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United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R06-89/047
December 1988
Superfund
Record of Decision
Pesses Chemical, TX
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SW72-101
REPORT DOCUMENTATION 1. RBKMTNO. 1
PAGE EPA/ROD/R06-89/047
SUPERFUND RECORD OF DECISION
Pesses Chemical, TX
k First Remedial Action - Final
1 7. At«M«»
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
1 *+** *""-
12/22/88
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ic Atone* aMfc2a)
The 4.2-acre Pesses Chemical Company site is located in Tarrant County, Ft. Worth,
Texas. The site is situated in a light industrial and commercial area with an estimated
19,500 people residing or working within a one mile radius. The site is divided into a
northern and southern section. The northern section is fenced and includes an occupied
office building and brick warehouse as- well as the former operations area, composed of a
netal warehouse, various equipment, a bag house, a storage yard, and two underground
sumps. The southern portion of the site is an abandoned field. In June 1979, the
Pesses Company began operations to reclaim cadmium and nickel from dry-cell batteries
and metal sludges (without the required construction or operation permits). During July
and August 1979, excessive cadmium emissions were investigated by both the city and
State air pollution control offices. Pesses ceased operations to obtain the proper
permits; however, after operations began again cadmium emissions were measured as high
as 2,900 percent above permit limits. In January 1981, the parent company declared
bankruptcy and site operations were discontinued. In March 1983, a grass fire at the
site resulted in toxic cadmium oxide fumes, which hospitalized a firefighter.
Approximately 1,500 deteriorating drums containing heavy metal sludges, powder, and
empty battery cases remained onsite. In April 1983, EPA removed 3,400 yd3 of soil,
(See Attached Sheet)
17.
Record of Decision - Pesses Chemical, TX
First Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: metals (lead)
e. COSAT1 FfeWOrau*
r~
It. Security CtoM (Thto ftoport)
None
20. Security OM« (Thta Pt«*|
None
21. No. o< PigM
52
22. Prie*
(SMAMUM.1*)
SM MMrucKww on fttvtnt
OPTIONAL FORM 272 (4-77)
(Fanmrty NTIS-3S)
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DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
INSTRUCTIONS
Optional Form 272, Report Documentation Page la baaed on Guidelines for Formal and Production of Scientific and Technical Reporta,
ANSI Z39.1S-1974 available from American National Slandarda Institute, 1430 Broadway, New York, New York 1001S. Each aeparataly
bound report for example, each volume In a multivoiume setehaH have Ita unique Report Documentation Page.
1. Report Number. Each Indfvtdually bound report ahaM carry a unique alphanumeric deelgnetion aaalgned by the performing orga-
nization or provided by the aponeoring organization In accordance wMi American National Standard ANSI Z39.23-1974, Technical
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uppercaae totter*. Arable numeral*, alaana*, and hyphen* only, aa In the following example*: FASEB/NS-75/a7 and FAA/
RD-73/W.
2. Leave blank.
3. Reclplenf a Aoceealon Number. Reaerved for uae by each report recipient
4. TWe and Subtitle. TWe ahoufd Indicate dearfy and briefly the aubfaet coverage of the report, aubordlnal* aubtitie to the main
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9. Report Dal*. Each report ahaM carry a date Indicating el leeat month and year. Indicate the beele on which It waa selected (e.g.,
dele of laaue, date of approval, dale of preparation, date published).
9. Sponaorlng Agency Code. Laeve blank.
7. Authors). ON* name(a) In conventional order (e.g., John R. Doe, or J. Robert Doe). Uat author's affiliation If It differs from
the performing organization.
8. Performing organization Report Number. Inaert If performing organfaton wtahee to aaalgn thla number.
9. Performing Organization Nam* and Mailing Addreaa. Give name, atreet ctty, state, and ZIP cod*. Uat no mor* than two levels of
an organizational htorachy. Dlaplay the name) of the organization exactly aa H should appear In Government Indexes such aa
Government Reporta Announcementa A Index (GRA 41).
10. ProfaoVTaaeVWork UnM Number. Uae the project, teak and work unK numbers under which the report waa prepared.
11. Contract/Grant Number. Inaert contract or grant number under which report waa prepared.
12. Sponaorlng Agency Name and Matting Addreaa. Include ZIP code. CM* mam sponsors.
13. Type of Report and Period Covered. Slate Interim, final, ate., and, M applicable. Inclusive datee.
14. Performing Organization Code, laave blank.
IS. Supplementary Note*. Enter Information not Included eleewhere but ueefut, such aa: Prepared In cooperation with... Translation
of... Presented at conference of... To be published In... When a report to revised, Include a statement whether the new
report supersede* or aupptomenl* the older report
16. Abstract Include a brief (200 worda or leaa) tactual summery of the meet significant Information contained In the report. If the
report contain* a significant bibliography or literature survey, mention It here.
17. Document Analyal*. (). Descriptor*. Select from the Theeaurua of Engineering end Scientific Terms the proper authorized terms
that Identify the major concept of the research and are sufficiently specific and precise to be used aa Index entrlee for cataloging.
(b). Identifier* and Open-nded Terme. Uee Identifiers for project namee, code names, equipment designators, etc. Use open-
ended terma written In deecriptor form for the** subjects for which no deecriptor exlata.
(c). COSAT1 Reid/Group. FtoM and Group aaaignmenta are to be taken form the 1964 COSATI Subject Category Uat Since the
majority of documenta are muitidlaclpUnary In nature, the primary Field/Group assignments) will be the specific discipline,
area of human endeavor, or type of physical object The application^) will be cross-referenced with secondary Field/Group
aaaignmenta that will follow the primary poating(a).
18. Distribution Statement Denote public reusability, for example "Rateaae unlimited", or limitation for reeaona other than
security. Cite any availability to the public, with address, order number and price, If known.
19. & 20. Security Classification. Enter U.S. Security Classification In accordance with U. S. Security Regulations (I.e., UNCLASSIFIED).
21. Number of page*. Inaert the total number of pages. Including Introductory pages, but excluding dlatribution Hat, If any.
22. Price. Enter price In paper copy (PC) and/or microfiche (MF) If known.
A SPO 1983 0 - 381-526(8393) OPTIONAL FORM 272 BACK (
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TX
First Remedial Action - Final
16. Abstract (continued)
drummed material, and debris from the site and installed a clay cap in the storag
yard to prevent exposure to contaminated soil. Heavy metals contamination from
airborne dust and surface water runoff are the main potential threats at the site
addition to soil contamination, two sumps in the southern portion contain 1,914
gallons of liquid contaminated with metals and 16.6 yd3 of sludge contaminated wit
cadmium and nicJcel. There is also limited offsite cadmium contamination of soil.
primary contaminants of concern affecting the soil, buildings and equipment, and
debris are metals including cadmium, lead and nickel.
The selected remedial action for this site includes excavation of contaminated
offsite soil and wastes, and consolidation with onsite contaminated soil, followed
in situ stabilization/ installation of a concrete cap around the fenced portion of
site and around the south warehouse and office building, and a RCRA clay cap placed
the south field; decontamination of the metal warehouse and equipment with resultan
solid wastes combined with the soil remediation, and waters treated and discharged
into the sewer system; offsite disposal of drums and debris, as well as equipment tJ
cannot be adequately cleaned, and offsite deep well injection of wastewater above PC
discharge requirements; and cleaning and sealing the sumps. The estimated present
worth cost for this remedial action is $1,200,000 with annual O&M of $7,000.
