United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
. EPA/ROD/R06-85/005
March 1985
Superfund
Record of Decision:
-------
mrco, 'IEXAS
Record of Decision
Abstract
'!he IDI'CO site is located about three miles southeast of the City of
LaMarque, Texas and occupies approximately 11.3 acres near the junction
of State Highway 3 and the Gulf Freeway. '!he site has been used for
recycling styrene tars and disposal of industrial chemical wastes. Due
to numerous complaints, the Ci ty of LaMarque passed an ordinance
prohibiting disposal of liquid wastes in surface impoundments which
forced the owners to close the site. Subsequent owners attempted to
recycle the wastes in the lagoons but later abandoned the project.
'!he cost-effective remedial alternative selected for this site
involves transport of surface water in the impoundments by pipeline to an
industrial wastewater treatment plant, the incineration of PCB liquid
organics at a TSCA permitted facility, the incineration of non-PCB liquid
organics at a OCRA permitted or interim status facility, and off-site
disposal of the tars/sludges and soils at a OCRA (double-lined)
-------
i'
Record of Decision
Remedial Alternative Selection
SITE: MOTCO. LaMarque. Texas
DOCUMENT~ REV I EWED
I am basing my decision on the following documents describing the analysis
of cost effecti,veness of remedial alternatives for the MOTCO site:
, v
- MOTCO Remedial Investigation Reports: Initial
Secondary Investigation. Source Sampling.
- MOTCO Source Control Feasibility Study
- Summary of Remedial Alternative Selection
- Responsiveness Summary
Investigation.
, U
DESCRIPTION OF SELECTED REMEDY
o Contaminated pit water - off-site biological treatment
o Organic liquids - off-site incineration *
o Sludges/tars - off-site landfill*
o Soils-off-site landfill
* On-site incineration alternative will continue to be considered into
design phase.
DECLARATIONS
t,
Consistent with the Comprehensive Environmental Response. Compensation. and
Liability Act of 1980 (CERCLA). and the National Contingency Plan (40 CFR
Part 300). I have determined that the selected remedy at the MOTCO site is
a cost effective remedy and provides adequate protection of public health.
welfare. and the environment. The State of Texas has been consulted and
agrees with the approved remedy.
I have also determined that the action being taken is appropriate when bal-
anced against the availability of Trust Fund monies for use at other sites.
In addition. the off-site transport. storage. destruction. treatment. or
secure disposition is more cost effective than other remedial action. and
is necessary to protect public health. welfare or the environment.
,'.
, 0
The EPA is currently engaged in an additional Remedial Investigation/Feasi-
bility Study to evaluate potential groundwater contamination remedies and
residual soil cleanup.
J2'j~I.'~ \;. '1 B 5"
Date
G)-.L~
Dick ngton.. .
Regional Administ ator
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. . - .- 0- -- - .
-~~--~--- -------
-~.._---. -
--: - ----. --
MOTCO Source Control Record of Decision Concurrences
The MOTCO Source Control Record of Decision has been reviewed and I concur:
.'
Branch
uJJ..Qi~,* )1. rc~
W111iam Rhea, Ch1ef
Hazardous Materials Branch
Air & Waste Management Division
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..
....
TEXAS DEPART~1ENT OF WATER RESOL'~EC~iVED
1700:--1. Congress A\'enue EP~ c--G' ,
i-\ I \to ,;U:-; .n
Austin. Texas
(AS WATER DEVELOPMENT BOARD
Louis A. Beecher\. Jr.. Chairman
George W. McCleskey. Vice Chairman
Glen E. Roney
W. O. Bankston
Lonnie A. "Bo" Pilgrim
Louie Welch
o.,,~t1:0~~.
/1;;;~~
~~ ~< 51
.f/~~:;::':~O
1S35 FEB 19 A:.; II: 19
TEXAS WATER COMMISSION
Sn~=~!='U,!..iJj'~ B~, !,"'~'l:jfopkins. Chairman
."J. '-I~. t \ I "",rv-..;,rr
. Lee B. M. Biggart
Ralph Roming
Charles E. Nemir
Executive Dircctur
February 14, 1985
t.I
Mr. Sam Nott, Chief
Superfund Branch
U. S. Environmental Protection Agency
Region VI
12101 Elm Street
Dallas, Texas 75270
/'
Dear Mr ~~- '.:>oJ-A.
~--
-'
Re:
MOTCO Draft Record of Decision
We have reviewed the draft MOTCO Source Control Record of Decision which you
sent for our comments on January 25, 1985. We have no objections with the
alternatives sele~ted and the rationale given for their selection. The
choice of alternatives will be between Alternative 3 (off-site incineration)
and Alternative l~ (on-site incineration).
We look forward to working with you on the Remedial Design and Remedial
Action phase of this project.
t.
V?relYUH-
Bryan J. Dixon, P. E., Chief
Solid Waste' and Spill Response Section
Enforcement and Field Operations Division
DLS:mtrn
't~\
<;t.t."~-~
1836.1986
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,
..
"
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
MOTCO
LA MARQUE, TEXAS
FEBRUARY, 1985
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'.
'.
TABLE OF CONTENTS
SITE LOCATION AND DESCRIPTION.
SITE HISTORY. . . . .
. . . .
. . . . . .
....1
. . . . . . .
. . . .
. . . . .
. .. 3
CURRENT SITE STATUS.
. . . ..
.......
......
. . 4
ENFORCEMENT ANALYSIS. .
. . . . .
. . . . . . .
......8
ALTERNATIVES EVALUATION.
. . -. .
. . . .
. . . . . . .
.. 9
COMMUNITY RELATIONS. .
. . . . . . . .
. . . . . .
. .. . . 21
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS.
. . . . . .
. . 22
RECOMMENDED ALTERNATIVE. . . .
FUTURE ACTIONS. .
. . . . . .
. . . . .
. . . 24
. . . .
.....
. . . .
. . . . . . . . 27
SCHEDULE.
. . . .
. . . . . .
......
. . . . . .
. . . 29
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TABLE A SUMMARY OF REMEDIAL ALTERNATIVES
MOTCO SOURCE-CONTROL REMEDIAL ACTION
Alternative
Remedial Action
Cost (millions)
Capital O&M
Pub 1 i c Hea 1 th
Considerations
Environmental
Cons i derati ons
1. Off- si te
incinerate
[need permit]
off- si te
landfill
34.5
Eliminate immediate
public health risks.
Minimizes direct
contact. Excavation/
transportation risks-
volatiles release.
Waste destroyed
or conta i ned.
Heat val ue
recovery
possible.
NA
Technical
Considerations
Public Conunent
O&M
,Evaluation needed
to obtain permits.
More capacity/less
clean-up time.
t4i nimal on- site
staging. Reliable.
None
PRP support
Publ ic-mild
opposition
2. Off-site 42.3 NA Same as 1. Waste destroye.d Permits in place. Mild None
incinerate or conta i ned. Less capacity/more opposition
[permi t clean-up time.
in-place] Minimal on-site
off- site staging. Reliable.
landfill
3. On- si te 48.9 NA Same as 1. Same as 2. Difficult design/ Public choice None
incinerate Less risks of construct.
Off-site hazardous vapors. Considerable
landfill operations. less
reliable technologies.
4. On-site 47.1 3.2 Same as 1. Waste destroyed. Same as 3. Not Annual
incinerate Minimal Excavati on Poor location for acceptable inspection.
on- si te ri sks. No landfill. Maximum High
landfill transportation risks. on-site construction. Maintenance.
Minimal hazardous longest implementation
vapor risks. ti me.
5. No Action NA NA Direct contact to Exposures to Periodic emergency Not Periodic
[not residents of bi ota of responses. acceptable emergency
retained] carci nogenic, hazardous responses.
volatile contaminants material.
from air emissions or
run-off. Continued
groundwater
contamination.
Nute:
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
MOTCO
LA MARQUE, TEXAS
FEBRUARY, 1985
SITE LOCATION AND DESCRIPTION
The MOTCO site, located about 2 miles southeast of the City of LaMarque,
Galveston County, Texas, is situated on an 11.3 acre tract of land near the
junction of State Highway 3 and the Gulf Freeway (I-45/US-75) (Figure 1-3).
The site is bounded on the east by State Highway 3, on the northwest by an
abandoned trailer park, and on the southwest by the right-of-way for Houston
Lighting and Power transmission lines (H.L.& P. R-O-W) (Figure 1-3).
The MOTCO site sits on the Gulf Coastal Plain at the edge of a coastal
marsh system, and area surface topography slopes gently toward the Gulf of
Mexico. At approximately +5 feet mean sea level (msl) elevation, the site
is well within the 100-year tidal floodplain of +12 feet msl and subject to
inundation. The seven waste pits are surrounded by an exterior dike which
collects precipitation. Site security is provided by a 6-foot chain link
fence, and site access is through locked gates.
In addition to site boundaries mentioned above, pertinent features in the
vicinity of the site include:
o Water-filled borrow pits-150 ft. southwest across
the H.L.& P. R-O-W.
o Central Freight Lines (truck terminal) and Dispos-all
Company yard -500 ft. to the southeast.
o Gulf Freeway (I-45/US-75)-1000 ft. to the west-southwest.
o Omega Bay Subdivision-1500 ft. west-southwest.
o Bayou Vista Subdivision-1500-2000 ft. south-southwest.
o Private residence-2000 ft. northwest.
Approximately 3000 people live within a 1-mile radius of the site, and
about 12,000 people live within a 3-mile radius.
The uppermost geologic unit beneath the site is the Beaumont Clay Formation
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--.----------
,
2
Predominant near-surface geologic units are two channel sand/silt deposits
at about 5-10 ft. deep and 20-30 ft. deep, and an additional bar finger
deposit at about 40-50 ft. deep. These layers are separated by clayey
silts and silty clays, and the upper two sand/silt deposits apparently
intersect with unlined pits.
Seven unlined pits with a surface area of 4.6 acres and average depths of
15 feet are at the site. The pits contain four major types of wastes. The
first layer of wastes consist of approximately 3 feet of water over the
remaining waste in the pits. Treatment of up to 15 million gallons of
water is expected to be required during the cleanup. Under the water,
there exists seven million gallons of organic liquids of which five mil-
lion gallons wtll require disposal in accordance with the Toxic Substances
Control Act (TSCA) due to the presence of polychlorinated biphenyls (PCBs).
