United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-88/03S
June 1988
Superfund
Record of Decision
Bailey Waste Disposal, TX
                  DALLAS, TEXAS

                    UBRMN

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  50272-101     	
  REPORT DOCUMENTATION
         PAGE
1. REPORT NO.
         EPA/ROD/R06-88/035
                                               3. Recipient's Accession No.
  4. Title and Subtitle
   SUPERFUND RECORD OF  DECISION
           Waste Disposal,  TX
          Remedial Action - Final
                                               5. Report Date
                                                    06/28/88
  7. Author(s)
                                                                        8. Performing Organization Rept. No
  9. Performing Organization Name and Address
                                                                        10. Project/Task/Work Unit No.
                                                                        11. Contract(C) or Grant(G) No.

                                                                        (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 & Period Covered

                                                    800/000
                                                                        14.
  IS. Supplementary Notes
  16. Abstract (Limit: 200 words)
      The Bailey Waste  Disposal site  is  an inactive  industrial waste facility located
   approximately 3 miles  southwest of Bridge City, Orange County,  Texas.  The site  is part
   of a  saltwater marshland near the  confluence of the Neckes River  and Sabine Lake,  and
   lies  within the 100-year floodplain.   The site occupies approximately 280 acres  and
   includes two rectangular ponds, A  and B, constructed by dredging  the marsh and piling
       sediments to  form  levees.  The ponds were constructed in the  mid-1950s as part of
       Bailey Fish Camp,  which operated  until the 1960s.  Industrial wastes, primarily
   organics, were disposed of along the  north and east margins of  Pond A during the 1950s
   and 1960s.  Four  separate areas of contamination  in the vicinity  of the ponds have been
   identified.  They include:  a waste channel, located north of Pond A that contains a
   minimum of 44,000 yd  of industrial waste and debris; an area east of Pond A, that
   contains 21,000 yd^  of municipal and  industrial waste; a drum disposal area south  of
   Pond  A, that contains  fifty-eight  corroded drums  with an estimated volume of 80  yd3 of
   industrial waste;  and  a series of  waste pits, north of Pond A and west of the waste
   channel, that contains 1900 yd^ of tar-like wastes.  The primary  contaminants of
   concern affecting the  sediments include:  VOCs including benzene  and toluene, aromatic
   and cnlorinated hydrocarbons, organics including  PAHs, and metals.
   (See  Attached Sheet)
 17. Document Analysis  a. Descriptors
   Record of Decision
   Bailey Waste Disposal,  TX
   First  Remedial Action  - Final
   Contaminated Media:-  sediments
                               or9anics  (PAHs), VOCs  (benzene, toluene)
       £ATI Field/Group
       lility Statement
                                                        19. Security Class (This Report)
                                                               None
                                                        20. Security Class (This Page)
                                                               None
                                                         21. No. of Pages
                                                                 62
                                                         22. Price
(See ANSI-Z39.18)
                                        See Instructions on Reverse
                                                                                 OPTIONAL FORM 272 (4-77)
                                                                                 (Formerly NTIS-35)
                                                                                 Department of Commerce

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    ROD/R06-88/035
     y waste Disposal, TX
    t Remedial Action - Final

16.  ABSTRACT (continued)


   The selected remedial action for this site includes:   relocation,  consolidation and
treatment of contaminated sediments and wastes using a solidification technique
developed during design followed by onsite disposal and capping of the residual matrix.
The estimated present worth for this remedial action is  $13,700,000.

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                                                                                 £-7
                             RECORD OF DECISION
SITE NAME AND LOCATION

Bailey Waste Disposal Site
Orange, Texas
STATEMENT OF BASIS AND PURPOSE

     This decision document presents the selected remedial action for the
Bailey Waste Disposal site in Orange, Texas, developed in accordance with
CERCLA, as amended by SARA, and the National Contingency Plan.  This
decision is based on the administrative record for this site.  The attached
index identifies the items comprising the administrative record upon which
the selection of the remedial action is based.

