United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R06-93/084
September 1993
SEPA Superfund
Record of Decision:
Texarkana Wood Preserving,
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<'
50272-1 01
REPORT DOCUMENTATION 11. REPORT NO. .
PAGE EPA/ROD/R06-93/084
2.
3. Reclplenrs Acc8nlon No.
4.
TItle and Subtitle
SUPERFUND RECORD OF DECISION
Texarkana Wood Preserving, TX
Second Remedial Action - Final
Author(s)
5.
Report Da..
09/30/93
6.
7.
8.
Performing Organization Repl No.
9.
Performing Organization Name and Addrna
10 Project TaakJWork Unit No.
11. Contl1lCt(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nama and Add.-
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Cover8d
Agency
800/800
14.
15. Supplementary Nat..
PB94-964203
16. Abstract (Umlt: 200 words)
The 25-acre Texarkana Wood Preserving site is a former wood treating facility located
in Bowie County, Texas. Land use in the area is mixed industrial, residential,and
agricultural. The site lies within the 100-year floodplain of Days Creek, an
interstate tributary of the Sulphur River, which is located to the east of the site.
The estimated 70 residences located within one-third mile of the site use municipal
drinking water, but the aquifer underlying the site' is con&idered to be a class II
aquifer. Since the early 1900s, several lumber-related businesses have operated at the
site, with documented creosote-based wood treating operations as early as 1954 in the
southwest portion of the site. These treatment activities included improper processing
of w~ste materials onsite and led to present site conditions. The site contains a
heavily-contaminated process area consisting of a number of waste ponds on the west
part of the site, water retention ponds on the east portion of the site, and a few
disposal tanks which still remain onsite. In 1981, Texarkana Wood Preserving Company
(TWPC) purchased the site. After the State observed illegal discharges into Days Creek,
it conducted subsequent investigations from 1968 to 1984 that found TWPC to be either
negligent or delinquent in its efforts to fulfill various wood treating permitting
requirements. In 1984, TWPC ceased onsite wood treating operations. From 1986 to
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Texarkana Wood Preserving, TX
Second Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: organics (PAHs, phenols)
b.
Identifiers/Open-Ended Terms
c.
COSATI FlelcIIGroup
18. Availability Statement
19. Security Class (ThIs Report)
None
20. Security Class (This Page)
None
21. No. of Pages
38
22. Price
(See ANSI.Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272(4-77)
(Formerly NT\So35)
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EPA/ROD/R06~93/084
Texarkana Wood Preserving, TX
Second Remedial Action - Final
Abstract (Continued)
1988, EPA implemented measures to control surface runoff and site access, including
constructing fences and a berm around the main operations pond, and pumping down onsite
ponds to prevent overflow. A 1990 ROD addressed contaminated soil, sludge, and shallow
ground water, as OU1. This ROD provides a final remedy for contaminated ground water in
deeper zones, as OU2. The primary contaminants of concern affecting the ground water are
organics, including PAHs and phenols.
The selected remedial action for this site includes extracting and treating contaminated
ground water from the deeper aquifer onsite using the carbon adsorption water treatment
system implemented in the 1990 ROD; reinjecting the treated water into the shallow
aquifer; treating carbon residuals offsite or onsite using thermal destruction or
recycling; and monitoring ground water. The estimated present worth cost for this
remedial action is $320,000, which includes an estimated total O&M cost of $227,000 for 30
years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific ground water cleanup goals are based on site-specific risk-based
reference dose values, and include acenaphthene 6.1 mg/l; anthracene 30.7 mg/l;
2,4-dimethylphenol 2 mg/l; fluoranthene 4.1 mg/l; fluorene 4.1 mg/l; naphthalene 0.4 mg/l;
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RECORD OF DECISION
CONCURRENCE DOCUMENTATION
FOR THE
TEXARKANA WOOD PRESERVING COMPANY SUPERFUND SITE
OPERABLE UNIT TWO
,"
."
