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
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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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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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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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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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