United States
Environmental Protection
Agency
Office of
Emergency end
Remedial Response
EPA.ROD R06-85.007
June 1985
&EFA
Superfund
Record of Decision:
-------
,. REPORT NO.
EPA/ROD/R06-85/007
(Please read instfuct;'O;'; on ihe'r;;"e~s'e be/o;e completing)
3, RECIPIENT'S ACCESSION NO,
\2.
SUPERFUND RECORD OF DECISION
Triangle Chemical, TX
5, REPORT DATE
June 11, 1985
6. PERFORMING ORGANIZATION CODE
4. TITLE AND SUBTI"LE
7. AUTHORCSI
B, PERFORMING ORGANIZATION REPORT NO,
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PRDGRAM ELEMENT NO.
". CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C.
Agency
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Triangle Chemical Company site is a 2.3 acre tract located on Texas.
State Highway 87, just north of the Bridge City, Texas city limits. The Triangle
Chemical Company operated a chemical mixing and blending facility from the early
1970s until 1981. During the company's operating period, various types of
industrial cleaning compounds, automobile brake fluid, windshield washer solvents,
hand cleaners, and pesticides were produced. Raw materials and finished products
were stored onsite in bulk surface storage tanks and 55-gallon drums. Currently,
approximately 51,000 gallons of hazardous materials are stored in 12 above-ground
storage tanks.
The selected remedial action includes: incineration and deep well injection
of the tank and drum contents; decontamination of all onsite structures; offsite
disposal of trash and debris; and mechanical aeration of contaminated soils to
background levels. Total capital costs for the selected remedial alternative is
estimated to be $385,000 with O&M costs approximately $500 per year.
.
KEY WORDS AND DOCUMENT ANAL.YSIS
b.IDENTIFIERS'OPEN ENDED TERMS
c. COSA TI Fitld/Gruup
17.
a.
DESCRIPTORS
-
Record of Decision
Triangle Chemical, TX
Contaminated Media: soil
Key contaminants: VOCs, toluene
18. DISTRIBUTION STATEMENT
119. S~:nR~ TY CL.ASS ! T/,is RepIJ'1/
120 SE CU R' T Y CL.ASS , This p~~,,;
i None
21. NO, OF PAGES
54
22 PRICE
..-
I
EPA Form 2220-1 (Ru. 4-77)
PREVIOUS ECIT'ON ,5 Oe50L..ETE
".~"'''-' .."'.""..'" '-'.-;", ,
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INSTRUCTIONS
1,
REPORT NUMBER
Insert Ihe l:.PA reporl number as it appears on the cover of Ihe publkation,
LEAVE BLANK
2.
3.
RECIPIENTS ACCESSION NUMBER
Reserved for use by ~adl r~port rcdpienl,
TITLE AND SUBTITLE
Title should Indica Ie dearly and briefly Ihe subj~,'1 ,'oVl:rage 1.>1' Ihe r"porl. and lx' d'spla)'nlprumin,'nlly, S,'I sllhlilk. if 11"".1, m "mali,'r
Iype or otherwise subordinale it to main lille, When a report is prepar~d in ml.>r,' Ihan ,'n,' vulume, r"l",..llh,' primary lilk. a.ld hllanl<'
number and Include subtitle for the specific lille. '
4.
5.
REPORT DATE
Each report shall cury a dale indicating at leasl monlh and ycar, Indkall' Ih,' h;asis un whkh ill\as ,,'IC,'lcd (1')[.. JQr,' "J i.mll', ,)QI,' of
tlPP'OIItll. diltt of prtptlrtltion. ttc.).
PERFORMING ORGANIZATION CODE
Leave blank,
6.
7.
AUTHOR/SI
Give name(s) in ,'onvenlional order (JollII R. DoC', J. Robar /)0(', ('II'.). Lisl aUlhur's al'liliallun if il ,Iiff,'r, frllm III<' l>crfurlllin~ ,.ft:ani.
ution.
8.
PERFORMING ORGANIZATION REPORT NUMBER
Insert if performing organizalion wishes 10 assign Ihis number,
9.
PERFORMING ORGANIZATION NAME AND ADDRESS '
Give name, street, ciiy, state, and ZIP cod~. Lisl no more than Iwo levels of an ur~anizaliunal hireardlY.
10. PROGRAM ELEMENT NUMBER
Use the program element number under whi.:h Ihe reporl was prcpared. Subordinale nUIIIl>.:r~ mOl)" ~ illl'hhk,lmp;u,'nlh,''''s,
11. CONTRACT/GRANT NUMBER
Insert conUact or grant number under which report was prepared.
12. SPONSORING AGENCY NAME AND ADDRESS
Include ZIP code.
13. TYPE OF REPORT AND PERIOD COVERED
Indicate interim fmal. etc.. and if applicable, dales covered.
14. SPONSORING AGkNCV CODE
Insert appropriate code.
15. SUPPLEMENTARV NOTES
Enter information not included elsewhere but useful, such as:
To be published in, Supersedes, Supplements, etc.
16. ABSTRACT '
Include a brief (200 words or less) factual summary of the mosl sil!nilkitnl Infurmali"n ,'unlaln"" III ,I,,' "'p"fl. II III,' f,'p"rl ,'''II;IIIIS a
significant bibliography or literalure survey, menlion it here,
Prepared in .uopcratiun with. Iranslallt'" III, 1',,''''"1,''' ;,1 ...'nh''''I1''' III,
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS. Select from Ihe Thesaurus of I.nginecrin~ and 5.,.'11111" [Cfms Ihc prupCf aUlllllrll,'J ,,'I Ills Iliallt.knllty II", m;'Jllr
concept of the resea,,:h and are sufficiently >pecific and predse to be used as rnJe:\ enille, lur ,alalll~an~.
(b) IDENTIFIERS A~D OPf'.!\-I:.NDED TERMS. L'se Idenufieh for prO)ed nam", ,'ude nam~s, "4ulpm"111 j"sl~n;'lors, \'t,' Cst.' "1'.11'
ended terms written In deso.:riplor form for those ~ubjects for which no des"lplur c"isIS.
(c) COSA TI III,LD GROL'P. Held and group assignments are to be laken frum the I ~65 (,OS.I\'II Suht""t ('al"!!lIry l.i,l, Slno.:,' Ihe ma.
jority of document> arc multidisciphnar)' rn nalure, the Primary I ieldi(;foup asslgnmcl1u s) Wlllbc Sl',', ,I", .Ii" Il'hn,'. a"'a III IIlIlIIan
endeavor. or Iype of physl.:al object. The applicationls) will be cro>s.rcr'eren.cd wllh scnmoary 11..1".'( .rllup ~"I~IIII"'lIls Ihal "1111011""
the primary postinglsl. '
18. DISTRIBUTION STATEMENT
Denote releasabilil) to the publil: or hl1l1lallOn for reason> uther than s.:.urll~ lur e,\aml"le "I(dl.'as,' 1.1111""1"11." I II,' all' a';lIbh,IoI) III
the public, Wllh address and prke.
19.8<20. SECURITY CLASSIFICATION
DO NOT submit dassified reports 10 Ih,' :'-iatlOnal Tc.hm.allnformation si:rv..c,
21. NUMBER OF PAGES
Insert the 10lal number uf pages, indudanl! Ihi' onl.' and unnumbered pagcs, hul c:\dudc dlStrlbuliun 11'1. ,I ~ny,
22. PRICE
Insert Ihe pll.e s~t by the ~ational fc.hm.:al Infofmatlon Savilc ur Ih... Cuvernmcnt I'lIntm!: Olrilc, ,I knll"n,
EPA Fo,m 2220-1 (Rev, .-77) (Reve,..)
! .... '''-.,
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE: Triangle Chemical Company, Inc., Texas State Highway 87, Bridge City
Texas
DOCUMENTS REVIEWED
I have reviewed the following documents describing the analysis of cost-
effectiveness of remedial alternatives for the Triangle Chemical Company site:
- Triangle Chemical Company Site Investigation, Roy F. Weston, Inc.,
September, 1984
- Triangle Chemical Company Feasibility Study, Roy F. Weston, Inc., Mar~,
1985.
".
- Staff summaries and recommendations.
DESCRIPTION OF SELECTED REMEDY
o Storage tank and drum contents - offsite incineration, deep well injection.
o Storage tank sludges - offsite landfill.
o Onsite structures - decontaminate and leave onsite.
o Trash - offsite landfill.
o Contaminated soil - onsite mechanical aeration.
DECLARATION
Consistent with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) .and the National Contingency Plan (40 CFR
Part JOO), I have determined that the selected remedy for the Triangle
Chemical Company 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 wi"ththe approved remedy. In addition,
the action will require future operation and maintenance activities to
ensure the continued effectiveness of the remedy. These activities will be
considered part of the approved action and eligible for Trust Fund monies:
-------
'.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust fund monies for use at other
sites. In addition, offsite destruction of liquids and secure disposition
of solids is more cost-effective than other remedial action and is necess~ry
to protect public health, welfare or the environment.
L II. 17rJ
(/ DA TI;
'.., .
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
TRIANGLE CHEMICAL COMPANY
BRIDGE CITY, TEXAS
".
.~"" .
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TABLE OF CONTENTS
Site Location and Description
1
1
3
5
~.. .
6
.
7
16
17
18
Site History
Current Site Status
Migration Pathways
Enforcement Analysis
Alternatives Evaluation
Community Relations
Consisting with Other Environmental Laws
Recommended Alternative
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t
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
TRIANGLE CHEMICAL COMPANY
BRIDGE CITY, TEXAS
Site Location and Description
The Triangle Chemical Company site is a 2.3 acre tract located on Texas
State Highway 87, approximately one-half mile north of its junction with
State Highway 62 just north of the Bridge City, Texas city limits as
shown in Figure 1. The site is bound on the north by a commercial property,
on the south by a residence, on the east by Highway 87, and on the west bY
Coon Bayou, in an area that is projected to become increasingly urbani zea'
in the next decade (Figure 2). The population of Bridge City is approximately
10,000 people. There are 15 houses and 50 mobile homes within -1/4 mile of
the Triangle Chemical site.