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RECORD OF DECISION
FOR
PESSES CHEMICAL SITE
FORT WORTH
TARRANT COUNTY, TEXAS
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DECEMBER 1988
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TABLE OF CONTENTS
DECLARATION BY THE REGIONAL ADMINISTRATOR
DECISION SUMMARY
I. SITE BACKGROUND 1
Location and General Description
Site History
Enforcement Activities
II. SITE CHARACTERISTICS 5
Geology
Hydrogeology
Topography
III. SITE ASSESSMENT 6
Nature and Extent of Contamination
Risk Assessment Summary
Remediation Goals
IV. RESPONSE ACTION 10
Description of Remedial Alternatives
Evaluation of Alternatives
V. RECOMMENDED REMEDY AND STATUTORY DETERMINATION 20
RESPONSIVENESS SUMMARY
APPENDICES
I. Administrative Record Index
II. Texas Water Commission Letter of Support
III. Documentation of Significant Changes
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LIST of FIGURES
DECISION SUMMARY Pa
1 - Site Location Hap 2
2 - Pesses Site 3
3 - Concerns Common to All Alternatives 11
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LIST of TABLES
DECISION SUMMARY Page
TABLE 1: Chemicals of Concern in Various Media 7
TABLE 2: Remedial Alternatives Evaluation 15
TABLE 3: Action Specific ARARs for Pesses 16
TABLE 4: Comparative Cost Analysis for Alternatives 19
TABLE 5: Tentative Remedial Action Schedule 20
iii
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DECLARATION BY THE REGIONAL ADMINISTRATOR
PESSES CHEMICAL COMPANY
RECORD OF DECISION
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DECLARATION
PESSES CHEMICAL COMPANY
RECORD OF DECISION
December 1988
SITE NAME AND LOCATION
Pesses Chemical is located in Fort Worth, Tarrant County, Texas.
STATEMENT OF PURPOSE
This decision document presents the selected remedial action and the
rationale for this action as warranted for the Pesses site. This decision
is in accordance with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA) as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA), and the National Contingency Plan
(40 CFR Part 300).
STATEMENT OF BASIS
This decision is based upon the administrative record for the Pesses
Chemical Superfund Site. The attached index (Appendix A) identifies
the items which comprise the administrative record.
Based upon the findings in the Remedial Investigation for this site, the
residual contamination remaining in surface and subsurface soils and the
Pesses warehouse (following the 1983 Emergency Response Action) pose health
.and environmental threats which require remediation. Ground water has not
been and should not be affected by this site. Therefore, the remedy selected
will address all concerns of the site and will represent the only operable
unit required for final remediation of the Pesses site.
The Agency for Toxic Substances and Disease Registry (ATSDR) has been
consulted and supports this conclusion.
DESCRIPTION OF SELECTED REMEDIAL ACTION
o Contaminated off-site soils will be incorporated with treatment of
contaminated onsite soils.
o Contaminated soils will be treated in place utilizing a stabilization
technique available for shallow soils. A concrete cap will be placed
within the fenced portion of the site around the south warehouse and
office building. A RCRA clay cap will be placed in the south field.
o The metal warehouse and miscellaneous equipment will be cleaned and
left in place. Liquid and solid wastes will be generated as a result
of this decontamination process. Solids will be combined with the
soils remediation and the waters will be treated and discharged into
the sewer system. Equipment which cannot be adequately cleaned and
water which cannot meet discharge requirements will require off-site
disposal.
o The site will be maintained annually and inspected every 5 years
for review of the remedy's effectiveness.
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DECLARATION
Consistent 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 Contingency Plan, I have
determined that this decision will provide adequate protection of
human health and the environment. This remedy attains Federal and
State requirements that are applicable, or relevant and appropriate to
the site. This remedy satisfies the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume as a
principal element and utilizes permanent solutions and alternative treat-
ment technologies to the maximum extent practicable. This remedy is cost
effective. Because hazardous substances will remain onsite above health
based levels, five-year facility reviews will be conducted after
commencement of the remedial action to ensure that the remedy continues
to provide adequate protection of human health and the environment.
The State of Texas has been consulted and supports this remedial
decision for the Pesses Chemical Superfund Site.
DATE Robert E. Layton Jr.,' P.E.
Regional Administrator
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DECISION SUMMARY
PESSES CHEMICAL COMPANY
RECORD OF DECISION
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DECISION SUMMARY
PESSES CHEMICAL COMPANY
RECORD OF DECISION
December 1988
I. SITE BACKGROUND
Location and General Description
The Pesses Chemical Company Superfund Site is located at 2301 South
Main Street in Ft. Worth in Tarrant County, Texas [Figure 1]. The site
is triangular in shape, approximately 4.2 acres in size. An office
building, brick warehouse, and asphalt parking lot within the northernmost
fenced portion of the site are currently occupied. The former Pesses
operations area within the southern fenced portion of the site and the
south field are abandoned. The former operations area consists of a
metal warehouse with various pieces of equipment, a baghouse, two under-
ground sumps, and a storage yard with a concrete pad [Figure 2].
Bordered on the north by the Cenikor Drug Rehabilitation Foundation, on .
the east and much of the south by the Ney Railway Yard, and on the west
by South Main Street, the site is situated in a light industrial and
commercial area. Morningside Drive borders the southern tip of the site.
Residential districts are located approximately one half mile to the
northeast and three-fourths mile southwest of the site. Two hospitals
and five schools are within one mile of the site. In 1984, approximately
19,500 people were estimated to reside or work within a one mile radius
of the Pesses site.
Site History
The Pesses Company of Solon, Ohio [METCOA] purchased property in
Ft. Worth, Texas, in December 1978. Operations to reclaim cadmium and
nickel from dry-cell batteries and metal sludges began in mid-June of
1979. Furnaces fired by natural gas were heated to separate cadmium from
the mixture in the form of cadmium oxide gas. Once the gasses were cooled
and condensed into liquid, the cadmium was formed into solid balls weighing
approximately 1.25 pounds each. These balls were then shipped to various
plating facilities off-site. Nickel and iron scrap were collected in 55
gallon drums for shipment to the Pesses Company reclamation plant in
Pennsylvania.
The Pesses Company did not obtain the construction or operation permits
required by the State prior to operations. In July and August of 1979,
excessive cadmium emissions were investigated by both the City and State
air pollution control offices. Pesses ceased operations to obtain the
proper permits. Once operations were again underway, February 1980,
cadmium emissions were measured as high as 2900 percent of the 0.01 pound
per hour permit limits. In January 1981, the parent company in Ohio claimed
bankruptcy and operations at the Ft. Worth plant were discontinued.
