United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-89/053
September 1989
EPA Superfund
Record of Decision:
United Creosoting, TX
V
\
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'DOCUMENTATION i. REPORT NO. 2.
PAGE EPA/ROD/R06-89/053
SubtMo
*FUND RECORD OF DECISION
3d Creosoting, TX
rid Remedial Action - Final
ig Orgainlneon Neme and Addreee
Ing Organization Hum and Addreee
Environmental Protection Agency
A Street, S.w.
ington, D.C. 20460
3. Recipients Acceeeion No.
5. Report Dele
09/29/89
8.
a. Performing Organization Hept No.
10. ProjecVTaek/Work UnH No.
11. Contr*ct(C) or Grant(G) No.
(C)
(G)
13. Type at Report t Period Covered
800/000
14.
lentary Notee
(Limit: 2OO word!)
0-acre United Creosoting site is in Conroe, Montgomery County, Texas. The site
tly is occupied by a distributing company, a construction company, and a residentia
ision. From 1946 to 1972, the United Creosoting Company operated a wood preserving
ty at the site which usocl PCPs and creosote in the wood preservation process. PCP
eosote wastes were stored in two waste ponds on the property of the distributing
y. During 1980 the county improved area roads using soil and waste pond backfill
he site. Because residents living near the improved roadways experienced health
ms, the county sampled and compared leachate composition from the affected roadways
e site and determined that the leachate from both the site and the roadways were
linated with PCPs. Roadway soil was subsequently removed and disposed of using land
reatment. In 1983, due to contaminated stormwater runoff from the former waste pon>
the property owner was directed under terms of an EPA Administrative Order to
e contaminated soil, divert surface water drainage away from the residential portio
site, and cap contaminated soil. This Record of Decision (ROD) specifies a final
for the contaminated soil and complements a 1986 ROD which determined that no
is necessary to remediate shallow ground water. The primary contaminants of
n affecting the soil are organics including PAHs, PCPs, and dioxins.(See Attached
ml AnalyeJa a. Dmcriptora
ord of Decision - United Creosoting, TX
ond Remedial Action - Final
taminated Media: soil
Contaminants: organics (PAHs, PCPs, dioxins)
ifterc/Open-Ended Term*
Ml Field, Group
dly Statement
19. Security CIซM (This Report)
None
20. Security Clue (Thiซ Page)
Mnn o
21. No. ofPigee
83
22. Price
(.18)
See Instruction* on Re vent
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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PA/ROD/R06-89/053
nited Creosoting, TX
econd Remedial Action - Final
5. Abstract (continued)
le selected remedial action for this site includes excavation and onsite treatment of
1,000 cubic yards of soil containing contaminants which exceed target action levels,
;ing critical fluid extraction and recycling or discharging wastewater generated during
le treatment process; incinerating and disposing of the liquid organic concentrate
;sidues offsite; spreading treated soil on commercial portion of the site; backfilling
isidential areas with clean fill; and air monitoring. The estimated present worth cost
)r this remedial action is $22,000,000 which includes present worth O&M costs of
-9,750,000 for 30 years.
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RECORD OF DECISION
FOR
UNITED CREOSOTING SITE
CONROE
-
MONTGOMERY COUNTY, TEXAS
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SEPTEMBER 1989
105
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TABLE OF CONTENTS
DECLARATION BY THE REGIONAL ADMINISTRATOR
DECISION SUMMARY
I. LOCATION AND GENERAL DESCRIPTION 1
I. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
I. COMMUNITY PARTICIPATION 6
V. SCOPE AND ROLE OF REMEDIAL ACTION 7
V. SITE CHARACTERIZATION 7
'I. SUMMARY OF SITE RISKS AND REMEDIATION GOALS 12
I. DESCRIPTION OF ALTERNATIVES 20
X. EVALUATION OF ALTERNATIVES 24
X. SELECTED REMEDY 29
RESPONSIVENESS SUMMARY
APPENDICES
POTENTIAL ARARS FOR REMEDIAL ALTERNATIVES
[Table 4-2 from Feasibility Study Amendment Report] A
TEXAS WATER COMMISSION LETTER OF SUPPORT B
ADMINISTRATIVE RECORD INDEX C
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LIST OF FIGURES
'a DECISION SUMMARY Page
1 - Site Location Hap 2
w 2 - United Creosotmg Site Schematic 3
3 - Site Surface Water Drainage 8
4 - Area Wells Downgradient of United Creosotmg 10
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LIST of TABLES
DECISION. SUMMARY
Page
TABLE 1: Chemicals of Concern in Soils 12
TABLE 2A: Residential Exposure Scenario 16
TABLE, 28: Worker Exposure Scenario 16
TABLE 3: Remedial Alternatives Cost Comparison Summary .... 28
TABLE 4: Target Action Levels for Contaminants in Soils ... 30
TABLE 5: Applicable or Relevant and Appropriate Requirements
for the Selected Alternative 32
APPENDICES
Table 4-2: Potential ARARs
[from Feasibility Study Amendment Repo-t] A-l
111
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DECLARATION BY THE REGIONAL ADMINISTRATOR
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DECLARATION
UNITED CREOSOTING COMPANY
RECORD OF DECISION
September 1989
NAME AND LOCATION
i
ed Creosoting Company
oe, Montgomery County, Texas
EMENT OF BASIS AND PURPOSE
decision document presents the selected remedial action for the
ed Creosoting site, in Conroe, which was chosen in accordance
the requirements of the Comprehensive-Environmental Response,
ensation, and Liability Act of 1980 (CERCLA), as amended by the
rfund Amendments and Reauthonzation Act of 1986 (SARA) and, to
extent practicable, the National Oil and Hazardous Substances
ution Contingency Plan (NCP). This decision document explains .
factual and legal basis for selecting the remedy for this site.
Texas Water Commission supports the selected remedy. The
rmation supporting this remedial action decision is contained in
administrative record for this site.
SSMENT OF THE SITE
al or threatened releases of hazardous substances from this site,
ot addressed by implementing the response action selected in this
rd of Decision, may present an imminent and substantial endangerment
ublic health, welfare, or the environment.
RIPTION OF THE SELECTED REMEDY
major components of the selected remedy include the following:
mple the residential area to better delineate all soils falling above
e target soil action levels established in this Record of Decision.
,cavate all soils from residential and commercial portions of the site
at are above the respective human health criteria and treat via
'itical Fluid Extraction.
spose of the organic concentrate from the extraction process by
'f-site incineration.
- human health criteria and as treatment standards for K001 contaminated
ils are met, the treated soils will be reburied on the appropriate
rtion of the site.
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DECLARATION OF STATUTORY DETERMINATIONS
Tne selected remedy is protective of hunan health and the environment,
complies with Federal and State requirements that are legally applicable
or relevant and appropriate to the remedial action, and is cost-effective.
This remedy utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable, and
it satisfies the statutory preference for remedies that employ treatment
that reduce toxicity, mobility, or volume as their principal element.
Because this remedy will not result in hazardous substances remaining
on site above health-based levels, the five-year review will not apply
to this action.
9/2Q/8Q
_
Robert E. Layton, Jr./P.E.
Regional Admini st-ator
Environmental Protection
_
Date
Agency, Region 6
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DECISION SUMMARY
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DECISION SUMMARY
UNITED CREOSOTING COMPANY
RECORD OF DECISION
September 1989
I. LOCATION AND GENERAL DESCRIPTION
The United Creosoting Company site is located 40 miles north of Houston
in the City of Conroe, Montgomery County, Texas [Figure 1]. The site is
one fourth mile southwest of the Missouri-Pacifie Railroad and Loop 336
intersection. Bound on the west and south by Alligator Creek, on the
north by Dolores Street, and on the east by the Missouri-Pacifie rail
lines, the property is approximately one hundred acres in size. The
physical characteristics of the sue have been altered by redevelopment
of the property, which has resulted in residential and light industrial
structures typical of suburban settings.
Approximately 13,000 people currently live within a two-mile radius of the
site. The site is now occupied by the Clarke Distributing Company, Conroe
Construction Company, and the Tanglewood East Subdivision [Figure 2].
However, other residential areas surround the site to the immediate north,
west and south, while industrial and commercial land uses are evident to
the east.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The United Creosoting Company operated as a wood preserving facility
from 1946 through the summer of 1972. With the exception of the process
building, where timber was debarked and cut to the desired product, the
process areas became scarred by an accumulation of the black oily chemicals
used for treating the lumber. Historical aerial photographs and analytical
data obtained to date have been utilized to describe tne process areas as
they existed during active operations.
Formed lumber, such as telephone poles and railroad ties, were treated in
a two-step process by the pressurized addition of pentachlorophenol [PCP]
and creosote. The pressure cylinders were rinsed and the wastewater
routed to one of the two process waste ponds located onsite. Segregation
of the two waste streams allowed possible reclamation and reuse. The
larger pond held mainly the creosote waste and the smaller pond the PCP
process waste.
No evidence exists that PCP was produced onsite. However, PCP was stored
in one or more of the storage tanks onsite. Creosote was produced via a
coal tar distillation unit onsite and stored in lined pits just east of
the process waste ponds. Creosote and other distillate fractions of coal
tar included polycyclic aromatic hydrocarbons [PAHs] of varying molecular
weights. Coal tar pitch, a dark brown to black amorphous residue, was an
unusable by-product which was apparently disposed of in the larger process
waste pond.
