be completed by May 1990. The
public will be notified, in advance, of the start of the treata-
bility study.
Comment #7; The meeting room location is not very close to the
site and the Proposed Plan was not sent to the community.
USEPA Response: The meeting room was selected because it was
near the site, available on the appropriate date, and provided
the needed space at a reasonable cost. The room had been used
for an earlier meeting on this site, and no opposition was
expressed. Any future meetings will be held at the Ryan Civic
Center.
Information on the site, and announcement of the meeting, was
mailed to all individuals who expressed an interest in the site.
Both major Houston newspapers ran articles on the proposed remedy
and meeting. Specific information on the Proposed Plan was also
mailed to the Ryrn Civic Center.
A-2
-------
Comment #7; Why are you cleaning up this site where there are
other sites on Collingsworth, Cavalcade, and Crosstimbers which
are much worse?
USEPA Response; The creosote site on Collingsworth is the South
Cavalcade Superfund site. We are working on a possible remedy
fox that site. We expect to have a proposed plan ready in August
and will hold a public meeting and comment period at that time.
The information on the North Cavalcade site was available a few
months earlier than the South Cavalcade site.
The lead battery facility on Jensen and Cavalcade is being
investigated by the Texas Water Commission.
The Crosstimbers site is being investigated by USEPA to determine
if it could be a future Superfund site.
Comment; t9; Is creosote the only problem at this site?
USEPA Response: Yes, for the site. We did, however, find poly-
chlorinated biphenyls (PCS) on the border of the site. This
appears to have been caused by a spill from the railroad. We
will be looking into this in the near future.
comment 10; Will the proposed remedy be as safe in the future as
the other remedies?
USEPA Response; Yes, it will.
A-3
-------
APPENDIX B
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
-------
APPENDIX B: APPLICABLE OR RELEVANT AND APPROPRIATE REQUIRMENTS
Section 121(d)(2) of CERCLA as amended in 1986 by SARA requires
tn?*- the selected remedy attain requirements adopted under Fed-
eral and state environmental laws. These requirements are called
"ARARs" which means "applicable or relevant and appropriate
requirements".
The Feasibility Study for the North Cavalcade site included a
review of these laws, and identified those which could be ARARs
based on the types of wastes at the site, the types of remedial
actions contemplated, and the site location. This appendix lists
all the laws which the Feasibility Study identified as potential
ARARs for this site, and indicates whether each of the final
remedial alternatives can comply with the laws.
SAFE DRINKING WATER ACT
National Primary Drinking Water Standards: Establishes health
based standards for public water systems (maximum contaminant
levels) ; an ARAR for all alternatives because the groundwater
contamination can reach an aquifer used as a drinking water
supply.
National Secondary Drinking Water Standards: Establishes
aesthetic based standards for public water systems (secondary
maximum contaminant levels); an ARAR for all alternatives
because the groundwater contamination can reach an aquifer used
as a drinking water supply.
Maximum Contaminant Level Goals: Establishes drinking water
quality goals set at levels of no known or anticipated adverse
health effects, with an adequate margin of safety; not an ARAR
but a factor to be considered for those contaminants where the
Maximum Contaminant Levels have yet to be promulgated.
Underground Injection Control Regulations: Provides for protec-
tion of underground sources of drinking water; an ARAR for all
alternatives because the treated groundwater will be re-injected,
CLEAN WATER ACT
Water Quality Criteria: Sets criteria for water quality based on
toxicity to aquatic organisms and human health; an ARAR for
disposal of water into Hunting Bayou from the groundwater
treatment system.
National Pollutant Discharge Elimination System: Requires treat-
ment performance for the discharge of pollutants for any point
source into waters of the United States; an ARAR for disposal
of water into Hunting Bayou from the groundwater treatment
system.
R-l
-------
National Pretreatment standards: Sets standards to control
pollutants which pass through or interfere with treatment pro-
cesses in public treatment works or which may contaminate sew-
age sludge; not an ARAR because disposal from the groundwater
treatment system will not be to the Houston sewage treatment
plant.
OCCUPATIONAL SAFETY AND HEALTH ACT: Regulates worker health and
safety; an ARAR for all site activities.
HAZARDOUS MATERIALS TRANSPORTATION ACT: Regulates transportation
of hazardous materials; an ARAR for the offsite transport of
recovered oil and creosote for burning; applies to the ground-
water treatment system.
EXECUTIVE ORDER ON FLOODPLAIN MANAGEMENT: Requires Federal agen-
cies to avoid to the extent possible, the adverse impacts asso-
ciated with the destruction, or loss of wetlands and to avoid
support of new construction in wetlands if a practical alterna-
tive exists; not an ARAR because there will be no site activity
within the floodplain.
SOLID WASTE DISPOSAL ACT
Standards Applicable to Generators of Hazardous Waste: Estab-
lishes standards for generators of hazardous wastes; an ARAR
for all alternatives except No Action.