Natural grade elevations at the site range from four to seven feet above
mean sea level. The site is located in the l00-year floodplain as identified
by the Federal Emergency Management Agency. However, the combination of
frequently intense rainfall, gentle site slope, and poor drainage and tidal
influences in the bayou system, which discharges into the Sabine River
approximately three miles downstream, has resulted in inundation of the
site once every 6 years. .
Groundwater is a major part of the public and industrial water supply in
the region and is furnished by the Chicot and Evangeline aquifers, which
are hydrologically connected and considered a single unit called the Gulf
Coast aquifer. The shallow water table normally lies about 6 feet below
the ground surface. However, during periods of heavy rain the water table
has risen to as high as 2 feet below the surface.
The site surface includes five ~uildings and thirty tanks, as seen in Figures
3 and 4. Twelve of the tanks currently contain hazardous liquids totalling
51,000 gallon5. The buildings were used for office space, processing
areas, and loading areas.
,
Site History
The Triangle Chemical Company operated a chemical mixing and blending
facility from the early 1970's to 1981. During the company's operating
period various types of industrial cleaning compounds, automobile brake
fluid, windshield washer solvents, hand cleaners, and pesticides were
produced. Raw materials and finished products were stored in bulk surface
-------
,
"
,
,
..
"
.
./
".... , ~
c . .)'",~..,
. . '.'~. l
-.- / cr
. "..!..~,t ..
o ,-'-V "
.
.
,.
..... .. ,""
.....
.." .,.
.
,
. - -....,
FIGURE 1
SITE VICINITY
t~AP
~
--......."-:
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i
\
LEGEND
I
.0
SCALE
I
a
MILES
I
I
I
I
1/2. .
) I
~
) t
-
Urban
Agriculture
Forest
Wetlands
Rangeland
Water
---'''''-
FIGURE 2
PROJECTED
REGIOtIAL LAt!D USE
1995
I
JURCE: AREAWIDE WASTE TREATMENTJ!
MANAGEMENT PLAN
SOUTHEAST TEXAS AREA I'~ I
TRIANGLE
CHEMICAL
COMPANY
I
4
I
8
~
t
I
. ,
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APPROX81ATE
'ROPERTY
L-
.
I
.
I
. /
/
.
.
I
.
I
.;,'. ..
LOADING DOCK PROCESS ..LOING
00 00
~. 00
IItOUSIARD r WICS 0 00
PROPERTY 0 ~~S
REDIIRD
CHEMICAL
OFFICE I LAI
ITATE MIIHWAY .7
. FIGURE 3
TRIANGLE CHE~ICAL C~PANY
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INSIDE PROCESS BUILDING
r:
PI4
..13
'12 -
BROUSSARD
PROPERTY
rip&
0/'4
P3
P2
'1
COON 8AYOU INLET
A4
A3
AI
AI
"'.A. '.
-RED 81 RD
CHEMICAL
\ I
i I
\
. \
\
I I \
STATE HI8HWA" a7
..-.-
LeGeND
B EMPTY TANK
tl TANK CONTAINING LIQUIDS
~.
Fi qure 4
LOCATION OF PROCESI .
AND STORAGE TANKS
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2
During the latter period of plant operation, numerous fish kills in Coon
Bayou were reported by the local residents. Documented fish kills near the
site are listed in Table 1. Subsequent investigations by the Texas
Department of Water Resources (TDWR) indicated that these fish kills could
have been the result of discharges of hazardous materials from the site. .
In August 1981, TDWR acquired a temporary injunction against Triangle
Chemical Company, calling for compliance with pollution control laws and
prevention of further untreated discharges from the site.
In October 1981, TDWR found the site to be abandoned. Limited sampling of
drums, spill areas, runoff areas, and Coon Bayou documented that hazardous
materials were located onsite and were migrating offsite via stonmwater
runoff and direct discharge reinforcing the possibility that the fish
kills could have been caused by hazardous material spills from the site.
The drums stored onsite were noted to be in a deteriorated condition with
some bulging and leaking.
~. .
After the Trustee in bankruptcy for the Triangle Chemical Company i~dicated
that the cOmpany assets were insufficient to perform any necessary cleanup
work at the site, the Environmental Protection Agency (EPA) initiated an
Immediate Removal Action under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) to deter public access to hazardous'
materials on the site in April 1982. This action consisted of: (1) building
a six-foot high chain link and barbed wire fence around the material storage
area, (2) posting warning signs around the site, and (3) constructing a
drainage canal in front of the main drum storage area to prevent runoff
from reaching Highway 87. The cost of this action was $8,082.25.
In August 1982, a Planned Removal Action was conducted to remove the drums
and contaminated debris at the site. Under this action, the drums were'
staged and liquids were pumped to bulk transport trucks for offsite disposal.
Empty drums were crushed and removed from the site along with contaminated
trash and soil. The soil removal operations were limited to the drum
staging and crushing area. The wastes removed from the site during this
action were taken to an approved hazardous waste disposal site owned by
Chemical Waste Management, Inc. in Port Arthur, Texas and included: 21,000
gallons of liquid, 350 cubic yards of contaminated soil and trash, and
1,095 55-gallon drums. The cost of this action was $74,755.25.
In July 1982, -TDWR nominated the Triangle Chemical Company for inclusion on
the National Priorities List. The site ranked high enough to be placed on
the list and bec.ame eligible for remedial investigation/feasibility study
(RI/FS) funding. In August 1983, a cooperative agreement between EPA and
the State of Texas was approved, awarding $183,000 to conduct the studies.
Roy F. Weston, Inc. of Houston, Texas was selected to conduct the RI/FS.
The onsite activities for the remedial investigation were completed in
April 1984 and the final report was received in September 1984. The
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TABLE 1
DOCUMENTED FISH KILLS ON COON BAYOU
DATE LOCATION CAUSE NO. FISH KILLED
03/27/76 Near SH 62 & Winfree Rd. Low D.O. No Count
09/06/77 Near Confluence of Cow Low D.O. 10,000
Bayou
10/24/77 Private Pond Adjacent to Low D.O. 1,250
Coon Bayou & Hoo Hoo Rd. .~.
03/25/78 Between US 87 and Mouth Low D.O. 1 ,000.
of Coon Bayou .
05/05/78 Between US 87 and Mouth Low D.O. 38
of Coon Bayou
11 /2/81 Near Hoo Hoo Rd. Bridge Low D.O. No Count
10/19/82 Private Pond 1 Mile Low D.O. No Count
Upstream From Plant
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3
In response to suspected unauthorized activities on the Triangle property,
a third emergency action was undertaken to completely enclose the site with
a six-foot chain link fence in March 1985.
Current Site Status
The site investigation performed at the Triangle Chemical Company generated
substantial information concerning the regional geology, site geology and
~drogeology, and site geochemistry.
Regional stratigraphic information is presented in Table 2. Bridge City
and Orange County are located in the southernmost surface exposure of the
Beaumont Clay Formation, consisting primarily of interdistributary muds and
distributary sands and silts of the Pleistocene Age. As seen in Figure 5,
the soils at the site consist primarily of silty clays of the formation.
The uppermost stratum is a dark brown, clayey silt containing some organics
fiber, representing a weathered soil horizon of the Beaumont formation.
Underlying the clayey silt is a silty clay containing trace fine sands.
This soil layer was found to be stiff and moist during the site" investigation.
Within the silty clay unit are lenses of light brown silt containing traces.
of clay and very fine sand. This silt is typically saturated and soft,
varying in thickness from 2 feet to 5 feet across the site.
Adjacent to Coon Bayou, a light gray silty clay was identified underlain by
a black silty clay containing a significant amount of organic fiber.
..
Groundwater elevations, monitored during the site investigation, indicate
that shallow groundwater occurs across the site at depths of 2 to 6 feet
below the surface. Fluctuations in the shallow water table elevation are
associated with local weather conditions. During periods of heavy rainfall,
the water table has been identified as high as 2 feet below the surface.
Based on measured groundwater elevations, horizontal groundwater flow
occurs in a northeasterly direction across the si te and di scharges into
Coon Bayou. The influence of tidal variations on the water table elevation
is not significant enough to effect overall groundwater flow.
.
As seen in Table 3, the onsite shallow groundwater is slightly contaminated.
Because the ma«imum contaminant concentrations are well below the
concentrations established by the National Drinking Water Standards and the
Clean Water Act water quality criteria (Table 4 and 5, respectively), the
groundwater does-not present a significant threat to human health and the.
environment. It should be noted that the shallow groundwater is presently
subject to future contamination from leaching of contaminants due to an
elevated water table during severe rainfall events.
The site is located immediately adjacent to Coon Bayou, which is a tributary
01 the Cow Bayou and Sabine River drainage systems. There are no stream
gauging stations in Coon Bayou, however, flow variability in Coon Bayou is
similar to the variability of Cow Bayou, in which the flow ranges from 0 to
4,600 cubic feet per second (cfs), with a~ average of 101 cfs. Both bodies
of water are influenced by tidal fluctuations; extremely high tides have,
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'TABLE 2
STRATIGRAPHY OF THE
TEXAS GULF COAST REGIO~
-
f.re I,...... 5rrl.. "rell...phlc '''III ,,'~.....I..t~ ""It. 'd.c." '_I ...,..... I--.h
- . -.--- .--..-.-- Ai 1-;;1;';''-- -.
. ---:-~'I~
.. :-~~~-jj"~i._-
:0: i:: .....,.." 'J.t.. ,",.11""'"
.. .. "..1.'.....'" .-!''!''.C'~9J....r.!8!!.lCIII dlleo. ....Un ...1.'." .. ..,.tl.'n-.
~o: .~"!..!~..., 1-
.-.--- --.- 11111.. 5.'" . --....
t'1I........ Cu II" .... 1.....11- ....Un ..II.' .... .....,1.,...' .... ,..
-....- La.... c:o.ah.
~
....... r-. t.. ",........."', """'f'"
c..U.I,. lit................".......,..... ..........
-----=: "'f"""'"'' .......... -.;.-
''''''''.tI.f''''' .,. 0810.111. 5.".'''' 1...1.."""
0810.111. ......- rI_l,. r...-II- .... ,.,
W..hl,..oe c:o.a.,.