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WOT*
2T30-W
USOS 7 .5 mftuft MriM tocograaMc map
Conroc. TO Ourtorngta, 1971
1000
1000 1000
1 HJOMCTV
FIGURE 1 LOCATION MAP OF UNITED CREOSOT1NQ
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Missouri Pacific
Railroad
Conroe
Construction
Company
Clark*
Distributor
Company
Tangle wood
East
Subdivision
Vacant
ATM
Apprpxlmate^cak
1"-340FWt
FIGURE 2 SCHEMATIC SITE LAYOUT
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In February 1970, the Texas Water Commission [TWC, at that time the Texas
Department of Water Resources, TWC's predecessor agency], conducted a site
investigation of United Creosoting and found no discharge of waste water
from the, site. Abandoned in 1972, the most apparent evidence of the
former wood preserving operations was the remnant of the two waste ponds,
an office building, and a garage structure. In 1977, the TWC inspected
the site and reported that the former waste ponds were being backfilled.
Redevelopment of the sue had begun at this time.
During the summer of 1980, Montgomery County obtained soils from the
United Creosoting site for improvements to Metis Road, Mockingbird Lane,
and various roads in the Lake Conroe Forest Subdivision. These soils
consisted of surface soils and pond backfill from the Clarke Disfibuting
property. Citizens living along Metts Road complained of headaches,
burns, respiratory problems, and danage to vegetation. Samples were
collected from the roads and several locations on the Clarke Distributing
Company property. Analysis of leachate from these soils indicated PCP
concentrations up to 20.3 mg/L. Montgomery County officials removed the
contaminated soils from the affected roadways and disposed of the soils
by landfarm treatment.
In August 1982, TWC installed three monitoring wells on site. Additional
wells were installed by the United States Environmental Protection Agency
[EPA] Region 6 Field Investigation Team and by the National Center for
Groundwater Research in 1982 and 1983. Analytical results of samples
taken from these wells indicated that PAH and PCP contamination existed
in the uppermost water bearing zone.
TWC submitted the United Creosoting site as a candidate for cleanup under
the Superfund program in August 1982. The immediate concern at that time
was contaminaled surface water runoff flowing from the former waste ponds
area into Tanglewood East Subdivision. The TWC collected additional
soil, water and air samples from the site during the remainder of 1982
and inlo early 1983. In September 1983 the United Creosoting site was
included on the proposed National Priorities List by EPA and thus became
eligible for remedial funding. T48 Federal Register 40658, September 8,
1983]
In early December 1983, EPA initiated an immediate response action at
United Creosoting. Twenty-five surficial soils samples were taken in
the vicinity of the former wasle ponds and within the Tanglewood East
subdivision. The soils were found to be contaminated with PCP and
chlorinated dioxins and dibenzofurans, trace byproducts of commercial
grade PCP. It was suspected that the source of the contamination might
be storm water runoff from former waste pond areas located on the Clarke
Distributing property.
Based on the sampling results, Clarke Distributing was directed under the
terms of an EPA Administrative Order on Consent to undertake an immediate
response action within the area of the former waste ponds. The action
was completed in April 1984. Exposed sections of contaminated soils were
regraded so that surface water drainage was diverted away from the
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subdivision. Areas of contaminated soil were capped with a synthetic
membrane and at least 6 mcnes of compacted clay. Access to the cap area
was "estncted by the addition of 200 feet of fence, and drainage ditches
were constructed to channel cap area runoff to the south through Clarke-
owned -vacant land.
A Cooperative Agreement for a Remedial Investigation and Feasibility
Study (RI/FS) was awarded to the State of Texas in March 1984. Fieldwork
for the Remedial Investigation was conducted in two phases, the first in
December 1984 and the second in August 1985. The data generated was used
to estimate the extent and magnitude of contamination at the United
Creosoting site, and to develop and evaluate several remedial alternatives
for the Feasibility Study.
This feasibility study was completed in May 1986. Alternatives evaluated
in the report included offsite and onsite thermal desfuction, offsite
and onsite land fill disposal, consolidation and permanent or temporary
capping, and no action. In August 1986, EPA proposed a remedy for the
site which included:
o Purchase of seven properties above and adjacent to the former
pond area;
o Consolidation of soils contaminated above health-based levels
and vis.ibly contaminated soils in the pond area;
o Construction of a temporary cap over the pond area;
o Evaluation of innovative technologies as possible permanent
remedies, and;
o Natural attenuation of the ground water contamination.
EPA also proposed to consider a re-evaluation of this remedy in five
years if no innovative technologies became available.
In August 1986, EPA held a public meeting at tne Travis Junior High
School in Conroe to discuss this proposal and the other alternatives
developed with tne residents in Conroe. The major comment received from
the residents was a request that EPA purchase all of the homes in the
Tanglewooa East subdivision. However, this was not necessary to
implement the remedy and therefore could not be done. The public also
expressed concern over the use of incineration near a residential area.
A third major comment at the meeting regarded the use of biological
treatment as a remedy.
EPA signed a Record of Decision on September 30, 1986, selecting the
originally proposed alternative as the remedy for United Creosoting.
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On October 17, 1986, Superfund was reauthorized with significant changes
to the types of alte-natives to be evaluated. Tnese changes included the
preference for onsite remedies and the use of treatment technologies to
reduce the nobility, toxicity, or volume of waste to the maximum extent
practicable. In March 1987, two treatabi1ity studies were initiated to
evaluate innovative technologies as possible remedies for the site. These
treatability studies involved biological treatment and critical fluid
extraction. A biological treatment bench scale study was conducted from
August 1988 to November 1988. Critical fluid extraction was evaluated
with a pilot scale unit set up on sue in March 1989.
The results of these treatability studies were reported in an amended
feasibility study in June 1989. Tnese results, along with a proposed
plan to use critical fluid extraction as the remedy for the site, were
presented to the public in July 1989.
Implementation of a permanent remedy at this time would preclude the need
for the consolidation and temporary capping portion of the "emedy selected
in the 1986 ROD. EPA will finalize the acquisition of the seven properties
in the former pond area. Six of these properties have been purchased;
EPA is awaiting the removal of an Internal Revenue Service lien against
the seventh property.
During the course of the ongoing investigation, EPA has identified nine
Potentially Responsible Parties [pR?sj fo" this site. Althougn PRPs have
been given the opportunity to participate in all actions that have been
taken tnrough the 1986 Record of Decision, no responses have been received
to date.
The PRPs will also be offered the opportunity to participate in the
implementation of the final selected remedy. If negotiations are still
unsuccessful, the cleanup will be Fund financed, and appropriate cost
recovery actions will be sought at a later date. Any additional PRPs
identified will also be offered the opportunity to voluntarily participate
in implementing the selected remedy.
II. COMMUNITY PARTICIPATION
During the 1940's, when United Creosoting began operation, the site was
relatively isolated from any significant population concentrations or
urban development. Once operations ceased, in 1972, the property remained
essentially dormant until redevelopment of the area began in 1977.
Residential property owners were basically unaware of the previous land
usage and the potential hazards until the site was added to the National
Priorities List in September 1983.
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An initial property owne-s1 meeting was held on September 6, 1983, to
discuss the Superfjnd program and current site conditions. The vast
majority of those in attendance demonstrated a very high level of concern
about the long-term effects of continuous exposure to contaminants found
onsue. In suosequent meetings they have requested a total buyout of the
r" subdivision.
The press release announcing the public comment period and public meeting
f for the alternatives presented in this ROD was issued on July 10, 1989.
The,comment period began on July 17 and ended on August 15, 1989. An
open house was held with the area residents on July 15 to outline the
alternatives presented in the Feasibility Study Amendment Report. Forty
people registered at this open house. The public meeting was held on
August 3, 19S9, in the St. Marks Lutheran Church Fellowship Hall in
Conroe, Texas. Forty-eight people registered at the meeting and six made
' oral statements o" asked questions.
f IV. SCOPE AND ROLE OF REMEDIAL ACTION
This Record of Decision specifies the final remedy for contaminated soils
at the Unite: Creosotmg site. Since contaminants will be removed from
these media to nealth based levels, this ROD complements the 1986 decision
that no action is needed to remediate tne shallow ground water.
V. SITE CHARACTERIZATION
~j Topography
The natural topography at the United Creosotmg site comprises gently
_ rolling uplands and the natural vegetation consists of virgin forest. As
a result of industrial and residential development, much of the natural
soils in the site vicinity have been disturbed or covered by fill material
and various structures. Alligator Creek, which skirts the southwestern
f portion of the site, winds through residential properties in a southern
direction under subdivision streets in a galvanized culvert. Once offsite,
Alligator Creek flows in an improved channel for five miles to the West
Fork of the San Jacinto River.
Surface water drainage enters Alligator Creek at various locations on and
off the United Creosoting site [Figure 3]. Overall site surface water
* drainage flows to the south. The subdivision properties drain into the
streets of Tanglewood East, and then into Alligator Creek via culverts.
Conroe Construction property runoff flows west into the subdivision
drainage system at Arlington Street. Clarke Distributing Properties dram
to the south and into a ditch which feeds Alligator Creek. The cap area
over the former waste ponds also drams into this ditch, and runoff from
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I
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paved areas is forced into the ditch by curbing. There is minimal "unoff
fron Clarke Distributing into the east drainage ditch, just west of the
Missouri-Pacific Railroad. This railroad ditch and tne vacant area
drainage ditch do not interact.
Geology
The United Creosoting site is geographically situated in the West Gulf
Coastal Plan Physiographic province of Texas. The natural soils at the
site consist of the Conroe and Splendora series. These soils range from
gravelly loan to loamy fine sand of nearly level to 5-percent slopes.
The soils have moderate available water capacity.
The site is underlain by unconsolidated sand, gravels, and clay in
alluvial deposits. These deposits are of Pleistocene Age (3 million to
20 thousand years old) and were formed by high-gradient braided streams
that flowea coastward from uplands to tne north. The surficial sediments
at the site belong to the Willis Sand Formation, the most coarse of the
Pleistocene Formations.