Standards Applicable to Transporters of Hazardous Waste: Estab-
lishes standards which apply to transporters of hazardous waste
within the U.S. if the transportation requires a manifest under
40 C.F.R. Part 262; an ARAR for the offsite transport of
recovered oil and creosote generated from the groundwater
treatment system.
Standards for Owners and Operators of Hazardous Waste Treatment,
Storage, and Disposal Facilities: Establishes minimum national
standards which define the acceptable management of hazardous
wastes for owners and operators of facilities which treat,
store or dispose of hazardous wastes. Each subpart follows:
General Facility Standards (Subpart B): Sets siting require-
ments for floodplains; not an ARAR because nr .reatment or
disposal unit will be located in a floodplain.
Releases from Solid Waste Management Units (Subpart F): Sets
groundwater remediation levels; an ARAR for all alterna-
tives.
Closure and Post-Closure (Subpart G): Sets standards for main-
tenance of disposal sites; an ARAR only for the landfill
alternative.
B-2
-------
Financial Requirements (Subpart H): Sets financial require-
ments for responsible parties maintaining a disposal site;
not an ARAR because only an administrative requirment.
Use and Management of Containers (Subpart I): Sets require-
ments for storage of wastes in containers; not an ARAR
because containers will not be used in any alternative.
Tanks (Subpart J): Sets requirements for storage of wastes in
tanks; an ARAR for the groundwater treatment system.
Surface Impoundments (Subpart K): Sets requirements for dis-
posal or treatment of wastes in surface impoundments; not an
ARAR because no alternative uses surface impoundments.
Waste Piles (Subpart L): Sets requirements for storing and
treating wastes in piles; an ARAR for Landfill and Inciner-
ation which requires storing wastes in piles prior to dis-
posal or treatment.
Land Treatment (Subpart M): Sets requirements for treatment of
wastes by placing them in land; not an ARAR because no
alternative uses this method.
Landfills (Subpart N): Sets requirements for disposal of
wastes in landfills; an ARAR only for the Landfill
alternative.
Incinerators (Subpart 0): Sets requirements for incineration
of wastes; an ARAR only for the Incineration alternative.
Land Disposal Restrictions: Establishes allowable concentration
levels for burial of hazardous wastes; an ARAR only if waste is
disposed or placed away from the present area of disposal, an
ARAR for soils for Landfill and Incineration, will be ~ ARAR
for soils for Biological Treatment pnly if the wastes mot be
treated in-place, an ARAR for all alternatives with respect to
incineration of the creosote collected from the groundwater.
TEXAS DEPARTMENT OF HEALTH
Allowable Limits of Metals in Drinking Water: Sets health-based
standards for public water systems; these set groundwater
remedial levels for all alternatives.
Location of Wells used for Drinking Water Supplies: Restricts
placement of drinking water wells; restricts location of solid
waste disposal sites; only an ARAR for those alternatives which
leave wastes in the ground.
TEXAS WATER COMMISSION
Water Quality Standards for Surface Waters: Prohibits point
source discharges which cause toxicity in natural streams;
these are an ARAR for all groundwater treatment alternatives.
B-3
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TEXAS AIR CONTROL BOARD
Prohibition of Air Contaminants which Adversely Effect Human
Health: Health-based standards for air; only an ARAR for those
alternatives which disturb the soil and may cause a release.
Control of Air Pollution from Visible Emissions and Particulate
Matter: Maximum allowable levels of particulates in air; an ARAR
for incinerators.
Storage of Volatile Organic Compounds: Regulates handling of
tanks containing volatiles; an ARAR for the groundwater
treatment system if recovered creosote is stored in a tank.
Oil/Water Separators: Controls volatile emissions from separ-
ators; an ARAR for the groundwater treatment system.
Vacuum Producing Systems: Requires incineration of emmissions
from vacuum producing systems; an ARAR for the groundwater
treatment system
C-4
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FEDERAL ARARS
k
^^tandard , Regui rement ,
Criteria, or Limitation
SAFE DRINKING WATER ACT
National Primary Drinking
Water Standards
(40 CFR Part 141)
National Secondary Drinking
Water Standards
(40 CFR Part 143)
Maximum Contaminant Level
Goals
Underground Injection
Remedial Alternative
No
Action
L
r
NO
NO
___
Control Regulations
(40 CFR Part 144-147)
_ -L J
T 1
CLEAN WATER ACT
Water Quality Criteria
^40 CFR Part 131)
'National Pollutant Dis-
charge Elimination System
(40 CFR Part 125)
National Pretreatment
Standards
(40 CFR Part 403)
Land- Incin- Soil
fill erator
i i
r t - -
YES YES
YES YES
YES
YES
YES
YES
YES
YES
_ i 1 ! _-
t t T 1
OCCUPATIONAL SAFETY AND
Flushing
YES
YES
YES
_ _ _.
r 1
YES
YES
Biological
Treatment
L -
r
YES
YES
YES
\
r
YES
YES
i
r T
YES YES YES
YES
HEALTH ACT
(29 USC 651-678)
_ _ i i _ i _.L -4-
_ -j. .j. _ .j. _-j- - t
HAZARDOUS MATERIALS TRANS-
PORTATION ACT
(49 CFR Part 107, 171-177)
EXECUTIVE ORDER ON
FLOODPLAIN MANAGEMENT
(Order No. 11,988)
YES
YES YES
YES
-4- 4-
r T T
1
NO = does not comply; YES = complies; = not an ARAR for this alternative
* Although not an ARAR, the MCLGs are other factors to be considered.