"1-- 5 ......' ,... 0' J..,.. ...1 f.r
. C.'.'_II. 'u"
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" . .. ......- . ,....,,,.... ............. C.."""I. ..""...- ..., ,.f
~ ~ . -""'c r........ ,.......It,.cot...-,'''' Lo...c. r_.,.
::J "'., ' . Ce......I. II, ""'''''('1'''' .t',
v. . f coello'", """f"""""" .........,"'" ......... ... "'r'p" ,,,,,.,,,",,,,
Ii e . .,.... -, M (111_..... 1M -'''.
l: ', . e "'r'." re...U.. ....ule'.') 't" ,..&.It... """1"'''''''''''-
~ 0
.. -..... !I''''.''' r.e. ,...,..1.... ......".. r,l. tl., ....~I.rp;;r.;;-;;:.--
.. Oll...,-U) "I. tI., Wh'..""1 C;'... """0'.' ,.. ... ..u,Iar.. ....t ..I
.
I' - -. ...I...I.!!!- U... 0." C-O....!l..--.-.---
" -~"'l._"'L.'."
! 1:.11 n.- S~...'.IUfW" """'er .., '''Iu..'' -.r. n' ...........
" 1"..111" 5.""01- ........., rer-tl- .....19 I.. c.....t...
:; .....eta 'i.....:'~; ,.:;.1.;:,-'-- I'",.,...."" . ...........,- c..I.... ,..... "".. ,..,u
: ,.....U.. !i";~!:;;:-!i-li,:...s~~'!!"'-""" 'It"'. 108 .~.t .., I.,.....
I" .. I'~ul ~.!.!E!'L"""" 1,-.'.."""-- '''w..... eo..." -,. .... I.. "., t .u ,..
'i --- ~!~rlh 5"'.'''. """"" ... olin...'" .... oiIoow ,...... ...10 Oll-.oco. I. ..~.
.. _~!'!!.!."'L.r;!.,-. -.- .. ..,d.olollr ...1..
............ !;....h.- 10 ..... ...por t . "., I....... """""","
Ioc... ...- _-~I~lO~;!-';~}!~--
.J!,!!..!!.!!--~!!!!!! - Nt""""'''' .... .. ,..."....;.
e c: I:,~~.!'!'-' ~ J!!.!.!!!!!!!.L"!!.- ,....tM"". ....,....'n'.'
j ~ ;;,!'!.!_:i-..!--- - ',......."" ,".ft'.. ...;.
... : .~=~~.!.!'~~!!'." . ",..,.-,..'_,,,,, ..,......
~" .."'!"'-:~. .!:t' f. ~j~~~
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'-- ~~ !!i!! ii :.~r._::.._. '
....1_- '!! !!,!!.~r!!!L.. !.
-- ". *!!.!i!"9-
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orra......
, 118'
lse
PROCDI--
SIll
I
IILn CLAyeCL)
IUCIC OMANIC
-3 IlL TV CUy eCl)
-,- ,
I CUftY8LT ;----T~
I ..n CLAY 8IL-CL) I
.. I aT -.J I
I I
" , ------' . I
I t , I
t
I an CLAYCCL) I
-IS .L .L
FI~UP.F. 5
SITE GEOLOGY
.~.- -
..
U.IIID .:
T ..OUIID I...'ACI
DIPTH 0' WILL CAI... .. .011..
.L UNTH 0' WILL ICIII.II . la. PACK
-%- WATIII n.LI'.
.-
lUll' ...-zeIIf1&.. .-.-
VlItTICAl . r. ~
- OIOLOOIC.COIITACT
- t- ,.
1IIC COWTaCT ,,",.111110)
IU.I.'ACI CIIOII
-------
'BLE 3
TRIANI., JE!t1ICAL COt1PArlY
ANALYTICAL PESULTS
GROUNDWATERS
dMlDD "IT ~ "I ..'D ... --- --, PI"" ... U8:0''''~
CDD!IfIM11III -.u. I .u. 1-""'10''111 ..... I _.I. .-1Itft.1OIft .u.1 lUll( IUI8 L"T
"""18 ../I lIP .. .. .. .. .IIS
.. 7.' 7.1 1.1 1.1
0..1- ../I " lIP .. .. .11
ower ..'I lIP .. .11 " .1'
..... ../I lIP lIP .. .. .11
_Id.' ..'I lIP lIP .11 lIP .11
SUnr ../I lIP .. .. .. .11
ZIIIe ..'.1 .15 .11 .II " 'IS
10: .." 75.' 51.1 31.1 11.1 ..1 ..1
IlpeeU'e 0iIIIdIIe'- . ...,. ..111 '" ... I..S
- .." lIP lIP '.1.
oua or--I.'r." "" lIP .. I...
011 a Or...........,I, ../l .. 1.1
"I. III !'OU.... "Ialll...
.....,.- OIl.''''' .." II II II II n. II
"I.II~ "U'~!!!.!!!8 ...!!!.!!
DI-.~.,I "'hlla'. .." 51 lIP lIP " II
... (t-I''''' ""1) "''''a'8 .." $I lIP .. .. II
"'.Itt. "U".I ""!eldn
Della-III: ../I .,- .
~!~.., ~Ua!!!'t !!Id ~!~~~!~It!
,"....".......... .." 11-28 .. u II
:.:
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.1 .. t.JM8lul la _1,lIcal ...,.11- ,.......
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TABLE 4
U.S. EPA DRINKING WATER STANDARDS
STANDARD
CONSTITUENT
MAXIMUM CONCENTRATION
119/1
Primary Drinking
Water
Secondary Drinking
Water
Arsenic
Barium
Cadmium
Chromium
Fluoride
Lead
Mercury
Nitrate (as N)
Selenium
Silver
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-0
2,4,5-TP Silvex
Chloride
Color
Copper
Corrosivity
Foaming Agents
Iron
Manganese
Odor
0.05
1.0
0.01
0.05.
1.4 .: 2.4
0.05
0.002
10
0.01
0.05
0.0002
0.004
0.1
0.005
0.1
0.01
.;.. ..
250
15 color units
1
Noncorrosive
0.5
0.3
0.05
3 Threshold Odor
Number
6.5 - 8.5
250
500
pH
Sulfate
Total Dissolved
Soli4s (TDS)
Zinc
5
References:
40 CFR Parts 141 and 143.
-------
Compound*
Diethylphthalate
Di-n-Butyl Phthalate
Pentachlorophenol
TABLE 5
CLEAN WATER ACT
WATER QUALITY CRITERIA
Water Quality Criteria
Fish and Drinking Water
Water Quality Criteria
Drinking Water Only
350 mg/l
34 mgl1
434 mg/1
44. mgl1
1.01 mgH.,.
1.01 mgl1
* Volatile organic compounds detected at Triangle Chemical Compa~y .
-------
4
Data generated during the site investigation, presented in Table 6, shows
that the surface water directly adjacent to the site is only slightly
contaminated. Concentrations of contaminants detected are well below
drinking water and Clean Water Act water quality standards. Therefore, .
contamination of surface waters from the site is not considered to be
si gni fi cant.
During the site investigation, several 55-gallon drums of chemical product
were observed in a building on property owned by the Triangle Chemical
Company, north of Redbird Chemical Company. These drums are in deteriorated
condition, and pose a threat to human health due to direct contact with the
public. Therefore, disposal of these drums is addressed as part of the
remedial action at the site.
The results of the site investigation and supplemental sampling perfonme~..
during the feasibility study indicate that approximately 51,000 gallons of
hazardous materials are stored in 12 above ground storage tanks onsite.
The analytical results of samples taken from these tanks are presented in
Tables 7 and 8.
The results of the site investigation also indicate that soil contamination
is restricted to past drum and tank storage areas onsite. Concentrations
of metals detected are within the range of levels found to occur naturally
in the soil in the area. Onsite soil contamination is extensive for
volatile organics compounds (VOC), as seen in Figure 6, which illustrates
the lateral and vertical extent of soil contamination of greater than 500
parts per million total volatile organics. Concentrations of' specific
volatile compounds found in the soil are listed in Table 9. A total of 1,990
cubic yards of contaminated soils are onsite; no contaminated soils were
detected offsite.
..
The following conclusions were developed from the remedial investigation:
o Near surface soils on the site have been contaminated from
migration of the waste materials through spills and leaks
from drums and tanks.
o Groundwaters below the site are not significantly impacted
by the fac.n i ty.
o Surface waters in the vicinity of the site are not significantly
impacted. .
o Air quality at the site has not been measurably impacted.
o Tanks containing hazardous materials remain unsecured onsite.
o A large quantity of general refuse, a portion of which is
potentially contaminated with chemical product, remains
onsite.
o A drum storage area on Triangle Chemical Company's northern
property remains unsecured.
-------
TABLE l
TPIANr,lE cHEtncAl COf1PAtlY
A~AlYTICAl RESUrTS
SURFACE ~JATERS
aMUtk40 II" T OF B-IW B-IW-D fiElD DETICI'ION
CDtCOO'RATION INLET INLET DIPLIQ\TE 8Lt\NK LIMIT
Pheno t s ~/I NF .005
pH ~/I 6.2 7.2 7.0
Chrami um ~/I NF NF .05
Copper ~/I 0.19 .03
Lead ny/I NF NF .5
Niekel ~/I NF NF .l
Si her ~/I NF NF .l
Zine ~/I 0.04 NF .02
P!ior~ ty~!!uta!!t B8s~J.~u.!~!J!
Di-n-Butyl Phthalate ug/l 22 38 13 10
Diethyl Phthalate ug/l NF NF 13 10
1.
-------
TABLE 7
ANALYTICAL RESULTS OF TANK SAMPLING
DUPING EMERGENCY RESPONSE ACTION
. . AUGUST. 1982
tANR NUMBER
COM POUN D* A2 A3 A4 13 14 21**
TrichloroethyleDe 2,351 16,000 69
1,1,2-TrichloroethaDe 13 401
laDzeDe 10 52 72
1,1,2,2-TetrachloroetheDe 39 550
TolueDe 620 733 412 3,400 711
lfapthaleDe 1,112 4 6 ,28s'.~' 58
Ethyl leDune 132 77 . 20,000 82
2-lthylhezyl Phthalate 220,000 309
1,2-DichloroethaDe 710
2-CbloroethylviDyl Ether ..