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PE88ES CHEMICAL
COMPANY
1/1 MIL! RADIUS'
SITE LOCATION
LATu at 4»'00' M
^ ? IfSO' W
SOUMCI: U4.0.t. 74 MINUTI SIIIIIS
TOPOOMAPNIC
PONT WOHTN, TIXA8
QUAOIIANOLI 1tT2
1000 2000 3000 4000 5000 6000 7000 FEET
FIGURE 1 LOCATION MAP OF PESSES CHEMICAL COMPANY
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In March 1983, a grass fire at the site resulted in toxic cadmium oxiae
fumes which hospitalized a firefighter. Approximately 1500 deteriorating
drums remained onsite with heavy metal sludges, powder, and empty battery
cases. Since the Pesses Company lacked the funds necessary for site
cleanup, the Environmental Protection Agency Emergency Response Team
removed 3,400 CUDIC yards of soil, drummed material, and debris from the
site in April 1983. A clay cap was placed in the south storage yard to
prevent exposure to contaminated soils remaining onsite.
In April 1984, particulate air sampling revealed .014 - .048 parts per
billion cadmium at the site boundary. The Pesses Chemical Company sue
was placed on the National Priorities List in October 1984 with a score
of 28.86 due mainly to the potential off-site migration of heavy metals
via airborne dust and surface water runnoff.
From June 1985 through November 1985, the south storage yard was occupied
by a tenant through the bankruptcy court. The tenant had placed several
trailers on the cap and truck grooves on the cap indicated that the clay
layer had been damaged. The EPA Technical Assistance Team repaired damage
to the cap and resecured the site in November 1985.
The Remedial Investigation was initiated in November 1987. At this time,
the northern portion of the site was leased out by the bankruptcy trustee.
The tenant had no access to the southern portion of the site. Sampling-
results of the Phase I Remedial Investigation revealed high levels of
cadmium and lead in soils on the northern portion of the site between the
north brick warehouse and office building. Since this area was transversed
frequently with heavy machinery, the tenant agreed to place a 5 inch
asphalt cap and a 6 foot chain link fence across this area to reduce
potential health risk to his employees. The action was overseen by EPA
personnel in August 1988. The tenant remains onsite.
Enforcement Activities
The goal of EPA is to recover as much cost as possible from the bankruptcy
court, proceedings out of Solon, Ohio. In addition, EPA has currently
identified five separate potentially responsible parties for the Pesses
site. These parties will be given the opportunity to conduct or participate
in the remedial action selected for the site. If they fail to accept this
opportunity, EPA will issue an administrative order for their participation.
If they refuse the order, EPA may fund and implement the site remedy
and then initiate cost recovery actions against them.
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II. SITE CHARACTERIZATION
Topography
The site surface is fairly flat, although the land does slope slightly in
certain areas. The railroad tracks are elevated above the site to form
a drainage ditch area along the east boundary of the site. The area
north of the Pesses warehouse generally drains east to this ditch and
then northward toward a storm sewer located on the east site of the
Cenikor property. Drainage south of the Pesses warehouse is towards
storm sewers located along South Main Street.
The Pesses site is situated within the drainage basin of Sycamore Creek
which is a tributary to the West Fork of the Trinity River. Sycamore
Creek has its headwaters in rural areas southwest of downtown and flows
northeasterly via an open channel through urbanized areas to the south
and east of downtown Ft. Worth. The creek is approximately 1.1 miles
southeast of the site. Pesses is not located in the 100 year flood plain
of Sycamore Creek-Trinity River
Geology
Pesses is situated on the outcrop of the undifferentiated Washita and
Fredricksburg groups. This outcrop is approximately 425 feet thick in
the vicinity of the site. Shallow soils are mostly calcareous silty clay
which resulted from weathering of the underlying shaley limestones and
marls. The geology below the site consists of interbedded clay layers and
discontinuous limestone units down to a 40 foot depth. At this point,
the number of semiconsolidated limestone and shale units increase with
depth to approximately 380 feet below ground surface.
Hydrogeoloqy
From an estimated altitude of 290 feet above mean sea level, the Paluxy
Formation is isolated from surface infiltration by 380 feet of low permea-
bility clay, shale, and shaley limestone. The Paluxy Formation yields
small to moderate quantities of water for municipal, industrial, and
agricultural uses in Ft. Worth. The closest well to the site was identified
at Saint Joseph Hospital, 0.6 mile north of the site. This well has been
inactive for at least 40 years.
Although shallow perched water conditions were encountered to a depth
of 15 feet, these localized conditions were discontinuous. This water
does not constitute an uppermost water bearing unit. No water bearing
zones are present from 15 feet to 100 feet below the surface. Therefore,
the Paluxy Formation is the uppermost aquifer below the site.
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III. SITE ASSESSMENT
The Remedial Investigation fieldwork was conducted in December 1987 and
February 1988. The primary objective was to acquire site-specific data
needed to document the existence of hazardous substances and threats of
releases of hazardous substances at the Pesses site. This data was used
to evaluate the potential effect of site contaminants on human health
and the environment.
Contaminants of concern were selected by assessing their toxicity,
concentration, and persistence. Because the contaminants of concern at
Pesses are common elements in the environment or are the result of other
industrial activities in the area, background concentrations were used for
comparative purposes. In the absence of health criteria or background
information, toxicity information was used to quantify risks associated
with a chemical. Qualitative evaluations were done for contaminants of
concern for which toxicity information was not available.
Nature and Extent of Site Contamination
Although the imminent health threat had been alleviated by the Emergency
Removal Action in 1983, some soils retained high metal concentrations. The
building and miscellaneous equipment were left unaddressed and some drums of
debris remained onsite. The RI sampling effort confirmed the following
facts:
o Organic contaminants were not found at concentrations which pose
health or environmental impacts.
o Cadmium, nickel, lead, and copper are the inorganic contaminants of
concern. Table 1 lists concentrations of these metals in the various
media at Pesses.
o Soils onsite contain elevated metal concentrations to an average
1 foot depth. A limited area of contamination extends 10 feet in
depth.
o Two sumps located in the south storage yard contain 1,914 gallons of
liquid and 16.6 cubic yards of sludge. The liquids contain less
than 1 mg/1 of metals. The sludges contain 750 mg/kg of cadmium
and 1,100 mg/kg of nickel.
o The bagnouse at the northeast corner of the metal warehouse contains
dust of high cadmium content.
o The metal warehouse contains cadmium contaminated dust on the floor
and walls. Miscellaneous equipment inside the warehouse contains
similar dust.
o Exposed insulation fibers in the metal warehouse tested negative for
asbestos.
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o Waste piles and drums inside and outside the building contain nigh
cadmium and nickel concentrations.
o Limited off-site areas of shallow soils contain cadniun as a result of-, ml
(1) excessive cadmium oxide emissions during active site operations;
(2) drainage from the site to the Cenikor Foundation;
(3) tracking from the south storage yard in 1985 when the clay cap
was disturbed by active use of the area with heavy machinery.
o Airborne particulates did not contain contaminants at levels of concern
during fieldwork activities.
Site Risk Assessment Summary
The following summary highlights the broad concerns raised as a result of
the risk assessment process, but does not present the numerous assumptions
and constraints employed in the actual ^^sessment. Please refer to the
Remedial Investigation Report for a complete presentation of the risk
assessment.