The Willis Formation consists largely of clayey sand and gravel, and some
localized clay beds. The gravel is fairly coarse, is uniformly sandy,
and contains much fossilized or petrified wood. The Willis Formation
dips toward the Gulf at about 10 feet per mile and, in the vicinity of
the sue, is estimated to be approximately 70 feet thick. The approximate
elevation of the top of the Willis Formation at the United Creosoting
Company site is 230 feet MSL.
Underlying the Willis Formation are the Goliad Sand (Pliocene Age),
Fleming Formation (Miocene Age), Catahoula Sandstone (Miocene Age), and
the Jackson Group (sandstone and clay members of the Eocene Age).. The
thickness of these sediments above the top of the Jackson Group is
approximately 3,600 feet in the vicinity of the site.
Hydrogeology
Ground water is the major source of public and industrial water supplies
in Montgomery County, Texas. At least 60 wells have been reported in
frequent use within the Chicot and Evangeline aquifers up to two miles
downgradient from the United Creosoting site [Figure 4]. High volume,
multiple-user wells such as the City of Conroe municipal supply wells are
generally screened in the deeper Evangeline sand and single-user domestic
wells are found in the shallow Chicot formation.
In the Conroe area, the Chicot Aquifer consists of the Willis Sand. The
Evangeline Aquifer comprises a sequence of alternating sands and clays of
the Goliad Sand and part of the Fleming Formation above the Burkeville
Aquiclude. The flow direction in both the Chicot and Evangeline Aquifers
is generally southward at a hydraulic gradient of 4 feet per mile and
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LEGEND:
MLOW SUMAC!)
FIGURE 4
*
EXISTING AREA WELLS DOWN-GRADIENT OF THE UNITED CREOSOTING SITE
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5 feet per mile, respectively. The Chicot Aquifer is as shallow as 66 to
76 feet below g-ouna surface and is recha-ged by precipitation. The
Evangel me sits 825 to 1,190 feet below ground surface and has decreased
In water level as much as 10 to 25 feet over the last decade due to
withdrawals in the Conroe area.
As a domestic wate" resource, use of the the shallow water bearing zone
directly beneath the site is not anticipated due to the extremely low
yield. This 25-foot zone is comprised of two interconnected sand lenses
separated intermittently by a thin clay layer. The upper, unconfined
lens begins at a depth of 14 to 44 feet below the ground surface and
averages approximately 10 feet thick while the lower, semi-confined lens
begins at a deptn of 26 feet. Ground water movement in this shallow
aquifer averages between 5 to 15 feet per year in a southern direction.
A second water bearing zone exists at an approximate depth of 56 to 84
feet below the ground surface and is approximately 20 feet thick. Ground
water movement in tms deeper zone also averages between 5 to 15 feet per
year in a southern direction. However, a clay aquitard separates this
zone from the shallow aquifer. The thickness of the aquitard ranges from
22 to 32 feet and the permeability of this layer is approximately 10
feet per day, indicative of clays which can retard vertical migration.
Nature and Extent of Soils* Contamination
The Remedial Investigation fieldwork at United Creosoting was conducted
in Decembe'" 1984 and August 1985 with the purpose of acquiring site-specific
data needed to document the existence of hazardous substances and any
threats of releases of nazardous substances at the site. Contaminants of
concern in soils* were selected by assessing their toxicity, concentration,
and persistence. Background concentrations of some of the contaminants
commonly found in suburban settings were used for comparative purposes.
The 1985 RI Report confirmed the following:
The light commercial area contains mainly subsurface soils
contamination in the former ponds area down to a depth of
20 to 25 feet [water table]. A total of 40,000 cubic yards
is estimated above background concentrations.
No soil contamination was found in the clays beneath the
water table.
The residential area contains mainly shallow soils
contamination to an average depth of 3 feet. Around the
former waste ponds area, along the prior processing area,
and in prior drainage pathways, the total estimate is
approximately 53,000 cubic yards above background
concentrations.
*0tner media specific findings can be found in the 1986 Record of Decision.
(i.e. ground water, air, etc.)
11
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Visual areas of contamination throughout both the industrial
and residential areas in tne form of "tar mats" and stressed
vegetation include approximately 6,000 cubic yards (included
in the above estimates).
Contaminants of concern include polycyclic aromatic hydrocarbons [PAHs],
pentachlorophenol [PC?], and chlorinated isomers of dioxin and dibenzofuran
Table 1 lists only the maximum concentrations of these compounds found in
different areas of the United Creosoting site. Most of the high
concentrations reported in the residential area were reported in the area
close to the asphaltic mat of the southwest portion of the commercial
area.1 Average concentrations over the residential area are significantly
lower for each contaminant.
During the investigation of options for treating the soils, the site was
not re-sanpled. A more detailed sampling effort will be required before
conducting the remedial design. Tms was expressed as a concern at the
August 3, 1989, public meeting. Therefore, EPA will conduct pre-design
sampling in tne residential area.
VI. SUMMARY OF SITE RISKS AND REMEDIATION GOALS
In 1985, tne Agency fo" Toxic Substances and Disease Regisfy [ATSDR]
was consulted to establish remedial action criteria for the sue. At
that time, ATSDR indicated that a criterion of 100 pans pe" million
[ppm] of total PAHs in the soil would adequately protect human health.
Since 1985, the methodologies for evaluating risks and remedial action
criteria have been refined. The remedial action criteria used in this
ROD were developed based on these refined methods published in: Risk
Assessment Guidance for Human Health Evaluation Manual, 1989 OSWER
Directive 9285.701A and the Superfund Public Health Evaluation Manual,
1986 OSWER Directive 9285.4-1.
The overall goal of the remedial action is to reduce the potential
risks posed by the site to between one in ten thousand and one in one
million excess cancer risk incidents. The methodologies outlined in
the guidance were used to develop site specific criteria for the
contaminants at United Creosoting to meet this objective.
Human Health Impacts
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 a typical assessment. Only the worst case
risk is presented. Conservative assumptions were used to explore the
potential for adverse health effects to occur under conditions that tend
to overestimate risks. As a result, the risk assessment 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.
12
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The United Creosoting site comprises two separate areas, a residential
area borae"ed on the east by a lignt commercial area. Therefore, a
different set of circumstances determine the exposure for residents living
onsite versus that for employees working onsite. For instance, workers
onsite^would spend only a portion of their day in potential contact with
contaminants in comparison to residents which live onsite. In addition,
this partial exposure would last only for the number of years a person
was employed onsite.
Since the residential exposure scenario is the most conservative, potential
adverse health impacts were analyzed to develop a "worst case" example.
This exposure scenario is based on an individual living on the site for
70 years, from infancy through adulthood. The assumption is made that
exposure to the maximum concentration level identified onsite occurs
every time exposure occurs over a resident's 70 year lifetime. Table 2A
lists other assumptions which were used for this scenario. For comparison,
Table 2B lists the assumptions which could be used for an office employee
wooing onsite.
Chemicals onsite which are not cancer-causing [noncarcinogenic] compounds
are found mainly in subsurface soils in the former ponds area or in
surficial tar mats in the residential area. Current exposure is thus
limited. If the areas are disturbed, adverse health effects can result
from the levels identified at United Creosoting as established by ATSDR
in 1986. For example, after continued exposure, an individual might
develop skin irritations fron contact with PAHs in soils. However, these
symptoms would disappear when exposure is eliminated. PCP is currently
considered noncarcinogenic, yet ingestion may nesult in kidney and liver
problems.
One assumption requiring discussion involves the tar mat areas in
residential areas which contain high levels of PAHs. As a mat degrades
and becomes similar to soil, uptake of contaminants from incidental
exposure may increase. The risk of a person developing health problems
from ingesting or dermally contacting contaminants in the soil-like
material may also increase. However, contaminants in the tar are unlikely
to be ingested at the same rate as if ingested in the form of actual
soil. Although this scenario is extremely conservative at present, over
the long term, the given soil ingestion rate may become more realistic.
PAHs known or suspected to be cancer-causing [carcinogenic] compounds may
vary in toxic potency. Coupled with noncarcinogenic effects, the picture
of toxicity becomes complex. Therefore, exposure and uptake of these
compounds into the body varies not only with the circumstances at United
Creosoting, but also with the mixture of PAHs present. For example,
current risk assessment methodology assumes the total maximum concentration
of all carcinogenic PAHs is essentially all benzo(a)pyrene [BAP], one of
the most toxic PAHs onsite. At United Creosoting, BAP represents from
0.5 to 14% of the total carcinogenic PAH concentration.
15
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Under tne scenario evaljatea, a pe-son who is exposed to the maximun
concentration of carcinogenic PAHs found in the residential area might
have a seventy-four in one thousand chance of developing cancer over his
expected seventy year lifetime if no remedial action is taken at the site.
However, tnis is an extremely conservative estimate of the excess cancer
risk for PAHs found in soil at the United Creosoting site. First, the
high concentration utilized in this risk estimate for exposure to PAH
contaminated soils was detected in a tar mat area and a soil ingestion
rate was used. Next, the total concentration of carcinogenic PAHs was
assumed all BAP. Therefore, the actual excess cancer risk due to
carpinogenic PAHs at the site is most probably lower than seventy-four
in one thousand and can even be zero.
Some dioxins and furans are also known to be carcinogenic and are present
in the soils at United Creosoting. However, EPA has established criteria
for dioxins ana furans in soils. Guidance used to evaluate the levels
present in soils at United Creosoting include Interim Procedures for
Estimating Risks Associated with Exposures to Mixtures of Chlorinated
Dibenzo-p-Dioxins and -Dibenzofurans, EPA/625/3-87/012, March 1987 and
also International Toxicity Equivalency Factor (1-TEF) Method of Risk
Assessment for Complex Mixtures of Dioxins and Related Compounds, Report
No. 176, August 1988.Although concentrations of these contaminants at
United Creosoting do exceed the health cruena for soils in a residential
area, exposure is somewhat limned due to grass cover in most yards.