Under the organic liquids, approximately 18,000 cubic yards of sludges and
tars are present. Under the sludges and tars are an estimated 45,000 cubic
yards of highly contaminated soil. For illustrative purposes, cross-sections
indicating the various layers within pits 1, 2, 3, and 4 is provided in
-------
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PIT 1
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TARS
PIT 2
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LEGEND
@ Location 01 Anolylicol Sampling S.o.;on
61
'*' Loco.;on 01 Bulk 155gol., 5gol., t Li.er I Sampling
~ S'o';on
10
.L
I
Locotion 01 Probing
Location 01 Crus' os Encoun.ered
HEAVY SLUDGE
.
Locotion 01 Sam pting
57
o
7
WATER
Oil
NOTE:
For Location 01 Proliles, See F,g. 5.1
Loyer designo'ions are lield descroph
For engineering descriplrons, see
Appendi. D . Tables D-I and D. 2.
w
€p
Oil
.
VISCOUS
TAR
PIT 4
I -
....
MOTCO
SITE
SCALE:
HORtZ. r"= 50'
VERT. r"= 10'
...
COMPANY
0'" 11- ZO'.' ,.~.-
,... /.1-1'.'1 B3C.!3
PROFILES OF ~.'
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3
SITE HISTORY
The MOTCO site was purchased by U.T. Alexander in 1959 for the purpose of
recycling styrene tars generated by local industry. In 1961, damage from
Hurricane Carla caused discontinuation of the recycling business. The pits
on the site were then used for disposal of industrial chemical wastes. In
1963, Alexander transferred ownership of the site to Petro Processors, Inc.,
a Texas corporation, of which U.T. Alexander was president. In 1964, the
site was permitted as a disposal facility by the State of Texas and it con-
tinued to operate until 1968. In 1968, due to numerous odor complaints,
the City of LaMarque, in which the site is located, passed an ordinance pro-
hibiting disposal of liquid wastes in surface impoundments which effectively
forced Petro Processors out of business. In 1969, the Mainland Bank fore-
closed on the site.
Through a series of subsequent owners who did not operate the site (including
J.W. Yeatman and Associates and Wye Development Corporation), it eventually
became the property of T. Holman, J.R. McDonald, and MOTCO, Inc., a Minnesota
corporation. These owners unsuccessfully attempted to recycle the wastes
in the lagoons and then abandoned the project. At some point in time during
the recycling attempts, MOTCO bought Holman's and McDonald's interest in
the site. In 1976, TDWR cancelled MOTCO's permit by means of an administrative
order and required a closure plan. Shortly thereafter, MOTCO filed for
bankruptcy and the trustee abandoned the site as a worthless asset. In
1977, MOTCO forfeited its right to do business in Texas, but remains an
active corporation on the Minnesota Secretary of State's records. Attempts
to contact MOTCO or its agent have been unsuccessful.
Summary of Response Actions
From May-September, 1980, the U.S. Coast Guard (USCG), with recommendations
and technical assistance from EPA and TDWR, used Clean Water Act Section
311 funds to remove drums that had been stored in and around an abandoned
service station building, extend and raise the perimeter dikes, and secure
the site by erecting a 6-foot chain-link fence around the perimeter.
In February 1981, the Response Action Plan for the MOTCO Site was issued by
EPA. In 1981-82, Black & Veatch Consulting Engineers completed an Initial
Site Investigation (including Tankage Waste Inventory) and a Secondary Site
Investigation. These efforts included characterization of pit wastes; ana-
lysis of surface soils, sediments, and waters; and a groundwater monitoring
program. Contamination of the shallow groundwater was confirmed, but the
areal and vertical extent and degree of contaminant migration were not
-------
4
The EPA has conducted three emergency response actions (September 1981;
March 1983; and September 1983) to treat and discharge excess pit surface
water collected in the extended and upgraded dikes constructed by the USCG
in 1980. These actions were conducted following periods of heavy rainfall
and/or storm surges to reduce the potential for release of contaminants
from dike overtopping.
In July, 1982 EPA Region VI ranked the MOTCO site using the Mitre Model for
inclusion on the National Priority List of Superfund sites. A hazard
ranking of 62.5, the highest ranking of any site in Texas, was assigned.
In early 1983, EPA issued concurrent work assignments to CH2M HILL for a
Remedial Action Master Plan (RAMP) and a Source-Control Feasibility
Study. The draft RAMP was submitted in May, 1983. Based on a detailed
assessment of available data and information in the RAMP, specific additional
data requirements were identified, and a specialized sampling/analysis.
program was conducted September to November, 1983.
In early 1984, an Initial Remedial Measure (IRM) was conducted by CH2M
Hill, as contractor for EPA, and with Coastal Environmental Control as
subcontractor. This IRM included removal and off-site disposal of wastes
in the nine above-ground tanks, and demolition/removal of those tanks.
In accordance with the National Contingency Plan (NCP), Section 300.68, the
EPA determined in late 1983 that offsite remedial actions may be necessary
at the site. To this end, an additional investigation was begun in the
summer of 1984. The results of that investigation indicate that the saline
water table around the site is contaminated with constituents from the
pits. Additionally, contamination at the ppb level was found in a potential
drinking water aquifer, 175 feet below the site. This contamination may be
attributable to leakage through an abandoned well located on the MOTCO site.
CURRENT SITE STATUS
Hazardous Substances Present
The wastes in the pits are stratified and the different strata have been
identified and characterized in remedial investigations and other previously
reported activities. While it is necessary and appropriate to categorize
waste types, it should be recognized that complete separation of strata
from each pit will not be possible, and some intermingling will occur upon
removal. A brief description of the character, quantity, and other applicable
information for each waste is presented in this section, and a summary of
quantities is given in Table 1-1.
The water layer present on the pit surfaces fluctuates with seasonal rain-
fall and evaporation. The water has been found to represent a mass transfer
-------
Table 1-1.
Onsite Waste Media Sumrnary--MOTCO Site--Source Control
Media
Estimated Quantity
Brief Description
Pit Surface Water
15 million gal.
Acidic, contains metals and organics.
Organic Liquids
Pits 1-6
Pits 7, 7N
5 million gal.
2 million gal.
>50 ppm PCB, high fuel value.
<50 ppm PCB, medium fuel value.
Sludges, Tars, and Solids
pits 5 & diked area sludges
2,100 cu. yd.
Very low fuel value, high content of moisture
and inorganics, with some organics. ,
Medium fuel value, varying moisture content,
high organics and metals.
Pits 1-4, 6, 7, 7N
15,900 cu.yd.
Contaminated Soils
45,000 cu. yd.
Clayey and sandy/clay soils with oil/tar/
chlorinated organic and metals contamination.
Miscellaneous Debris
1,000 cu.yd.
Plastic extrusions, beads, flakes; concrete,
tires, empty drums.
Buried Metals
500 cu. yd.
Abandoned gas station area (storage tanks) and
other identified areas.
-------
5
water. Maintaining the pit surface water layer is essential as long as the
organic liquids exist. However, as has been demonstrated by the need for
three previous emergency actions the potential for release from overtopping
exists. Therefore, a delicate water balance must be maintained over the
pit. The data collected during the EPA actions revealed that pit surface
water contamination levels increased as the water layer was reduced, apparently
due to proximity with underlying organic liquids. Table 1-2 summarizes the
ranges of selected parameters present in the surface water.
The organic liquids underlying the pit surface waters comprise the majority
of waste on the site. These organic liquids can be generally characterized
as ignitable (flashpoint <140 degrees F), medium viscosity, high molecular
weight polymer (primarily styrene) intermediates with varying amounts of
chlorinated hydrocarbons and other constituents. Though many similarities
exist, organic liquid waste constituents and properties vary considerably
from pit to pit. For example, pits 1-6 contain PCB contaminated organic
liquids, while Pit 7 does not.
The presence of PCB in the liquid organic waste requires consideration of
the treatment and disposal regulation of the Toxic Substances Control Act
(TSCA). A further consideration is the presence of the volatile organics,
such as vinyl chloride, in the liquids. The volatile organics represent
health risk through air pollution along with a potential hazard from fire
or explosion. Tables 1-3 and 1-4 summarize the ranges of selected parameters
present in the liquid organics.
The sludges/tars/solids/soi1s represent the following specific wastes:
1.
Bottom sludges and tars in all on-site waste pits.
2.
3.
Surface crust and interbedded solids layers in pit 7.
Residual sludge in the diked tank farm area resulting
from settling of precipitates formed in emergency
treatment and discharge actions.
4.
Soils immediately beneath or adjacent to the pits.
For comparison with organic liquid constituents, characteristics of the
tars/sludges are summarized in Table 1-4. The soil contamination is
expected to be similiar, but at lesser levels, to those constituents
identified in the previous media.
The hazard to human health that each waste parameter might pose is also
listed Tables 1-3 and 1-4. While concentration levels, dosages, etc., have
not been analyzed in order to pinpoint the exact health hazards posed by
the waste, it is understood that millions of gallons of material in the
present uncontrolled condition at MOTCO with the listed characteristics
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Table 1-2.
Pit Surface Water Character - Selected
Parameters
Parameter
Concentration
Minimum Maximum
pH, S. U .
Conductivity, umhos/cm
Salinity, ppt
COD
TOC
Total Phenolics
2
2300
1.2
30
40
Trace
Aluminum
Arsenic
Chromium
Copper
Cyanides
Iron
Lead
Mercury
Nickel
Zinc
10
4
4700
3.2
150
250
42
130
Present
Trace
Trace
Trace
10
Trace
0.45
2.42
12.0
40
4.3
Present
Trace
0.3
0.22
1. 84
Sodium
Calcium
Magnesium
Chloroform
1,1-dichloroethane
1,2-dichloroethane
1,1,2-trichloroethane
Vinyl Chloride
Methylene Chloride
Diphenyl acetamide
Bis-(2-chloroethyl)ether
100
30
10
300
100
50
0.065
0.310
5.400
1.900
0.430
0.350
1.100
0.112
NOTES:
1.
All values in mg/l unless noted; some
rounding was performed.
2.
Summary includes all available prior data.
3.
Wide variations between pits, with water
depth in each pit, and over time.
-------
Table 1-3.