     The State of Texas has been consulted on the selected remedy and has
no objections.
DESCRIPTION OF THE SELECTED REMEDY

     The remedy addresses the environmental threat at the site by
consolidating and stabilizing the waste to prevent human contact and
future migration.  The components of the selected remedy include:

     o  Relocation of affected sediments from the marsh and drainage channel,
        as well as waste from the drum disposal area and pit A-3, to the
        Waste Channel; and

     o  stabilization of the Waste Channel and the Area East of Pond A
        using the technique developed during the remedial design.
DECLARATION

     The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant and
appropriate to this remedial action, and is cost-effective.  This remedy
satisfies the statutory preference for remedies employing treatment
that reduces mobility as a principal element.  Because this remedy will
result in hazardous substances remaining onsite, a review will be

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conducted within five years after commencement of remedial action and every
five years thereafter, to ensure that the remedy continues to provide
adequate protection of human health and the environment.
„
Date                                     Robert E. Layton y., P
                                         Regional Administrator
                                              \

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                                DECISION SUMMARY
                           BAILEY WASTE DISPOSAL SITE
                             ORANGE COUNTY, TEXAS


 I.  SITE LOCATION AND DESCRIPTION

     The Bailey Waste Disposal  Superfund Site is an inactive industrial  waste
     facility located approximately 3 miles southwest of Brrdge City, Orange
     County, Texas, at the north end of the Rainbow Bridge west of Texas
     State Highway 87 (Figure  1).  The site is connected to Highway 87 by a
     short bridge spanning a drainage channel adjacent to, and parallel  with,
     the highway.

     The site is part of a saltwater marshland near the confluence of the
     Neches River and Sabine Lake.  Two ponds were constructed on the property
     by dredging the marsh and  piling the sediments to form levees.  The
     industrial  wastes are located in pits along the levees.  The site,
     including the two rectangular ponds, occupies approximately 280 acres.


II.  SITE HISTORY AND ENFORCEMENT ACTIVITIES

     Two ponds,  A and B, were constructed in the mid-1950s as part of the
     Bailey Fish Camp.  The fish camp was active until the-1960s when it was
     destroyed by a hurricane which introduced saline waters into the ponds,
     killing the freshwater fish.

     Industrial  wastes, primarily organics, were disposed of along the north
     and east margins of Pond A during the 1950s and 1960s.  Both during
     industrial  waste disposal operations and following their cessation, the
     site was used to dispose of residential trash.

     In 1979, the Environmental Protection Agency (EPA) released a report
     which stated that industrial wastes were disposed of at the site.  The
     Texas Water Commission did a preliminary assessment of the site in
     1980.  In 1981 and 1982, Gulf States Utilities (landowner at that time)
     conducted an investigation to determine the dimensions and chemical
     characteristics of the waste pits.

     In October  1984, the site was proposed for the National Priorities  List
     (sites  which appear to present a significant risk to public health  or
     the environment).  In December 1984, the State of Texas entered into a
     Cooperative Agreement with EPA for a Remedial  Investigation (RI) and a
     Feasibility Study (FS). The total  funds awarded to the State for these

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      studies was $707,615.  The RI field work began in January of 1986.
      A final report for the RI was submitted in October 1987.

      The Potentially Responsible Parties (PRP) were offered the opportunity
      to perform the FS.  In October 1987, a Consent Order was signed allowing
      the Bailey Task Force (comprised of PRP's) to conduct the FS.  Further
      fieldwork to additionally characterize the site took place during the
      FS.  A final FS report, which provides a comparison of ..potential
      remedial alternatives, was submitted by the Bailey Task Force in March
      of 1988.
III.  COMMUNITY RELATIONS

      The Texas Water Commission (TWC) initiated the Remedial Investigation (RI)
      on the Bailey Uas.te Disposal  site in 1987.  Prior to initiation of the
      study, TWC held an informational meeting to inform local residents about
      the site history, the proposed studies andxthe timeframe involved in the
      Superfund process.  The study was completed in late 1987 and TWC held a
      public meeting on November 17, 1987, to discuss the results of the study.

      An Administrative Order was signed on October 11, 1987, with the Bailey
      Task Force, a group of potentially responsible parties (PRPs) to conduct
      the Feasibility Study (FS).  This study was completed in the Spring of
      1988.  On April 25, 1988,  EPA announced, via press releases, that the FS
      was available for review at local repositories and for public comment
      until May 24, 1988.  The press release also announced a public meeting
      on May 17 at the Holiday Inn, Port Arthur and was mailed to the site
      list.  EPA prepared a more detailed fact sheet describing the Superfund
      process, the background of the site, the alternatives considered, EPA's
      preferred remedy and the public involvement process.  This was also
      sent to the site mailing list.

      The public meeting began at 7:00 p.m. on May 24.   About 20 people attended
      the meeting.  Attendees did not wish to formally  comment on EPA's
      preferred alternative.  A  few questions arose about the time frame and
      and cost of the project.  The meeting adjourned at 7:25 p.m.


 IV.   SCOPE AND ROLE OF THE RESPONSE ACTION

      The environmental  threat at the site is degradation of existing
      conditions and subsequent  releases to the environment.  The remedial
      action goal  developed in the  Feasibility Study was to prevent a future
      release of contaminants from  the site into the surrounding surface
      waters.  The response action  must block or eliminate the pathway of a
      release from the site.