2,000
l,4-DichlorobeDzene 5,561
1,2-DichlorobeDzeDe 43,500
If-NitrolodipheDylamine 218 800
PCB (polychloriDated biphenyll) 75
Chromium 0.15 0.02 150 0.04
Copper . 11 0.35 4.0 0.07 5.8 0.42
Laid 2.5 1.0 0.09 7.1 0.3
. Bickel 0.5 0.2 0.03 1.3 0.3 0.06
Silver 0.2
Zinc 12.9 0.5 1.1 0.4 0.09
Mercury 0.003
* All concentrations of organic compounds expressed as parts per billion (p~b)
All concentrations of inorganic comDounds (metals) expressed as parts per billion
(ppb)
-------
: 8
TRIANGLE ~rtEMICAL COMPANY
ANALYTICAL RESULTS OH TANK CONTE~ITS
... fII
~ .......-.~.. 11 U II . " " II fU 81 15 .
"",dalal'1~ -.11 .. I.U2 .. .. .. .. .. .. .. .. ..
""""18
....In -.I1 ' .r .. .. " " " " " " " "
........ ..Ii .r .. .. .. " " " " " " "
~ l1li1 .r .. .. .. .. .. .. .. .. .. ..
~~.. 8II1 .r .. .. .. " " " " " " "
2.H 1III1 .r .. .. .. " " " " " " "
2..,5-9 1III1 .r .. .. I.on " .. .. .. .. .. ..
~J"'- Op 181 " " 100 125 1]1 .. 181 .. 115 110
I88II:t1wlty ..' .. .. .. .. .. .. .. .. .. ..
.. 1.1 '.2 11.2 11.1 .,.. . .,... aI. lI.t t.' 1.1 '.0
An8Ie ..,. .. IF 0.011 0.013 II:Jft 5 1.011 1.021 1.11' I.DOt .. IUI'I 5
_1- l1li1 " " " " 10ft 5 .. I." .... .. .. IUI'I 5
. Q8II- ..,. .. .. .. 0.. 10ft 5 " .. " .. .. 10ft 5
CIIn8I- l1li1 I.. 1.1. .. ".0 11M 5 0.15 '.15 '.15 .. '.21 11M 5
.... l1li1 1.. J.' I.D 2.' 11M 5 0.' 1.. J.2 .. 1.. IUI'I 5
....., l1li1 "" .... .. IIJI8 . 10ft 5 " .. '.D5 .. IUI'I . IIJI'I .
181-- l1li1 " " " " 10ft 5 .. 1.18 " .. .. IIJI'I 5
811.. l1li1 " " " " 10ft . 0.1 .. '.1 .. .. IIJI'I 5
........t8 l1li1 .,- 92 .. 100 II:Jft . .,.. . .,... .. ..- " -
o.bu....u. l1li1 J,.. I 1.- t,2IOO II:Jft . 10ft . lUll. 13,- 2." 100 1...
IIIIIIII8 . .. .. .. 0.01 O.U 0.1' 0.01 .. .. .. ..
CblCII'III8 . O.OJ " " 0.21 0.02 .. 0.01 .. .. .. ..
Mal QrtIa . 13.. J.]] 1.'71 20.. I] 17.' 1." 0.'1 2.. ..57 ....
.1"P"'8 . 0.01 " " 0.21 0.02 .. 0.01 .. .. .. ..
~~. . 10.' U.7 U.O 10.6 11.' 11.' 10.7 ,i. 10.' 11.0 10.2 10.1
.ltI'GIIB . 0.11 " 1.1). 0.11 .. .. O.U .. .. I.U ..
AlII . 1.10 " 0.02 1.] .. 0..' 1.1 1.1 0.10 0.10 0..
"
".
-------
TABLE 8 (CONT.)
TRIANGLE CHEMICAL COMPANY
ANALYTICAL RESULTS ON TA~K CONTENTS
.... f1I
-..:.. v- -___~ .M AI AI II II ., II IV D . .
--.atr . -': 08t' r- L 1.8 1.5 I.t ..0 1.5 1.1 2.. I.t 1.1 1.5 1.'
...,.. -.&.. 1.- ..- 1.- 1.0]9 ...U I... 1.- 1.- 1.1159 1.- 1.-
IIWIIt .. .. .. .. 11.- It... .. . .. .. ..
r - a a 811* 8IIl 12 U J7 . 2.110' .., S 111 12 " t
""""tr ... ... '.17 '.11 1.11 '.1. .. .. .. '.11 '.12 ....
1 ""'" a
...... DU. 1D2. DII. ... lIM. 181. 111.
I... tI ...... ua
J ....,. tIIIIIeItr """,,'~ ._)1-'''''' --.... ..... t88 .... U - faIIII to -"'.8111 .... ...,. IIIID. U..,. II1II'.
.'.......... -.. ....- "-..., ...........................
S """""'''-'''''''"""".",,,,,-,,,-toe....at'''''',, J - 1 j. 1IIIU8r,.. -- ... ........ .au. 18k!tI...,
....... --...,.... -~ 8Itdc ... ... ,... .u8Ct1an t8:ll1I...- ... -t8IIUI. lilt ... -* ......... .-...A. ..Uty GIIIIItI'CIi f8ta.
. .... ., ..... I ...... ....... ..... ..........'" . - t ...-"M18 ~ Wit...AI t"", ...,...
, .... ., ..... ..... -- fD8 fl1- .. dI881w. 81181"", -* .. ~.
,
, .
Ii>
j
. i
-------
.d
. .
.'
9AOtJSSo\AO
F'-~
,1.7
,
CHA" \.... F£NC£ '\
--
.-,.-.-.--.-.
HOM( ,
OFFIC£
,..
.D
~
..
~
I:
.,
i
...
~
...
'It
I
:1 . ~--
L ~
......--. .. / --,--- '--'-1--"
-- --
i'AQP[R ry
LOADING BUILDING
PAOCfSS IIJILDItG NO S
L : \.j::1G DOCK
LOA~ DOCie RA'"
0000
0000
AEIIIIIAD Ql[MI:Al. PWOPERTY
PPOCE5S
,iI,ILC:'4G
:'0.1
PAOC£SS
1UL00NG
NO.2
..~...~..""
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-=-
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,
"
rAlo\,.;t. E Ct4EMlCAL
I PftOPf.RTY UN(
ICM.r,r.40'
Fiaure 6
LOCAnOIl 0" .O'L 80..IIQSI
SOIL ZONES WITH TOTAL Y.O.C.
-------
TABLE 9
TRIANGLE CHEMICAL COMPANY
ANALYTICAL RESULTS
SOILS
1 '
55-4
SURFACE
SS-4
DETECTION
. NATURALS
IN SOILS
COMPOUND
UNIT OF
CONCENTRATION
SC-l
SURF ACE.
SC-l
SC-2
SC-2
1 '
SURFACE
1 .
SC-3
SURFACE
SC-3
1 '
SC-4
SURFACE
SC-4
1 '
LIMIT
AVE.
RANGE
Phenols ug/gm NF NF NF NF NF 0.233 NF 0.051 0.086 NF .005
pH SU 8.1 7.7 8.3 7.9 8.3 8.3 8.1 7.6 7.6 7.0
ChrOOlium mg/kg 4.8 5.0 3.0 4.4 12.1 7.2 7.5 12.4 4.9 3.4 .05 200 5-1.000
Copper mg/kg 11. 5 10.0 7.2 7.6 14.1 10.7 8.5 10.2 9.1 5.2 .03 20 2-100
Lead mg/kg 57.2 19.5 36.6 49.2 89.3 22.1 23.0 27.1 43.4 15.7 .5 10 2-200
Nickel mg/kg 4.2 2.2 4.2 2.0 5.7 NF 4.9 6.3 NF NF .1 40 5-500
S 11 ver mg/kg NF NF NF NF NF NF NF NF NF NF .1
Zinc mg/kg 102 28.0 28.1 64.1 65.1 232 35.2 11.6 26.3 3.2 .02 SO 10-300
Prioritv Pollutant
Base Neutrals
Di~-Butyl- Phthalate ug/mg NF NF NF NF NF NF NF 23 NF NF 10
. As per .Chemical Monitoring of Soils for Environmental Quality and Animal and Human Health". Dale E. Baker and Leon Chesmin. contribution to journal
series of Agricultural Experiment Station.
Page retyped for NTIS - September 5, 1985
. : I
":.';"
-------
TABLE 9 (continued)
TRIANGLE CHEMICAL COHPANY
ANALYTICAL RESULTS
VOLATILE ORGANICS IN SOILS
COHPOUND.
NW-2A
SS-SA
SS-9A
SS-11C
SS-l1C
SS-l1C
SS-12A
SS-14A
SS-14B
REDBIRD
24.
14.
24"
6"
16"
32"
30.
18"
30"
24"
TRIP BLANK
LAB BLANK
Priority Pollutant Volatiles
Chlorobenzene NF NF NF NF 0.62 NF NF NF NF NF NF NF
1,2 Trans Dichloroethylene NF NF NF NF 0.13 NF NF NF NF NF NF NF
Ethyl benzene NF NF NF NF NF 0.18 NF NF NF NF NF NF
Non-Priority Pollutant Volatiles..
Acetone 0.15 0.16 1.4 0.06 0.09 0.05 0.05 0.03
Carbon Disulfide 0.12 0.21 0.22 > 0.05 > 0.04 0.05
Furan
Tetrahydrofuran 0.07 0.11 0.04 0.04
Aldehyde C4 0.32
Methylketone C4 0.41
Aldehyde C5 -- 0.04
Hethylketone C5 0.09 0.12 9.7 0.04
Dioxane 0.26 0.22 0.04
Hethylketone C, 2.4
Methylketone C7 22.0
Total Alcohol) C5 1.3
Methylketone C. 0.68
Alkylbenzenes)C. > 3.9
Hydrocarbons C.