The risk assessment was conducted using conservative assumptions according
to the general public health evaluation guidelines outlined in the Superfund
Public Health Evaluation Manual, 1986 Directive 9285.4-1. The purpose of
using conservative assumptions is to explore the potential for adverse"
health effects using conditions that tend to overestimate risk. As a
result, the assessment of risks should not be construed as presenting an ^
absolute estimate of risk to human health. Rather, it is a conservative
analysis intended to indicate the potential for adverse health effects to
occur.
"Maximum plausible cases" of exposure that current residents or nearby
workers may be subject to under the present site use conditions were
used to estimate "worst case risk". For example, a "maximum plausible
case" assumes that exposure to the maximum concentration level identified
onsite occurs every time exposure occurs. The "worst case risk" is then
estimated over an individual's expected 70 year lifetime.
Although none of the heavy metals of concern are cancer-causing [carcinogens]
from direct contact or ingestion, adverse health effects can still occur
from the levels of heavy metals present onsite. For instance, an individual
on the site might dermally contact heavy metal contaminants in soils
and/or waste piles and after continued exposure might develop problems
with her kidney, nervous system, etc.
Cadmium and nickel are carcinogens via inhalation. In other words, besides
incidentally ingesting contaminants through hand to mouth interactions,
an individual might stir up soils/waste and inhale heavy metal particulates.
An individual who trespasses onsite has a two-in-one-thousand chance of
developing cancer over his expected 70 year lifetime due to exposure to
the maximum concentrations of both cadmium and nickel identified onsite.
However, if an individual were to work on the site and be exposed to
contaminants for longer and more frequent periods of exposure, he might
have a two-in-one-hundred chance of developing cancer.
8
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Remediation Goals
From the risk assessment, potential health hazards exceed EPA's one in ten
thousand maximum risk for leaving the site as it presently exists. Target
soil action levels were determined from the worst case exposure scenario
that was provided in the baseline risk assessment and from comparison
with background sample values of metals in the site vicinity:
Metal of Concern Action Level
Cadmium 15 ppm
Nickel 100 ppm
The cadmium and nickel concentrations ensure that a carinogenic risk from
the site will not exceed a one in one million risk. Since areas which
contain elevated cadmium and nickel concentrations correspond with areas
of elevated lead and copper, lead and copper concentrations detected
onsite will not present a health or environmental impact once cadmium and
nickel contaminated soils are addressed.
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IV. RESPONSE ACTION
The remedial activities at the Pesses sue have not been separated into
operaole units. Each remedial alternative described in this Record of
Decision addresses all contaminated media identified at the site.
Description of Remedial Alternatives
In accordance with the National Contingency Plan [NCP], initial remedial
approaches were screened to determine which might be appropriate for this
site. The Feasibility Study Report describes the details of this screening.
From the possible remedies developed for Pesses, six alternatives were
chosen for detailed analysis. A No Action Alternative is included in the
final analysis to comply with the NCP requirements.
Common elements among the remedial action alternatives include considera-
tions for the metal warehouse, baghouse and miscellaneous equipment, and
the two sumps located onsite. All remedial alternatives consider cleaning
the building and leaving it in place. Drums and other contaminated debris
which cannot be included in the main soil remedy will be disposed off-site.
Equipment that cannot be adequately cleaned and left in place may also be
disposed off-site. The sumps will be cleaned and sealed in place.
As part of any remedial alternative, solid and liquid wastes will be
generated as a result of building, equipment, and personnel decontamination.
Each alternative assumes that solid wastes can be combined with the soils
remediation and liquid wastes can be treated onsite and discharged to the
storm sewer. However, those solids which cannot be combined effectively
with the soils remediation will be included with the drums and other
debris for off-site disposal. Similarly, if wastewaters cannot be treated
to meet applicable or relevant and appropriate discharge requirements,
then off-site deep well injection will be necessary. The decon water
levels anticipated and the sump waters tested are below the criteria for
deep well injection. Figure 3 is a schematic of how each concern will
be addressed.
In the Feasibility Study, cleaning and demolition of the surface structures
was considered as a separate alternative. In this Record of Decision, the
cleaning, demolition, and off-site disposal alternative is not considered
. except in part (equipment that cannot be adequately cleaned and left in
place). By cleaning the structures and leaving them in place, the building
can be reused and the equipment salvaged.
Alternative 1: No Action
No remedial action would be conducted. Since site contaminants would
remain onsite above health based levels, annual maintenance and 5-year
facility reviews would be required. This alternative would cost
approximately $60,000 in net present worth dollars over a 30 year period.
10
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Figure 3: Concerns common to all alternatives.
Metal
Warehouse
and
Clean &
Leave in place
and (Sumps}
^ > 4
Solids
7 ^
4
Liquids
o
Combine with Main Soils Alternative
or
Off-site Disposal
Treat & Discharge
or
Deep Well Injection
11
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Alternative 2: Capping
A concrete cap would be placed in the fenced area and a clay cap would
be placed in the south field area. The concrete cap is considered for
its durability and reliability, since continued light industrial use of
the area around the buildings is anticipated. The clay cap would be
constructed in accordance with minimum technology requirements under the
Resource Conservation and Recovery Act (RCRA). Contaminated off-site
soils would be brought back onsite prior to capping.
Implementation of this remedy is estimated to take 6 months. Since
site contaminants would remain onsite above health based levels, annual
maintenance and 5-year facility reviews are required. The total present
value cost for this remedy is estimated at $940,000 over a 30 year period.
Alternative 3: In Situ Vitrification Plus Capping
The soils would be treated in place to immobilize the heavy metal
particulates (stabilization). Wastes and off-site soils would be
consolidated on site prior to treatment and included in the process.
The site would be capped as described in Alternative 2.
The vitrification process utilizes electricity to melt the soil into a
glassified mass which traps the heavy metals inside. Due to the large
area to be remediated, the energy requirement would need to be
quantified. Also, the adequate capture of volatile cadmium is uncertain.
A treatability study would be necessary prior to implementation of this
remedy.
Implementation for this remedy is estimated to take from 9 to 14 months.
Annual maintenance and 5-year facility reviews would be required. The
cost estimate for this alternative is $3.8 million over a 30 year period.
Alternative 4: In Situ Stabilization Plus Capping
The soils would be treated in place to immobilize the heavy metal
particulates (stabilization). Wastes and off-site soils would be
consolidated on site prior to treatment and included in the process.
Soils deeper than 2 feet in depth which are above the target action
level will have to be excavated and included in the treatment process.
The site would be capped as described in Alternative 2.
A large roto-tiller would be used to inject and mix a stabilizing agent
into the contaminated soils. Water would be used to compact and set
the soils into a hardened mass in place. Treatability studies have
been performed which show adequate results for both cement and asphalt
stabilization of the soil at the Pesses site. However, a small scale
test might be required prior to implementation to ensure proper mixing
and setting. The specific in-place technique for shallow soils
identified in the FS Report has been utilized at other similar heavy
metal sites.
12
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Alternative 4: In Situ Stabilization... (continued)
Implementation of this remedy should not exceed 6 months. Annual
maintenance and 5-year facility reviews would oe required. This altern-
ative is estimated to cost $1.2 million over a 30 year period.