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V.  SITE CHARACTERISTICS

    GEOLOGY

    The site is directly underlain by fluvial, alluvial, and deltaic deposits
    consisting primarily of silty clay and clayey sand.  Based upon borings
    at the site, and along the adjacent highway,  the sedimentary sequence
    can be separated into four distinct units A,  B,  C,  D (Figure 2).
    The uppermost layer (Unit A) ranges in thickness from 18 to 37  feet  and
    consists primarily of soft clay.  The wastes  have beer, deposited in,  or
    on, Unit A.

    Underlying Unit A is a loose clayey sand, Unit B, which ranges  in  thick-
    ness from 15 to 23 feet. Units C  and D underlie  the less-consolidated
    alluvial sediments of Units A and B. Unit C  is a very stiff clay and
    Unit D is a compact clayey sand.   Unit D  is  generally encountered  at 80
    - 100 feet below the surface.  Because of "saltwater intrusion,  groundwater
    found in Units A through D is not a potential  source of drinking water.
    Two aquifers which have been developed for water supply, the Chicot  and
    the Evangeline, are identified in the site vicinity.  The Upper Chicot
    extends to 200 - 300 feet below sea level, and the  Lower Chicot is defined
    to 1200 feet.  The Evangeline is  located  below 1200 feet.  Approximately
    110 wells are located within a 3  mile radius  of  the site.  The  closest
    public water supply well is 1.5 miles northeast  of  the site and is 385
    feet deep.  The Bridge City wells are 2.6 miles  northeast and are  585
    feet deep.
    RI  RESULTS

    The Remedial  Investigation  (RI)  consisted  of  a surface and subsurface
    field  investigation  to assess  the  distribution of waste materials  and
    to  evaluate  the  potential  for  the  migration of chemical  constituents
    away from the waste  locations.  The  field  activities  included
    installation  of  monitoring  wells,  soil  borings,  and  biota sampling.
    Table  1 shows the  range of  analyzed  constituents for  various media.

    The site was  divided into  four major areas.   These areas are defined as
    the Waste Channel, Area East of  Pond A,  Drum  Disposal  Area, and  the
    waste  pits.   The areas are  geographically  distinct,  and to some  extent
    varied in the types  of wastes  present.   Figure 1 shows the four  areas and
    other  site  features.

    The Waste Channel  is located along the  north  side of  Pond A along  a
    levee  which  separates Pond  A from  the marsh.   Industrial  wastes  and
    debris are  visible over the majority of  the ground surface.  The waste
    is  generally  encountered within  2  feet  of  the surface  with an  average
    thickness of  5 feet  and a minimum  total  volume of 44,000 cubic yards.
    The major contaminants found were  ethylbenzene,  styrene, benzene,
    chlorinated  hydrocarbons and polynuclear aromatic hydrocarbons.

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MATERIAL TYPF
INFERRED TYPCAL AQU[FE
AG£ FORMATION DEPTH (FT.)
PLEISTOCENE I HOLOCENE (?) \ HOLOCENE
1 1
1 1
BEAUMONT FQRMATION \ ALLUVIUM (?) \ ALLUVIUM-
\ 1
1 1
09 ^i 
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      The Area East of Pond A separates Pond A from a drainage channel  that
      runs parallel to Highway 87.  Rubbery chunks of wastes are visible
      along the ground surface.  The northern portion of this area contains
      municipal wastes.  Where industrial wastes are present, they contain
      primarily aromatic volatile hydrocarbons and metals.  The average
      thickness of the waste is 4 feet with a minimum volume of 21,000
      cubic yards.

      The Drum Disposal Area is located south of Pond A and contains  fifty-aight
      corroded drums.  The drums are open and a black powdery carbon  material
      covers the ground surface.  The material contains low levels of organics
      with a minimum estimated volume of 80 cubic yards.

      The waste pits are located north of Pond A and west of the Waste  Channel.
      Four pits have been identified in this area, A-l, A-2, A-3,  and B.
      Only a few traces of tarry wastes were found in pits A-l, A-2 and A-3,
      however, Pit B was estimated to have 1900 cubic yards of tar-like wastes.
      Analysis of the wastes has shown aromatic hydrocarbons, substituted
      napthalene and PAH compounds.   Surface water samples were collected  from
      Pond A,  the waste pits, the drainage channel and the marsh.   Selenium
      was the  only constituent detected slightly above the primary drinking
      water standard.
 VI.   SUMMARY OF SITE RISKS

      In  order to evaluate endangerment, levels of contaminants  present  are
      compared to applicable or relevant and appropriate standards.   If  no
      standard exists then a risk estimate is developed based  on potential
      exposure scenarios.  Risk estimates had to be developed  because no
      standards exist for soil  contamination at this site.   Standards do exist
      for drinking water, however, drinking water is not currently impacted
      by  this site.