Environmental Impacts
Environmental concerns have been partially addressed in past removal
activities and in the 1986 Record of Decision. For example, the source
of ground water contamination is mainly PCP and noncarcmogenic PAHs
found in the former ponds area. The temporary cap and diking of this
area prevented further contaminated surface water runoff. The 1986
Record of Decision specified removal of this source. This Record of
Decision includes how these compounds will be addressed in order to
alleviate further degradation of groundwater and allow natural
attenuation of the aquifer.
Remediation Goals
Remediation goals for the soils at the United Creosoting site involve
reducing the potential for adverse human health and environmental impacts.
Action levels for soils that were developed in the 1986 Record of Decision
[ROD] took into account both human health and environmental impacts.
However, these levels can now be expressed in a more definitive manner
than possible in the 1986 ROD.
17
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Toxicity information and tne methodology for utilizing the information
is Dette".defined today tnan prior to the 1986 ROD. In the past, an
entire class of compounds we-e identified as problematic if carcinogenicity
was suspected for one of tne individual chemicals. However, individual
chemical toxicities of particular groups of compounds are better understood
and more easily communicated today. For instance, the 2,3,7,8-dioxin
isomers are now known to be the only isomers of dioxin and furan that
exhibit carcinogenic characteristics. Another example is apparent with
respect to PAHs. Although no criteria have been established for PAHs in
soils to date, as for dioxins, a risk assessment methodology has been
developed to estimate and better express action levels for these contaminants
in soi1.
The potential threat to huinan health posed by chlorinated dioxins and
dibenzofurans is based on the established criteria for 2,3,7,8-tetrachloro-
dibenzodioxin (TCOD). Chlorinated dibenzofurans and all other isomers of
dioxins are considered to be less toxic tnan 2,3,7,8-TCDD and are expressed
in toxic equivalents of 2,3,7,8-TCDD. Therefore, although 2,3,7,8-TCDD
was not detected at the United Creosoting site and is not typically found
with the other dioxin isomers associated with PCP, the target action
level for dioxins and furans in soils is expressed in parts per billion
(ppb) toxic equivalencies of 2,3,7,8-TCDD:
Target Soil Action Levels for Dioxins and Furans
Residential Soils
Industrial Soils
1 ppb Total 2,3,7,8-TCDD Equivalents
20 ppb Total 2,3,7,8-TCDD Equivalents
These levels are intended to be utilized as criteria in evaluating a
representative distribution of contaminants in shallow soils. The
difference between residential and industrial soils was derived from the
differences in exposure anticipated in a residential setting versus a
light commercial area.
Today, most remedial activities are driven by carcinogenic compounds
since the action level for carcinogens may be orders of magnitude more
stringent than those levels developed for noncarcinogens. However, if
carcinogens are not present, noncarcinogenic compounds may also drive a
remedial action when concentrations occur at levels of concern to either
human health or the environment. Therefore, two sets of criteria for
contaminants in soil can be established to effectively remediate a site
based upon both carcinogenic and noncarcinogenic action levels.
18
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The contamination at United Creosoting is distributed in such a manne"
that both carcinogenic and noncarcinogenic contaminants appear in shallow
soils throughout the site. However, subsurface soils in the former ponds
area contain mainly pentachlorophenol [PCP] and noncarcinogenic PAHs.
As specified in the 1986 ROD, these compounds present a threat to human
health if disturbed and also present a threat of continued groundwater
contamination. Although the 1986 ROD set a clean-up level of 100 parts
per million [ppm] for Total PAHs in soils, this ROD presents two sets of
action levels for PAHs in soi l--carcmongemc and noncarcinogenic PAHs--
to ensure effective protection of human health and the environment.
Target soil action levels for the areas where no carcinogens are present
were calculated on the basis of noncarcinogenic health effects. These
calculations are less complicated than carcinogenic estimates, as described
in the same guidance documents previously referenced for calculating
excess cancer risk. For example, the most conservative exposure scenario
was used: a child who ingests 0.0002 grams of soil per day. Each chemical
has a reference dose for acceptable daily intake. The ratio of the
calculated intake to the reference intake should not exceed unity.
EPA retains the 1986 ROD action level of 150 ppm for PCP in soils. This
level is ten times more protective than the level calculated for human
health [1,500 ppm]..Yet this level is appropriate in consideration of
removing subsurface contaminants to prevent further impact to the upper
water bearing zone. Therefore, the target soil action level calculated
for PAHs to be protective of human health [20,000 ppm] was also decreased
by a factor of ten to account for the potential impact of subsurface PAHs
to the environment:
Target Soil Action Levels for PCP and Noncarcinogenic PAHs
150 ppm Total PCP
2,000 ppm Total Noncarcinogenic PAHs
These levels are intended to be utilized in evaluating a representative
distribution of contaminants in subsurface soils. Naphthalene was utilized
for evaluating the effects of noncarcinogenic PAHs and for deriving a
target soil action level in terms of "Total Noncarcinogenic PAHs".
The potential threat to human health posed by carcinogenic PAHs is based
upon the toxic potency of benzo(a)pyrene [BAP]. The current methodology
in assessing excess lifetime cancer risk assumes that all carcinogenic
PAHs are BAP. For this reason, many RODs have specified target action
levels for "Total Carcinogenic PAHs" in soil, assuming 100 percent BAP.
However, other carcinogenic PAHs are now known to be toxic relative to
BAP. EPA is currently attempting to rank other PAHs against BAP in
toxicity equivalents similar to that method used for TCDO.
Since the number which represents "Total Carcinogenic PAHs" is a
summation of individual carcinogenic PAHs, the toxicity of the mixture
19
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Is not effectively represented. Two samples may snow the same total
concentration of PAHs and yet tne toxicmes may be significantly different.
An action level, howeve0 expressed, actually reflects the BAP concentration
calculated from the risk level assumed for remediation of a site. Therefore,
this ROCT expresses action levels in ppb BAP equivalencies to ensure that
the toxicity level of a mixture will be evaluated rather than merely the
total concentration of carcinogenic PAHs at the time of remedial action:
Target Soil Action Levels for Carcinogenic PAHs
Residential Soils 330 ppb Total BAP Equivalents
' Industrial Soils 40,000 ppb Total BAP Equivalents
These levels a-e intended to be utilized as the criteria in evaluating a
representative distribution of contaminants in surface soils. The difference
between residential and industrial soils was derived from the differences
in exposure anticipated in a residential setting versus a light commercial
area, as previously outlined in Tables 2A and 28.
The level for residential soils is set at the current detection limit of
individual PAHs in order to approach an excess risk level of one in one
million. Tne level expressed for industrial soils corresponds to an excess
risk of one in ten tnousand. These levels fall within EPA's acceptable
range for determining excess lifetime cancer risk.
VII. DESCRIPTION OF ALTERNATIVES
In accordance with the National Contingency Plan [NCP], 40 Code of
Federal Regulations Part 300, initial remedial approaches were screened to
determine which might be appropriate for the United Creosoting site. The
1986 Feasibility Study describes the details of this screening. The 1989
Feasibility Study Amendment Report revises this screening to account for
changes in developing and evaluating remedial alternatives under the
Superfund Amendments and Reauthorization Act of 1986 [SARA], Public Law
99-499, 100 Stat. 1613. From the possible remedies developed to address
contaminated soils at United Creosoting six alternatives were chosen for
detailed analysis. A No Action Alternative is included in the final
analysis to comply with the NCP requirements.
Alternatives which involve excavation activities (all except the No Action)
take into account the proximity of residences and area businesses during
implementation. Potential air emissions during excavation would require
intensive air monitoring and dust control. During remedial design, several
methods to control these emissions will be developed and evaluated to
ensure protection of human health. For example, knock-down spray [water]
could be used to control particulates stirred up during excavation. Since
contaminants are semi-volatile, the knock-down spray may be combined with
the pace of excavation [slower rate] to prevent adverse air emissions. A
contingency plan will be developed as part of the remedial design and area
residents will be informed of what to expect during this activity.
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This plan will describe the physical and work practice measures that will
be undertaken to minimize ana capture ai" emissions from the excavation
and processing of waste. In addition, it will summarize ai" quality
monitoring that will be performed at the site and in the community.
Finally^ it will establish the criteria for temporary relocation during
construction.
This Record of Decision is based upon soil sampling information obtained
in the 1985 Remedial Investigation. Each of the alternatives presented
in this ROD were developed on the basis of 72,000 cubic yards of soils
targeted for excavation in the 1986 ROD. While this data is adequate
t<5 frame the selection of broad remedial approaches possible for United
Creosoting, it is not sufficiently detailed to prepare an engineering
design for the remedy. Therefore, prior to the design of the remedy,
the residential areas will be resampled to accurately map contours of
soil contamination. This information will be assessed with the target
soil action levels specified in this ROD to clearly delineate areas of
surface soils that will be treated by the remedy. EPA will then meet
with the community to review and discuss this information. In accordance
with established agency policies, any significant difference in the
remedy that this data may produce will be addressed in an amendment to
this Record of Decision or in an "Explanation of Significant Differences"
document.
Soils at United Creosoting are contaminated with a RCRA listed hazardous
waste, K001 Wood Preserving Waste [40 CFR 261.32]. Therefore, the Land
Disposal Restrictions [LOR] for treatment and disposal of soils containing
the K001 listed waste are applicable requirements. For example, Best
Demonstrated Available Technology [BOAT] standards for treatment of K001
Nonwastewaters will be used to evaluate placement [rebunal] of treated
soils at the site, along with target soil action levels based on human
health criteria and current land use.