~~.~
Earl Hendrick
site Remedial Project Manager
...-
(
~
La~~
Texas Construction Section, 6H-SC
S
rl Edlund, Chief
erfund Programs Branch, 6H-S
ad~/
, '12~ .Cu -' , ..d?/.
Mark A. pey e / ;'
Acting Chief, Superfund 'ranch
Office of Regional Counsel
."
~¥
George Alex der, Jr.
Regional Counsel, 6C
~R~
Allyn M. Davis
Hazardous Waste Management
Division 6H
."
"-
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.
I) .'
,
v.,
..
,.
0"
"j\'t",II.
,
Record of Decision
Texarkana Wood Preserving Company
Superfund Site
Operable Unit Two
ft'
u.s. Environmental Protection Agency
Region 6
September 1993
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,)
,
."
.'
DECLARATION
TExARKANA WOOD PRESERVING COMPANY
RECORD OF DECISION
SEPTEMBER 1993
statutory Preference for Treatment as a
principal Element is Ket
and a Pive-Year Review is Required
SITE NAME AND LOCATION
Texarkana Wood Preserving Company
Texarkana, Bowie County, Texas
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
Operable unit Two for the Texarkana Wood Preserving Company (TWPC)
Superfund site (Site) in Texarkana, Texas. This selection is made
in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA) and the
National oil and Hazardous Substances Pollution contingency Plan
(NCP). This decision is based on the administrative record file
for this Site.
The State of Texas concurs with the selected remedy.
ASSESSMENT OF THE SITE
""
. .
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this Record of ~Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the en-
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DESCRIPTION OF THE SELECTED REMEDY
This operable unit is the second of two operable units planned for
the site. Operable Unit One addresses the principal threat at the
Site from the contaminants in the soil, sludge and the Gravel Zone
ground water. Operable Unit Two involves remediation of the deeper
ground water contaminated above the action levels in a limited area
of the Silty Sand Zone around Monitoring Well-16.
".
The major components of the selected remedy include:
o
Extraction of the Silty Sand Zone contaminated ground
water;
o Treatment of this contaminated ground water by the
carbon adsorption unit installed for Operable unit One;
o Injection of this treated ground water into the
Gravel Zone; and
o
Real estate notice recordation.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the en-
vironment, complies with federal and state requirements that are
legally applicable or relevant and appropriate to the remedial
action and is cost-effective. This remedy utilizes a permanent
solution to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mObility, or volume as a principal element.
Because the ground water remediation for Operable unit Two might
not be complete within five years after the start of Operable Unit
One remediation, a five year review will be necessary for this
unit. This review will be conducted in conjunction with the five
year review to be performed for Operable unit One on the site.
q-?iJ . ti3
..
Joe D. winkle
Acting Regional Administrator
U. S. EPA - Region 6
Date
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TABLE 01' CONTB1ft'S
LOCATION AND DESCRIPTION
. . . . . . .
. . . . . . . .' . . .
0"
SITE HISTORY AND ENFORCEMENT ACTIVITIES. .
HIGHLIGHTS OF COMMUNITY PARTICIPATION.
. . . . .
. . .
. . . . . .
. . . . . .
SCOPE AND ROLE OF OPERABLE UNITS WITHIN THE SITE STRATEGY. .
0"
SUMMARY OF SITE CHARACTERISTICS. . .
. . . . . . .
. . . . .
SUMMARY OF SITE RISKS AND REMEDIATION GOALS. . .
. . . . . .
DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . .
Common Elements. . . . . . . . . . . . . . . . .
Alternative 1-A: NO ACTION. . . . . . . . . . . . . . .
Alternative 1-B: EXTRACTION AND TREATMENT. . . . . . .
Al ternati ve 2: EXTRACTION, TREATMENT AND INJECTION. . .
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES.
. . . . . .
criteria. . . . . . . . . . . . . . . . . . . . . . . .
Analysis. . . . . . . . . . . . . . . . . . . . . . . .