Pit Waste Character - Selected Parameters
Organic Liquids Tars/Sludge
Parameter Minimum Maximum Maximum
Viscosity, cps 20 4,000 40,000
Heat Value, Btu/lb 4000 16,200 12,000
Ash, wt % 0.2 10 >30
Total Sulfur, wt % 0.0 6 <1.0
Moisture, wt % 0.04 >40 >60
Flash Point, OF <60 (immediate} >180 >180
Halogens, wt % 0.50 18 2.0
Molecular wt. (no. avg.) 270 340 N/A
Carbon, wt % 30. 83 30
Hydrogen, wt % 6 10 N/A
Nitrogen, wt % 0.05 2.3 N/A
Phosphorus, wt % 0.0 2.3 <0.2
Specific Gravity 1.0 1.15 1.3
pH, S.U. 1.0 4.0 N/A
Inorganics, mg/kg Hazard
Aluminum 2.0 5,000 12,000
Antimony T,C NO 3.0
Arsenic T,C ND 3.0 30
Barium T, I ND 10.0 200
Boron T, I ND 5.0 20
Cadmium T,C,N ND 920 920
Calcium 20 800 8,000
Chromium T,C,N ND 100 550
Cobalt T, I ND 10 10
Copper C,M,I 3.0 500 45,000
Iron 40 400 >6,000
Lead T,C,TE NO 500 46,000
Lithium R,TE ND 1.0 55
Magnesium NO 220 2,000
Mercury T,N,I ND 5.0
Molybdenum NO 5.0 30
Nickel I,C (airborne) NO 15.0 150
Platinum I NO 1.0 6.0
Potassium ND 500 4,000
Silicon I (airborne) 10 30 320
Sodium 30 1,350 2,500
-------
Table 1-3 Cont'd.
Pit Waste Character - Selected Parameters
Inorganics, mg/kg
(cont I d)
Hazard
Organic Liquids
Minimum Maximum
Tars/Sludge
Maximum
Tin
Titanium
Vanadium
Zinc
Zirconium
I,T (compounds)
T,C (salts)
T (compounds)
NO
NO
NO
1.0
NO
20
50
5.0
30
3.0
600
200
22
750
35
NOTES:
1.
Summary includes all available prior data.
2.
wide variation between pits, and between strata in each pit;
some rounding was performed.
3.
NO - Not detected.
N/A - Not applicable.
- Not available.
.4.
Hazard:
[33-35]
R - Reactive
T - Toxic
C - Known or
M - Known or
N - Known or
TE - Known or
I - Irritant
suspected
suspected
suspected
suspected
carcinogen
mutagen
neoplastic
teratogen
-------
Table 1-4.
Pit Wastes - Primary Organic Constituents
Volatiles
Hazard
Range (mg/kg)
ND-5,440
ND-400
ND-6,000
ND-800
ND-3,200
38-41,500
ND-61,OOO
ND-220
ND-4,OOO
ND-IO,OOO
ND-ll,200
ND-400
ND-90
ND-3,200
ND-7,600
ND-300
ND-200
ND-900
ND-25,700
ND-16,OOO
ND-l,800
ND-3,OOO
Benzene
Chlorobenzene
Ethylbenzene
Chloroform
l,l-dichloroethane
1,2-dichloroethane
1, 1, 2-trichloroethane
1, I, I-trichloroethane
I, I, 2, 2-tetrach1oroethane
1,I-dich1oroethy1ene
1,2-trans-dichloroethylene
Trichloroethylene
Methylene Chloride
Toluene
Vinyl Chloride
1,2-dich1oropropane
1,3-dichloropropylene
Tetrachloroethylene
2-Chloropropane
Methyl Ethenyl Benzene
Hexane
Xylene
Pesticide/PCB
PCB (Total)
Dieldrin
Extractables
Bis(2-chloroethyl ether)
Bis(2-chloroisopropyl ether)
Napthalene
Acenapthalene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo (a) anthracene
Pentachlorophenol
2-methyl napthalene
Biphenyl
I,C,T
I,T
I,T
C,T
I,T,TE
I,C,T,M,TE
I,T,C
I,T
I,T,C
I,T,C
I,T
I,T,C
I,T,C
I,T
I,T,C
I,T
T
I,T,C
-NHD
-NHD
-NHD
I,T
I,T,C,N
N,C
ND-IOO
ND-17
T,C
T,C,M
I,T
T
-NHD
T,C,N
C(impurities)
T,N
I,C
C,N
T,N
T
I,N
ND-3,900
ND-500
ND-36,OOO
ND-6,000
ND-4,500
ND-7,200
ND-8,430
ND-l,300
ND-3,OOO
ND-3,000
ND-670
ND-4,OOO
-------
Table 1-4 Cont'd.
Pit Wastes - Primary Organic Constituents
Extractables (Cont'd)
Hazard
Styrene
Methyl napthalene
Phenyl napthalene
Propylene benzene
Ethenylidene Bis benzene
n-Nitroso diphenylamine
I,T
-NHD
-NHD
-NHD
-NHD
T,C,N
Range (mg/kg)
ND-22,OOO
ND-18,OOO
ND-7,OOO
ND-11,OOO
ND-8,OOO
ND-4,700
Notes:
1.
ND - Not Detected.
2.
Hazard:
-NHD
I
T
C
M
N
TE
jd/GAM2/015
(33-36]
- No Hazard
- Irritant
- Toxic
- Known or
- Known or
Known or
- Known or
Data
suspected
suspected
suspected
suspected
carcinogen
mutagen
neoplastic
-------
"
6
Affected Pathways
Groundwater
The MOTCO site is underlain by interbedded sands and clays of the Beaumont
Formation. The sands are the primary water bearing units (aquifers),
although the clays may also be capable of storing and yielding water because
they have been fractured by swelling and shrinking. The Beaumont Clay is
one of the five formations making up the Chicot Aquifer of the southern
Texas Gulf Coast region.
The Chicot Aquifer, the uppermost fresh water aquifer in this area, contains
two principal sand aquifers: the Alta Lorna Sand at its base and a higher
unidentified sand. The Alta Lorna Sand is 600 to 800 feet below the site
and supplies water to many industrial, municipal, and private users in the
area. The upper sand is not named nor described in the available literature.
The sand layer 175 to 195 feet below the site may represent this upper
sand. Both the Alta Lorna Sand and the upper sand produce fresh water. The
sands within the top 50 feet underlying the site produce highly brackish to
saline water and are not used locally because of this high salt content.
The Alta Lorna Sand and the upper fresh-water sand in the Chicot Aquifer are
confined (under artesian conditions) and recharge from infiltration of preci-
pitation. Recharge probably occurs well to the north and west of the site
where the aquifers approach the surface and no saline water overlies them.
Pit surface elevations are generally 2-4 ft. higher than elevations of sur-
rounding land and the shallow, highly saline groundwater. This localized
mounding effect results in hydraulic gradients downward and away from the
site, increasing migration of contaminants. The onsite waste pits are
unlined, and intercepted by relatively transmissive layers of sandy silt
and silty sands interbedded with silty clays and clay layers which are
slickensided. Three relatively transmissive (10-2 to 10-4 em/see) zones
are present: apparent sand channel deposits at 5-10 ft. and 20-30 ft., and
a bar finger deposit at about 40-50 ft. Typical of deltaic deposits, these
interbedded layers vary in thickness and depth, and may not be continuous
or isolated.
Numerous site investigations have confirmed contamination of the shallow
groundwater and subsurface soils, with particularly high levels of organic
contamination in the immediate vicinity of the pits. Migration limits of
material from the pits have been estimated, based on soil and groundwater
sampling and analyses, at up to 300 feet laterally from the pits, and ex-
tending vertically to about 70 feet below the ground surface. Migration
extends primarily to the south and west in the deeper transmissive strata,
-------
7
the sand 175 feet below the site has been found, but is probably due to
material moving through an abandoned well and not due to migration of the
wastes through the stratum to that depth. Wells located in the 600-800 ft.
Alta Lorna Sand near the site have been sampled and no contamination was
found in the samples.
Migration mechanisms observed include direct movement through the more trans-
missive layers intercepting the pits,dispersion, and migration along fracture
planes in the clays. Movement along fracture planes in the clays has been
noted visually (oily discoloration), indicated from organic vapor readings,
and confirmed through chemical analyses. Thus, shallow clay layers do not
represent an effective barrier to migration, even with apparent water premea-
bilities up to 10-7 cm/sec.
These overlying clay deposits and differential hydraulic gradients provide
some measure of protection to the deep aquifers from contamination by wastes
at MOTCO. But migration through an abandoned well onsite, faults, and the
ability of many organic compounds to penetrate clay represent potential
continuing risk.
Levels and type of groundwater contamination vary widely, but generally
contamination is highest near the pits. Present are aromatics, polynuclear
aromatics, chlorinated hydrocarbons, and chlorinated ethers in levels ranging
from at or below detection up to 3300 mg/l of bis (2-chloro ethyl) ether in
OWM-5 sampled 9 November, 1981. Other typical constituents include benzene;
1,2-dichloroethane; 1,1,2-trichloroethane; vinyl chloride; styrene, naptha-
lenes; methylene chloride; and indene.
Air Qual i ty
Pit wastes contain hazardous volatile organics, some of which are identified
carcinogens that are released at widely varying rates depending on the depth
of the water layer, wind, and temperature. When pit wastes are undisturbed,
concentrations of vinyl chloride at the site perimeter have been measured
at up to 170 ppb on hot summer days, while on cold winter days measurements
are very near or below detection. If disturbed, pit wastes release extremely
high concentrations of volatile organics. Table 2-8 shows the results of
previous air sampling.
In addition to the threat from direct contact with the wastes or inhalation
of vapors, the volatile organics represent potential fire hazards, particu-
larly in contained vapor headspace in transport and/or storage vessels.
Receptors of hazardous emissions depend largely upon wind directions, but
include major public traffic (1-45 and intersecting roadways) and residential
-------
Table 2-8:
Summary of Air Sampling By The Texas Air Control Board (TACB) At The MOTCO Site.
Date
VCM
(ppb)
Sampling Point Location
Sampling
Duration
5/5/78
5/5/78
5/5/78
12
0.5
5
Downwind of Pit 4.
Upwind of Pit 4
"Downwind all pits"
Grab
Grab
Grab
7/27/78
7/27/78
7/27/78
0.5
NO
0.1
Trailer park
Central Freight
"N-E"
24-hr compo
24-hr compo
3-hr compo
7/30/78
7/30/78
0.1
14
Trailer park
Central Freight (not downwind)
24-hr compo
24-hr compo
7/31/78
7/31/78
30
5
Trailer park (downwind)
Central Freight
24-hr compo
24-hr compo
8/1/78
8/1/78
7
17
100 ft. north (downwind) of pits
100 ft. north (downwind) of pits
3-hr compo
3-hr compo
11/6/79
11/6/79
11/6/79
0.1
19
1*
South of Pit 2 (wind from north or northeast)
South of Pit 2 (wind from north or northeast)
South of Pit 4
Grab
Grab
Grab
11/7/79
11/7/79
11/7/79
11/7/79
11/7/79
3*
2*
6*
0.1*
0.1*
South of Pit 1
South of Pit 7
South of Pit 6
South of Pit 2
South of Pit 3
Onsite, various spots.