Conversely, PCP was not produced onsite and was not used in a manufacturing
process as a reactant, intermediate, etc [40 CFR 261.31]. Therefore,
Land Disposal Restrictions for the F021 listed PCP Waste are not applicable
for soils contaminated with PCP and trace dioxins/furans. Treatment
requirements for F021 wastes have not been promulgated to date. Therefore,
health based levels developed in this ROD would be more appropriate for
United Creosoting soils. However, other handling and temporary storage
requirements are relevant and appropriate for alternatives which treat
and dispose of contaminated soils onsite.
Ground water monitoring is included in all of the soil remedial alternatives
as part of post closure monitoring to ensure that natural attenuation
will occur. Although the time frame for establishing a trend towards
natural attenuation is dependent on the type of alternative implemented,
the cost for a 30 year period is included in each alternative since the
post-closure monitoring was specified in the 1986 ROD. For example,
excavation and ultimate destruction of the contaminants in the ponds area
may achieve a noticeable trend toward natural attenuation in a more timely
manner than consolidation and capping.
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Alternative 1: No Action
No remedial action would be conducted for soils at United Creosoting.
This alternative would not reduce the potential site hazards and would
not provide long-term protection of human health and the environment.
Since contaminants would remain onsite above health based levels, annual
maintenance and 5-year facility reviews would be required.
This alternative would cost approximately $244,100 in net present worth
dollars estimated over a 30 year period.
Alternative 2: Containment Onsite
Two separate caps would be constructed in accordance with minimum
technology requi 'enents untie" the Resource Conservation and Recove-y Act
of 1976 (RCRA), as amended, 42 U.S.C.ง6901 e_t _seฃ. One cap would be
placed over the former pond area and the other cap would be placed over
the tank farm area. Contaminated soil in the residential area would be
excavated and consolidated in one of these areas. Residential areas
excavated would be backfilled with clean fill and restored to pre-remedial
conditions as practical.
This alternative would prevent direct contact with tne contaminants as
long as the caps are intact. However, future land use could not be
effectively restricted to prevent contact with subsurface contamination
if the caps are damaged or the area disturbed. Vertical migration of
contaminants would be reduced, but the ground water would continue to be
impacted by the more mobile contaminants.
Implementation should take about 1 year to complete. Since contaminants
would remain onsite above health based levels, annual maintenance and
5-year facility reviews would be required. Tnis alternative would cost
approximately $2.4 million in net present worth dollars estimated over a
30 year period.
Alternative 3: Onsite Incineration And Reburlal
Soils would be excavated and treated in a mobile unit brought onsite
designed specifically for United Creosoting contaminated soils. The unit
would be equipped with advanced pollution controls and automatic shutdown
devices to ensure that all Federal and State requirements would be met
on a continuing basis.
Since incineration is a proven technology for destruction of these
contaminants, treated soil could be spread on the commercial portion of
the site as target soil action levels and LOR treatment standards are
met. Residential areas excavated would be backfilled with clean fill and
restored to pre-remedial conditions as practical.
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"ne mobile treatment unit would be amoved fron the me once treatment
>f United Creosotmg soils is completed. Implementation should take
pproximately 2 years. Maintenance and monitoring of the site would be
lecessany for the following year to ensure effectiveness of the remedy.
however, since contaminants would be destroyed, 5-year reviews would not
>e necessary for soils. This alternative would cost approximately $46
nil ion in net present worth dollars estimated over a 2 year period.
ilternative 4: Onsite Biological Degradation And Reburial
i
>oils would be excavated and treated onsue utilizing an enclosed
)iological treatment process.
\ biological treatment pilot study was conducted with contaminated soils
:rom United Creosoting site during the FeasiDility Study. This experiment
showed that biological treatment would:
(1) effectively reduce creosote compounds in soils to
acceptable levels, but
(2) eight yea^s of treatment would be required
to accomplish tnis Deduction, and
(3) the net toxicity of dioxin compounds
was not reduced altnough concentrations
of some isomers were reduced.
'reated soil rebuned on the commercial portion of the site might need a
:ap similar to that described in Alternative 2 since target action levels
:ould not be met. Although a 15 percent volume increase is anticipated,
excess treated soil could not be placed in the residential area. Residential
areas that were excavated would be backfilled with clean fill and restored
:o pre-remedial conditions as practical.
implementation would take from 8 to 10 years to complete. Since contaminants
tfould remain onsite above health based levels, annual maintenance and 5-year
:acility reviews would be required. This alternative would cost approximately
$7 million in net present worth dollars estimated over a 30 year period. If
j cap were included, this cost estimate would increase by about $2 million and
'mplementation would take an extra year to complete.
Alternative 5: Onsite Critical Fluid Extraction And Reburial
Soils would be excavated and treated onsite utilizing critical fluid
extraction. Contaminants would be removed from the soils and concentrated
in liquid form. The organic concentrate would be taken offsite for
iestruction and disposal at a commercially available incinerator. Although
10 facilities are currently permitted to burn dioxin contaminants, a few
facilities have applied for certification and should be available in the
lear future.
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Water generated from the process would be recycled o- discharged as necessany.
Appropriate testing would be performed to ensure water quality is adequate
for the ultimate discharge destination.
A pilot .scale treatabi1ity study using propane as the extracting medium
was conducted at United Creosoting during the Feasibility Study. This
study found:
(1) that organic compounds could be extracted from the soils
sufficiently to meet the health based concentration action
levels for industrial and commercial exposure,
(
(2j that processing soils onsite would take
approximately two years.
These results show that treated soil could be spread on the commercial
portion of the site as target soil action levels and LDR treatment standards
are met. Residential areas excavated would be backfilled with clean fill
and restored to pre-remedial conditions as practical.
The mobile treatment unit would be removed from the site upon completion
of the remedy. Implementation should take about 2 years from the date
' the unit is moved on site. Maintenance and monitoring of the site would
*" be necessary for the following year to ensure effectiveness of the remedy.
However, since contaminants would be removed and destroyed, 5-year reviews
would not be necessary for soils. This alternative would cost approximately
vป $22 million in net present wo^tn dollars estimated over a 2 year period.
Alternative 6: Off-Site Incineration And Disposal of Contaminated Soils
Soils would be excavated and taken offsite for incineration and disposal
in a commercially available facility. Although no facilities are currently
*- permitted to burn dioxin contaminants, a few facilities have applied for
certification and should be available in the near future.
Implementation should take approximately 2 years. Maintenance and monitoring
of the site would be necessary for the following year to ensure effectiveness
of the remedy. However, since contaminants would be removed and destroyed,
5-year reviews would not be necessary for soils. This alternative would
"^ cost approximately $190 million in net present worth dollars estimated over
a 2 year period.
fป
VIII. EVALUATION OF ALTERNATIVES
i
This section provides an analysis of the remedial alternatives considered
for soils remediation at the United Creosoting site. The no action
alternative [1] is not protective of human health or the environment, but
is utilized as a point of comparison with the other alternatives. No
further consideration is warranted for this alternative since the excess
cancer risk posed by the site is greater than EPA's action level of one
in ten thousand and the groundwater would continue to be impacted by
contaminated soils in the former pond area.
24
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Protection of Human Health and the Environment
Incineration alternatives [3 and 6] and critical fluid extraction with
incineration of the concentrate [5] would provide adequate protection of
human health and the environment by eliminating or preventing risk of
exposure through removal and destruction of contaminan*- in soils. The
biological treatment alternative [4] would not adequate.y address the
dioxin contaminated soils, although the human health risks would be reduced
to some extent from the degradation of PAHs. The capping alternative [2]
would1 prevent the direct contact threat and provide a barrier to any off-
site migration of contaminants via rainfall runoff, airborne dust, and to
some extent vertical leaching. However, capping alone is not a preferred
form of protection to the environment since the ground wateฐ would possibly
continue to be impacted by contaminated soils renaming in the formen
pond area.
Applicable or Relevant and Appropriate Requirements [ARARS]
All action alternatives can be designed to meet all potential applicable
or relevant and appropriate requirements of federal and state environmental
laws. Those "equipments identified for each remedial action alternative
at the United Creosoting site are included in Appendix A, as taken from
the Feasibility Study Amendment Report Table 4-2.
Since chemical-specific ARARs do not exist for the contaminants in soil
at United Creosoting, target soil action levels have been established
through current risk assessment methodology. All of the treatment
alternatives meet the target soil action levels except for the biological
alternative [4], which does not meet the dioxin target action level set
in this ROD.
Long-term Effectiveness and Permanence
Incineration alternatives [3 and 6] and critical fluid extraction with
incineration of the concentrate [5] would achieve long-term effectiveness
and permanence by destroying the contaminants of concern. Although biological
treatment [4] would permanently reduce the health and environmental impacts
from PAHs and PCP, impacts from dioxins would not be significantly affected.
Capping alone [2] would not achieve the same level of long-term effectiveness
and permanence as the treatment alternatives since the caps would have to
be maintained to prevent human health impacts and since the ground water
would possibly continue to be impacted from contaminants in the former
ponds area.
25
-------
Reduction in Toxicity, Mobility, and Volume
Incineration alternatives [3 and 6] and crmca1 fluic xtraction with
incineration of the concentrate [5] would achieve the greatest reduction
in toxicity due to ultimate destruction of the contaminants of concern.
Biological treatment [4] would not significantly affect the toxicity of
dioxins, although some reduction in toxicity of PAHs would occur. The
capping alternative [2] would not affect the toxicity of any of the
contaminants of concern.