OVerall Protection. . . . . . . . . . . . . . . .
Compliance with Applicable or Relevant and
Appropriate Requirements, ARARs . . . . . . .
Long-term Effectiveness and Permanence. . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . .
Reduction of Toxicity, Mobility, or Volume of the
Contaminants through Treatment. . . . . . . .
Short-term Effectiveness. . . . . . . . . . . . .
Implementabili ty . . . . . . . . . . . . . . . . .
Cost. . . . . . . . . . . . . . . . . . . . . . .
State Acceptance. . . . . . . . . . . . . . . . .
Community Acceptance. . . . . . . . . . . . . . .
r
SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . .
Statutory Determinations. . . . . . . . . . . . . . . .
Protection of Human Health and the Environment. . . . .
Compliance with Applicable or Relevant and Appropriate
Requirements. . . . . . . . . . . . . . . . . . .
Action-specific Ground Water Remediation ARARs
Location-Specific Ground Water Remediation ARABs
To Be Considered. . . . . . . . . . . . . . . . .
Cost Effectiveness. . . . . . . . . . . . . . . . . . .
Utilization of Permanent Solutions and Alternative
Treatment Technologies (or Resource Recovery
Technologies) to the Maximum Extent Practicable:
Preference for Treatment as a Principal Element. . . .
.-
DOCUMENTATION OF NO SIGNIFICANT CHANGES.
APPENDIX A, RESPONSIVENESS SUMMARY
. . .
.......
. . . . .
. . .
. . . . .
APPENDIX B, THE STATE OF TEXAS, LETTER OF CONCURRENCE. . . .
APPENDIX C, ADMINISTRATIVE RECORD INDEX.
..........
1
4
9
10
11
14
18
19
19
20
21
22
22
23
23
23
23
24
25
25
25
25
25
25
26
26
27
27
28
28
28
28
28
29
29
30
36
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I. LOCATIO. um DBSCRIPl'IOII
The Texarkana Wood Preservinq Company (TWPC) superfund Site is
located in Bowie County, Texas (Fiqure 1). The Bowie County
line runs throuqh the Site. The population of Texarkana is
approximately 50,000. The Miller County, Arkansas line is
approximately 2800 feet due east of the Site. As shown in
Fiqure 2, Days' Creek, an interstate tributary of the Sulphur
River, is located less than 500 feet east of the site. The
site is within the 100-year flood plain of Days Creek. Fish
may be taken from this creek by fishermen. The si te is
bounded on the west by the Texas and Pacific Railroad riqht-
of-way, on the south and on the north by Lubbock Street. The
site is fenced and hazard siqns are posted around the site to
discouraqe people from enterinq the site. No one lives on the
site. Adjacent land uses include industrial, residential, and
livestock qrazinq. A small residential community of
approximately 70 families is located one-third of a mile from
the site. There are no schools in this subdivision. Althouqh
the community around the site is connected to the city water
system and does not use the qround water for drinkinq, the
aquifers discussed in this ROD are considered to be Class II.
Approximately 1,000 people live within one mile of the site.
The Site topoqraphy could be described as level qround,
slopinq sliqhtly to the southeast. Surface water runs from
the northwestern portion of the site to the drainaqe ditches
alonq Lubbock street. shortly after Lubbock street turns and
runs east/west, the runoff heads south into a natural drainaqe
ditch runninq throuqh a field, eventually draininq into Days
Creek. Surface water on the eastern portion of the Site
travels to the southeast, directly into Days Creek.
'0
The site stratiqraphy consists of Quaternary Alluvium under-
lain by the wilcox Formation. The Alluvium, called Surficial
silty Sand and Gravel Zone, consists of silty sand with qravel
and minor sediments with depth. Surface sediments are
predominantly silty sand with occasional silty clay and silt.
The basal deposits are qravelly sand or silty, sandy qravel.