Onsite, various spots.
Grab
Grab
Grab
Grab
Grab
8/5/80
0-123 (avg. 44)
Eleven bag grab samples.
8/6/80
44-161 (avg. 95)
Nine bag grab samples.
*r 'oosite charcoal/Tenax adsorbent tubes.
All othf'-
aluminized Tedlar bag samples.
-------
8
Surface Water and Soil/Sediment
Surface water and soil have been contaminated from the MOTCO pits when major
storm events resulted in overtopping of the dike. At about +7 ft. msl,
site perimeter dikes are well below the lOa-year tidal floodplain elevation
of +12 ft. msl, and would be inundated by major flood surges of 15-year to
20-year recurrence frequency. Nearby subdivisions and the southern edge of
downtown LaMarque are within the lOa-year tidal floodplain. Transport and
redeposition of hazardous substances could be a significant health threat,
particularly if failure or breach of the perimeter dike occurred. In the
event of release of the pit surface water layer from a breached dike, the
potential exists for widespread contaminant transport and significant pUblic
health impacts, especially considering high rates of release of hazardous
organic volatiles.
Contaminant migration to surface water and soils also occurs from contact
of normal runoff with tar seeps on the exterior of the perimeter dike.
Surface soils in the vicinity of MOTCO are contaminated at relatively low
1 eve1 s, based on resu1 ts of numerous samp1 i ng programs. Most vol atil e
contaminants are released from the soil ~urface, and residuals are most
likely non-volatile organics and some metals. Particular contaminated
areas near the site include the abandoned trailer park to the northwest,
and drainage pathways.
The MOTCO Site is in the Highland Bayou drainage basin, and site drainage
ultimately reaches Jones Bay. Major potential threats to these receptors
would be caused by flood surge events, and release through surface drainage
has occurred over the history of the site.
ENFORCEMENT ANALYSIS"
Approximately 20 potentially responsible parties (PRPs) have been identi-
fied for the site. Monsanto Company has taken the lead in forming a coali-
tion and has indicated an interest in conducting the remedy; however, it
has not offered to conduct the remedy by itself. The coalition is currently
having problems in agreeing to the apportionment of wastes between the par-
ties. "A neutral party is being sought to arbitrate the apportionment. Another
unresolved issue is how to handle the wastes for which no party is identified.
EPA has discovered that records may exist on waste transported to the site.
If there are records, then the chances of successful negotiations with the
PRPs to implement the remedy will be greatly enhanced. "
The remedy to be conducted at the site will be the ROD remedy. If negoti-
ations are unsuccessful, EPA recommends that the fund be utilized for the
cleanup of the site. Negotiations are currently in progress and EPA will
discuss any offers up to 30 days after the ROD is signed. At that time, if
a settlement is not reached, EPA will enter into a cooperative agreement
-------
9
ALTERNATIVES EVALUATION
A Source Control Feasibility Study was performed to determine what remedial
actions, if any, would be appropriate at the MOTCO site. The purpose of the
study was to propose source control remedial action to cost-effectively
mitigate and minimize damage to, and provide adequate protection of, public
health, welfare, and the environment, resulting from the presence and
release of hazardous substance from the MOTCO site to the air, surface
waters and soils, and subsurface groundwaters and soils.
A source control remedial action is necessary at the MOTCO site in accordance
with 40 CFR Part 300.68 (e) (2) which states that, "Source control remedial
actions may be appropriate if a substantial concentration of hazardous
substances remain at or near the area where they were originally located
and inadequate barriers exist to retard migration of substances into the
environment".
The primary threats that the MOTCO site pose to the public health and
safety are:
(1) Direct contamination of groundwater supplies in the area;
(2 )
Transport of the onsite waste material to populated areas
from severe flooding;
Hazardous emissions to the air from pit wastes resulting from
transport during severe floodings, dike rupture, or removal of
waste pit surface water layer. .
(3)
Remedial Objectives
Specific objectives of the proposed source control remedial action are:
1. Prevent further contamination of the shallow aquifer and eliminate
the potential threat to nearby surface water from the pit wastes.
2.
Eliminate the threat to the public health from potential air
releases and runoff from the pit wastes.
Control and minimize air quality impacts, during and after remedial
actions, from release of hazardous volatiles.
3.
4.
Mitigate the potential for release due to tidal flood surges for
-------
10
5.
Close the site in a manner sufficient to:
o provide site drainage
o divert rainfall run-on
o minimize areas of ponded water
o mitigate impacts on air, surface and subsurface
waters and soils from migration of residual
contami nants
Clean up criteria associated with each objective were not established since
the goal of this action is source control; that is, to contain/remove the
material from the uncontrolled condition that now exists. This would mean
containing or removing the specific wastes in bulk, i.e. tars, sludges,
etc. In accordance with 40 CFR 300.68(e)(3), the contamination caused by
the present waste is the subject of an ongoing off-site remedial investiga-
tion study. That project will gather the necessary information to better
ascertain what is needed to determine "how clean is clean" for MOTCO with
respect to residual soil and groundwater contamination. Meanwhile, the
hazardous materials causing the shallow groundwater pollution and posing a
threat to the public health, welfare, and the environment through potential
air and surface water releases must be mitigated. To this end, 11 source
control alternatives were considered including a no-action alternative.
To determine components of each of the 11 alternatives refer to Table 3-2.
Note that Table 3-2 is organized with each alternative listed horizontally
across the top of the table with the components designated by an 'X' verti-
cally under the respective alternative.
Initial Screening of Alternatives
In accordance with Section 300.68 (g) of the NCP, treatment and disposal
technologies for each waste type were grouped into components for assembly
into a limited number of complete remedial action alternatives. Characte-
ristics of the waste limited the types of proven technologies that could be
considered and impacted on the number of alternatives that could be developed.
As an example, the organic liquids are ignitable and contaminated with PCBs
at approximately 70 ppm. Furthermore, the liquids are not conducive to
solidification. The Toxic Substances Control Act (TSCA) will not allow the
landfill of PCB laden ignitable liquids. With the waste incapable of being
solidified, a landfill disposal option for the organic liquids is eliminated.
Considerations such as these, outlined in detail in the Feasibility Study,
-------
Ta~le ]-2. Co~ponent Hatrlx of Initial Alternatives - MarCO Site
-L 2... 2... -!L -L 6 ..L. 8 9 ~ --!!...
Incinerate. . . . . . . . . . . . . . .. . . . . . . . .. .. . . . . . " -- ........ ~..... Q!!!!.!!..... Q!.!!ill..... Q!.!!ill..... !!!!!.!!!..... !!!!!!!!..... ~..... ~...... ~...... ~.
Lana fill OUsite Offslte OCfsite Onslte Offalte On/Off Onslte Offslte Offalte Onslte
uNo "Base "RCRAI "RCkA "RCRA/
Hedla/Component ~" Case" ~ ~ ~
CIJiHON ElEHENTS X X X 1 I k X I 1 X
ORGANIC VAPORS
Closed-System/Inert Cas I X X 1 I 1 1
HISC. DEBRIS
Offslte landfill X X X I I I
Onslte landfill X ! 1 X-
BURIED HnAlS
Excavate/Dispose X X X 1 X ]I X -I 1 X
W PIT SURfACE \lATER
I Offalte Biological Treatment X X 1 I 1 1
m Onslte Pretreat/Off site Blo Treat. I X
Onslte Complete Treatment X 1-
ORGANIC lIQUIDS
Onslte Incineration
. Liquid Injection lea11)
- Rotary Kiln I(all) - Xeall)
Offslte Incineration
- Waste Incinerator XepCB) X(a11) - I(PCB)
- Industrial Thermal X(all) _X (non PCB) X(non-PCB)_X(all)_X(all) _1(a11)
SlUDGES/TARS/SOLIDS
Offalte landfill X I I I I
Offalte Incinerate (R.Kiln) I
Onslte Incinerate (R. Kiln) I X -
Onslte landfill 1 1
COh~AHINATED SOILS
Offalte landfill I I I A I 1
Onalte Landfill I 1__1 1-
VERTICAL BARRIERS
Circum. Slurry Wall I X
Te~porary Sheet Pile X I X X I X I X
-------
11
According to Section 300.68 (h) of the NCP, three broad criteria should
be used in the initial screening of alternatives:
(1)
Cost. For each alternative, the cost of installing or implementing
the remedial action must be considered, including operation and
maintenance costs. An alternative that far exceeds the costs of
other alternatives evaluated and that does not provide substantially
greater public health or environmental benefit should usually be
excluded from further consideration.
(2 )
Effects of the Alternative. The effects of each alternative should
be evaluated in two ways: (a) whether the alternative itself or
its implementation has any adverse environmental effects; and (b)
for source control remedial actions, whether the alternative is
likely to achieve adequate control of source material, or for
offsite remedial actions, whether the alternative is likely to
effectively mitigate and minimize the threat of harm to public
health, welfare or the environment. If an alternative has
significant adverse effects, it should be excluded from further
consideration. Only those alternatives that effectively contribute
to protection of public health, welfare, or the environment should
be considered further. .
(3) Acceptable Engineering Practices. Alternatives must be feasible
for the location and cond1tions of the release, applicable to the
problem, and represent a reliable means of addressing the problem.
Eleven alternatives were screened in terms of the criteria of the NCP. The
rationale for rejecting or selecting each alternative for further detailed
evaluation follows.
Alternative 1 - No Action: 40 CFR 300.68(h)(2)(ii) sets forth one criteria
for the rejection of a remedial alternative and one criteria for the
acceptance of a remedial alternative. The criteria for the rejection of an
alternative is the resulting of adverse effects due to the alternative. As
documented previously, past releases of hazardous contaminants into the
air, surface water and groundwater has occurred and is occurring. The no
action alternative will allow this to continue. The continuing release of
hazardous contaminants demonstrates inadequate isolation and control of the
wastes at -the MOTCO site indicating that the no action alternative fails
the criteria for the acceptance of an alternative under the NCP. Resulting
risks to the public health and the environment caused by the no action
-------
12
Alternative 2--0ffsite Incineration/Offsite Landfi11--Retained (Incineration
of liquid organics at facilities currently not holding TSCA permit but
would obtain a permit.) . .