Incineration alternatives [3 and 6] and critical fluid extraction with
incineration of the concentrate [5] would achieve the greatest reduction
in mobility through ultimate desfuction of contaminants. Biological
treatment [4] would not significantly affect the already low mobility of
dioxins, although some reduction in mobility of PAHs would occur through
destruction. Capping ~2] would reduce the mobility of contaminants,
although not to the sane degree as the treatment alternatives.
Incineration alternatives [3 and 6] and critical fluid extraction with
incineration of the concentrate [5] would achieve the greatest reduction
in volume due to ultimate destruction of contaminants. Biological
treatment [4] would result in a volume decrease through destruction of
PAHs. Howeve-, the volume of soils containing dioxin above human health
levels would actually increase. Capping [2] would not affect the volume
of contaminants.
Short-term Effectiveness
Incineration [3 and 6], critical fluid extraction with incineration of
the concentrate [5], and capping [2] would yield comparable short-term
effectiveness in reducing the human health and environmental risks
currently identified at the United Creosoting site.
Off-site incineration and disposal [6] would increase short-term health
risks due to increased handling and off-site transport of a high volume
of contaminated material. Biological treatment [4] would increase
short-term health risks due to increased handling of excavated material
over a prolonged implementation period, possibly 10 years.
Implementability
The capping alternative [2] would be relatively easy to implement in a
short timeframe. Incineration alternatives [3 and 6] and critical fluid
extraction with incineration of the concentrate [5] would not be difficult
to implement and could be implemented in approximately two years time.
The off-site incineration alternative [6] would prove impossible to
implement if commercial facilities refuse to accept contaminated soils
from Superfund sites due to space limitations. Residual ash from
incineration of soils would not be significantly less than the original
26
-------
volume of soil -equiTing treatment. The biological alternative [4] would
prove difficult to implement due to space constraints and would take
eignt to ten years to complete.
Cost
Table 3 lists the comparison of each treatment alternative in terms of
capital, operational, post closure monitoring and maintenance, and overall
present worth costs. Onsite critical solvent extraction followed by
incineration of the organic concentrate [5] is less costly than incineration
of soils [3] in both capital and operation cost. Site maintenance and
monitoring costs for the year after implementation are comparable. The
off-site incineration alternative [6] achieves the same 1-evel of protection
in a similar timef^ane, yet costs nine times more than the onsite alternatives,
The biological treatment alternative [4] does not achieve the same level
of protection as the othe" treatment alternatives although the operational
and present worth costs are much less costly. This alternative would have
to be supplemented with one of the other alternatives to account for dioxins.
The capping alternative [2] is less expensive than treatment alternatives.
Cost estimates are based on a 30 year maintenance and monitoring plan
whereas the actual maintenance would be required indefinitely. In addition,
5 year facility reviews would possibly fina this alternative in need of a
replacement cap o" alternate technology due to failure.
State and Community Acceptance
No written comments or questions were received during the public comment
period. Verbal questions and concerns raised at the open house and at
the public meeting on the alternatives presented by EPA focussed mainly
on three topics:
o how implementation of a remedial alternative would affect
daily lives of residents,
o how EPA could better communicate with residents throughout
the duration of the project [design and implementation],
o a total buyout of the subdivision.
EPA and the Texas Water Commission have concerns about the contractual
difficulties associated with a sole source contract since the critical
fluid extraction technology is currently a patented process. This
portion of the alternative could possibly be considered for a sole source
contract. EPA has authority to approve a contract sole source. However,
several options exist for contracting out the remedial alternative in a
competitive manner. These will be explored thoroughly during remedial
design.
27
-------
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X. SELECTED REMEDY
Onsite Critical Fluid Extraction, Offsite Disposal of Wastes,
and Reburial of Treated Soil
All soils exceeding the established target action levels as listed in
Table 4 will be excavated and treated utilizing critical fluid extraction.
Carcinogenic action levels are intended to be utilized as criteria in
evaluating a representative distribution of contaminants in shallow soils.
The difference between residential and industrial soils was derived from
the differences in exposure anticipated in a residential setting versus a.
light commercial area. Noncarcmogenic levels are intended to be utilized
in evaluating a representative distnbution of contaminants in subsurface
soils. Environmental concerns have been incorporated into these levels;
significant removal of subsurface contaminants in the former pond area
should prevent further groundwate- degradation. See Remediation Goals,
Section VI, for a detailed explanation of these numbers.
Excavation will proceed as necessary to prepare feed material for the
critical fluid extraction process. This activity will require
intensive monitoring to ensure that air emissions are suppressed to
levels which will not create a potential health impact to residents or
workers in the vicinity of the site. Although costs are not included
for temporary relocations, this option should be included and costs
adjusted on the basis of the pre-remedial sampling effort [Description
of Alternatives, Section VII] and circumstances at the time of remedial
design. Care would be taken to keep the residents and area businesses
aware of the activities to take place so as to minimize short-term
potential health impacts.
All soils excavated would be treated onsite utilizing critical fluid
extraction. Treatment activities will occur on the commercial side of
'the site, in a manner which minimizes disturbance of and impact to the
community. As contaminants are removed from soils and concentrated in
liquid form, appropriate precautions will be taken for temporary storage
of the concentrate onsite. Similarly, appropriate precautions will be
taken for the storage of propane or other solvent to be used in the
treatment process. As soon as practicable, i.e., sufficient quantity for
transport, the concentrate will be transported to an off-site disposal
facility. If no permitted incinerator facility is available to accept
the concentrate for destruction, an off-site temporary storage facility
is preferred to long-term onsite temporary storage of the concentrate.
Results of a pilot scale treatability study using soil from the United
Creosoting site show significant removal efficiencies of all contaminants
of concern. Confirmatory sampling should show that health levels are
met and that treatment standards for K001 contaminated soils are met
29
-------
L
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Table 4: Target Action Levels for Contaminants in Soils
United Creosoting Site - Conroe, Texas
Target Soil Action Levels for Carcinogenic Compounds
Polycyclic Aromatic Hydrocarbons
Residential Soils 330 ppb Total BAP Equivalents
Industrial Soils 40,000 ppb Total BAP Equivalents
Dioxins and Furans
Residential Soils 1 ppb Total 2,3,7,8-TCDD Equivalents
Industrial Soils 20 ppb Total 2,3,7,8-TCDD Equivalents
Target Soil Action Levels for Noncarcinogenic Compounds
Total Noncarci nogem c PAHs 2.CCO pp"i
Total PC? 15C ppn
30
-------
prior to reburial. AT- emissions due to treatment would not occur since
the process is a closed process. Water generated from the process would
be recycled or discharged as necessary. Appropriate testing would be
performer to ensure water quality is adequate for the ultimate discharge
destination.
Optimization of the process Is feasible to obtain the target soil action
levels specified in this ROD for industrial land use. Therefore, treated
soil could be spread on the commercial portion of the site as target soil
action levels and LDR treatment standards for K001 contaminated soils
are met. Residential areas excavated would be backfilled with clean fill
and restored to pre-renedy condition as practical. If the volume of soil
is excessive for placement on the commercial property, the remedy will be
clarified by an "Explanation of Significant Differences".
The mobile treatment unit would be amoved from the site after treatment
of contaminated soils are complete. Groundwater monitoring wells not to
be utilized as part of post-closure monitoring will be decommissioned and
the areas restored to pre-remedial condition as practical. To the extent
legally feasible, a notice will be recorded in the real property records
of any property physically impacted by the remedial action. Each notice
should include a statement of the concentration of contaminants remaining
on site.
Implementation should take about 2 yea-s. Maintenance and monitoring of
the site would be necessary for the following year to ensure effectiveness
of the remedy. However, since contaminants would be removed and destroyed,
5-year reviews would not be necessary for soils. Costs for this alternative
were presented previously in Table 3.
Statutory Determination
Onsite critical fluid extraction of soils and off-site incineration of
the liquid concentrate is protective of human health and the environment.
All requirements for this remedy that are Applicable or Relevant and
Appropriate [ARARs] can be met through adequate design and planning.
ARARs for this remedy are listed on Table 5 and Table 4-2 of Appendix A.
Table 4-2 contains additional detail for most of the ARARs specified in
Table 5. Table 5 summarizes and includes the ARAR for air emissions
during excavation activities.
Long-term effectiveness is achieved through removal and ultimate destruction
of the contaminants of concern. In addition, treatment is utilized to
the maximum extent practical in this alternative. Contaminants are removed
from soils onsite and concentrated in liquid form. The volume of contaminants
for off-site transport is thus reduced to a minimum. Ultimate destruction
of contaminants through incineration of the concentrate leaves behind
minimum residue, if any. In comparison to other alternatives which require
excavation for treatment of contaminants, implementation of this remedy
31
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is judged to be reliable and snould not pose sno"t term "isk to the community
and area businesses.
This remedy is cost effective in comparison to othe" treatment alternatives.
The total cost of the selected remedy is estimated to be $22 million
net present worth dollars (+50% or -30%) over a 2 year period. Five-year
facility reviews will not be necessary for the soils since contaminants
will not remain onsite above health based levels.
Community and state acceptance is favorable to this remedy in comparison
to other alternatives presented during public comment. The community has
requested more involvement in the remaining phase of the project. EPA
and TUC will incorporate this concern into the Community Relations Plan
as practical .
In comparison to tne selected remedy, the othe^ 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 the curr'ent risk estimate; inadequate
protection of the envi-onnent [groundwater].
Biological Treatment and Reou"ial - the toxicity of dioxins and furans
were not significantly affected by this treatment process
[treatability study].
Onsite Incineration and Reburial - although same level of protection is
achieved for human health and the environment, this alter-
native was not favored by the community; costs are higher for
this alternative than the selected remedy.
Off-Site Incineration and Disposal - although same level of protection is
achieved for human health and the environment, transport and
increased handling of the high volume of contaminated soils
creates short-term risk considerations during implementation
due to the close proximity of residents. In addition, the
costs for this alternative were nearly one order of magnitude
greater than those of the selected remedy.