The average thickness of the alluvium is 13\ feet and ranges
from 9~ feet to 20 feet. The basal gravel has an average
thickness of four feet and ranges in thickness from two feet
to seven feet. The Quaternary Alluvium is unconformable and
is underlain b~ the Wilcox Formation.
The Wilcox formation is representative of a fluvial deltaic
deposi tional environment and consists of clayey and sil ty
sands with clay, carbonaceous sediments and 1 iqni te. The
Wilcox Formation is encountered at an averaqe depth of 13\
feet. The upper portion of the Wilcox consists primarily of
clayey sand and comprises alternatinq laminae of sand and
clay, with qreater than fifty percent of the sediment beinq
sand. The thickness of the Clayey Sand Zone varies from
approximately 30 feet to 50 feet.
"
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v.
,"
APPROXIMATE SCALES
o
I
ao
I
MILES
o
I
100 100
I I I I
IClLOMETERS
."
100
I
FIGURE
1
TWPC REMEDIAL
INVESTIGA TION
GENERAL LOCATION OF
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II' J .. ;~~ ~ ~r\ ~~::A \ ;~~~( ~.~ I!"[~' /f.
? '\ ,I I"" InJ I \~~ """ ) ~ I \ )....- ~.: f ~
,I ~, ~ I'" I\... . ~ ...... J IA. ".l! / 4:
~ -r{: \ V- ~~ f' \ \.. ~ r=~ v,..&"#
'N ~ ~ (> ~ J ,6:; '~\~'J ~ - ]I"~.~. \ f ~ "f- ...' ~ L~l~ -~.,
) ..,.- ~..lniIrllSen \. 1- . ..... ~ ~., ',.
~ -. :~~ \.' ItOPPERS ~IIIII' ~ ~ ~~ ," ',,~, \;~ ~ i=
, SITJ .- ..., ; .~ .Xh. J.' ~
'./~'~rr'lt"'l .. CD :J1' ~~ '.'. J~", . o(e~'It~. ~~~
b~' ~~' '. -. . n - I ~ ~~ 1 ~'., >. !;~A. ~(. '-':.J.:-.:.--= ;LJ :.
\. ~'.. '-.. V"' T~ '. .. ~ .:.,~~ .1.:.' ( ,
~I»J~ I.~J '~\ ~ - r'I\J;~ -wi I " '~,' ~~ :.. ':1' ""\"" .'"
~~ \':l~~: ~ \.~~... '.' ~U." (" -~ \
~~')~\HI~~'Fi"~"~'-'_&~] . ,~'-::~:;""T~:}!fC---~I"'~i:v I / ,r.-'~
- ~;l\I:\\\1 --.. . r. 1\ - ill
~~~roo..; '\.'. ~\ I I .2 , : I 4..-: \
. '\.: E' . . ;);'.. I ~ / -J ~ I ( - ~ ..... IE
~.\~\r~~" :...~.! . 'k=~'- ~ ..,:J I~.~ I~ / rl~
I~j:~~ -,~ - -:'MII?~'/'" V .: .4jl~~J~~;~'~~ J:I/ ~I\' ~ ~I( -~~
~.~l ~~~~~( \ ~ ~"7 rl'rt £/ Jft 'j TWPC 1~ .~\' ~~ ;- -.:..!.l:I~l)( )
"\./.;~ \1 'II! -., .t;~-_. I :,('-1 SITE. '.' "~ '\I'~I' .
~ ~J ! ~ . "~.'\ \ j ,!.:. Q:~ . i '\'-" .", ( f\, \, ,;r~ ~ 'i/.,~, :::::
. I -. . . I A--~'-: '" v ,. ~ ~
arr:~.~ If . ..~." ~~I -. ~{I (~.._~~~:fi ~£ ~.D')L~'j ~..; ,;':~
['&~I,~h.~tr~~.': ~ .:; \~\ ~j$! Jtuth(ffie:'0m-~tl~l: ,--: .~.~.~."t.~.r.?r:..,: ". ;~~;)
.1 f - {. I ~.l., , ~. j/ S?' . .:. j)" J...' T'" -
'1 ~ k I ~: ~":.4 1:1'~'('~ . /'~~~ l '" .;' ': ~~,~' . ..., ./" ',' " ,:: ,,~\
., ~ . . ~ . : .. . ""':JMII! tI ,J .~~ ~ - r. .../"'\..... .- / I I~~ ... ,.. "IIIiII
/ . ~!: l-~,j7J '~~../.;~~. ,I C' !." /( ~~ \\.::~\.~~~ ~~ ~ '
'" ':.\~~..'~ ~~~ :.\.,C~((:: I~(;:::" . \W.