Alternative 5: Excavation, Onsite Stabilization with Consolidation in
the South Field
All soils above the target action levels will be excavated and treated
above ground in an onsite treatment unit. The fenced area would be
backfilled with clean soil and all of the stabilized material would be
placed in the south field beneath a RCRA clay cap.
Due to space constraints at the site, the increased handling of contaminated
soils/waste might prove difficult. Excavation and stockpiling of clean soil
is necessary to create adequate capacity for the stabilized material.
Off-site stockpiling of clean material would need to be granted by area
businesses/railway yard. However, vacant land near to the site is also
minimal. If the clean material is taken too far from the site, cost
will increase substantially.
Implementation of this remedy would take a minimum of 6 months. The
site would be maintained annually and 5-year facility reviews would be
necessary. A representative cost estimate for this alternative would
be $1.4 million over a 30 year period.
Alternative 6: Excavation, Onsite Stabilization, Off-Site Disposal
This remedial action is essentially the same as Alternative 5 in terms
of excavating and treating the soils and waste in an onsite treatment
unit. However, the risks to human health and the environment are entirely
removed from the Pesses site. All stabilized material would be transported
off-site to a RCRA approved landfill.
Monitoring the site for the first year after implementation would be
included in this remedy. Since contaminants would not remain onsite,
annual maintenance and five year facility reviews are not required for
this alternative. A representative cost estimate for this alternative
is $8.3 million over a 2 year period.
13
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Evaluation of Alternatives
An evaluation of each alternative is shown in Table 2. The following
values were assigned for comparison between the alternatives for each
remedial selection criteria:
+ The alternative exceeds the criterion in comparison to the other
alternatives.
o The alternative can be designed to meet the criterion.
- The alternative would prove difficult in modification to meet the
criterion.
Protection of Human Health and the Environment
The No Action Alternative would not adequately protect human health
and the environment since the worst case risk posed by the site is
greater than EPA's action level of one in ten thousand. Capping
alone would prevent the direct contact threat and provide a barrier
to any off-site migration of heavy metal particulates via rainfall
runoff, airborne dust, and vertical leaching. Therefore, Alternative
2 is rated "o" . However, Alternatives 3-5 are each rated "+" since
stabilization plus capping would ensure added protection if the cap
were ever penetrated. Excavation and off-site disposal completely
removes contaminants from the Pesses site. However, Alternative 6 is
rated "+" since the risk is merely transferred to a different location
Applicable or Relevent and Appropriate Requirements [ARARs]
Table 3 lists the action-specific ARARs identified for each remedial
action alternative at the Pesses site. All action alternatives can
meet their specified ARARs. The No Action Alternative is a remedial
alternative that will not be included in the following references to
remedial action alternatives. See footnote on Table 2.
The Land Disposal Restrictions are not applicable to any onsite
remedy at the Pesses site due to the following rationale:
1) Listed wastes are not present onsite.
2) Although some wastes are characteristically toxic,
due to the cadmium content, those wastes which are
characteristic will not be removed from the area of
contamination (if excavated at all).
The Land Disposal Restrictions are relevant and appropriate for off-
site disposal of characteristically toxic soils as described in
Alternative 6. Although criteria have not yet been promulgated for
soil and debris, any standards which will be promulgated would more
than likely be met by treating soils/waste and/or cleaning equipment,
etc.
14
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TABLE 3
ACTION-SPECIFIC APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
PESSES SITE
FEDERAL
REQUIREMENTS
Occupational Safety
and Health Act
Clean Air Act and
National Ambient Air
Quality Standards
STATE OF TEXAS
REQUIREMENTS
ARAR for
REMEDIAL ACTIONS
23456
A A A A A
R R R R R
ARAR Met? (yes/no;
Alternatives whicf
do not meet ARAR,?
Yes
Yes
National Pollutant
Discharge Elimination
System treatment
standards.
Hazardous Materials
Transportation Act
and
Sol id Waste Disposal
Act [RCRA]
RCRA Clean Closure
RCRA Land Disposal
Restrictions
Water Quality Standards
Texas Administrative
Code Part 319 *
Texas Solid Waste Act *
R R R R R
Yes
A A A A A
R R R R R
- - - - A
Yes
Yes
Yes
APPLICABLE (A)
RELEVANT AND APPROPRIATE (R)
* MORE STRINGENT REQUIREMENT TO BE MET (Federal vs State)
16
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ARARs (continued)
Since chemical-specific and location-specific ARARs do not exist for
the contamination at the Pesses site, target soil action levels were
developed to be considered in each remedial action alternative.
Capping alone utilizes the target soil action levels to a lesser
degree than the treatment plus capping/removal alternatives. For
this reason, Alternative 2 is rated "o" and all other action alterna-
tives are rated "+".
Long-term Effectiveness and Permanence
All the remedial action alternatives will afford long-term effectiveness
and permanence. If appropriate maintenance is performed, those remedies
which leave contaminants onsite provide equivalent protection to that of
the off-site disposal remedy. However, capping alone may not prove as
reliable as the stabilization plus capping alternatives, due to the risk
of exposure if the caps become damaged. In situ treatment with capping
offers a higher degree of permanence and effectiveness since even if
the caps are damaged, the underlying soils are stabilized in form.
Therefore, Alternative 2 is rated "o" in comparison to Alternatives 3
and 4 which are each rated "+". Alternative 5 (Stabilization and
Consolidation in the South Field) and Alternative 6 (Off-Site Disposal)
each rate "++" since the management and the maintenance of the site
following implementation would be minimal. Although off-site removal
would offer the least long-term management at the Pesses site, the
stabilized materials are merely moved to a different location.
Reduction in Toxidty, Mobility, and Volume
All remedial action alternatives are rated "o" for reducing toxicity
since the toxicity cannot be altered by capping or by stabilization.
All action alternatives can reduce mobility. Since capping alone offers
minimum reduction, Alternative 2 is rated "o" for mobility reduction.
However, the stabilization alternatives will further reduce mobility
due to the matrix created to hold metals in a hardened mass. For this
reason, all the remaining remedial alternatives (3-6) are each rated
"+" for reducing mobility.
The excavation alternatives (Alternatives 5 and 6) substantially increase
the volume of material to be managed due to excavation and are, therefore,
rated "-" for volume reduction. Alternatives 2 and 4 do not substantially
affect the volume of contaminated material and are thus rated "o". The
only alternative which can reduce the volume of heavy metal contaminated
materials is Alternative 3 due to the shrinking of the clay soils during
the vitrification process. Therefore, Alternative 3 is rated "+" for
volume reduction.
17
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Short-term Effectiveness
(
Short-term effectiveness of all alternatives are equal in reducing the
health and environmental risks posed by contaminants currently at the
site. However, Alternative 4 is rated "+" in comparison to the other
alternatives since the in situ process poses minimum risk to human
health and the environment during implementation. Although Alternative 3
is also an in situ process, it is rated "-" due to short-term risks posed
to the community, workers, and the environment during implementation.
For instance, the volatile cadmium would have to be captured adequately
during the vitrification of soils instead of released to the environment.