Total Acetates 0.33
Dichlorobenzene 0.11 0.04
Detection Limit - 0.1 ~/g
. An units in)0L9/g
.. Concentrations reported are to be used as semi-quantification only
-------
5
The following target receptors were identified in the remedial investigation:
o Materials released onto the ground surface from the storage
tanks would either percolate into the soil or flow into Coon
Bayou. The risk to receptors via surface water migration has
been documented by fish k~lls caused by past releases of
similar materials that were stored in 55-gallon drums which
were disposed of during a removal action in August 1982.
o A sudden release of materials in the tanks would also present
a risk to persons living and working in the area and driving
past the site due to volatile organics released to the
atmosphere and direct contact with contaminated soil.
o The volatile organic compounds detected in the soils. several
of which are suspected mutagens. teratogens. and carcinogens.
could be released to the atmosphere during future development
of the site affecting worker health and safety. Toxicity.
characteristics and routes of exposure for the volatile organic
compounds found in the soil and tanks are listed in Table 10.
.;.. "
No significant migration of airborne contaminants onsite was detected
during the remedial investigation.
Migration Pathways
Groundwater
The Triangle Chemical Company site is underlain by the Beaumont Formation, .
one of five formations that make up the Chi cot Aquifer of the Texas Gulf
Coast.
The Chicot Aquifer is the youngest aquifer in the coastal plain of Texas
and includes the Willis Sand. Bentley Formation, Montgomery Formation.
Beaumont Clay and Recent Alluvium. Recharge to the lower portions of the
Chicot Aquifer occur at outcrop~ of the Willis. Bentley and Montgomery
Formations, north of Orange County. The Willis Sand consists principally
of reddish sands and gravel, silt and clay. The Willis Sand is not known
to yield fresh~ater to wells in Orange County and contains slightly to
moderately saline water. The Bentley and Montgomery Formations consist of
a basal gravelly.sand grading upward into finer sand, silt and cl~. Much
of the sediments of these formations are similar to the Willis Sand from
which they were at least partly derived.
The deltaic coastwise plain of the Beaumont Clay forms the land surface of
all of Orange County except along rivers and the coast where it is covered
by Recent Alluvium. Much of the surface exposure of the Beaumont Clay in "
the northern part of the County is covered by fine sandy 101m because of a
greater proportion of sand near the base of the formation. Southward the
Beaumont becomes progressively more clayey. While the Beaumont is generally
described as consisting of clay it contains much sandy material which can
be locally utilized for water supply. Sand beds in the Beaumont Clay yield
freshwater to domestic and livestock wells in Orange County.
" .. ~ .'";1""'.!'"-
-------
TABLE 10
TOXICITY DATA FOR SELECTED ORGANICS FOUND IN SOILS AND TANKS
AT TRIANGLE CHEHICAL COHPANY
ROUTE OF EXPOSURE
TOXICITY CHARACTERISTICS4 SKIN
CARCINOGEN MUTAGEN TERATOGEN INHALATION ABSORPTION INGESTION SKIN/EYE CONTACT
sans
Acetone X X X X X
Carbon Disulfide X X X X X X
Chlorobenzene X X X X X
Dichlorobenzene X X X X
1.2-Dichloroelhylene X X X
Dioxane X X X X X X
Ethyl Benzene X X X X X
Furan X X X X X X
Tetrahydrofuran X X X X X
IAtfKS
Benzene X X X X X X X
Dichlorobenzene X X X X X
Dichloroethane X X X X
Ethyl benzene X X X X X
. Napthalene X X X X X
l,l.2.2-Tetrachloroethane X X X X X X
Toluene X X X X X X
l,l.2-Trichloroethane X X X X X
Trichloroethylene X X X X X X
-------
6
The recent alluvium in bayous supplies small quantities of groundwater to
temporary residences. Although the alluvium is capable of furnishing large
quantities of groundwater, large scale development would induce or accelerate
movement of saline water from the rivers into the aquifer, eliminating th~
potential for using the aquifer as a major resource.
As previously discussed, shallow groundwater is encountered between 2 and
6 feet below the surface of the site. Fluctuations in the shallow water
table occur primarily due to local weather conditions, rising during
periods of heavy rainfall and falling during drier periods. Although a
tidal influence is seen in the water table, fluctuations due to this
influence are not significant.
The remedial investigation confirmed minor contamination of the shallow
groundwater. The fluctuations in the water table and heavy rainfalls .
associated with these fluctuations indicate that the observed groundwater"
contamination is due to periodic leaching of soils when the water tJble has
risen. Based on the observed contamination, soil permeability (10-3 em/see),
and direction of flow, it is possible that soil contaminants leached into the
groundwater could impact Coon Bayou.
Surface Water
Surface water has been contaminated from the site from runoff during flood
events and from leaking tanks and drums. Seventy-five percent of the site
lies in the lOO-year floodplain as designated by the Federal Emergency
Management Agency, and portions of the site have been inundated at least
once every six years. Potential exists for future contamination of surface
water due to erosion and transport of contaminated soil and a release of .
contents from deteriorating onsite storage tanks.
Air
Results of the remedial investigation indicate that air quality in the area
has not been adversely affected by the site. Volatile organic compounds
were released from the soil surface after spills from tanks and drums on
the site, but no contaminants were detected in the soil within one foot of
the surface. Volatile organics were detected in soils 1 to 5 feet deep in
concentrations as high as 500 ppm, and could be released suddenly during
future site development. It is unlikely, however, that significant air
quality degradaton will OCCur if the site surface remains undisturbed.
Enforcement
Potentially responsible parties (PRPs) for Triangle consist of the Triangle
Estate which is currently in Chapter 7 Bankruptcy; approximately six
companies and corporations that have either owned Traingle Chemical or were
sister companies of Triangle operating from the same location; and officers
of the companies and corporations associated with Triangle. None of the
companies involved are solvent.
. .-.-.. .'-";.""'~"'''''''''..'''''~'''
-------
7
The State of Texas obtained an injunction against Triangle in August of
1981. This injunction required Triangle to comply with all pertinent rules
and regulations. At the time of this injunction, Triangle was operating
under Chapter 11 Bankruptcy rules. Approximately two months after the.
injunction, the Texas Department of Water Resources (TDWR) discovered that
the facility had been abandoned.
In August 1982, EPA Region VI forwarded a cost recovery case development
plan to Headquarters. This CERCLA cost recovery action was for monies
expended in the emergency and planned removal actions begun in April 1982,
and continuing through August 1982. This cost recovery action is pending
in the bankruptcy court. .
Due to the insolvency of the entities involved with Triangle, remedial
action could not be obtained in a timely fashion through litigation.
However, PRPs will be offered the opportunity to voluntarily implement .;.:...
the selected remedy.
Alternatives Evaluation
The feasibility study for the Triangle Chemical site was perfonmed to
detenmine what actions, if any, would be appropriate as part of a penmanent
remedy for the site. Several alternative remedial methods were developed
to cost-effectively mitigate damage to, and provide adequate protection of
public health, welfare and the environment from past and future releases of
contaminants in storage tanks and soil currently onsite. .
. .
The National Contingency Plan. 40 CFR Part 300.68 (e) (2) states that
"Source control remedial actions may be appropriate if a substantial
concentration of hazardous substances remains at or near the area where
they were originally located and inadequate barriers exist to retard
migration of substances into the environment.M In accordance with the
plan, and based on the conclusions of the remedial investigation, a source
control remedial action is necessary at the Triangle Chemical site.
The major threats to public health and the environment attributed to
contaminants at the site are: . .
1. Direct c~ntaminat1on of groundwater
2. Rupture of storage tanks, releasing contaminants to the soil.
surface water. and atmosphere.
3. Uncontrolled releases of volatile organic contaminants in the
subsurface soils resulting from future developmental excavation.
Remedial Objectives
The feasibility study performed by Roy F. Weston Associates in March 1985
developed the following objectives based on the results of the remedial
investigation:
o Remove and dispose of the contents of the storage tanks in an
approved disposal facility. and decontaminate the tanks.
-------
8
o Prevent significant degradation of the shallow groundwater.
o Prevent significant degradation of surface water.
o Reduce contamination in the soil to mitigate future impacts on
human health. the environment. and site development.
o Remove and dispose of the trash in and around the buildings
onsi te.
At the time the facility was abandoned. 1.095 55-gallon drums used for
storing raw materials and products were located on the site. Therefore.
closure of the site must be in compliance with the Resource Conservation
and Recovery Act (RCRA) 40 C~R 264.178. which states that "at closure. all
hazardous wastes and hazardous waste residues must be removed from the
containment system. Remaining containers. 1 iners. bases and sol1 contaij'l1.ng
or contaminated with hazardous wastes or hazardous waste residues must be
decontaminated or removed." The Permit Applicant's Guidance Manual for
Hazardous Waste Land Treatment. Storage. and D1sposal Fac111t1es states
that. at closure of a fac11ity. s011s are considered to be decontaminated
when the concentrations of hazardous constituents are at background levels -
for soil in the area.
Criteria to measure the accomplishment of the objectives developed for the
contaminated soil were established based on time-weighted average permissible
exposure limits (TWA-PEL) and short term exposure limits (STEL) for volatile
organic compounds identified in the soils and regulatory requ1rements for
the closure of container storage facilities. These TWA-PEL's and STEL's
are listed in Table 11. Appropriate levels of soil clean up based on thes~
criteria were determined to be 100 ppm of total volatile organics. the most
conservative STEL. and 25 ppm. the most conservative TWA-PEL. Based on the
regulatory requirement for facility closure. the appropriate level of
clean up would be background.
Clean up criteria were not established for the removal of the tank contents.
Closure of the tanks will be done in strict accordance with 40 CFR 264.197.
with appropriate decontaminatidn of the tank interiors.
In accordanci with Section 300.68 of the National Contingency Plan. several
remedial methods were developed in the feasibility stu~ to accomplish the
objectives estap1ished for the penmanent remedy at the site. Two methods
were developed to dispose of the contents of the storage tanks. two methods
to address the onsite structures. seven methods to address the onsite
contaminated soi1. and one method to address trash and debris on the site.
A no-action alternative was also evaluated.