Rationale:
Least comparative cost to implement incineration of organic liquids,
the most hazardous media
All bulk wastes removed from site
Greater potential for cost reduciton for incineration of liquid organics
Maximum recovery of resources (fuel value and possibly sulfur)
Alternative 3--Commercial PCB/Industrial Non-PCB Incineration (TSCA/RCRA
Alternative)--Retained (Incineration of ~CB contaminated liqUld organlcs
at currently approved TSCA facilities and other liquid organics at RCRA
approved facilities.)
Rationale:
Use of industrial thermal processes (furnaces) at significiant cost
advantage for at least non-PCB organic liquids
Alternative 4--TSCA Facilities only--Rejected (All liquid organics
destroyed at TSCA approved facility.)
Rationale:
Highest cost for offsite incineration of organic
liquids--at least some non-PCB organic liquids could
be processed at industrial thermal facilities.
Alternative 5--0ffsite Incineration/Onsite Landfill --Rejected (Incineration
per Alternative 3 and Onsite RCRA Landfill)
Rationale:
Wastes remain onsite
Continued release and threat of release of hazardous
substances
Long term operation, maintenance, and monitoring required
Higher cost than alternate methods of disposal of sludges,
-------
13
Alternative 6--0ffsite Incineration of Sludges/Tars--Rejected
Rationale:
Considerably higher cost for offsite incineration of
sludges/tars than offsite landfill without comparable
benefit
Alternative 7--0nsite Landfill of Contaminated SOils--Rejected
Rationale:
Wastes remain onsite--continued, though reduced,
potential release
Long term operation, maintenance, and monitoring
required
No cost advantage
Alternative 8--0nsite Landfill of Contaminated Soils and
S1udge/Tars--ReJected
Rationale:
Wastes remain onsite
Continued release and threat of release of hazardous
substances
Long term operations, maintenance, and monitoring
required
No cost advantage
Alternative 9--0nsite Liquid Injection Incineration--
ReJected
Rationale:
...
Considerable onsite facility construction required,
though additional hazardous media (sludges/tars) must
still be transported
No cost advantage, though costs comparable to other
-------
14
Alternative 10--0nsite Rotary Kiln Incineration--Retained
Rationale:
Eliminates offsite transport of most hazardous media--organic
liquids and sludges/tars
Incremental cost of onsite incineration of sludges/tars
potentially advantageous
Highly contaminated soils could also be incinerated onsite
All wastes removed from site--no long term threat of release
Alternative 11--0nsite Incineration/Onsite Landfill (RCRA
Alternat1ve)--Retained
Rationale:
Little or no transport required
No significant use of offsite facility capacity
Retained to provide comparsion of complete onsite facilities
Descriptions of Retained Alternatives
The following detailed descriptions are of the retained alternatives listed
in Table 4-1. Cost estimates are listed in Table 4-2 at the end of this
section.
Common Components
The following components are considered common to all alternatives. Thus,
no further discussion or assessement of these components will be made in
screening and evaluation of alternatives, although estimated costs are
included in cost comparisons. These common elements include:
o Active Organic Vapor Control - Active control of organic vapors,
using closed systems with inert gas blanketing, is considered
essential for any remedial action involving organic liquids
(the major source of hazardous sub.stances at the MOTCO Site).
Any alternatives without active organic vapor control represent
a high risk of release which could easily exceed the risk of
release for a no action alternative, and would be rejected per
the NCP. It should be.noted that for alternatives with onsite
-------
15
incineration facilities at a greatly reduced cost since control
during transport of organic liquids is not required. Thus,
active control is included in all alternatives and is considered
a common component.
o Buried Metals and Miscellaneous Debris - Handling of at least
some miscellaneous debris will be required for any action
alternative. Excavation/assessment/disposal of buried metals
is desired to mitigate highly uncertain risk. Because the cost
of remedial action for this debris is very small compared to
total alternative costs, inclusion or rejection does not affect
overall assessments. Therefore, these components are also
considered common.
Alternative 2 (Base Case)--Offsite Incineration/Offsite Landfill
In addition to common components identified previously, offsite facilities
would be utilized for incineration of organic liquids (industrial thermal);
sludges, tars, and other solids would be solidified and landfilled; contami-
nated soils would be landfilled; the pit surface water would be treated and
discharged. Temporary steel sheet piling vertical barriers would be placed
where upper and middle transmissive zones intersect onsite pits to inhibit
groundwater intrusion. After removal of all waste media, excavated areas
would be closed and capped, including runoff diversion.
The elements are further described as follows:
Offsite Industrial Incineration-Organic Liquids
The key component of this alternative is offsite incineration of organic
liquids in existing industrial thermal processes for recovery of fuel value
and possibly sulfur content. Use of alternate destruction methods under
TSCA would be pursued, thus EPA approval is required and a trial burn may
be necessary. Incineration of non-PCB organic liquids could proceed,
however. This option represents the least cost to implement incineration,
and is the most applicable technology for organic liquids.
Pit surface water would remain until organic liquid layers were removed
(by pumping), to minimize release of hazardous volatile organics. Any pump-
able sludges/tars could also be removed and incinerated with organic liquids,
particularly where the volatiles content is high and/or sludges/tars are of
relatively low viscosity. All incineration ash will be disposed of per RCRA.
Offsite Biological Treatment of Pit Surface Water
A pump station and force-main pipeline would be constructed to convey pit
waters to the nearest existing permitted biological treatment facility,
-------
16
would be conducted onsite at MOTCO. A detailed assessment, including treat-
ability testing, would be necessary to identify compatability with existing
treatment processes, to project potential IIpass-throughll constituents, and
to develop any pretreatment to be conducted at GCWDA. Due to seasonal capa-
city concerns, a storage/surge tank would be provided at either location.
To allow receiving, treatment, and discharge of pit surface water from the
MOTCO Site, some revisions to the existing GCWDA discharge permit may be
necessary.
Sludges, Tars, and Other Solids
Sludges, tars, and other solids would be excavated and transported to off-
site commercial facilities for solidification and landfill disposal. [The
material must be compatible with the landfill and waste segregation by type
must be practiced.] Solidification could also be practiced onsite prior to
transport. Some risk of release of hazardous volatile organics is present.
However, the organic volatiles content of this media is generally about an
order of magnitude lower than the volatiles content of organic liquids.
Some residual organic liquids will likely be present, resulting in increased
risk and the need for additional care in handling and disposal.
Contaminated Soils
Contaminated soils, underlying or adjacent to the waste pits and in other
areas identified as contaminated, would be excavated and transported to
offsite commercial facilities for landfill disposal. Very highly contaminated
soil could be handled as sludge/tar, with solidification prior to landfill
disposal. No residual soil criteria is established for this source control
action due to inadequate data. Information gathered during the offsite
investigation and information gathered after removal of the bulk wastes are
required to determine what levels of cleanup are needed. However, past
sampling efforts have shown that a substantial amount of soil has been
grossly contaminated. Soil which has been visually infiltrated by organic
contamination and is structurally unstable to support capping for a final
closeout is the target for removal/containment.
Temporary Sheet Pile Vertical Barriers
As waste media are removed from the pits, surface water elevations will be
reduced to below surrounding groundwater elevations. The primary purpose
of temporary sheet pile vertical barriers would be to inhibit groundwater
intrusion, though some site dewatering would probably still be required.
Implementation of vertical barriers offers considerable cost reduction
potential through improved construction methods, such as easier excavation
techniques for contaminated soils; reduced water content in sludges/soils
allowing easier handling, transport, and disposal; and possibly reduced
,quantities of water requiring treatment and disposal.
The pros and cons of alternative 2 including effects, cost, and acceptable
-------
Table 4-1. Component Matrix of Retained Alternatives - Marco Site
2 3 10 11
Incinerate. .. . .. ... . .. .. ...... . . . ... ... . . ... Off site. . . . . .. Offsite...... ~....... Onsite
Landfill Offsite Offsite Offsite Onsite
"Base "RCRA/ "RCRA/
Media/Component Case" TSCA" TSCA"
COMMON ELEMENTS X X X X
ORGANIC VAPORS
Closed-System/Inert Gas X X
MISC. DEBRIS
Offsite Landfill X X X
Onsite Landfill X
BURIED METALS
Excavate/Dispose X X X X
PIT SURFACE WATER
Offsite Biological Treatment X X
Onsite Pretrt./Offsite Biotrt. X
Onsite Complete Treatment X
ORGANIC LIQUIDS
Onsite Incineration
- Rotary Kiln X(all) X(all)
Offsite Incineration
- Waste Incinerator X(PCB)
- Industrial Thermal X(all) Xenon-PCB)
SLL~GES/TARS/SOLIDS
Offsite Landfill X X
Onsite Incinerate (R. Kiln) X X
CONTAMINATED SOILS
Offsite LandfIll X X X
Onsite Landfill X
VERtICAL BARRIERS
Temporary Sheet Pile X X X X
BACKFILL/SITE CLOSURE X X X
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17
Pros:
+ Least cost for disposal of organic liquids by incineration, which is the
most applicable technology
+ Minimal onsite facility construction
+ No long-term operation, maintenance, or monitoring required
+ Overall cost minimization potential good
+ All waste media are removed from the site, and the most hazardous media
(organic liquids) are thermally destroyed
+ Recovery of at least the heat value of waste in industrial processes
+ Removal and transport of non-PCB liquids could proceed very quickly
pending resolution of PCB requirements
+ Commercial waste incineration capacity not consumed
Cons:
- TSCA permits and applicable State permits, possibly with trial burn,
required
- Time of implementation limited to capacity of industrial thermal
processes
- Risk during transport of organic liquids due to hazardous volatiles
and, to a lesser extent, sludges/tars
- Pit surface water treatability study required--possible metals
inhibition
- Probably GCWDA permit revision required
- Access agreement and easements for force-main pipeline required
- Risk of release of hazardous volatiles from sludges/tars during
processing (solidification) and long-term (landfill)
- Medium technical uncertainty and cost growth potential for
-------
18
Alternative 3--Commercial PCB/Industrial Non-PCB Incineration
(TSCA/RCRA Alternative)
If PCB approval is either not pursued or not ultimately obtained for
industrial thermal processes, then incineration of PCB wastes would be
conducted. at existing commercial hazardous waste facilities with PCB
approval. Non-PCB organic liquids would be incinerated at industrial
thermal processes with RCRA interim authorization or a RCRA permit due to
cost considerations. All other components are identical to Alternative 2.