Implementability
Alternatives 3 (In Situ Vitrification Plus Capping) and 5 (Stabilization
and Consolidation in the South Field) are each rated "-" due to difficulties
expected during implementation. For example, available power sources
may not meet the capacity requirements in the in situ vitrification
process. The adequate capture of cadmium volatilized is also an unknown
factor for the size area requiring vitrification. In Alternative 5,
the excavation and stockpiling of clean soils on the small piece of
vacant land available on and near the site will create administrative
as well as physical difficulties during implementation.
Treatment and off-site disposal (Alternative 6) is rated "o" since
implementation is easy, but involves increased handling of materials in
comparison to Alternatives 2 and 4. Alternatives 2 (Capping) and 4
(In Situ Stabilization Plus Capping) are rated "+" since they involve
minimal handling of contaminated material and are easy to implement.
Cost Comparison
No annual operational costs are anticipated for any of the remedial
action alternatives since implementation can be completed in one year
or less for each. Maintenance costs are similar for all the action
alternatives which leave material onsite. Although Alternative 6
requires minimal maintenance (1 year) since contaminants are entirely
removed from the Pesses site, the capital cost far exceeds that of the
onsite remedies. Alternatives 3 (In Situ Vitrification) is also
expensive due to high capital costs. Since these alternatives do not
offer substantial increase in the level of protection to human health
and the environment, they are not cost effective in comparison to the
other remedial action alternatives.
Although capping alone (Alternative 2) is the least expensive alternative,
the level of protection gained through the stabilization plus capping
alternatives is substantial. Therefore, Alternatives 4 and 5 are the
most cost effective alternatives. A comparison of capital, maintenance,
and total present value cost for each alternative is shown in Table 4.
State and Community Acceptance
State and community acceptance of various remedial alternatives will
be discussed in the Responsiveness Summary.
18
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TABLE 4
COMPARITIVE COST ANALYSIS FOR ALTERNATIVES
PESSES SITE
ALTERNATIVE
No Action
Capping
In Situ
COSTS ($1,000 UNITS)
CAPITAL MAINTENANCE
28 3
834 7
3,800 7
TOTAL
60
940
3,800
Vitrification
In Situ 1,100
Stabilization
Stabilization
and
Consolidation 1,400
Stabilization
and Off-Site
Disposal 3,500
1,200
1,400
3,500
* Present Worth Total Cost at 10% discount rate, 0% inflation rate,
over a 30 year period.
19
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V. RECOMMENDED REMEDY AND STATUTORY DETERMINATION
The recommended alternative for remediation of the Pesses site is the
In Situ Stabilization Plus Capping Alternative (4). This onsite alternative
is protective of human health and the environment and utilizes treatment to
the maximum extent practical for heavy metal contaminants. All requirements
for this remedy that are Applicable or Relevant and Appropriate can be met
through adequate design and planning. Long-term effectiveness is achieved
through proper maintenance. Easy to implement, this remedy is reliable and
will not pose short term risk to the community and area businesses as the
other remedial action alternatives.
This remedy is cost effective. Capital cost for this remedy is estimated at
$1.1 million. Maintenance is estimated at $7,000 per year. Five year facility
reviews are required for this remedy at a cost of $4,000 per review. The total
present worth cost of this remedy is $1.2 million over a 30 year period.
Compared to the recommended remedy, the other alternatives were rejected for
the following reasons:
No Action - inadequate protection of human health and the environment.
Capping - if the caps are damaged or not maintained properly, risk from
potential exposure to the untreated contaminants beneath the
caps could be equivalent to current risk estimate.
In Situ Vitrification - short-term risks posed and reliability uncertain
during implementation.
Stabilization and Consolidation - although end result is similar to the
recommended remedy, difficulties and substantial volume increase
during implementation.
Off Site Disposal - the substantial volume increase due to excavation and
the substantial increase in cost. Although more effective in
terms of long-term maintenance of the site, this remedy merely
moves the contaminants to a different location. Overall
effectiveness (short-term and implementation included) is not
substantially different than the recommended remedy.
TENTATIVE REMEDIAL ACTION SCHEDULE
REMEDIAL ACTION SELECTED [ROD SIGNED] . DECEMBER 1988
COMPLETE ENFORCEMENT NEGOTIATIONS* JUNE 1989
DESIGN INITIATED JUNE 1989
DESIGN COMPLETE APRIL 1990
CONSTRUCTION INITIATED JUNE 1990
CONSTRUCTION COMPLETE DECEMBER 1990
*Dates following this task dependent on PRP takeover.
20
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RESPONSIVENESS SUMMARY
PESSES CHEMICAL COMPANY
RECORD OF DECISION
-------
RESPONSIVENESS SUMMARY
PESSES CHEMICAL COMPANY
RECORD OF DECISION
December 1988
This community relations responsiveness summary is divided into two sections;
The first section provides a brief history of community interest and concern
raised during the remedial planning activities at the Pesses Chemical
Superfund site. The second section provides a brief summary of the community
concerns raised during the public comment period and EPA responses to the
comments.
BACKGROUND OF COMMUNITY INVOLVEMENT AND CONCERNS
The March 1983 fire at the Pesses site drew considerable press attention
as well as letters of concern about the site from Fort Worth officials.
EPA conducted a removal at the site in April 1983. The local officials
and citizens were concerned that the action by EPA should have been more
thorough and complete. The nature of conditions at the Pesses site required
that a more lengthy investigation be conducted under the Superfund law.
The Pesses site was proposed for the National Priorities List (NPL) in October
1984. The Texas Water Commission accepted the lead responsibility for
Pesses and held a meeting for local residents on February 26, 1985, to
explain the Superfund process and to gather information about any citizen
interest or concerns. EPA officials participated in the meeting to discuss
the removal action. Nine citizens attended the meeting. Their main
concerns included: (1) possible contamination off-site, (2) why the plant
was allowed to operate, and (3) what dangers exist from the site.
Due to the Superfund reauthorization, funds to conduct the more indepth
investigations were not awarded to TWC until April 1987. In November
1987 TWC sent a questionnaire to area officials and residents requesting
information on their concerns or issues relative to Pesses. Twenty
responses were received. Respondents mainly wanted to be kept informed
of site activities. TWC held a public meeting on December 3, 1987, to
brief citizens about field activities at the site. There were no local
officials nor citizens in attendance.
On October 18, 1988, EPA officials briefed Fort Worth health officials on
the investigation and proposed remedy for the site. On October 31, 1988,
EPA announced in the Fort Worth Telegram that the Administrative Record
on the Pesses site would be available at local repositories for public
review and comments between November 2 and December 2, 1988. A public
meeting on the proposals would be held on November 16, 1988.
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The public meeting was held at the Holiday Inn South, Fort Worth. Aoout
20 people attended the meeting which began at 7:00 p.m. There was no
opposition to EPA's proposed remedy. However, the City of Fort Worth
requested that contaminated soil be consolidated in the south field in
order that other portions of the land be available for industrial use.
A copy of the transcript from this meeting is available in the Administrative
Record. However, the issues discussed at the meeting are also summarized
in the following section.
SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA'S
RESPONSES.