~.\ ~ 2:~~~il1j , r! I. ~ 265 ~> ~#.. .~~ - --
"~"7:'qo/f1 . -~~. .
, . . i LI\ i "7° r /l ~ FIG U R E 2
IripMinl .' I I/;.
\;:. ,.~\':. t!,. ..\ ,0.>.- .INVE.STIGATION
~. '-. c= ~'. ':.} I .<;)~'S. ~t((_.~~~\. ~,~ SITE' LOCATION MAP
~. >C'--.' :. d. I[~'~~" .
.... ::-..~. II . ~~{ ~ ...-:. .
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Sediments consisting primarily of silty sand and poorly-graded
sand with occasional thin layers of carbonaceous material are
encountered below the Clayey Sand Zone. The Silty Sand Zone
is first found at a depth of 44 to 69 feet and extends to a
depth of 90 to 99 feet.
The Lignite Zone, consisting of several lignite layers
interspersed with clayey sand or silty clay, is first
encountered at a depth of about 99 feet. This unit extends to
a depth of approximately 115 feet. A deep clay is encountered
lower. The elevation of the top of the Deep Clay Zone
reflects the trend of the regional dip in the wilcox towards
the south east at approximately fifteen feet per mile.
u'
Three different ground water zones comprise the hydrogeologic
regime at the site: 1) the Surficial silty Sand and Gravel
Zone; 2) the Clayey Sand and Silty sand Zone; and 3) the
Lignite and Deep Clay Zone. A simplified hydrogeologic
description is presented in Figure 3 and Figure 4 presents a
generalized geologic cross section of the site. This ROD
addresses the Silty Sand Zone and the Lignite Zone, both
classified as Class II aquifers.
II. SITE HISTORY AND ENPORCBHBNT ACTIVITIES
The Site has been used for various lumber related activities
since early 1900. Analysis of aerial photos indicates that
wood preserving operations were underway as early as 1954 in
the southwestern portion of the Site. The wood treating
activities leading to the current site configuration. were
begun in late 1971 by the TWPC and included the use of both
creosote and pentachlorophenol (PCP). Figure 5 shows the
location of the wood preserving operations identified
throughout the site history.
Between 1903 and 1910, the site was owned and operated by
several lumber companies including the National Lumber
Company, the Southern Tie and Timber Treating Company, and the
National Lumber and creosoting Company. These three companies
operated on a 15-acre tract east of the railroad, west of the
north-south portion of Lubbock Street, north of the southern
boundary now marked by the EPA fence, and south of Lubbock
Street where it crosses the railroad tracks. The extent of
wood treating activities during this period is unknown.
"
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t
"
I'IGURB 3
SIKPLII'IBD HYDROGBOLOGIC CROSS-SBCTIOB
01' !'JIB !'BDRDIfA WOOD PRBSBRVIBG SI'l'B
Surflcfal SiltY SInd. (R... 7 to 13 feet, everage 9 feet thick) Silty Send with occalanal sflty clay ... .Ut. 10 8Dnltorfng well..
Laboratory hydrMlI fc concb:tfvlty test. on 2 s~les (avg.3.26x10.8C111Sec).