      A risk  assessment  was developed by first selecting indicator chemicals,
      then using toxicology data and exposure scenarios to  calculate  a risk
      level.   The exposure scenarios are derived by identifying  potential
      pathways and receptors for the contaminants.- The pathways considered
      were:

                o  Direct contact with the site;

                o  surface water contamination from site runoff;

                o  groundwater  contamination from leaching  of  site
,.                  contaminants; and

                o  consumption  of fish and other marine wildlife.

      A calculated risk  is presented as an upper bound lifetime  excess cancer
      risk. The actual  risk is  unlikely to be higher, and may  be as low  as

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       waste  may  he  conditioned  with  a  stabilizing  agent  to  ease  handling.
       After  the  wastes  have been  removed,  the  affected areas  would be filled
       and  revegetated.   The landfill would be  covered with  a  clay cap and
       liner.

       Alternative 5:  Offsite Landfill

       This alternative  consists of excavating  all  of the wastes  and trans-
       porting them  offsite  to an  authorized landfill for disposal.  A
       soil-cement wall  would be constructed as  described' for  Alternative 4
       to prevent instability problems  during excavation.  Transportation of the
       wastes would  be in 20 cubic yard  rolloff  boxes.  All  contaminated water
       will he transported off the site  for treatment or disposal at an authorized
       facility.

       Alternative 6:  On-Site Incineration,  On-Site Landfill  of  Ash

       This alternative  involves treatment  of alVwastes in  a  mobile rotary
     .  kiln incinerator  located on the  site.  The wastes would be excavated, as
       previously described  in Alternative  5, and conditioned  with a material
       such as sawdust to increase the BTU  value.   The wastes  would be
       transported directly  to the incinerator as they are excavated.  The
       residual ash will  be  45 percent of the original volume  of  the wastes
       and would be placed in an on-site landfill.  The on-site landfill
       would be constructed  as described in  Alternative 4.   Water entrapped
       in the wastes and in  Pit 8, would be  transported offsite for treatment
       or disposal at an authorized facility.

       Alternative 7:  On-Site Incineration,  Off-Site Landfill of Ash

       This alternative  is the same as Alternative  6, except the  residual ash
       would be accumulated  in 20 cubic yard  roll off boxes and transported to
       an off-site landfill   for disposal.


VIII.  ALTERNATIVES EVALUATION
       Evaluation Criteria

       Section 121(a) through (f) of the Superfund Amendments and Reauthor-
       ization Act contains factors which EPA must consider in selecting a remedy
       for a Superfund site.  These factors, as well as other criteria used
       during the evaluation of alternatives, are discussed below:

          1.  Consistency with Other Environmental Laws (ARARs)

              In determining appropriate remedial actions at Superfund sites,
              consideration must he given to the requirements of other Federal
              and State environmental laws.  Primary consideration is given to
              attaining applicable or relevant and appropriate Federal and
              State public health and environmental regulations and standards.
              Requirements under Federal and State laws that specifically

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    address the circumstance at a Superfund  site ara considered
   . applicable.  Relevant and appropriate requirements, while not
    applicable to a Superfund site, address  situations which are
    sufficiently similar to a site.

2.  Reduction of Toxicity, Mobility or Volume

    The degree to which alternatives employ  treatment that reduces
    toxicity, mobility, or volume must also  be assessed.  Relevant
    factors are:

    o  The treatment processes the remedies  employ and materials
       to be treated;

    o  the amount of hazardous 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, consider-
       ing the persistence, toxicity, mobility, and propensity
       for bioaccumulation of such hazardous substances and
       their constituents.

    EPA is also directed "by SARA to give preference to remedial
    actions that utilize treatment to remove contaminants from
    the environment.  Off-site transport and disposal without
    treatment is the least preferred option where practicable
    treatment technologies are available.

3,  Short-term Effectiveness

    The short-term effectiveness of alternatives must be assessed;
    considering appropriate factors among the following:

    o  Magnitude of reduction of existing risks;

    o  short term risks that might be posed to the community,
       workers, or the environment during implementation of an
       alternative including potential  threats to human health
       and the environment associated with transportation, and
       redisposal  or containment of treatment residuals; and

    o  time until  full  protection is achieved.

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      zero.  A target concentration or cleanup level would be calculated
      using a 10"'  (one in ten million) to 10"4 (one in ten thousand)
      lifetime cancer risk level.  The lifetime risk for the direct contact
      scenario for an adult exposed to the maximum concentrations of contami-
      nants found at the site is 9 x 10~6 and for a child it is 1.2 x 10"5.