Comment 1: The Environmental Protection Agency should consider excava-
tion with onsite stabilization and consolidation of the
material in the south field and capping with concrete or
clay (Alternative 5). This procedure allows for unrestricted
development of the northern portion of the site and limited
usage such as parking, storage or slab type construction,
on the southern portion while Alternative 4 would have
restrictions on future development
Response 1: Although Alternative 5 would allow unrestricted future
development of the northern portion of the site, future -
land development is not a consideration in selection of a
remedy for a Superfund site. Future continued land use is
considered in establishing action levels for reducing
risk to human health and the environment and this has been
accounted for in the case of Pesses. Please refer to the
evaluation of alternatives in the Decision Summary, page 14
of this Record of Decision. The southern portion of the
site allows limited use for either Alternative 4 or 5.
Comment 2: In the Remedial Investigation Report, Table 9-1 of the
Public Health Evaluation listed all detected materials but
did not list the appropriate selection criteria, such as
background concentrations, reported national averages, and
the equations promulgated in the referenced guidance
document, Superfund Public Health Evaluation Manual (U.S.
EPA, 1986). Inclusion of these criteria and equations are
necessary to demonstrate the final selection of cadmium,
copper, lead, and nickel as the indicator parameters for
site specific hazard assessment, as listed in Section 9.2
of the report.
Response 2: Although Table 9-1 does not list background concentrations
and reported national averages, this information can be
found in Section 4 of the Remedial Investigation Report.
Please refer to Table 4-4 for background soil information
and Table 4-7 for reported national averages. The
equations promulgated in the Superfund Public Health
-------
Response 2 continued:
Evaluation Manual (U.S. EPA, 1986) are typically used to
reduce the 1 ist of contaminants found at a sue to tne
list of contaminants of concern. These "indicator parameters'
are representative of the site contamination to be managed
for overall protection of human health and the environment.
However, in the case of Pesses, the initial screening left
only four inorganics for evaluation. See page 92 of the
report for the elimination criteria and discussion.
Therefore, further reduction in the list of "indicator
parameters" is not necessary.
Comment 3: In the draft Feasibility Study Report, it is unclear in
Figure 2-1 if the area between the office and the Pesses
chemical building is to be excavated to 2.5' or 12.5'.
Please clarify this ambiguity.
Response 3: Figure 2-1 is in error and will be corrected prior to
final publication. The area between the office building
and the Pesses warehouse should show 2.5 feet for excavation.
In addition, the 4 foot depth in the south field should
show only a 1 foot depth for excavation.
Comment 4: In the draft Feasibility Study Report, the interchangeable
use of "action level" and "clean-up level" is not clearly
explained. Please clarify if they are the same or derived
from different sources.
Response 4: These terms are the same. However, the term "action-level"
is more appropriate and will be used to the exclusion of
other terms in the final report.
Comment 4: The technology referred to as "in situ stabilization" is
an alternative discussed in the draft Feasibility Study
Report. However, the specific application of a "large
roto-tiller" type in situ stabilization is not a proven
technology for in-place stabilization of soils. With
respect to the generally shallow occurrence of contaminants
at the site, the use of such a device appears more
favorable than the standard auger rig mixture method
employed at other NPL sites. However, the agency should
conduct a pilot scale study of this technique and establish
criteria to measure effectiveness of this alternative
prior to issuance of the ROD.
Response 4: The "roto-tiller" type in situ stabilization is a proven
technology for in place stabilization of soils. The sue
contractor for the Pesses RI/FS project is aware of two
sites on which this technique has been used. One sue nad
5,000 cubic yards of soil stabilized and the other had
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Response 4 continued:
100,000 cuDic yards stabilized. In addition, treatability
studies conducted during the Pesses project snow effective
results for both cement and asphalt stabilizing agents.
However, a pilot scale study during remedial design will
be recommended to establish effective mixing criteria.
Comment 5: Alternative 5 does not provide added environmental security,
but simply increases the future usability of a portion of
the site. While this might be of some advantage to the
present and future site owners, it is not a consideration
for site remediation. With the following exceptions, EPA's
conclusion that Alternative 4, in situ stabilization and
capping, is an appropriate choice for remedial action:
A. The use of two different caps on the same site creates
an inconsistency in site remediation. The only apparent
benefit derived from a concrete cap is future sue reuse.
The responsibility of the PRPs at an NPL site is to
protect the public from potential health hazards created
by the site and not to reclaim the site for future use.
B. All site caps should be clay with a thickness equivalent
to the impermeability of eight inches of steel reinforced
concrete. Such a clay cap will be less expensive to
construct and maintain than either the eight inch concrete
or three foot clay cap currently recommended in Alternative
4. As the FS indicates that the impermeability of an eight
inch steel reinforced concrete cap is sufficient, an
equally impermeable clay cap should also be acceptable.
C. Site access restrictions for the lifetime of the facility
are recommended to ensure the continued integrity of
remedial actions.
Response The advantage identified for placing a concrete cap in the
5A4B: former operations area around the buildings is realized
under long-term protection and reliability of the remedy
selected. Since continued industrial use of the area
around the buildings was anticipated as part of the risk
assessment, and since remediation goals include consideration
of continued land use, a concrete cap in this area would
be more effective than a clay cap in maintaining an adequate
level of protection to human health and the environment.
5C: "Site access restrictions" for the lifetime of the facility
cannot be implemented. However, such restrictions are
not necessary if a concrete cap is placed around the
building onsite. Deed recordation of any remedial action
taken will be necessary at the Pesses site.
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Comment 6: The method of inclusion of off-site soils in the onsite
remediation should receive more detailed analysis.
Recommendation: the off-site materials be blended with
stabilizer while the material is above ground (i.e. while
it is being excavated and transported onto the site).
This approach will decrease the depth to which roto-tilling
will have to occur during in situ stabilization.
Response 6: This recommendation will be considered in the remedial design,
Comment 7: Highly contaminated materials should not be treated and left
on site. These materials should be transported to the
facility chosen to receive the hazardous materials generated
during remediation.
Response 7: This is a consideration which may be determined once
implementation is initiated. See page 10 of the Decision
Summary. If the miscellaneous equipment cannot be cleaned
appropriately, it can be included with the other debris/drums
to be transported off-site to a compliant permitted facility.
Comment 8: A soil washing alternative should be considered for the
Pesses site. Although clays are more difficult to clean-
than sand or loam soils, a grinder system might be used
prior to treatment to effectively remove the metals.
Response 8: A soil washing treatability study performed during the
feasibility study concluded that the soil washing
technology is infeasible for the form of metals in soils
at the Pesses site. A blender was used in one test to
powderize the soil and the result of soil washing was
still inadequate for removing the high levels of cadmium
in soils. For this reason, the technology was screened
prior to development of alternatives.
Comment 9: The Pesses site is potentially impacting wildlife on the
site. Numerous great-tailed grackles and other passerine
birds were observed using the fence around the site and
trees on the southern end of the site for roosting.
Sunflowers are known to attract many species of birds and
there is substantial stand of sunflowers on undeveloped
parts of the site, particularly the area inside the fence.
Response 9: In 1983 EPA removed 3,400 cubic yards of contaminated
soil and debris related to the Pesses Chemical Company
operations. In addition, a 6-inch clay cap was placed
inside the southern storage yard area (Figure 1) and
seeded with grass. This action minimized the off-site
migration of contaminated airborne particulates and
surface water runoff. EPA also believes that this action
effectively prevented direct contact between migratory
birds and the contaminants identified onsite.