-------
FEDERAL ARARS continued
Remedial Alternative
Standard , Requi rement ,
Criteria, or Limitation
SOLID WASTE DISPOSAL ACT
Standards for Generators
of Hazardous Waste
(40 CFR Part 262)
Standards for Transporters
of Hazardous Waste
(40 CFR Part 263)
NO
Action
I
r
Land-
fill
I
r
YES
YES
Incin-
erator
i
r
YES
YES
Soil
Fiu.shina
I
"
YES
YES
| Biologica
1 Treatment
i _
f
I
1
| YES
1
1
1
| YES
1
1
1
Standards for Owners and
Operators of Hazardous
Waste Treatment, Storage,
and Disposal Facilities
General Facility Standards
(40 CFR Part 264 B)
Releases from Solid Waste
Management Units
(40 CFR Part 264 F)
Closure and Post-Closure
(40 CFR Part 264 G)
Financial Requirements
(40 CFR Part 264 H)
Use of Containers
(40 CFR Part 264 I)
Tanks
(40 CFR Part 264 J)
Surface Impoundments
(40 CFR Part 264 K)
Waste Piles
(40 CFR Part 264 L)
Land Treatment
(40 CFR Part 264 M)
Landfills
(40 CFR Part 264 N)
Incinerators
(40 CFR Part 264 0)
Land Disposal
(40 CFR Part 268)
NO
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
NO = does not comply; YES = complies; = not an ARAR for this alternative
-------
STATE OF TEXAS ARARS
-\
^^omulgated
^Kandard , Requi rement ,
Criteria, or Limitation
DEPARTMENT OF HEALTH
Allowable Limits of
Metals in Drinking Water
Location of Wells used
for Drinking Water
Supplies
_ _ ' i
1
WATER COMMISSION
Water Quality Standards
for Surface Waters
j
_ .j
AIR CONTROL BOARD
Prohibition of Air Con-
^^minants that Adversely
^Bfect Human Health
Control of Air Pollution
from Visible Emissions
and Particulate Matter
Storage of Volatile
Organic Compounds
Oil/Water Separators
Vacuum Producing Systems
Remedial Alternative
No
Action
i
r ~
NO
YES
r 1
j
r 1
Land-
fill
L
r
YES
YES
. _
r 1
YES
( ~ H
YES
.
"~
YES
YES
YES
Incin-
erator
L J
r 4
YES
___
._ _.
r 1
YES
r
YES
YES
YES
YES
YES
Soil
Flushing
L " .
r
YES
L _ J
r 1
YES
_ _ _
r 1
YES
YES
YES
Biological
Treatment
L
r
YES
.
r
YES
L
r
YES
YES
YES
YES
\ ___ __ /
NO = does not comply; YES = complies; = not an ARAR for this alternative
-------
APPENDIX C
STATE OF TEXAS CONCURRENCE
-------
XAS WATER COMMISSK
Paul Hopkins Chairman '* ' ' ' J. 0. Head. G*rera> Counw!
John O. Howchins, Commi5?.<...e, * ' .;. Mkha«l E. FteM, C .ief Examiner
B. J. Wynne, HI, CommiMinwr Karen A. Phillip*. C hief Clerk
Allen li»-mUtf. 1 >. v ..!,.» 1 ) , ,
June 27, 1988
Allyn M. Davis, PhD., Director
Hazardous Waste Management Division
U.S. Environmental Protection Agency
Region VI
1445 Rosa Avenue
Dallas, Texas 75202-2733
Ret North Cavalcade Street Superfund Site
Draft Record of Decision
Dear Dr. Davis:
We have reviewed the proposed Record of Decision (ROD) for the
North Cavalcade street Site. We have no objection to the
selected remedy as described in the draft ROD of June 16 1988.
The selected remedy requires biological treatment of con-.aminated
surficial soils with oil/water separation and carbon
adsorption treatment of contaminated groundwater.
Sincerely,
Ai:
Executive Director
130(57 Cat/it-: S'JM-. .7"tiN." < i ... ,-.-.- .Vi N.,.. !(^,,,/X,;i )[j;-i, Area C o ie 5 2/
-------
APPENDIX D
INDEX TO THE ADMINISTRATIVE RECORD
------- |