Initial Screening of Alternatives
Section 300.68 (h) states that the following broad criteria should be used
in the initial screening of alternatives (methods):
-------
TABLE 11
PERMISSIBLE EXPOSURE LIMITS
FOR VOLATILE COMPOUNDS
FOUND AT TRIANGLE CHEMICAL COMPANY
OSHAl AOGIH2 AOGIH3
TWA (PPM) TWA (PPM) STEL (PPM)
SOILS
Acetone 1.000 750 1.000
Carbon Disulfide 10
Chlorobenzene 75 75
Dichlorobenzene 50-75 75 110
1.2-Dichloroethylene 200 200 250
Dioxane 100 25 100
Ethyl Benzene 100 100 125
Furan
Tetrahydrofuran 200 200 250
TANKS
Benzene 1 10 25
Dichlorobenzene 50-75 75 110
Dichloroethane 100 200 250
Ethyl benzene 100 100 125
Napthalene 10 10 15
1.1.2.2-Tetrachloroethane 5 1 5
Toluene 200 100 150
1.1.2-Trichloroethane 10 10 20
Trichloroethylene 100 50 200
OSHA TWA - Occupational Safety & Health Administration (OSHA) time
weighted average.
2
AOGIH TWA - American Conference of-Governmental and Industrial
Hygenists (AOGIH) time weighted average.
:I
AOGIH STEL - AOGIH short term exposure limit.
-------
9
(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 (e.g. by an order of magnitude) the
costs of other alternatives evaluated and that does not provide substanti~lly
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: (1) whether the alternative itself or its
implementation has any adverse environmental effects; and (ii) 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 contrib~te
to protection of public health. welfare. or the environment should be
considered further. '. .
(3) Acceftable Engineering Practices. Alternatives must be feasible for
the locat on and cond1t1ons Of the release. applicable to the problem. and
represent a reliable means of addressing the problem.
Each of the remedial methods was evaluated based on these criteria. The
rationale for preference of remedial methods is outlined below.
v
Methods for Disposal of Tank Contents
1. Offsite incineration/deep well injection/solidification and offsite
landfill
This method involves incineration of 32.100 gallons of ignitable liquids.
deep well injection of 24.000 gallons of non-ignitable organic liquids. and
solidification and offiste landfill disposal of 375 cubic yards of organic
sludges. The method provides for destruction of more than half of the
hazardous materials in the tanks. and minimizes the potential for direct
contact with the sludges and materials that cannot be incinerated.
There are several commercial incineration and injection facilities in the
area. thereby'reducing the risks associated with transporting hazardous
materials. For these reasons. the method is retained.
-
2. Solidification and Offsite Landfil1ing of all Tank Contents
This method involves the use of inorganic solids to absorb the liquids
and transform the waste into a dry soid material. which is transported to
an offsite landfill for disposal. The method is significantly more costly
than the incineration/deep well injection method without providing a
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10
Method for Disposal of Drums and Contents
1. Offsite incineration and deep well injection of contents/offsite
landffll of empty drums
This i.s the only method developed for the disposal of 135 drums that are
currently stored on the northern portion of Triangle Chemical Company's
property. The contents can be bulked with similar liquids from the
storage tanks and disposed of very cost-effectively.
Methods for Disposal of Contaminated Soils
1. Excavation of contaminated soil and disposal in an offsite landfill
This method is retained in the initial screening. This method involves
removal of the contaminated so 11 s, and the disposal of these so11 s in anr',
approved landfill offsite. The site would then be backfilled and graded
with clean soil. Human contact with the contaminated material and'the
potential for future groundwater contamination would be eliminated, thereby
meeting all of the objectives for remedial action.
2. Excavation of contaminated soil and disposal in an onsite RCRA landfill
In this method, a RCRA approved hazardous materials landfill for disposal
of contaminated soils would be constructed onsite. This method is rejected'
for the following reasons: (1) location of a landfill in the lOa-year
floodplain is not a recommended practice; (2) because the wastes would
remain onsite, a continued threat of release of wastes will exist; (3)
construction of a landfill will require demolition of the onsite structure~;
(4) extensive long-term maintenance and monitoring will be required; and
(5) the costs are significantly higher than offsite transport and disposal
with no additional health or environmental benefits.
3. In-Situ mechanical aeration of 50ils
Aeration of the. so11 s is a phy~ical decontamination method whereby the
contaminated soils are exposed to the atmosphere and the volatile organic
compounds are. released under controlled conditions. Contamination is reduced
to background levels in a short period of time, and capacity to manage
wastes from other contaminated sites is created by not utilizing space at
an offsite landfill. Post-closure activities associated with this method
include groundwater monitoring and site maintenance. Also, this method is
the least costly of all of the methods developed for soil remediation and
will meet all of the objectives developed for the site. For these reasons,
the method is retained for further evaluation.
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11
4. In-Situ Forced Air Injection Aeration of Soils
This method may be technically infeasible for use with the type of soil
found at the Triangle Chemical site. The clay soils will hinder the movement
of air. thereby requiring extensive amount of time and electrical energy
for a~equate exposure of the subsurface soils and release of the volatile
compounds to the atmosphere. Associated with these time and energy
requirements are higher operating costs. making this method more costly than
mechanical aeration while not providing a commensurate increase in protection.
For these reasons. the method is eliminated from further consideration.
5. Encapsulation of Contaminated 50il
Construction of a protective cap over the site would provide adequate
protection of the public from direct contact with the contaminated soil.
as long as the cap is properly maintained and no future site development< "
takes place. However. enscapsulation would not accomplish the objectives
of preventing groundwater contamination and mitigating future i~pacts due
to surface development. and would be difficult to maintain due to the
location of the site.
, ,
By allowing contamination to remain in the soil. a significant potential
for groundwater contamination will exist. and long-term groundwater monitoring
will be required in order to detect an contaminant migration from the site.
If contamination is detected. future remedial action addressing the
groundwater may be required.
Capping the site will not eliminate the potential for uncontrolled releases
of volatile organic compounds during future site development activities.
thereby posing a serious health threat to future construction workers at
the site.
Because the site is located in the IOO-year floodplain of Coon Bayou.
deterioration of the cap will be significant and long-term maintenance
costs will be extremely high. A cap is infeasible along the bayou shoreline.
where tidal action will cause continual cap erosion and exposure of
contaminated soil. .
For the reasofts discussed above. encapsulation is rejected as a remedial
method .
-
Disposal 0' Trash and Debris
1. ~ation and Disposal in an Offsite Landfill
Trash and debris will be separated into contaminated and uncontaminated
material. The contaminated material will be disposed of in a RCRA-approved
hazardous materials landfill. Over 95' of the material is non-hazardous.
and will be burfed in a sanitary landfill. All of the material will be
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12
/
Methods for Addressing Contaminated Buildings and Structures
1. Decontamination
Buildings will be steam cleaned and remain onsite. The rinsate will be
collected and disposed of by deep well injection. The method is technically
effective and will eliminate the risk of public exposure to contaminants.
Also, it may be possible to salvage the prefabricated buildings after
decontamination. The method is retained.
2. Demolition and Removal
Demolition and removal of the onsite structures is rejected because
capital costs are significantly higher than the cost of decontamination,
without a commensurate increase in benefits.
. ,
..., "
The comparative costs of each of these methods are listed in Table 12.
The costs 'associated with excavation to 25 ppm and 100 ppm are listed for
comparison of methods that would not attain full compliance of Federal
regulations, but would provide adequate protection of public health based
on established health criteria. For all 50il alternatives that are not
designed to reduce contamination to background levels, a total present
worth of $75,800 must be added for site management and long-term monitoring.
For example, the total present worth of site encapsulation (infiltration
controls) with mechanical aeration including capital costs and operation
and maintenance is $227,800.
Description of Remedial Action Plans
.
The alternative methods that were retained after the initial screening are
combined into alternative remedial action plans for a permanent 'remedy at
the site. Cost estimates and brief descriptions of the technical feasibility,
implementability, and environmental effectiveness of each plan are listed
in Table 13. Detailed descriptions of the methods included in each plan
are given below.
The methods involving the disposal of onsite debris and storage tank contents
and the decontamination of onsite structures are common to all of the
alternative p1ans, and therefore need not be evaluated with each plan. For
comparative purposes, the estimated costs of these methods are included in
the total remedtal plan estimates.
Disposal of Tank Contents and Decontamination of Tanks
Approximately 32,000 gallons of liquids and sludges in the onsite storage
tanks are amenable to incineration based on laboratory analysis of flashpoint,
organic content, and heat value. One commercial incinerator operates near,
the Triangle Chemical site, thereby reducing risk and cost associated with
transporting hazardous materials.
-------
TABLE 12
SUMMARY OF REMEDIAL ACTION METHOD COST ESTIMATES
MONITORING AND MAINTENANCE
REMEDIAL METHOD
TOTAL CAPITAL
COST
ANNUAL
PRESENT WORTH*
TOTAL PRESENT
WORTH
Tank Contents
So 11 d i fy and Landfil 1 An Contents $151,000 $151,000
Deep We 11 I nj ec t and I nc 1 nera te 118,000 118,000
Liquids, Solidify and landfill
Sludges
ContaMinated Soils
Excavaton to Background Quality 1,510,000 1,510,000
and, Onsite Disposal
Excavati on to 25 ppll Vol atl1 e 781,000 781,000
Organics and Offs1 te 01 sposal
Excavation to 100 ppM Volatile 572,000 572,000
Organics and Offs1 te 01 sposal
Excavation to Background Quality 868,000 868,000
and Offsite Disposal
Mechanical Aeration for Volatile 62 ,000 62,000
Organics Renloval
Forced Air Injection for Volatile 173,000 173,000
Organics Removal '164,000
Infil trati on Control s wi th Exclvati on 164,000
and Offs1te Disposal
Infiltration Controls with Mechanical 152,000 152,000
Aeration
Trash and Debris ~:
Segregation and Offsite Disposal 14 ,000 14,000
Buildings and Structures
" ..' Demolition and Removal 614,000 6~ ,J
. ",I
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..: ..1
-,
'.J
. .:' ~
TABLE 12 (CONT.)