5
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Response 9 continued:
The proposed remedy for the sue will address the long-
term potential threat of direct contact as well as
migration of contaminants off-site which might affect
human health and the environment. Soils will be solidified
in place', which will minimize impacts to the surrounding
area during implementation. The resulting solidified mass
will be capped. Long-term maintenance of the site will
ensure the integrity of the remedy.
Comment 10:
Response 10:
Comment 11:
Response 11:
Several heavy metal contaminants are present in Trinity
River fish and wildlife in amounts which may be adversely
impacting them and the predatory species consuming them.
The fact that these contaminants are present in significant
amounts in Trinity River fish and wildlife confirms that
they are not always bound to the sediments
they are unavailable to fish and wildlife.
birds utilize aquatic habitants downstream
in Sycamore Creek and the Trinity River.
to the extent
Migratory
from the site
EPA understands the concern in regard to heavy metals
present in the Trinity River. However, results of the
remedial investigation demonstrate that the site is not .
contributing to this problem. Water and sediments along
the pathway to the storm sewers were sampled during a
heavy rainfall event and were utilized to model the worst
case scenario of surface runoff. The site is not located
in the 100-year floodplain of Sycamore Creek. See also
Response 9.
In addition, sediment sampling results from the Fort Worth
Health Department show no detection of cadmium and show
the other contaminants of concern below or equivalent to
the upgradient levels detected in the segment of Sycamore
Creek potentially affected by runoff from the Pesses site.
PCBs were not sampled at the site. PCBs are common
industrial contaminants and the former industrial uses of
the site are unknown. Since 1,2,4-trichlorobenzene was
detected on the site and was used in many transformers
that contained PCBs, its presence constitutes a clue that
PCBs may also be present.
EPA disagrees. The concern of past unknown uses of the
site has been an integral part of the remedial investigation.
Although EPA had extensive information on the metal reclamation
operations of the Pesses company, the remedial investigation
sampling plan was devised to consider unknown contaminants
from previous site uses.
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Response 11 continued:
The initial sampling activities fauna insignificant levels
of organic chemicals in the soil onsite. The only area
where organfcs were detected is located at the southeast
corner of the fence, next to the railroad yard. Although
the solvent 1,2,4-tnchlorobenzene was detected [4 ppmj,
this compound is not related to PCBs.
Comment 12:
Response 12;
Comment 13;
Response 13;
Comment 14:
Response 14:
Open cans of paint are located onsite. The site is also
being used for outdoor storage of computer scrap. Analyses
of PCBs and computer-related contaminants (such as beryllium]
should be conducted before completing a cleanup plan for
the site.
The photographs which were submitted show open cans of
paint on the Cenikor Foundation property, located adjacent
to, but not on, the site. Similarly, the photographs
which show scrap metal parts are part of the Singer Metal
operation. These concerns are not related to the Pesses
site. Singer Metals, the current tenant on the northern
portion of the site, does temporarily accumulate metals
from computer components for shipment off-site. Since
no thermal processes are employed, these metal salvaging
operations should not hinder the site remediation.
Most of the contamination onsite has been shown down
between one and two feet, with the exception around the
buildings. Why is there a difference since these metals
bind to the clay?
These areas contain higher concentrations of the indicator
metals than other areas onsite. This may have resulted
from spills of pure liquid nickel-cadmium sludges. In the
molten liquid form, these contaminants would have increased
mobility over the solid form that they are now found onsite.
Three buildings are onsite.
considered for remediation?
Why is only one building
The Pesses warehouse, the south metal building, is the
only building formerly used by Pesses during active
operations. The office building and the north rental
property warehouse were not used for the thermal processes
of the Pesses operations.
Since the two north buildings are currently occupied, EPA
did recommend that the tenant request the State Health
Department to test dust content for heavy metals. This
recommendation was based on the fact that the heavy machinery
being used between buildings by the tenant was generating
dust which could be blown into the open doorways.
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Response 14 continued:
The tenant agreed ana also attempted to limit access oetween
buildings until the site is remediated. Sampling results
by the State Health Department confirm the fact that
some contaminated dust had been blown into the doorways
of the two buildings. The levels detected were 3 orders
of magnitude less than the dust in the Pesses warenouse.
However, the EPA had already determined that an additional
cap was necessary for the area where the tenant used heavy
machinery. In August 1988, the onsite tenant placed an
asphalt cap between the two buildings to further reduce
contaminated dust generation and prevent risks to his
workers until the site is permanently remediated.
Comment 15: How did the off-site areas become contaminated and to what
depth are they contaminated?
Response 15:
Comment 16:
Response 16:
During active operations at Pesses, the baghouse emitted
cadmium in excess of 2900 percent of the .01 pound per hour
State permit limits. The wind, predominantly to the northwest,
carried some of the cadmium particulates to most of these
areas. See Figure 1 of the Decision Summary.
The area directly across the street might be a result of
tracking as well as airblown dust deposition. The cap was
damaged in 1984 when the bankruptcy court leased out the
southern portion of the site and the tenant disturbed the
cap with trailers and trucks. The area on the Cenikor
property may also be a result of drainage along the ditch
by the railroad tracks.
All of the off-site areas are anticipated to be only shallow
contamination, less than a foot in depth. However, the action
levels will address any depth of contaminated soil.
Since contaminants are being left onsite, who will assume
responsibility for maintaining the site and for how long?
If the site remains abandoned and the property remains in
bankruptcy, responsibility for the first year is that of
the EPA, and the Texas Water Commission assumes responsibility
for the next 29 years. However, since contaminants remain
onsite above health based levels, annual maintenance will
be continued if determined necessary at the end of 30 years.
If potentially responsible parties participate in the
remedial action, they will assume responsibility. However,
if the site is sold, the responsibility of maintenance
reverts to the owner.
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APPENDIX A
ADMINISTRATIVE RECORD INDEX
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APPENDIX B
TWC LETTER OF SUPPORT
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TEXAS WATER COMMISSION
M«r'<-. c .,. f:
-"">- V
Allyn M. Davi3/ PhD., Director
Hazardous Waste Mana^ent Div
1445 Ross Avenue
Dallas, Texas 75202-2733
Re!
Dear Dr. Davis:
Sincerely,
P. Beinke
Executive Director
'""''-'" ' "' ' N' "-"* » *T...W1, . . ,..,<.. ,_.fc.,.
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APPENDIX C
DOCUMENTATION OF SIGNIFICANT CHANGES
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DOCUMENTATION OF SIGNIFICANT CHANGES
In the Proposed Plan, cleaning and demolition of the surface structures
was considered as a separate alternative. In this Record of Decision, the
cleaning, demolition, and off-site disposal alternative is not considered
except in part (equipment that cannot be adequately cleaned and left in
place). See page 10 of the Decision Summary.
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flDMINISTRflTIVE RECORD INDEX
FINfiL
SITE NOME: PE5SES CHEMICflL COMPflNY
SITE NUMBER: TXD 0980693656
INDEX DflTE: l£/££/88
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