      Existing site conditions could degrade through a flood or other natural
      occurrences, releasing the contaminants contained in the levees into the
      surrounding marsh.

                                                            /••
VII.  Description of Alternatives

      The Feasibility Study evaluated eight alternatives.  Alternative 2 and
      Alternative 3 were screened out during the FS process.

      Alternative 1:   No action

      This alternative would include construction and maintenance of additional
      fencing and implementation of institutional controls, such as deed
      restrictions on land use, to reduce access\o the property.

      Alternative 3:   Stabilization

      This alternative would stabilize the Waste Channel  and the Area
      East of Pond A  using the technique developed during the design.  The
      techniques  to be examined include:

           o  Inject  and mix reagents into the waste with a backhoe;
           o  pneumatically spread the reagents and mix with paddles;
           o  continuous feed, treat, and replace mixing plant; and
           o  excavate a small area, stockpile the waste, mix and replace.

      The affected sediments from the marsh and wastes from the Drum Disposal
      area and pit A-3 would be excavated and relocated to the Waste Channel.
      Berms would be  constructed around the Waste Channel  and the area east
      of Pond A to control  runoff of surface water during solidification.
      The solidification would involve mixing the wastes  with a reagent such
      as cement  and allowing the mixture to cure.  The processed mixture
      would reduce the mobility of the wastes and provide strength to support
      a  clay cap.  The cap  would consist of a flexible liner and a minimum of
      3  feet of  compacted clay.

      Alternative 4:   On-Site Landfill

      The on-site landfill  would be constructed in the southern portion of
      Pond B.  A  temporary  dike would first be erected in Pond B to segregate
      a  dry working area.  The sediments  in this area would be excavated to
      expose the  underlying clay layer.  A 3-foot-thick compacted clay liner
      will  he constructed on top of the clay layer followed by a flexible
   •   membrane liner  and a  leachate collection system.  The perimeter herm of
      the landfill  would he constructed in stages as waste is placed in the
      landfill.

      To avoid instability  problems during excavation of  the waste, a soil-
      cement .vail  would  he  constructed Around tie affected areas.  The wastes
      wou:j hs 2.xca-/ar.2d and trucked f.o the on-site landfill.  The excavated

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iste  may be conditioned with a stabilizing agent  to ease handling.
rter  the wastes have been removed, the affected areas would  be  filled
id  revegetated.  The landfill  would be covered with a clay cap  and
 ner.
 ternative 5:   Offsite Landfill
n's  alternative consists of excavating all  of  the  wastes  and trans-
irting  them offsite to an authorized landfill  for  disposal.  A         '
nl-cement  wall  would be constructed as described"  for  Alternative  4
i  prevent  instability problems during excavation.   Transportation  of the
tstes would be  in  20 cubic yard roll off boxes.  All  contaminated water
11  be  transported off the site for treatment  or disposal  at an authorized
Lcility.

ternative  6:   On-Site Incineration, On-Site Landfill  of  Ash
                                                                                   as
                                                                                   nt
                                          wastes  in  a  mobile  rotary
                                          wastes  would be  excavated, as
                                          conditioned  with a  material
                                           The wastes  would be
                                          they are excavated.  The
ris alternative  involves  treatment  of  all
In incinerator  located on  the  site.   The
•eviously  described  in Alternative  5,  and
ich as  sawdust to  increase  the  BTU  value.
•ansported directly  to the  incinerator as
(Sidual ash will he  45 percent  of the  original volume  of the wastes
id would be placed in an  on-site landfill.  The on-site landfill
luld be constructed  as described in Alternative 4.  Water entrapped
i the wastes  and in  Pit B,  would be transported offsite for treatment
• disposal  at an authorized facility.

ternative 7:  On-Site Incineration, Off-Site  Landfill of Ash

ITS alternative  is the same as  Alternative  6,  except the residual ash
iuld be accumulated  in 20 cubic yard rolloff boxes  and transported to
i off-site landfill  for disposal.
                                                                                    er-
TERNATIVES EVALUATION

'aluation Criteria

ction  121(a)  through  (f)  of  the  Superfund  Amendments  and  Reauthor-
:ation  Act contains  factors which EPA  must  consider  in selecting  a remedy
IP a Superfund site.  These factors, as  well  as other  criteria  used
iring the evaluation of  alternatives,  are discussed  below:

 1.  Consistency with Other  Environmental  Laws (ARARs)

     In determining appropriate  remedial actions  at Superfund  sites,
     consideration  must be given to the requirements  of other  Federal
     and State environmental  laws.  Primary  consideration  is given  to
     attaining applicable or relevant and  appropriate Federal  and
     State public health  and environmental  regulations and standards.
                s under Federal  and State  laws that specifically

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4.   Long-term Effectiveness

   .  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 amount  and con-
       centrations of waste  remaining  following  implementation of a
       remedial action,  considering the persistence,' toxicity,
       mobility,  and propensity to hioaccumulate of such hazardous
       substances and their  constituents;

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

     o  long-term  reliability of the engineering  and institutional
       controls,  including uncertainties associated with land
       disposal of untreated wastes andxresiduals.
5.  Implementability

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

    o  Degree of difficulty associated with constructing the
       technology;

    o  expected operational reliability of the technologies;

    o  need to coordinate with, and obtain, necessary approvals and
       permits from other offices and agencies;

    o  availability of necessary equipment and specialists; and

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

6.  Cost

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

    o  Capital cost;

    o  operational and maintenance costs;

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

    o  potential future remedial action costs.

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         7.   Community Acceptance

             This  assessment should look at:

             o  Components  of the alternatives  which  the community  supports;

             o  features  of the alternatives  about  which the  community has
                reservations; and
                                                            f
             o  elements  of the alternatives  which  the  community  strongly
                opposes.

         8.   State Acceptance

             Evaluation factors include  assessments of:

             o  Components  of the alternatives  which  the State  supports;

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

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

         9.   Overall Protection of Human Health and the Environment

             Following the  analyses of the remedial options against indi-
             vidual  evaluation criteria, the  alternatives are assessed
             from  the  standpoint of whether they provide adequate protection
             of  human  health and the environment considering  all  the
             criteria.
 IX.   Summary  of  the  Comparative Analysis  of Alternatives

      ALTERNATIVE 1

      The  remedial  investigation determined that  the groundwater  and  surface
      water  are not currently impacted by  the site.   Therefore, ARARs  for
      groundwater and surface water are not concerns.  No ARARs exist  at this
      site for contaminated soils,  so no chemical-specific ARARs  are  available.

      Alternative 1 does  not provide a reduction  of  toxicity,  mobility or
      volume.  No short-term risks  are associated with no action, however,
      this alternative does not provide long-term protection from release.
k>

      The  construction of additional fencing would not involve any implementa-
      tion problems.   The present worth of this alternative is $605,000.

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                                  10
 No  action  does  not  provide for overall  protection  of human  health  and
 the environment because  it does not  address  the  threat  of  release  from
 the site  into the  surrounding  environment.
 ALTERNATIVE  3

 Guidelines governing  capping  are  relevant  to  this  alternative.  The
 design  of the  cap would  meet  or exceed  the requirements*" for  cap
 permeability,  installation, maintenance and runoff control.  Stabilization
 of the  wastes  would reduce the mobility of the wastes with a slight
 increase in  the  volume.   Solidification reduces  the toxicity of the
 wastes  by decreasing  the  amount of  contaminants  that can  leach from the
 wastes'.

 Solidification may involve some excavation that  would expose the wastes
 to the  atmosphere.  To decrease the  potential for  adverse air emissions
 or problems  associated with surface  runoffv only small  areas will he
 excavated or open at  any  one  time.   With proper  maintainance, this
 alternative  would provide long-term  protection.  The timefrane for
 implementation of this alternative  is 14 months.

 Stabilization  uses proven technologies.  The  shallow water table and
 surrounding  surface water will require  controls  to prevent infiltration
 during  construction.  The present worth of this  alternative  is $13.7
 million.

 Stabilization  of the  site would reduce  the potential for  a release
 and provide  overall protection to the environment.

 ALTERNATIVE  4

 Excavation of  the wastes  and  transportation of them to  an on-site landfill
 slightly increases the volume of the wastes.  The  mobility is reduced by
 containment  of the waste, however, the  toxicity  would remain the same.
 The on-site  landfill   would meet all RCRA guidelines  for design and
 construction of above-grade landfills in a floodplain.

 Removal of the wastes would involve  significant  site disturbance within a
 sensitive ecosystem.  The surrounding environment  would experience exposure
 to the wastes.  With  proper maintainance,  this alternative would provide
 long-term protection.  The timeframe for implementation is 30 months.

Removing the wastes from  a shallow groundwater environment may pose
stability and  water management problems.   Extra  precautions  such as
dikes and a  soil-cement wall  will have  to  be  constructed  to  prevent
these problems.

The on-site  landfill   would provide long-term  protection to the environment,
howevar, the short-term risks associated with the  extensive  handling of
the wastes could impact the environment during remediation.  The present
    n of this  alternative is  $20,342,000.