SUMMARY OF REMEDIAL ACTION METHOD COST ESTIMATES
MONITORING AND MAINTENANCE
REMEDIAL METHOD
TOTAL CAP ITAL
COST
ANNUAL
PRESENT WORTH*
Drums and Contents
Removal with Offsite Disposal
Site Management
39,100**
Infiltration Control Method
All Other Methods
5,300
500
49,800
4,800
26,000
26,000
TOTAL PRESENT
WORTH
39,100
75,800
30,800
* Present worth values based on a discount rate of 1~ over 30 years.
** Cost will vary according to most applicable disposal technology.
. .
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TABLE 13
SUMMARY OF ALTERNATIVE REMEDIAL ACTION PLANS
FOR TRIANGLE CHEMICAL COMPANY
TECHNICAL ENVIRONMENTAL IMPLEMEtl- CAPITAL MONITORING/MAINTENANCE COSTS TOTAL PRESENT
PLAN FEASIBILITY EFFECTIVENESS TABILITY COSTS ANNUAL PRESENT WORTH WORTH
1. Disposal of Ut11izes con- I Removes all Requires $1,167,000 $500 $5,000 $1,172,500
Tank Contents ventional tech- wastes and con- 2 months.
and Trash, nolog1es. taminated mater- Perfom
Decontami nati on L imi ts of con- 1als from site. duri ng dry
of Structures, tam1nation to Air Missions season.
Excavation to background during excava-
Background qua 11 ty tion and tank
Qua 11 ty unproven. opening.
2. Disposal of Util f zes con- Removes all Requires 385,000 500 5,000 390,500
Tank Contents vent10nal wastes and 2-3 months.
and Trash, technologies, reduces all Perfom
Decontam1ncat1on exceptsof 1 contaminants dur1 ng dry
of Structures, aeration to background season.
Mechanical method. P110t 1 evel s. Air
Aeratf on of study recOMmend- emissions
So11 s to ed prior to full duri ng mechan-
Background implementation.. 1cal aeration
Qual1 ty Limits of con-. of so11 sand
tam1 nation to tank opening.
background
quality unproven.
3. Disposal of Utili zes con- Some contaminat- Requt'res 2 871,000 . 500 5,000 876,500
Tank Contents ventfonal tech- ed so11 s left months.
and Trash, nolog1es. Field onsite. Con- Perfom
Decontamination detenn1nat1on tamination below during dry
of Structures, of so11 con- short-tenn season
Excavation to tam1nant zone exposure limits. . .
...
100 ppm likely to be Air emissions
Volat11e 1l11prec1 see during excavation.
Or9~..fcs
. i
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TABLl 13 (CONT.)
PLAN
TECHNICAL
FEASIBILITY
ENVIRONMENTAL
EFFECTIVENESS
IMPLEMEN-
TABILITY
CAPITAL
COSTS
MONITORING/MAINTENANCE COSTS TOTAL PRESENT
ANNUAl PRESENT WORTH WORTH
377,000
500
5 ,000
382,000
4. Disposal of
Tank Contents
and Trash,
Decontamination
of Structures,
Mechanical
Aeration of
Sol1 s to 100
ppm Volatile
Organics
5. Disposal of
Tank Contents
and Trash,
Decontamination
of Structures,
Excavation of
Sol1 s to 25
ppm Volatile
Organics
6. No Action
,
!
i
:. ~)
"":::
.,
Requi res 2-3
months.
Perfonn
duri ng dry
sea son.
Utilizes con- Some contaminated
ventional tech- soils left onsite.
nologies, except Contamination
soil aeration below exposure
method. Pilot limits. Air
study recommend- emissions during
ed prior to full excavation.
implementation.
Field detennin-
ati on of sol1
contaminant zone
likely to be
impreci see
Same as 3
N/A
Same as 3
except con-
tami nati on is
below time
weighted
average
exposure
limit.
Does not accom-
pli sh si te
objectives,
Inconsistent
with land use
projected for
area. Poten-
tial for human
exposure and
threat to
heal th and
safety, poten-
tial for con-
tinued con-
taminant
min..a+inn.
Same as 3
NA
1,080,000
500
5,000
1,085,500
NA
NA
NA
NA
.
. .
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13
Deep well injection is an ~ppropriate disposal alternative for 24,000
gallons of non-ignitable liquids currently onsite. There are several
facilities in the Gulf Coast Region which inject non-flammable, low. solids
waste into saline groundwaters 4,000 feet below the ground surface. This
technology, although not destructive, will essentially eliminate potential
human contact with the tank materials.
The sludges in the tanks would be solidified with an inorganic solid and
landfilled at a permitted offsite landfill facility. Tanks would then be
decontaminated by recirculating detergent water and rinsing. Final rinsate
samples would be analyzed to certify that a tank would be decontaminated.
Larger tanks would also be mechanically scoured, if necessary. All of the
rinsate would be disposed of by deep well injection.
Trash and Debris Removal with Offsite Disposal
.;i. ".
Offsite disposal is the only remedial action which is applicable to the
site. Ninety-five percent of the trash is considered non-haza~ous, and
would be transported to a sanitary landfill in the area. That portion of
the debris that is obviously stained would be considered hazardous, and
will be disposed of in a RCRA approved hazardous materials landfill.
Decontamination of Onsite Structures
Decontamination would be accomplished by steam cleaning all floors, ceilings,
walls, and internal structures. The rinsate would be collected and disposed
of by deep well injection. Certification would be required to ensure that
the buildings were decontaminated before any future use would be possible.
Offsite Disposal of Drums and Drum Contents
The material s which are currently stored on the Triangle Chemical Company
property north of Redbird Chemical, will be analyzed and bulked with similar
materials found in the onsite storage tanks. The materials will then be
incinerated or deep well injected, as appropriate. The drums will be
decontaminated, crushed, and d~sposed of in a RCRA approved landfill.
Differences in the alternative remedial action plans are attributed to the
remedial methods developed as a permanent remedy for soil contamination at
the site. Only the descriptions for the soils portion of each plan are
given below. The complete plans include the selected remedial methods for
the tank contents, drum and debris removal, and decontamination of the
onsite structures.
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14
Plan 1 - No Action
In accordance with Section 300.68 (g) of the National Contingency Plan
(NCP). a no action alternative should be evaluated. This plan involves
leaving the site conditions as they currently exist. Section 300.68 (h)
(2) states that an alternative having significant adverse environmental
effects or that does not effectively mitigate and minimize the threat of
harm to public health welfare and the environment should be excluded from
further consideration. The no action alternative would allow the site to
continually pose a threat of: (1) a release of volatile organic contaminants
in the soil to the atmosphere during future site development or flooding.
(2) leaching of volatile organics into the groundwater during periods of
heavy rainfall due to an elevated water table. (3) a release of tank contents
causing extensive soil and surface water contamination. and (4) exposure of
the public during unauthorized entry to the site. The risks to public "
health and the environment associated with the no action plan are unacceptable
and the no action plan is rejected.
. .
Plan 2 - Excavation and Offsite Landfill
Contaminated 50115 are limited to the areas ons1te where releases from drums
and tanks had occurred during and immediately after operation of the facility.
The soils to be removed lie in a narrow band extending from about 1 foot
below ground surface to just above the perched ground water table found at
about six feet. A front end loader and a backhoe are required to excavate
the soils and load trucks for offsite transport. A four-foot dike would
be built to provide protection from the 100-year flood during"the excavation
period. Soils from the dike would be used as backfill after the contaminated
soil is removed from the site. Excavated soils would be transported and.
disposed of in a RCRA approved double-lined landfill. Various levels of
clean up were used for cost estimates based on (1) permissible exposure
limits for several of the compounds identified in the soil and (2) regulatory
requirements for facility closures. Volatilization of contaminants is
expected to occur during excavation and transport. Thus soil being placed
in a landfill may not be contaminated at the time of disposal. Because
volatilization will be much mo~e difficult to control during excavation
than during aeration. excavation .~ result in an undesirable environmental
effect at the.site.
The pros and cons of this alternative are listed below:
Pros:
+ Equipment required is readily available in the area.
+ Utilizes conventional technology.
+ Removes contaminants from the site.
+ Only two months required for implementation.
+ Eliminates potential of future groundwater contamination.
+ Eliminates potential for release of volatiles during
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15
Cons:
- Volatilization of contaminants will occur during excavation
and transport.
- Very high cost due to requirement for double-lined landfill
facil1 ty.
-Double-lined facility may not be readily available.
Plan 3 - In-Situ Mechanical Aeration
Contaminated soils will be exposed to the atmosphere under controlled
conditions using a tractor with a disc harrow. Treatment consists of four-
pass tilling of a six-inch soil layer. Treated layers will be excavated
and stor~d in a diked area for use later as backfill. Soil sampling will
be used to verify decontamination prior to excavation. Reduction of '..
contaminant concentrations to background 1 evel s wi" take approximately~.'
hours depending upon the ambient air temperature at the time of r~edial
action. Flood control structures wi". be built around the till- area to
control run-on, and provisions will be made to manage possible runoff from
the 1-hour 25-year rainfall event. The material from the dike, native
clays, will be used as final cover and grade material for the site. A
groundwater monitoring program will be established to ensure that the
groundwater will be adequately protected by the remedy. The existing
monitoring wells will be su,plementaed with one new shallow well at the
north property boundary, downgradient of contaminated soil Area B.
Air monitoring will be used to control the aeration operation. The areal
extent of tilling can be varied to ensure that no offs1te air quality
degradation occurs.
Pros:
+ Least costly alternative to implement.
+ Volatilization can be monitored and remedy can be
fmplemented under strfctly controlled conditions.
+ Does not depend Ufon the availability of an approved
double-lined facf ity. .
+ Capacity at an offsite facility not consumed.
+ Potential for volatilization durfng future sfte
development would be eliminated.
+ Risk due to transport of hazardous materials is
el iminated. -
+ Action can be completed within one month
Cons:
- Innovatfve tec.hnology; would require a pilot study.
- Background levels not set.
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16
1" the initial screening, the' construction of an onsite RCRA approved
landfill for the disposal of contaminated soils and trash was rejected.