Pros:
+ Minimal onsite facility construction
+ No significant long-term operation, maintenance, or monitoring
+ All waste media are removed from the site, and the most hazardous
media (organic liquids) are thermally destroyed
+ Removal and transport of both PCB and non-PCB liquids could be
initiated very quickly--no additional permits or approvals are
required
+ Commercial incineration of PCB wastes is well-demonstrated
Cons:
- Cost of permitted PCB-approved incineration substantially higher
than costs for industrial thermal incineration
- Consumes offsite commercial incineration capacity
- Time of implementation limited to capacity of PCB-approved commercial
incineration facilities
- Limited recovery of heat value or sulfur content
- Risk during transport of organic liquids due to hazardous volatiles
and, to a lesser extent, sludges/tars
- Pit surface water treatability study, GCWDA permit revision, and
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19
Alternative 10--0nsite Rotary Kiln Incineration
Rotary kiln incineration facilities would be constructed onsite for
incineration of organic liquids and sludges, tars, and other solids. Due
to the lower chlorine content for sludges/tars, scrubber neutralization
requirements would only be slightly increased compared to incineration of
organic liquids alone. However, ash quantity generated will be increased
about three-fold.
Pros:
+ No transport of sludges, tars, and other solids
+ Sludges, tars, and other solids are thermally destroyed, eliminating
potential long term release
+ Rotary kiln incineration is reasonably well-demonstrated
+ Technical and cost uncertainties with solidification of sludges/tars
are eliminated
+ Highly contaminated soils could be incinerated onsite
+ No transport of organic liquids, with associated risks of hazardous
volatiles release, is necessary
+ Pit surface water could be directly discharged after pretreatment
when TDWR effluent criteria are met
+ Substantial flexibility of pretreatment/discharge/transport
to GCWDA for pit water
+ Liquid injection incineration well-demonstrated
+ Minimal ash generated
+ No off-site commercial incineration capacity is used.
Cons:
- Extensive onsite facility construction required, including utilities.
- Highly acidic scrubber water is generated
- No recovery of fuel value or sulfur content
- Time of implementation controlled by construction and operation of
onsite incinerator
- Some air emissions will occur from operation
- Federal incineration permit technical standards must be met, State
-------
20
Alternative 11--0nsite Incineration/Onsite Landfill
In this alternative, onsite rotary kiln facilities would be constructed for
the incineration of liquid organics and sludges/tars as in Alternative 10,
with complete onsite treatment of pit surface water and acidic scrubber
water. Also, contaminated soils would be 1andfi11ed onsite.
Pros:
+ No transport of hazardous substances would be necessary
+ Additional backfill of excavated areas minimized, and need for
additional site closure is eliminated
+ Organic liquids and sludges, tars, and other solids are thermally
destroyed, eliminating long term potential release
+ Rotary kiln incineration is reasonably well-demonstrated
+ Essentially no offsite facility capacity is consumed
+ Highly contaminated soils could be incinerated onsite
+ Pit surface water could be directly discharged after
pretreatment when TDWR effluent criteria are met
+ No transport. to GCWDA required for pit water
o
Anticipated costs to implement incineration are higher than
Alternative 2 (industrial thermal) but less than Alternatives
3 and 4 (PCB approved commercial facilities only)
o Onsite incineration capacity could be selected based on
trade-off of costs and time of implementation
Cons:
~
Maximum onsite facility construction (all), requiring
extensive staging and land areas not presently available
on-si tee
- Contaminated soils remain in onsite landfill
- Long term operation, maintenance, and monitoring required
- Some long term risk of release of hazardous substances
from onsite landfill, particularly if below water table,
but reduced risk compared to no action 'for soils
- Time of implementation dependent on onsite construction
and operation
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21
- No recovery of heat value or sulfur content
- Air emissions will occur onsite
- Highly acidic scrubber water, requiring neutralization,
is generated
Incinerator ash, potentially hazardous (EP Toxic) due to
metals, is generated and probably requires solidification
and offsite disposal in a secure landfill
COMMUNITY RELATIONS
The public comment period was held from November 12 to December 3, 1984.
The public meeting took place on November 27, 1984, in La Marque, Texas.
Ninety-five people were in attendance with thirteen statements made at the
meeting by the public. Eight written statements were received during the
period with three additional written comments received after the December 3
deadline. In the presentation on November 27, the EPA indicated a preference
for Alternative 3 at a cost of $36.3 million as the remedial action. [NOTE:
Double-liner costs were not available at .the time of the public meeting.]
The major point of this alternative consists of the destruction of the
liquid organic waste at TSCA-permitted incineration facilities. The PRPs
and local government officials disagreed with this choice. The PRPs would
prefer Alternative 2, destruction of the liquid organics at facilities
currently without TSCA approval, by way of a waiver or expedited TSCA
approval of the facility. The local government advocated the destruction
of the liquid organics by an onsite incinerator as in Alternative 10.
In addition to the public meeting, two briefings to different local officials
took place during the public comment period. On November 16 the EPA Regional
Site Project Officer (RSPO), Don Porter, met with Dr. Ed Ibert of the Galves-
ton County Health District. Mr. Porter answered Dr. Ibert's questions about
the various remedies. On November 27, a briefing was held for the Mayor
and City Manager of La Marque. Attending for EPA were Sam Nott, Superfund
Branch Chief; Don Porter, and two Community Relations staff members - Cyrena
McMurry and Betty Reece. The CH2M Hill consultant responsible for the
development of the Feasibility Study (FS) was also in attendance. Questions
about the CERCLA Program and specific concerns about MOTCO were answered by
the EPA staff and consultant.
The "Responsiveness Sunvnary" outlines the history of cOl1l11unity relations
activities at MOTCO and includes a summary of all comments received about
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22
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The EPA has determined that in instances where CERCLA cleanups involve on-
site remedies the requirements of CERCLA supercede any requirements of
other environmental laws. It is the EPAls policy, however, to comply with
the substantive requirements of those other laws whenever possible. This
policy has several major impacts on any remedial proposal for the MOTCO
si tee
The environmental laws which will impact upon the remedial actions at the
MOTCO site include:
1.
Toxic Substances Control Act (TSCA) regulations, 40 CFR Part 761, for
PCB wastes,
2.
Executive Order 11990, Protection of Wetlands for sites located in
wetlands,
3.
Executive Order 11988, Floodplain Management for sites located in
fl oodp 1 a ins,
Clean Air Act to determine if the remedial action conforms to a State
Air Quality Implementation Plan (SIP).
4.
5.
Clean Water Act regulations, 40 CFR Part 122, for discharge of pollutants
into navigable waters; and
6.
Resource Conservation and Recovery Act (RCRA) substantive requirements,
40 CFR Part 264, for on-site alternatives and off-site transport and
di sposa 1 .
The Toxic Substances Control Act (TSCA) specifically governs the disposal
of the PCB contaminated ignitable liquid organics. These waste materials
must be disposed of in one of the following ways: high temperature incin-
eration, a chemical waste landfill, a high efficiency boiler or an
approved alternate method of destruction.
'I'
Various limitations on disposal methods and locations result from the
requirements of TSCA. The landfill option of TSCA is eliminated because of
the ignitability of the waste in addition to the technical inability to
stabilize the liquid organic material for such disposal. High efficiency
boilers cannot dispose of the wastes because the waste is not transformer oi1
as required by regulation. Furthermore, the wastes have a high chlorine
content rendering them unfit for use in a boiler. The disposal options
left to consider are incineration methods and other alternative methods
approved by the EPA. These other alternative methods may consist of indus-
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23
Executive Orders 11990 and 11988 apply to the protection of wetlands and
floodplain management, respectively. The MOTCO site is in a floodplain and
these orders should be considered in the design phase of any permanent on
site remedial measures. If an on-site disposal alternative is not implemented,
these orders would not be applicable.
The Clean Air Act will govern the possible release of volatile organic
compounds. Provisions and necessary site safety precautions are to be
-implemented regardless of the alternative action selected. On-site activities
will comply with technical requirements of the Clean Air Act eliminating
the need for Federal permits.
The Clean Water Act (CWA) governs the discharge of pollutants into navigable
waters. When disposing of the contaminated pit water at MOTCO, the CWA
will be complied with by using a permitted facility for off-site disposal
or by complying with the discharge requirements of the CWA for anyon-site
solution.
RCRA requires that off-site wastes must go to a RCRA approved facility.
Substantive disposal requirements of RCRA will govern anyon-site landfill
construction and hazardous waste incineration.
The primary RCRA technical requirements of concern for on-site solutions
are those governing landfill construction and hazardous waste incineration.
Before discussing the RCRA requirements, it must be understood that the liquid
organics at the MOTCO site are the pivotal waste; any site solution revolves
around the handling of this waste. The liquid organics can only be disposed
of by incineration or by an alternative method of destruction under the
TSCA regulations, in this case, by a furnace process. An on-site remedy
fulfilling the TSCA requirements would call for fncineration of the liquid
organics. This incinerator, to be cost-effective, should be used to destroy
the sludges/tars per the RCRA requirements. An on-site RCRA landfill might
then be the solution to contain the incinerator ash, the contaminated soil
and the miscellaneous debris. This scenario of legal and technical require-
ments was considered for the remedial action at the MOTCO site in Alternative 11.
Alternative 11, as outlined previously, is the second most expensive solu-
tion of the feasible choices to the MOTCO disposal problem. The expense
revolves around the cost for the construction of the rotary kiln and the
RCRA landfill. The on-site incineration of the liquid organics and the
sludges/tars would cost an estimated $33.3 million. In comparison, the use
of off-site permitted facilities would require $23.92 million to dispose of
these wastes. The construction of a RCRA double-lined landfill to contain
the incineration ash and contaminated soils requires $7.95 million versus
disposing of the waste at an off-site permitted facility at a cost of $7.01
million. In total, the on-site solution costs $4.9 million more to implement
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24
RECOMMENDED ALTERNATIVE
As required by the National 'Contingency Plan, 40 CFR Part 300.68 (j), the
cost-effective alternative for the remedy to the source control action at
the MOTCO site has been determined. This choice is Alternative 3 (see
Tables 4-2 and 4-20.) - The major parts of this complete offsite treatment
and disposal alternative consist of the transport of the pit surface water
by pipeline to an industrial wastewater treatment plant, the incineration
of the PCB liquid organics at TSCA permitted facilities, the incineration
of the non-PCB liquid organics at RCRA permitted or interim status
facilities, and the offsite landfill of the tars/sludges and soils at RCRA
permitted (double-lined) facilities.