Grevel Zone. (Range 2 to 7 feet, ever... 4 feet thick) lirevelly 88nd or silty nndy ,revel. Appurs to thtcken tClll8rd the Korth. 15
8Oftltorlng wells, cOlllpleted fn zone. Confined spt- wfth ,redlent to south.st st ~r... 35 to 40 feet per .U.. lechartet Deys Creelc.
Slug test. perfonned on 4 of 15 weUs ..Ith .en hydrMltlc concb:tlvlty of 5.68x10 _sec. 10 fUIIP test perforwed.
Clevev Send Zone' (R.... 20 to 50 feet, ever... 40 feet) Prl_rlly cl8Y8Y 88nd and COIIIprftet altematfng 1_IMe of 88nd a clay with
greater then 501 .and. With depth the clayey send ione ,r8de8 Into the silty 88nd zone. Clsyey SInd Zone a Sflty Sand Zone Is
bufeaUy a coertlng .....rd sequence with the ffnest sedillents occurfng Just belOll the sUUYfUl-"Il~ b«ntIry ... the coerteat
sedillentl being fOtnl8bcwe.Y'e Ugnlte'.J-eboratory hydrMlUC concb:tfvlty tests on5 slllllplea (8ft. 3.95.,0. _see). Vertleal seepege
velocity rqes frC18 5.5.,0 to 1.3ZX10 feet per day. CIIlculated .Inf- bresltthrough tf- fs IIfIPI'CIXI_tely 500 yesrs. Cont-fnetlon
In MY 16 end MIl 19 fndfcate that .f,ratlon Is roughly 6 to 20 tf... f..ter then expected.
SiltY Sa Zone- (Depth of cantact Ir8d8tfanal frC18 44 to 69 feet) Prf.rlly allty 88nd a poorly"""",,,,, ..Ith OCC88fCll'l81 thin I....
of carbonaceaus _tarfal. 5 _ftorfng weUa Installed to a pred8t.,..fned depth of 60 f..t. Iredlent to the 8ClUth8est at en --8118
of 31 to 33 feet per .Ile ... does not recharge Deys Creelc but CCII'ItfrulUt wfth Nlf~l flOll. Il!f tests perfOf'8ld on 2 of 5 wella about
,.,0'5 CIIIsec. 10 pulp teat perf~. Horizontal seepage velocity ranges J.b10. to 1.1x10' feet per d8y (clay ... silty 88nd).
J..1Ir1f.1!. (Depth of conteet 90 to " feet, 16 to 22 feet thick) '110 lignite beds eech ana to two feet thick Interll8dded with cl~ to
sUty send ~ silty clay. Lignite beds My not be cantfrulUt. only MIl 15 ... MIl 21 penetrate to thfs depth. '110 slug tests ewr8118
8bout 3.SA10 _sec. horizontal concb:tlvlty.
DeeD Clay- (Depth of cantact 106 to 121 feet, .Inl- of 4 to 8 feet thick) Redlill to high pl..Uclty, wry stIff to hsrd clay with silt.
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275
260
245
230
215
200
185
170
GW
SW-SJ,4
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III
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c(
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ML
SM
T.D. .. 16.5 FT.
T.D. - 25 n.
T.D. ..
SP
lolL
CLA"tEY SAHD
. SC
SC
s-------
c-------
c----:::I
---::'":1
----.)
c
SM -----1
/
L____-C /'
-"2 S
---
SM
SM T.D. C" 63 FT.
SM
T.O. .. 62 n.
SIltY SAND
SM
SP-SM
UG ----(.---
. -----?.._-_.r-------"L
------.
l.--------
SM
UG
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SM
UGNI1E
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::115
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ace
mo
. ............... "'...... SP-SJ,4
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GW-GM
SC-SM
L
T.D. .. 15 n.
T.D. .. 16 FT.
"t
II
,
lOCAT10N
l.1Ae
LEGEND
USCS ClASSIFICATION
UGNITE UNIT
GEOLOGIC CONTACT
.. ~STATIC WATER LEVEL AND
. . ..~...... POTENTIOMETRIC SURFACE
IN GRAVEL ZONE WELLS (1/89)
¥ STATIC WATER LEVEL
IN OTHER WELLS (1/89)
---GRADATIONAL OR
~APPROXI~A TE
GEOLOGIC CONTACT
SCREENED INTERVAL
CH
155
T.D. .. 120 FT.