The cost of this construction was estimated to be $1,510,000. The expense
involves the special construction requirements for floodplain protection'
and demolition of all onsite sturctures to provide enough area to build a
landfill. Excavation of the soil to background levels and disposal at an
approved offsite facility is estimated to cost $684,000. The costs of
incineration and deep well injection of the tank contents must be added to
each of these, and the cost of debr1s disposal and structure decontamination
must be added to the offsite disposal alternative. The total cost of the
onsite landfill alternative plan would be $1.63 million versus $1.17 million
for the offsite disposal alternative.
Excavation of the soil to background levels and offsite disposal, in
combination with the recommended actions for the structures, tank and dr~
contents, and onsite debris also complies with the applicable environmerita1
laws and regulations. However, this is much more costly than the r~ommended
alternative ($1.17 million versus $393,000> and does not offer a commensurate
increase in benefits to human health and the environment. Also, because
volatilization of the organic contaminants will occur during excavation and
transport, it is likely that the soils will be effectively decontaminated
prior to landfill disposal, and that landfill capacity could be better used
for hazardous materials from other sites. Therefore, excavation and offsite
disposal is not as cost-effective as mechanical aeration.
Excavation of soil to 100 ppm and 25 ppm would provide adequate protection
of human health and the environment based on permissible exposure limits to
contaminants found in the soil, but would not fully comply with applicable
laws and regulations. The difference in cost between excavation to 100 ppm'
and excavation to background concentration is $296,000 ($1.17 million versus
$876,000>, and between excavation to 25 ppm and background levels is $86,500.
However, groundwater monitoring would be required for a 30 year post-closure
period, and future corrective actions may be required if contaminant
migration via groundwater was detected. It would therefore appear that
excavation to background would be more cost-effective than excavation to
either 100 ppm or 25 ppm, when the potential for future groundwater action$
at the site is considered.
Community Relations
Very little public interest has been expressed. The public notice period:
began on April 5, 1985 and ended on April 19, at which time the public
comment period began. A public meeting was held in Orange, Texas on May 1.
Five people attended the public meeting, and no statements were made. The
public comment period ended on May 10, 1985; one comment was received
during the peroid. The comment and a written response are included in the
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17
Consistency with Other Environmental Laws
It is EPA policy to give primary consideration to remedial actions that
attain or exceed applicable and relevant standards of other Federal public
health and environmental laws. The environmental laws which will have an
impact on the proposed remedies for the Triangle Chemical site include:
1. The Resource Conservation and Recovery Act substantive
requirements, 40 CFR Part 264, for closure of tanks and
container storage facilities.
2. Executive Order 11988, Floodplain Management for sites
located in flood plains.
3. Clean Water Act, water quality crietria for human health
and drinking water.
4. Occupational Health and Safety Administration time weighted
average-penmissible exposure limits for air quality monitoring.
.... ...
Closure of tanks and containers is regulated by the Resource Conservation
and Recovery Act (RCRA) subparts I and J. Subpart I is the applicable
regulation governing the closure of facilities in which hazardous materials
were stored in containers. The subpart indicates that containers and soil
containing or contaminated by hazardous wastes must be decontaminated or
removed. The regulations in subpart J apply to facilities that use tanks
to store hazardous wastes and state that, at closure, all hazardous wastes
and residues must be removed from the tanks. RCRA also requires that
offsite landfills used for disposal of hazardous wastes be double-lined,
RCRA approved facilities. These requirements would also govern the
construction of an onsite landfill. A brief description of all the
applicable and relevant RCRA regulation is given in Table 14.
Executive Order 11988 applies to the protection of floodplains. The Triangle
Chemical site is located in the 100-year floodplain. Therefore any onsite
remedy should be designed with.consideration given to floodplain protection.
The Clean Water Act outlines water quality criteria for human health. These
numerical standards are applied to address the issue of -how clean is clean"
for the shallow groundwater at the site.
The Occupational Safety and Health Administration time weighted average-
permissible exposure limit standards are applied to ensure that no degradation
of offsite air quality will occur during remedial action.
.- . ..-. +'-,';-.-r"
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TABLE 14
RCRA REGULATIONS APPLICABLE TO TRIANGLE CHEMICAL COMPANY
40 CFR DESCRI PTION (F APPLICABILITY TO IMPACT ON CONTAMINANTS
REGULATION REGULATION TRIANGLE CHEMICAL REMAINING ONSITE
264.18 Facilities located in Parts of the. site are No present f1 ood protection.
100-year flood plain inundated by 5 feet of Tanks may need reinforcement,
must be designed. water in a 100-year and contaminated areas may
constructed. operated flood. Ti dal surges may need to be diked.
and maintained to cause addi tional structural
prevent washout of any damage
hazardous waste ~y a
100-year flood.
264.50 A contingency plan to Liquids to be stored A contingency plan would be
minimize hazards during onsite are hazardous required.
an unpl anned release and ignitable.
must be developed by
owners of a hazardous
waste facn i ty.
264.90 Facilities that treat. Liquids to be stored Legal interpretations may
store, or dispose of onsite are hazardous. require groundwater monitoring
hazardous waste must Hazardous wastes may if hazardous wastes are left
establish groundwater remain in the soil. onsi tee
protection standards
which may include long-
term monitoring for
30 years.
264 .178 Soils containing hazardous Hazardous wastes have Allowing wastes to remain onsite
wastes and waste residues been found in onsite l- may be a violation of RCRA.
must be removed or 5011 5.
decontaminated.
..'
.J
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TABLE 14 (CONT.)
40 CFR DESCRIPTION OF APPLICABILITY TO IMPACT ON CONTAMINANTS
REGULATION REGULATION TRIANGLE CHEMICAL REMAINING ONSITE
.
264.191 Owners which treat or Liquids to be stored Existing tanks are of unknown
store hazardous wastes onsite are hazardous. structural integrity and may
in tanks must confom need to be modified.
to tank design standards
which define structural
integrity.
.
264.192 Tanks used to store Some liquids to be Tanks have no known liners
corrosive hazardous stored onsite are or corrosion inhibition
liquids must be equipped corrosive. systems and must be
with an inner liner or modified.
other corrosi on
inhibition system.
264.192 Storage of hazardous Liquids to be stored Weekly tank inspections
liquids in tanks re- onsite are hazardous significantly increase site
quires an inspection management costs.
schedule to assess
tank conditions which
incl udes at least
~ekly spot checks
for signs of leakage.
,.
..
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TABLE 14 (CONT.)
40 CFR DESCRIPTION OF APPLICABILITY TO IMPACT ON CONTAMINANTS
REGULATION REGULATION TRIANGLE CHEMICAL REMAINING ONSITE
,
264.197 Ignitable liquids must Some liquids to be Compliance with management
be separated and managed stored onsite are regulations may require
with respect to extreme i gni table. costly monitoring instru-
heat or pressure, mentation.
uncontrolled toxic mists,
and uncontrolled flammable
fumes.
265.198 Ignitable liquids must Some liquids to be Compliance may require
be stored in tanks stored on-site are costly construction of
which comply with ignitable. tank storage area dikes
requirements of the and proper drainage
National Fire Protection systems.
Association.
Penmit applicants
Guidance Manual
for hazardous
waste land
treatment
storage, and
di sposal
facilities.
Agency considers
contamination to be
removed when the
concentrations of
hazardous constituents
in the soil are at
background levels.
Sets criteria for.
soil cl eanup
Required for full
compliance with Federal
Environmental Regulations
and Guidance.
.
.-
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18
Recommended Alternative
Section 300.68 (j) of the National Contingency Plan states that "The
appropriate extent of remedy shall be determined by the lead agency's
selection of the remedial alternatives which the agency determines is cost-
effective (i.e. the lowest cost alternative that is technologically feasible
and reliable and which effectively mitigates and minimizes damage to and
provides adequate protection of public health, welfare or the environment)."
To this end, incineration and deep well injection of the tank and drum
contents, decontamination of all onsite structures, offsite disposal of
trash and debris, and mechanical aeration of the contaminated soils is the
recommended remedial action for the Triangle Chemical site. Schematic
drawings of the mechanical aeration method of this alternative are presented
in Figures 7 and 8. This alternative complies with the closure requirene~ts
for tanks (40 CFR 264 subpart J) and container storage facilities (40 CFR
264 subpart I). This alternative is also the lowest cost alternative that
will comply with all applicable and relevant Federal environmental laws and
regulations. Decontamination of the soil to background levels would effectively
mitigate the potential for future groundwater contamination.
Operation and Maintenance
Post closure monitoring and maintenance will be required for any remedial
plan selected for the Triangle Chemical site, although post-closure activities
will be more extensive for alternatives in which wastes remain onsite. For
all plans, post closure activities will include vegetation control, fence
repair, and quarterly groundwater monitoring from existing monitoring wells
to verify that the groundwater is not impacted by remedial construction. .
For plans that do not clean up contaminated soi15 to background levels,
additional groundwater monitoring and site surface maintenance will be
necessary for a period of up to 30 years.
Operation and maintenance for the recommended alternative will involve
landscaping and fence repair at the site, groundwater monitoring from the
three existing onsite monitoring wells, and construction of an additional
shallow monitoring well at the site boundary directly downgradient of soil
contamination. Area B. Groundwater monitoring will be performed for a period
of 5 years. If no significant contamination is detected in the monitoring
wells by the end of this period, the remedy will be considered effective
and further monftorfng will not be requfred. If significant contamination
is detected during the monitoring period, corrective .easures will be
evaluated.
Annual operation and maintenance costs for the recommended alternative is
estimated to be $500 and the present worth is estimated to be $5000.
Schedule
Approve Remedial Action
Award Cooperative Agreement for Design
Award Cooperative Agreement for Construction
June, 1985
June, 1985
June, 1985
-------
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5ECTION A-A
TYPICAL .~ ACCESS GRADE
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2' VERTICAL EXTENT OF CONTAMINATION
0.5' TRANSITION TO CLEAN ZONE
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LJ' TYPICAL DETAIL FOR CUT STABILITY
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US EPA Regie
Philadelphia,
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VERTICAL EXTENT
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ACCESS ORADE
LEGEND
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NOTE: VERTICAL ICALE EXAGGERATED TO
SHOW CONSTRUCTION DETAIL
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Figure 8
TRIANGLE CHEMICAL COMPANY
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SOIL TILLING SECTION VIEWS,
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