The requirement for double-lined landfill facilities was implemented after
the development of the cost data for the Feasibility Study. The added cost
of the double-liner requirement is shown in Table 4-20. The cost figures
used to develop Table 4-20 are based upon factors applied to previous
single-liner disposal costs. With the implementation of additional waste-end
taxes from CERCLA reauthorization and probable increase of commercial
disposal costs, the costs for future landfill disposal could double. The
absence of cost information for double-lined facilities makes the estimation
of off-site disposal difficult, but for 1985 estimates the figures in Table
4-20 are the best available. The cost for on-site construction of a
double-lined facility is adjusted from the figures of the Feasibility Study
by using an economic model developed for the Economics Analysis Branch of
the Waste Management .and Economic Division, Office of Solid Waste and
Emergency Response.
At this time, Alternative 3 is the lowest cost alternative that is technolog-
ically feasible under 40 CFR Part 300.68 (j). The technologies used for
all elements of the action are proven through past experience. This past
experience also provides for a high degree of confidence in the cost data
available to assess the alternative. Protection of the health, safety and
welfare of the public and the environment is ensured by the use of existing
facilities of proven capability to either treat or dispose of the waste.
~
The selection of Alternative 3 does not preclude the implementation of
Alternative 10, the ~nsite incineration alternative, as the final remedy
for the source-control action. Because of the rapid development of the
technology of onsite incinerators in terms of efficiency and capacity,
coupled with the rising costs and shortage of capacity with existing facil-
ities, the use of mobile units for incineration may be cost competitive
with existing facilities in the very near future. To eliminate consideration
of an inplace incinerator, mobile or permanent, at the MOTCO site at this
time is premature in view of the dynamics of the market for incineration of
hazardous wastes. While Alternative 3 currently appears to be the cost-
effective choice, it is the intention of the EPA to pursue evaluation of
both Alternative 3 and Alternative 10 into the design phase. Detailed cost
estimates, based upon conceptual designs of the two alternatives, will'
-------
Table 4-2.
Summary of Estimated Costs of Retained Alternatives by Component - MOTCO Site
Incinerate. . . .. . . . . . . . .. . . . . .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Landfill .
2
OfWte..... .
Offsite
Base
Case
Media/Component
(Appendix B
Cost TableJ
COMMON ELEMENTS
(B-ll
1,800
ORGANIC VAPORS
Closed-System/Inert Gas
(B-21
912
MISC. DEBRIS
Offsite Landfill
Onsite Landfill
[B-31
149
BURIED METALS
Excavate/Dispose
[B-4J
190
PIT SURFACE WATER
Offsite Biological Treatment
Onsite Pretrt./Offsite Biotrt.
Onsite Complete Treatment
[B-5.11
[B-5.21
[B-5.3)
795
ORGANIC LIQUIDS
Onsite Incineration
- Rotary Kiln
Offsite Incineration
- Waste Incinerator
- Industrial The~l
[B-6.11
[B-6.2)
[B-6.2)
12,000
SLUDGESITARS/SOLIDS
Offsite Landfill
Onsite Incinerate IR. Kiln)
[B-7)
4,120
CONTAMINATED SOILS
Offsite Landfill
Onsite Landfill
[B-8.1)
[5-8.2]
4,000
VERTICAL BARRIERS
Temporary Sheet Pile
[5-9)
1,450
BACKFILL/SITE CLOSURE
[B-10)
3,090
PW of Annual O&M
[B-8.31
TOTALS
$28,506
ROUNDED
(1984 $1000)
~
Cost Rank
1
, of Alt. 2
100
Est. Implementation Time (yrs.)
3
4-3
3
OfWte.... .
Offsite
"RCRA/
TSCA"
1,800
10
oTi'STte..... .
OffSIte
11
o'i1STte
0iiSiti!
"RCM/
TSCA"
1,800
1,800-
912-------[B-6.1J-------[B-6.1)-
149
190
795
19,800
[B-6.2)
4,120
4,000
1,450
3,090
36,306
36,300
2
127
4
149
[8-9.2)-
190
190
1,750
1,740-
33,300
33,300-
[8-6.1)
[5-6.1)-
4,000
7,350-
1,450
1,450-
3,090
716
45,729
46,546
lli22Q
46,500
3
4
160
163
4
5
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Table 4-2D Double-Liner Cost - MOTCO Site
Alternatives
2 3 10 11
Estimated ($K) 28,500 36,300 45,700 46,500
Double-Liner Adjustment 6,000 6,000 3,200 700
New Total 34,500 42,300 48,900 47,200
Change +21% +17% +7% +1%
Adjustments to Feasibility Study-Appendix B Cost Tables:
Table B-3
Tabl e B-4
Table B-7
Table B-8.1
Table 8-8.2
Ori gi na 1 ($K)
149
190
4,120
4,000
7,350
with Double-Liner ($K)
224
236
7,700
7,010
7,950
-------
25
promising with respect to cost-effectiveness, and implement that alternative.
If the two alternatives prove to be equally cost-effective, then both alter-
natives should be bid upon. This will allow the market to determine which
of the alternatives is cost-effective.
Comparisons between the chosen alternative and the remaining alternatives
are summarized in Tables 5-3 and 5-4. A discussion of the critical differ-
ences and the process used to choose the alternative follow.
Alternative 11, the complete on-site solution, is the second most costly
alternative. Alternative 11 consists of on-site treatment of the pit water,
construction on the MOTCO site of a rotary kiln unit to destroy the liquid
organics and sludges/tars waste, and construction of a double-lined 1andce11
at the site to contain the highly contaminated soils. The water treatment
and incinerator are environmentally effective methods of waste disposal ,but
a RCRA landfill constructed at the MOTCO site is not cost-effective or an
environmentally sound method of waste disposal. The landfill would have to
be constructed above the contaminated water table. Further, it was deter-
mined during the preliminary evaluation of alternatives, that the cost of
building a landfill above the 100-year floodplain at the MOTCO location was
prohibitive. The landfill would have to be built at grade, above the water
table, but below the 100-year floodplain level, to be competitive in cost
with other alternatives. Additionally, the construction requirements of ,
this alternative are more substantive than the other alternatives and has
more extensive operations and maintenance requirements than the other alter-
natives. With all these restrictions, Alternative 11 would be competitive
in costs with the other alternatives, but provide little advantage over any
other alternative. Alternative 11 is not a good choice for the source-con-
trol action at MOTCO.
The comparison between Alternative 2, Alternative 3 and Alternative 10 is a
discussion of the dynamics of the hazardous waste incineration market. Alter-
native 3 is the status quo solution to the disposal of the wastes at MOTCO
and merits description first before discussing the remaining alternatives
and the respective solutions to the problems presented by Alternative 3.
The major problems with Alternative 3 are the cost and availability of inci-
nerator capacity at currently permitted facilities. At feed rates of only
7500 gallons per day, the time fnvo1ved in the clean-up of the MOTCO site
becomes drawnout using only currently permitted facilities. The increase
in the time required to perform the cleanup also means an increase in the
number of low-risk actions associated with such a cleanup. Transportation
accidents, loading' spills, etc., are bound to occur as the time of cleanup
increases. The same problem of incineration availability also causes the
price of incineration to be unstable. Substantial cost increases can be
expected for incinerating PCB wastes in the future. Quotes from vendors
for incinerating portions of the material at the MOTCO site have increased
20 percent between the completion of the Feasibility Study and the develop-
ment of this Record of Decision. Such an increase over the last four
months illustrates the potenti~l problem with Alternative 3.
-------
n
o
~
o
~
. ,
Table 5-3.
Alternative Evaluation - Environmental Effects/Remedial Response Objectives - MOTCO Site
Alternative
Description
Key Criteria/Rationale
2
Offsite Industrial Incineration
Offsite Biotrt.
Offsite Landfill
Backfill/Site Closure
All media removed from site
Site effectively closed
Risk of Release during transport of
Short-term and long-term release of
liquids can be mitigated
organics from sludges/tars
3
Offsite Commercial PCB Incin.
Offsite Industrial Non-PCB Incin.
Offsite Biotrt.
Offsite Landfill
Backfill/Site Closure
Similar to Alternative 2 except:
Anticipated longer implementation time increases
potential release onsite an~ during transport
period of
10
Onsite Rotary Kiln
Onsite Pretrt.
Offsite Landfill
Backfill/Site Closure
Probable least risk of release of hazardous vapors:
Transport of most hazardous media not required
Simpler requirements for control of organic vapor onsite
Sludges/tars incinerated--potential long term release elimi-
nated and short term release reduced
Highly contaminated soils could be incinerated
All identified waste media removed from site
Host hazardous media are thermally destroyed
Site effectively closed
onsite
Ash. scrubber water. and air emissions generated by onsite"
rotary kiln are manageable
11
Onsite Rotary Kiln
Onsite Complete Trt.
Onsite Landfill
Similar to Alternative 10 except:
Contaminated soils remain onsite
Continued long-term potential release
Effectiveness of site closure depends
and maintenance
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~
Table 5-4.
Alternative Evaluation - Engineering Assessments - MaTCO Site
Alternative
Description
Key Criteria/Rationale
2
Offsite Industrial Incineration
Offsite Biotrt.
Offsite Biotrt.
Offsite Landfill
Backfill/Site Closure
Most likely minimum implementation time based on capacity alone
Some permitting and PCB approval probably required, with poten-
tial for delay
Minimal onsite construction and staging
Technologies reasonably well-demonstrated and available
Site effectively closed--all media removed.
No long term operation, maintenance, or monitoring
Recovery of heat value and possibly sulfur
3
Offsite Commercial PCB Incineration
Offsite Industrial Non-PCB Incin.
Offsite Biotrt.
Offsite Landfill
Backfill/Site Closure
Similar to Alternative 2 except:
Limited offsite commercial PCB capacity available, possibly
resulting io extended implementation time
No recovery of heat value or sulfur content
Cost escalation likely
Could begin immediately--no further permits or approvals required
10
Onsite Rotary Kiln Iocin.
Onsite Pretrt.
Offsite Landfill
Backfill/Site Closure
Extensive onsite construction and staging
Onsite implementation of rotary kiln less demonstrated than
commercial or industrial incineration
Eliminates transport of most hazardous media
Eliminates technical and cost uncertainties for solidifica-
tion/landfill of sludges/tars
11
Onsite Rotary Kiln Incineration
Onsite Complete Trt.