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                                 11
ALTERNATIVE 5

Excavation of the wastes and transportation offsite would slightly
increase the volume of the wastes because a conditioner would he added
to ease handling.  The mobility would be reduced by containment of the
wastes, however, the toxicity would remain the same.

Removal of the wastes could involve significant site disturbance within
a sensitive ecosystem.  The surrounding environment woald experience
exposure to the wastes.  With proper maintainance, this alternative
would provide long-term protection and would take 20 months to implement,

Removing the wastes from a shallow groundwater environment may pose
stability and water management problems due to infiltration during
remediation.  Extra precautions such as dikes and a soil-cement wall
will  have to be constructed to prevent these problems.

The offsite landfill would provide long-term protection at the site,
however, the short-term risks associated with the extensive handling of
the wastes could impact the environment during remediation.  The present
worth of this alternative is $27,702,000.

ALTERNATIVE 6

Excavation of the wastes, followed by incineration, would decrease the
volume of the wastes by 55 percent.  The mobility of the ash would be
reduced by containment in an on-site landfill.  The toxicity of the
organic constituents would be reduced, however, the metals in the ash
would he more concentrated.

Removal of the wastes for incineration would involve significant site
disturbance within a sensitive ecosystem.  The surrounding environment
could experience exposure to the wastes.  With proper maintainance,
this  alternative would provide long-term protection and take 28 months
to implement.

Removing the wastes from a shallow groundwater environment may pose
stability and water management problems due to infiltration during
remediation.  Extra precautions such as dikes and a soil-cement wall
will  have to be constructed to prevent these problems.

On-site incineration with an on-site landfill would provide long-term
protection to the environment, however, the short-term  risks associated
with  this alternative could impact the environment during remediation.
The present worth of this alternative is $61,462,000.

ALTERNATIVE 7

Excavation of the wastes, followed by incineration, would decrease the
volume of the wastes by 55 percent.  The mobility of the ash would he

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                                     12
    reduced by containment  in an off-site landfill.  The toxicity of the
    organic constituents would be reduced, however, the metals in the ash
    would be more concentrated.

    Removal of the wastes for incineration would involve significant site
    disturbance within a sensitive ecosystem.  The surrounding environment
    would experience exposure to the wastes.  This alternative would provide
    long-term protection and would take 22 months to implement.
                                                           'S
    Removing the wastes front a shallow groundwater environment may pose
    stability and water management problems.  Extra precautions will have
    to be taken to prevent  these problems.  Incineration involves multiple
    steps of handling the wastes which increase the risks of exposure.

    On-site incineration with an offsite landfill would provide long-term
    protection to the environment, however, the short-term risks associated
    with this alternative could impact the environment during remediation.
    The present worth of this alternative is $63,302,000.


X.  SELECTED REMEDY AND STATUTORY DETERMINATIONS

    The selected remedy at  the Bailey Waste Disposal  site is Alternative 3,
    Stabilization.  The goals and objectives of remedial action, as defined in
    the Feasibility Study,  are to minimize the potential for waste migration
    and the potential for short-term air emissions resulting from remediation.
    Stabilization will  minimize the potential  for waste migration by blocking
    the route of transport.  Short-term air emissions will  be reduced by
    employing an in-situ method or operating in small areas.  Short-term
    risks to personnel  and the environment will be minimal  because extensive
    waste handling is not involved.

    The Applicable or Relevant and Appropriate Requirements for the selected
    alternative are:

    40 CFR 264.18(b)  (RCRA) - Facilities in 100-year floodplains must he
    designed, constructed, operated and maintained to avoid washout.

    Executive Order 11988 (Floodplain Management) - Action taken must avoid
    adverse effects and minimize potential harm to the surroundirrg area.

    40 CFR 264 (RCRA) - Construction requirements for hazardous waste
    storage facilities.

    29 CFR 1910 (Occupational  Health and Safety Act)  - Protection standards
    for workers.

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                              13
Alternative 3 addresses the environmental threat by
consolidating and stabilizing the waste to prevent human
contact and future migration.  This alternative provides
protection to human health and the environment, with minimum
short-term impacts.  Hith the exception of Alternative 1,
Alternative 3 can be completed in the shortest timeframe and
at a cost less than the other alternatives that also met the
established goal of the response action.

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                          ATTACHMENT A
                   Bailey  Waste  Disposal  Site
                     Responsiveness Summary
Comment  §1
                                                           S
"Based upon  a  review of  the Feasibility Study and the preceeding Remedial
Investigation,  it would  appear  that the "no action" alternative, which
would include  continuation of site security, is more than adequate to address
the site under  Super-fund."