I I
o 200 400
NOTE:
HORIZONTAL SCALE NEAP. WELlS
MW-OI, Io4W-02 AND MW-09 HAS
BEEN EXAGGERATED TO SHOW
OET AILS.
J
~
FIGURE 4
-:wPC REMEDIAl INVESTIGATION
GENERAUZED GEOLOGIC
CROSS-SECTION X-X"
DEEP r:J.AV
I
800
HORIZONTAL SCALE IN FEET
I J
1000 1200
T.D. - 119 n.
I
800
I
1400
I
1800
1800
2000
1
2200
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I'
~/
~
--
/)
()
.
I I
I .
L______------_!~-~~~-~~---~
: PROCESSINC. STORACE. .
L._____-~~~~~~~-------~
l'
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Several individuals owned portions of the Site between 1910
and 1920. In mid-1920, the Consolidated Lumber Company
acquired 25.37 acres (which roughly corresponds to the
boundaries now delineated by the EPA fence) and operated at
the site for about two years. The State Line Lumber Company
took over the site in 1933. Clara B. Butcher, or her heirs,
owned the Site from 1933 until it was sold to TWPC in 1981.
During that time, various companies leased the property. The
Power Mill and Lumber Company (later the Thomas E. Power
Lumber Co.) held a lease in 1942. In 1946, the site was
leased to the Charles H. Proetz Lumber Company for a minimum
period of five years. Analysis of an aerial photo taken in
1954 indicates what appears to be creosoting operations in the
southwestern corner of the Site. This is the first
documentation of on-site creosoting activities.
In 1972, the processing area was moved from the south-western
portion of the site to the central portion of the Site.
Therefore, the site may be broken down into two parts, the
pre-1972 treatment area and the post-1972 treatment area as
shown in Figure 5. Both areas have a heavily contaminated
process area consisting of a number of waste ponds on the west
part of the site and water retention ponds on the east portion
of the Site. Most tanks have been scavenged from the Site,
however, a few still remain in the main process area of the
post-1972 treatment area. There are also a few buildings, and
concrete slabs on the site.
The portion of the site east of Lubbock Street ap~eared ~o be
occupied by office buildings or workshops. North of the
apparent processing area, on the west side of Lubbo~k street,
the site was used for lumber storage. There was a large
building located just north of where the pretreatment storage
ponds are today.
The TWPC first came to the attention of the State of Texas
following discharges into Days Creek. The first state
investigation occurred in December 1968. The following six-
teen years, until the TWPC ceased operation in August 1984,
were marked by a series of state investigations in which the
TWPC was found to be either negligent or delinquent in their
efforts to fulfill various wood treating permitting re-
quirements.
"
The Site was nominated to be included on the National
Priorities List (NPL) in December 1984. In June 1986, the
Site was included on the third NPL update. Subsequently, EPA
has taken measures to control surface runoff and Site access.
Stabilizing actions taken by EPA from 1986 to 1988 included
constructing fences to minimize access, constructing a berm
around the main operations pond to prevent surface runoff and
pumping down this and other ponds to prevent overflow. The
pumped liquid, primarily rainwater runoff, was put in pond
number 1.
."
-------
Fourteen potentially responsible parties (PRPs), former owners
and operators were identified in a PRP search conducted in
1985. On January 16, 1986, Notice Letters were sent to the
PRPs notifying them of their potential liability and of
planned investigations at the Site. The PRPs contacted were
asked if they would like to either conduct or finance the
Remedial Investigation and Feasibility Study (RIfFS) at the
Site. Of the PRPs notified, all declined to participate in
the RIfFS process. On December 17, 1986, Action Letters were
sent to the PRPs informing them of an imminent and substantial
endangerment to public health or welfare or the environment
due to actual or threatened releases of hazardous substances
on or from the Site. The Action Letters requested the PRP's
to post warning signs and install a fence around the site.