Documentation of No Significant Change
The Proposed Plan for the United Creosoting site was released for public
comment in July 1989. The Proposed Plan identified Alternative 5,
Critical Fluid Extraction with Incineration of the Organic Concentrate,
as the preferred alternative. EPA reviewed all comments obtained during
the public comment period and determined that no changes to the remedy,
as it was originally identified in the Proposed Plan, were necessary.
35
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RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
UNITED CREOSOTING COMPANY
RECORD OF DECISION
September 1989
This Community Relations Responsiveness Summary is divided into the
followrng sections:
Section I - Background of Community Involvement and Concerns. Tms
section provides a brief history of community interest and concerns raised
during remedial planning activities at the United Creosoting sites from
the time the site was proposed for inclusion on the National Priorities
List.
(
Section II - Summary of Comments Received During the Public Comment
Period. Comments are paraphrased and EPA's responses are provided.
I. BACKGROUND ON COMMUNITY INVOLVEMENT
During the 1940's, when United Creosoting began operation, the site was
relatively isolated from any significant population concentrations or
urban development. By the time operations ceased in 1972, some
development had occurred in the general area. The property remained
essentially dormant until redevelopment of the area began in 1977.
Residential property owners were basically unaware of the previous land
usage and the potential hazards until the sue was added to the National
Priorities List in Septembe0 1983. Sunnarized below are significant
events in community involvement following the proposed inclusion of this
site on the National Priorities List:
1983
SEPTEMBER - An initial property owners' meeting was held on
September 6, 1983, to discuss the Superfund program and current site
conditions. The vast majority of those in attendance demonstrated a very
high level of concern.
DECEMBER - On December 8, 1983, a homeowners meeting with EPA was held to
discuss a proposed "Immediate Response Action" to place a temporary cap
over the buried sludge pits on the property of Clarke Distributing and to
review plans to recontour portions of this commercial property to prevent
runoff of contaminants. Initial sampling plans associated with this
action were also reviewed.
1984
FEBRUARY - On February 28, 1984, the results of the initial sampling
effort associated with the Immediate Response Action were discussed with
homeowners. While low levels of organic contaminants were found in
soils, no immediate health risks were detected. The initial set of
samples were used to frame a more intensive Remedial Investigation
sampling effort.
1
-------
MARCH - An EPA fact sheet was published announcing the funding of the
Remedial Investigation in March 1985.
1986
. fc JANUARY - On January 27, 1986 a homeowners meeting was held to discuss
* !ป the results of the Remedial Investigation sampling effort. The
**T- _ meeting was jointly conducted by ATSDR, TWC, and EPA staff. Citizens
W were extremely concerned that property values had been adversely affected
* by the designation of United Creosoting as a Superfund site, and were
concerned about the safety of living in close proximity to hazardous
9 : waste.
JULY - On July 1986, the Feasibility Study for the site was released
a 1ong with EPA's proposed remedy. Based on an evaluation of available
technologies, EPA proposed onsite incineration of contaminated soils.
^ AUGUST - Two community workshops were held on August 20 and 26 and a
" * W general public meeting was held on August 26. People living in the
\ i ' community were intensely opposed to incineration and instead wanted a
;:,j complete buy out of the subdivision. Because contaminants in surface
- 1| soils were below concentrations recommended by ATSDR, no short term
' h health threat was presented. Therefore EPA explained that it lacked the
- authontyto buy out homes. Properties immediately over or adjacent to
buried waste we^e, however, eligible for purchase by the government since
i all actions to treat or consolidate wastes would require excavation.
Much of the community wanted EPA to investigate innovative remedies such
* . as biological treatment.
ฃ.- SEPTEMBER - On September 30, 1986, the first Record of Decision for
\* United Creosoting was signed. As outlined in more detail elsewhere in
this document, it provided for:
o Purchase of the 7 properties immediately adjacent to, or
over, buried waste;
o Demolition of residences over the former waste ponds;
o Consolidation of the waste under a temporary cap;
ro Research by EPA into innovative treatment technologies
r other than incineration; and
. J o Re-evaluation of remedial options within five years.
OCTOBER - Fact sheets describing the remedy were mailed to the residents
On October 16, 1989, the Superfund Amendments and Reauthorization Act
of 1986 was signed, replacing the existing Superfund law.
-------
1987
CH - EPA mailed a newsletter to residents explaining the status of
ilementation of the ROD and trie impact of the new law.
_E_ -'An updated newsletter was mailed indicating that funding had been
,ained to begin implementing the ROD.
1988
UARY - "SITE" program fact sheets were issued announcing a period
m February to March 1988 for EPA to receive comments on a proposed
ot treatment study using the Detox Industries' biological treatment
:hniques. (Tnis experiment was never conducted due to difficulties
jenenced by the vendor. Instead, biological treatment was investigated
the Texas Water Commission, inaependent of the SITE program.)
:IL - EPA mailed a progress report to the residents.
' - On May 12, 1988 EPA and TWC conducted an open house to review design
"ns for the temporary cap.
JE_ - EPA mailed a progress report to the residents.
MEMBER - EPA nailed a progress report to the residents.
1989
SRUARY - Notice that the SITE program demonstration with DETOX was
jlaced by a TWC evaluation was mailed to the community.
UL - TWC issued a notice to community residents announcing the pilot
lonstration of the critical fluid extraction process on site.
_Y - The press release announcing the public comment period and
5Tic meeting was issued on July 10, 1989. An open house was held with
i area residents on July 15 to outline the alternatives presented in
2 Feasibility Study Amendment Report and to discuss the upcoming
jlic comment period on these alternatives. Forty people registered at
s open house.
-WARY OF PUBLIC COMMENT
; comment period began on July 17 and ended on August 15, 1989. The
)lic meeting was held August 3, 1989, in the St. Marks Lutheran Church
lowship Hall in Conroe, Texas. Forty-eight people registered at the
ปting and six made oral statements or asked questions. Although no
'tten comments or questions were received, the following concerns were
sressed at the Public Meeting:
nment No. 1: In a neighborhood situation, why won't EPA and TWC buy
: the homeowners and put them in a safe situation.
-------
Response No. 1: Under Section 104 [Response Authorities] and 111 [Use
of Fundsj of Title I - Provisions Relating Primarily to Response and
Liability of the Superfund Amendments and Reauthorization Act of 1986
[SARA], the acquisition of property is authorized when a short or long
term health threat exists and purchase is necessary to physically
execute a remedy.
The purchase of six homes and one vacant property was deemed necessary in
the 1986 ROD in order to excavate the former ponds area and remove the
source of contamination. EPA believes that there is no immediate health
threat for residents of the neighborhood and intends to conduct more
detailed sampling to characterize existing soil contamination. These
data will be evaluated using the cleanup criteria specified in this ROD
and the results snared with residents of the community.
Comment No. 2: People that work on a Superfund site, such as United
Creosoting, are in very self-contained clothes that protect them from any
harm that might come from fumes out of the ground. And yet we have
little children playing out here barefoot without any breathing apparatus
that will continue to do so during this cleanup period.
Response No. 2: EPA and TWC field staff who work on hazardous waste
sites as an occupation are potentially exposed to a wide spectrum of
chemical contamination from many different places. EPA requires them
to wear protective clothes because of the cumulative exposures they
may experience. Security at the site du-ing construction will
prevent children and adults from trespassing in the excavation a~eas.
Comment No. 3: Tne previous ROD (1986) said that there is no danger from
the contaminated ground water--once the contaminants are removed and
the ground water clears itself. However, the 400 years required for this
to occur is a long time*
Response No. 3: The model used to estimate the 400-year attenuation
period is based upon contaminant dispersion. Natural attenuation of the
aquifer also involves absorption and possible degradation of contaminants.
Whatever the time necessary for concentrations to decrease to background
levels, use of the shallow aquifer is not anticipated due to low yield of
the aquifer.
Comment No. 4: I am not comfortable with the extent of past sampling
performed in yards of the neighborhood to believe that we [the residents]
are adequately protected.
Response No. 4: EPA agrees that more detailed sampling is required. The
sampling conducted in 1985 was intended to provide the basis for
evaluating broad remedial options; it was not sufficiently detailed to
prepare design plans. Before the Remedial Design is commenced, EPA will
conduct a more intensive sampling campaign in the community to identify
contours of surface and subsurface contamination. The results of this
survey will be shared with residents.
-------
Comment No. 5: One commentor cited the Congressional Office of
Technology Assessment (OTA) Report as being critical of EPA's
implementation of Superfund. Exanples tnat the commentor raised were the
Compass Industries sue in Oklahoma (where OTA asserted that EPA made no
commitment to clean up ground water needing remediation) and the site
the State of Washington (where OTA contended tnat EPA selected a remedy
without treatability studies).
Response No. 5: EPA disagrees with much of OTA's report and has
responded with a rather extensive rebuttal. For example, the Record of
Decision for the Compass site did commit EPA to pumping and treating
groundwater if needed. The main component of the remedy - a hazardous
waste cap over an abandoned industrial dump - was expected to prevent the
generation of contaminated ground water due to the unique geo-physical
features of the site. With respect to treatability studies, it is true
that under the original 1980 statute there was limited use of treatability
studies. Due to the changes to the law in 1986, treatability studies are
now basic components of -emedy selection as evidenced by the two studies
conducted at the United Creosoting.
Comment No. 6: One commentor indicated that people felt left out and
recommended that EPA recognize a committee of homeowners with whom the
agency would regularly communicate during design and construction activities,
Response No. 6: There are several, facets of EPA's response to this comment:
(A) Regarding past community relations efforts - As shown at the
beginning of this Responsiveness Surmary, EPA and the TWC have kept
citizens informed tnrougn a variety of techniques. EPA has given citizen
concerns an important weight in decision making (e.g. the 1986 decision
to seek other innovative technologies rather than incineration).