Onsite !.andfill
Similar to Alternative 10 except:
Maximum onsite construction and staging
Longest implementation time
Long-term operation. maintenance, and monitoring
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26
A minor problem with Alternative 3 is the transportation risks associated
with the removal of the liquid organics. Approximately 1450 trucks over
the course of 2 to 3 years are needed to complete the job. Safety measures
to load the trucks and attention to driver safety will be needed to control
the situation. .
o
Recognizing the cost and safety problems with Alternative 3, other methods
of incinerating the liquid organics were examined. An initial survey for
an alternative that would satisfy the TSCA requirements of alternative PCB
destruction processes [40 CFR 761.60 (e)] revealed the availability of
different industrial thermal processes (predominantly furnaces) in the
Galveston Bay area. These processes might be capable of destroying the
waste, protecting the environment, providing a cost savings and also allow
the currently permitted PCB incinerators to continue to serve private
industry's needs. Cost estimates were then prepared based on the use of
industrial thermal processes. These estimates revealed a substantial cost
savings that could be available through the use of these processes. This
cost savings is the difference between Alternative 2 and 3.
Q
The lack of TSCA permits and the difficulty of forecasting the willingness
of the facilities to obtain permits and become eligible for burning of the
MaTCO wastes are the drawbacks to Alternative 2. It is EPA policy to
require compliance with other environmental laws during CERCLA off-site
response actions. Since the State of Texas or the EPA has no legal way of
guaranteeing a permit to a facility currently without TSCA approval prior
to the signing of the Cooperative Agreement and subsequent award of the
bid, Alternative 2 serves the purpose of demonstrating the benefits of an
increased number- of facilities, but cannot be the alternative advocated by
the EPA. If any of the facilities did obtain the necessary State and TSCA
permits, the resultant increase of competition would be expected to bring
the cost of the cleanup down and Alternative 2 would thus be implemented as
Alternative 3.
In the area of transportation risks, Alternative 2 gives no advantage over
Alternative 3. The removal and transportation of the liquid organics would
be the same procedure in either remedial action.
Q
The solution to the problems of off-site incineration is manifest in Alter-
native 10 in the form of on-site incineration. The rotary kiln unit proposed
in Alternative 10 is advantageous over Alternative 3 because of the elimination
of the transportation of the material from the MOTCO site. The complete
elimination of transportation risk is not found in Alternative 10 because
some hazardous material in the form of incinerator feed fuel would have to
be moved onto the site in order to destroy the lower BTU material. A minor
lessening of risk i~ obtained in Alternative 10 at an expensive price.
The $9.4 million increase of Alternative 10 over Alternative 3 is not justi-
fiable based upon a minor increase in transportation safety. Measures to
~
-------
,
.
27
improve transportation safety in Alternative 3 can be implemented at little
cost in the form of contractual requirements upon the transportation company
winning the award to include extensive equipment checks and review of driver
safety records.
The cost of Alternative 10 is the obvious disadvantage in comparison to Alter-
native 3. In the same manner as the costs of Alternative 3 are unstable,
on-site incineration is equally dynamic. As the market for destruction of
hazardous waste by incineration expands, the economics of on-site incinera-
tion becomes favorable in comparison to utilizing off-site facilities. This
was aptly illustrated in the cost sensitivity analysis done in the Feasibility
Study. As Table 5-1 indicates, a best case situation for Alternative 10
was equal. to the best case for Alternative 3, adequate indication that the
market for incineration is soft, making estimation temporal. By the time
the implementation of a remedial action is perfonned at MOTCO, on-site
incineration may be very competitive in costs. While implementation of an
on-site remedy is difficult from the standpoint of design and construction,
the cost benefits may be there to supplement the environmental benefits and
yield a favorable alternative.
The cost impact of the requirement for waste disposal at double~lined land-
.fills is an unknown factor. Indications "are that the double-liner regula-
tion will compound the cost increase for off-site disposal and as seen by
the estimate in Table 4-2D, close the gap between the cost difference of
Alternative 3 and Alternative 10. Alternative 3 relies on off-site landfill
as a disposal method moreso than Alternative 10 and is impacted to a greater
extent by cost increases due to the double-liner requirements. Alternative
3 is effected by two unstable markets while Alternative 10 is les~ vulnerable
to the cost surge of incineraton and landfill disposal methods.
The analysis of the alternatives produces the following conclusions. Off-
site biological treatment is the best solution for the pit water. Inciner-
ation of the liquid organics, on-site or off-site, is the optimum for that
waste. The handling of the sludges/tars/solids would be contingent on the
treatment of the liquid organic, where on-site incineration would provide
for destruction of the sludges/tars/solids while off-site incineration of
the liquid organics would mean off-site land disposal as the cost-effective
choice. The contaminated soils would be handled by disposing of that
material in an off-site facility. All offsite facilities will be in full
compliance with applicable laws at the time of disposal.
Q
The cost-effective alternative at the time of completion of the Feasibility
Study is Alternative 3. This alternative is the remedy of choice by the
EPA. However, due to the uncertainty of costs and capacity at TSCA permitted
incineration facilities and the expected rise in costs for off-site landfill,
Alternative 10 is to be pursued into the design stage and possibly into the
bid stage where the alternative which is bid the lowest, while meeting the
-------
() .r;:t>. c....;
,,,. 0
~
, -
Table 5-1.
summary of Significant Results of Cost Sensitivity Analyses - MOTCO Site
2
3
10
11
Onsite
Onsite
"RCRA/
TSCA"
Alternative
Incinerate.....................
Offsite............
Offsite
Base
Case
Offsite...........
Ons i te. . . . . . . . . . . .
Landfill
Offsite
"RCRA/
TSCA"
Offsite
Variation
Base Costs (Ref. 'Table 4-2) $28.5 $36.3 $45.7 $46.5
Rank 1 2 3 4
Organic Liquids
Low/High Costs $24.9/34.5 $36.3/45.8 $35.7/62.4 $36.6/63.2
\ of Base Costs, lowjhigh 87%/121% 100\/126% 78%/136% 79\/136%
Rank, lowjhigh, 1/1 3/2 2/3 4/4
"Best Case/Worst Case"
Low/High Costs $16.5/41.1 $27.9/52.4 $27.8/66.2 $29.8/67.0
. % of Base Costs- lowjhigh 60\/144\ 77\/144\ 60\/145\ 64\/144%
Rank, lowjhigh 1/1 3/2 2/3 4/4
NOTES:
1.
2.
3.
All costs in 1984 $ million.
Variations for organic liquids are independent and different between alternatives.
Variations for best case/worst case mixture of independent and cornman.
jd/GAM/019
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28
This arrangement will cause more expense for design and bid document prepa-
ration, but has the potential for large cost savings in implementation.
The end result is the implementation of the most cost-effective and environ-
mentally sound remedy at the MOTCO site.
FUTURE ACTIONS
As described on page 4, Summary of Response Actions, the Agency is conduc-
ting an off-site remedial investigation in order to evaluate the need for
remedial measures with respect to the groundwater contamination at the MOTCO
site. In addition to the groundwater evaluation, the extent of residual
contamination in the soil around the MOTCO site" is also a part of this
study. . The investigation report will be finalized in March 1985, and the
Feasibility Study, if needed, will be completed in the Fall 1985.
Immediate attention will be required at the MOTCO site to determine the
proper action for an abandoned well located on the site. Recent sampling
of the well is currently in analysis with results available by May, 1985.
At that time, the EPA will decide, in conjunction with the State of Texas,
on the proper course of action concerning the well.
An additional investigation is recommended for the MOTCO site once the high-
ly contaminated soils are removed, but before site closure. The purpose of
this investigation would be to determine the extent of contamination remain-
ing at the site after the removal of the source of the contamination. The
reasoning for this recommendation is as follows:
1. Cleanup time - The estimated clean up time for the recommende~ alter-
native is 4 years. A determination of "how clean is clean" is better made
at the end of this time period than at the beginning.
2. Changing site conditions - The lengthy clean-up period, along with the
removal of the source, will impact upon the site conditions in a manner
which cannot be predicted. Localized groundwater gradients will be affected
by the clean up and might very well be used to help in site closure. For
example, allowing the groundwater to re-enter the 140TCO pits upon removal
of the visibly contaminated soil, determining the characteristics of the
water, and treating the water in the pit, might allow for removal of less
soil because of the cleansing of the contaminants from the soil by the
groundwater.
3. Potential cost-savings - The cost figures for site closure can only be
considered the roughest of any possible" estimate. Stopping the project for
a short time period, 3 to 6 months, in order to study the changes made to
the area by the removal of the gross contamination might allow for a much
clearer estimate and more economical solution to the site closure. Further-
more, the the data gathered with the ongoing off-site investigation could
be supplemented with 1988-1989 data to yield a better informed closure
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29
The cost for such an investigation would be minimal in comparison to the
total project or eve~ the closure costs. An estimate for the cost of this
closure investigation might be set at $300,000 (1985 dollars) based on past
investigation costs at the site. The contingencies built into the recommended
alternative estimate should be able to pay for the closure investigation.
SCHEDULE
o
o Source Control Record of Decision (ROD) Signed
o Cooperative Agreement for Design Signed
March 1985
March 1985
Q
o Design Completed
o Bid Award
June 1986
August 1986
o Construction Begins
September 1986
u
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r
Record of Decision
Remedial Alternative Selection
SITE: MOTCO, LaMarque, Texas
DOCUMENTS REVIEWED
~
I am basing my decision on the following documents describing the analysis
of cost effecti,veness of remedial al ternatives for the MOTCO site:
- MOTCO Remedial Investigation Reports: Initial
Secondary Investigation, Source Sampling.
- MOTCO Source Control Feasibility Study
- Summary of Remedial Alternative Selection
- Responsiveness Summary
Investi gati on,
v
DESCRIPTION OF SELECTED REMEDY
o Contaminated pit water - off-site biological treatment
o Organic liquids - off-site incineration *
o Sludges/tars - off-site landfill*
o Soils-off-site landfill
* On-site incineration alternative will continue to be considered into
design phase.
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), and the National Contingency Plan (40 CFR .
Part 300), I have determined that the selected remedy at the MOTCO site is
a cost effective remedy and provides adequate protection of public health,
welfare, and the environment. The State of Texas has been consulted and
agrees with the approved remedy.
I have also determined that the action being taken is appropriate when bal-
anced against the availability of Trust Fund monies for use at other sites.
In addition, the off-site transport, storage, destruction, treatment, or
secure disposition is more cost effective than other remedial action, and
is necessary to protect public health, welfare or the environment.
t
"
The EPA is currently engaged in an additional Remedial Investigation/Feasi-
bility Study to evaluate potential groundwater contamination remedies and
residual soil cleanup.
v
J!1~I.-~ \) . \1 B~
Date
G)J.-~
D1Ck ngton,. .
Regional Administ ator
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