EPA Response to Comment  #1


The Bailey site is  located in a floodplain so the wastes have the potential
to migrate into the surrounding surface watersxdue to erosion or collapse
of the levees during a flood.   The Comprehensive Environmental Response,
Compensation and Liability Act  (CERCLA) requires that EPA abate the danger
of an actual or threatened release at a site.  Because of the threat that
is present at the Bailey site,  the Feasibility Study developed the primary
goals and objectives that a remedial action must meet.  The remedial action
must minimize the potential for waste migration and protect human health
and the environment.  The "No Action" alternative does not meet the established
goals and objectives because it does not address or mitigate the threat of
a release.
Comment #2

"The Bailey Task Force believes that, based upon all studies to date, the
Site is a prime canidate  for a no-action alternative....  The Bailey Task
Force also believes that, except for the no-action alternative, EPA's
preferred alternative, stabilization, is the best remedy for the Bailey
site."

EPA's Response to Comment #2

See response to Comment #1.


Comment #3

"... a roadway would have to be built across the area east of Pond A in
order to reach the westerly portion of our 741 acres.  This will cause
engineering and public awareness problems which are certainly unacceptable;
therefore an alternative  solution to access as well as compensation for the
land area being utilized  for waste disposal must be considered."... "The
best solution would be to disposa the waste offsite and out of the area."

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The EPA agrees that  it would  he  unacceptable to construct a roadway across
the Area East of Pond A, as a road could jeopordize the integrity of the
stabilized area.  When completed, the selected remedy will not affect access
to the surrounding property.   Stabilization will only affect the areas that
are presently contaminated.   It  will not create new waste areas.

Offsite disposal of  the wastes was evaluated in the Feasibility Study,
however, it was not  selected  because of possible irnmplementation problems
and short-term impacts.  CERCLA  requires that offsite remedies should be
the least favored when onsite remedies are available.

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                           ATTACHMENT B

                           INTRODUCTION

-action 113(j)(l) of  the  Comprehensive Environmental  Response,
Compensation, and Liability  Act  (CERCLA)  provides that  judicial
review of any issues  concerning  the adequacy of any response action
shall be limited to the administrative record which has been
compiled for the site at  issue.

Section 113(Jc)(l) of  CERCLA,  requires  that  the United States
Environmental Protection  Agency  (Agency)  establish administrative
records for the selection of CERCLA response actrions.   The
administrative record is  the body  of documents upon which the
Agency based its selection of a  response  action.   The Agency's
decision on selection of  a response action  must be documented
thoroughly in the administrative record.  The Agency must ensure
that the record is a  compilation of documents leading up to and
reflecting the Agency's response decision.

In .accordance with U.S. EPA  Headquarters  OSWER Directive 9833.3,
Section 113(k) of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA),  as amended in  1986
by the Superfund Amendments  and  Reauthorization Act (SARA)
the U.S. EPA is required  to  compile and make available  to the
public Administrative records containing  documents used to
support response actions  authorized under CERCLA and SARA.
The Administrative Records are to  be maintained at the  relevant
U.S. EPA Regional Offices as well  as "at  or near the facility at
issue."

This Administrative Record File  Index  consists of information
upon which the Agency based  its  decision  on selection of response
actions.  It is a subset  of  information included in the site
files.  The records in this  Administrative  Record File  Index
have been arranged in chronological order (from the earliest
date to the most recent date), based on the date of the corres-
ponding document.  Each document contained  in the Administrative
Record File has been  stamped with  a unique  Document Number, to
assist in the location of the document within the Record File.

This Administrative Record File  Index  has been compiled in
accordance with OSWER Directive  Number 9833.la Interim  Guidance
on Administrative Records for Decisions on  Selection of CERCLA
Response Actions.  This guidance reflects,  to the extent practicable,
revisions being made  to the  National Contingency Plan (NCP).

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                PFCORD INDEX
            • T:, .- '
            .t. I M H L
   ^. iMHME:    i^ailsv  Waste ZnsDosai bit;a
SITE NUMBER:   TXD  380864649
INDEX DfiTE:    06/06/88

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                          Attachment
                       EXAS  UATKR COMMISSION
Paul Hopkins, Chairman

John O. Houchins. Commissioner

B. J. Wynne, III, Commissioner
J. D. Head, General Counsel
Michael E. Field, Chief Examiner
Karen A. Phillips, Chief Clerk
                           Allen Beinkc. Executive Director

                              June 27, 1988
   Allyn M. Davis,  Ph.D., Director                               "•£  '^
   Hazardous Waste  Management Division                            ^>  --
   U.  S. Environmental Protection Agency  s                       '
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