While the agency's record in this regard has been adequate, EPA agrees
that more intensive efforts will need to be made in the future in terms
of presence at the site and opportunities for public review. To this
end, EPA will revise the site's Community Relations Plan to provide
greater and more regular contact.
(B) Regarding special status of a community group - EPA recognizes the
impact tnat remedial activities will have on the Tanglewood East sub-
division and understands the need to increase communication with the
homeowners during these activities. Comments received through this
communication will be addressed based on their technical, scientific,
and legal content as well as how they reflect upon the wishes of the
community as a whole.
(C) Technical Assistance Grants - Groups of citizens are eligible to
receive grants of up to $50,000 (one per Superfund site) to secure
assistance in reviewing the technical merits of EPA plans and data.
Announcements and Workshops for interested citizens have been issued and
conducted by EPA in the Houston area in the past. EPA representatives at
the meeting offered to return to Conroe to provide more information to
any interested group. Receipt of a Technical Assistance Grant does not
center special status to the receiving citizens group in terms of how
their comments or recommendations are received by EPA as explained above.
-------
{
'
f
w
Comment No. 7: How much propane is going to be brought out to implement
the supercntical process? Isn't propane flammable?
Response No. 7: The conceptual design estimate is approximately
160 Ibs/hour propane as fresh make-up per process unit. With two units
proposed, a tank eight feet in diameter and sixteen feet long would be
required. State and local fire regulations would be followed in the
placement of propane supply at the site. In addition, each extraction
unit would be equipped with combustible gas detectors and emergency
relief systems designed to protect the health and safety of the operators
and local residents.
Comment No. 8: How many times has supercritical fluid extraction been
implemented successfully? Where?
Response No. 8: Several pilot scale tests have been performed favorable
at various places around the country. As a full scale remedy under the
r Superfund Program, the technology has not yet been utilized. However,
i the technology is currently being used on a full scale basis at a
petrochemical plant here in Texas.
r
Comment No. 9: If you are going to concentrate the contaminants in the
soil into a supertoxin, how much of that stuff is going to be able to
accumulate here before U is moved away?
Response No. 9: EPA's preference is to accumulate only enough concentrate
to transport out safely and economically for disposal. However, if no
off-site incineration facilities become available, an off-site temporary
storage facility will ce necessary. The least preferred option would be
to store this concenfate onsite. However, any drums stored onsite (even
for a short period of time) would be secured on the commercial portion of
the site. A site safety plan and periodic inspections, as well as 24-hour
security, would be part of the remedy implementation.
Comment No. 10: Is EPA going to purchase, or lease, the vacant area in
Jack Clarke's property where the treatment process is proposed to occur?
Response No. 10: No .
Comment No. 11: I don't feel comfortable to have my family at home
during the remedial action implementation. Will temporary relocations
still be offered?
Response No. 11: Yes. The criteria by abating possible fugitive air
pollutants, work shutdowns, and temporary relocation will be developed as
a component of the design and shared with the community for review and
comment.
- %
Comment No. 12: How will we know if air emissions reach a dangerous
level? Wil 1 alarms go off? Will you go door-to-door to notify us?
-------
isponse No. 12: Tne contingency plan described above will deal with
ese specifics. EPA's aim in developing this plan is to prevent
iposure, to measure possible pollutants at the source as well as in the
immunity, and to provide a system of reporting this information to
jsidents. Tne contingency would be designed to avoid any acute
*oblems.
)mment No. 13: In reference to previous sites that EPA has cleaned up
)TA Report], a problem was identified as the extreme youth of some of
le people that you used in making decisions; the short time that they
e,out of college. I's this the situation on this project?
;sponse No. 13: No. The level of review, at both EPA and TWC, provides
great level of expertise prior to selecting a remedial action for the
lited Creosoting site. In fact, recommendations by both junior and
jnior level staff are weighed by several tiers of uppe'- management at
3A prior to the final selection of a remedial action at any Superfund site,
11le staff level project managers have changed, EPA supervisors and
anagers reviewing this Record of Decision also evaluated the 1986 Record
7 Decision.
jmment No. 14: At the last meeting, in 1984 or 1986, EPA told us that
? shouldn't be digging in our yards over 2 feet, that it was a danger.
DW it isn't a danger?
esponse No. 14: Residents of the houses located directly over the
uned waste deposits (since purchased by EPA) were advised not to dig
n their yardsthis did not extend to all residents of the community.
ighly concentrated waste deposits are not expected to be buried elsewhere
n the community. However, should such pockets be found, EPA or the Texas
ater Commission should be notified. For example, EPA is currently
ampling and analyzing soil from one resident's yard because water pooled
n a hole contained an oily sheen.
PA does not believe that the surface soils represent an acute threat.
n the 1986 ROD and in this decision, EPA plans to consolidate soils
hat are contaminated. The extent of this effort will not be known
ntil the pre-design sampling campaign is completed.
otnment No. 15: You have all but told most of us that there is nothing
n our yards or properties that is going to be cleaned up other than the
ix homes that you have bought. However, you cannot predict what is
nder my home. If 10 years from now, my neighbor's home is knocked down
am not the expertbut what if the pond is exposed right there next to
y house? Who will take care of that? We will still have the same
roblem we have today.
esponse No. 15: EPA has developed cleanup criteria for this ROD which
ndicate the need for careful sampling of some of the residential area
ot previously targeted for cleanup. This will ensure that if
.ignificant contamination exists beneath a home, EPA will be able to
dentify the problem prior to initiation of the remedial action.
1
-------
With this additional information, EPA can be extremely accurate about
predicting ar.y contamination beneath a home. However, if a house is ever
knocked down, and you feel concern about the soil being contaminated,
please contact the EPA Region 6 office. EPA will address your concerns
based -upon the circumstances and information available then.
Comment No. 16: Have you considered air slides like a mining operation,
pulling the dirt up completely enclosed into the treatment unit?
Response No. 16: That is a design criteria and may be considered during
remedial design.
i
Comment No. 17: If you have information for the homeowners, the public
library is not that convenient. We are the only ones interested anyway.
Response No. 17: The public library is the closest repository to the
site and was chosen as one of the repositories for this reason.
Comment No. 18: The map provided in the handout, Figure 2, is
confusing.You have a site that looks like two or three sites. Where do
you draw the line7
Response No. 18: EPA ag-ees. A new figure has been provided in this ROD,
Figure 2 on page 3 of the Decision $unma"y. which shows the current land
uses of the sue as a
-------
APPENDIX A: TABLE 4-2
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-------
APPENDIX B: TWC LETTER OF SUPPORT
-------
05/26/19S9 13 = 25 TEXfiS UPTER COMMISSION
512 463 8317 P.02
TEXAS WATER COMMISSION
B. J. Wynne, III,
Paul Hopkins, Cnmrniuioner
John O. Houchmt. Cornmisi>ontr
Allen Beinke, Executive Director
Michael ฃ. Field, General Counsel
W. Foiter, Chief Gcrk
Mr. Robert E. Layton, Jr., P.E.
Rational Administrator
U. S. Environmental Protection Agency
Region VI
1445 Rocs Avanua
Dallas, Texas 75202-2733
Ra: Draft Record of Decision
United Creosoting Suparfund Site
Dear Mr. Layton:
We have reviewad the draft Record of Decision (ROD) and
responsiveness summary for the United Creosoting Superfund Site.
We feel that the use of.the target action levels (TAL) proposed
in the draft ROD represent a considerable improvement over the
action levels art in the 1986 ROD by more accurately defining the
risks posed by the contaminants present. At the same time
however we ara concerned that the adoption of these TAL1a
presents some uncertainties which cannot be addressed at the
present time.
The additional sampling proposed in the residential area will
fill currently existing data gaps as to the extent of
contamination. Furthermore the methodology used to convert
empirical data to risk based equivalents has only recently been
developed as EPA guidance and is still being refined. In light
of this the limits of contamination and the scope of the remedy
cou}.d change considerably. We are concerned that the public and
the Texas Water Commission lack all the data necessary to fully
evaluate the proposed remedy at this time.
For the reasons stated above TWC concurs with EPA's proposed
Record of Decision on the condition that upon completion of the
proposed additional sampling and data evaluation, EPA will, in
addition to any other administrative requirement, make this
information available to the public and reopen the Administrative
Record to allow a formal public comment period, conduct a public
meeting and issue a Responsiveness Summary. The proposed remedy
upon which we conditionally concur includes:
-------
09/25/1999 13=26 TEXflS USTER COMMISSION 512 463 8317 P.33
Mr. Robert E. Layton, Jr., P.E.
Page Two
Sampling of the residential area to better delineate
' ' all soils falling above the target soil action levels
faป established in this Record of Decision.
I Excavation of all soils from residential and commercial
^_ portions of the site that are above the respective
human health criteria and treatment via critical fluid
extraction.
i
ta Treatment of contaminated soils to human health
criteria and reburial on the appropriate portion of the
site.
fc:
Disposal of the organic concentrate from the extraction
i process by off-site incineration.
On a related matter, we would like to comment on the obligation
of State monies for a period of 30 years after the remedial
1 construction activities are complete, such a commitment by the
*- state of Texas may be a violation of Article VIII, Section 6 of
the Texas Constitution which addresses the appropriation of money
beyond a two year period.
L.
Sincerely yours,
Allen Beinke
Executive Director
-------
APPENDIX C: ADMINISTRATIVE RECORD INDEX
ENVIRONMENTAL
FROTECTICW
AGENCY
OAU>S. TEXAS
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