All the notified PRPs declined to voluntarily install a fence
or take any action. On February 5, 1987, Special Notice
Letters were sent to each identifiead PRP asking them to
participate in the RIfFS. All the PRPs declined to
participate in the RIfFS.
On April 16, 1990, a revised PRP search was initiated by EPA
to gather additional information on known PRPs, to identify
and to obtain information on any additional PRPs. The main
impetus behind this effort was to issue Special Notice Letters
to all identified PRPs in order to request the PRPs to perform
or finance the Remedial Design and Remedial Action (RDfRA) for
Operable unit One. The ROD was signed on, and became
effective, September 25, 1990. The Special Notice Letters
were issued to PRPs on October 5, 1990, starting the 60 day
moratorium period to receive a Good Faith Offer to perform or
finance the RD/RA. The end of the 60 day moratorium period
was December 12, 1990, at which time, no "Good Faith Offers"
had been received by EPA. All identified PRPs were.
subsequently notified that EPA would continue work at the Site
and that EPA still might pursue them in a cost recovery action
at a later date.
I:II:. JlJ:GBLI:GJft'S OJ' coJIKtJB:In PARTICI:PATI:OJr
The Texas Water Commission (TWC), predecessor to the Texas
Natural Resources Conservation Commission (THRCC) and EPA have
provided significant public outreach to the Texarkana
community by way of public meetings, fact sheets and media
interviews. A Community Relations Plan for the Site was
finalized in December 1987. It was revised by TWC and EPA in
1991. The Supplemental Remedial Investigation (SRI) report,
the Focused Feasibility study (FFS) report and the Proposed
Plan were released to the public in January 1993. The
Proposed Plan Summary was released to the public on January
21, 1993. All of these documents were made available in both
the Administrative Record and in two information repositories
maintained at the Texarkana Public Library and Texarkana City
Hall. A public.. comment period was open from January 26, 1993,
to March 24, 1993. In addition, a public meeting was held on
.,
".
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- - - - ~ . .. - . - -. -
.'
and the preferred alternative as presented in the Proposed
Plan for the Site. At this meeting, representatives from EPA
and TWC answered questions about this site and the remedial
alternatives under consideration. One comment was received
during the public comment period. This comment and those
expressed at the public meeting are addressed in the
Responsiveness Summary which is attached as Appendix A to the
ROD and will be released to Texarkana residents with a summary
of the ROD after the ROD is signed. This decision document
presents the selected remedial action for Operable Unit Two
for the site chosen in accordance with CERCLA, as amended by
SARA, and the National oil and Hazardous Substances Pollution
contingency Plan. This decision is based on the
Administrative Record, an index of which is attached as
Appendix C.
IV. SCOPE AND ROLE OP OPERABLB UNITS WITHIN THE SITE STRATEGY
As with many Superfund sites, the problems at the TWPC are
complex. During the investigation of the site, EPA and TWC
concluded that the deeper ground water aquifers might be
contaminated. To expedite the remediation of the source and
the Gravel Zone ground water, the site remediation studies
were separated into two parts, called operable units. These
are:
Operable Unit One: contaminated Soil, Sludge and Gravel
Zone Ground Water (average depth below grade of 13 feet)
Operable unit Two: Silty Sand Zone (average depth below
grade of 50 feet) and Lignite Zone Ground Water (average
depth below grade of 100 feet). These are Class II
ground water zones.
"
Al though this ROD addresses Operable Uni t Two, a brief
description of Operable unit One is presented here to enable
the reader to understand how EPA's remedy for Operable unit
Two relates to the total remediation of the Site. EPA
determined that the principal threats to human health and the
environment at the site are contaminated soil, sludge and
contaminates in the Gravel Zone ground water. The potential
routes of exposure are through direct contact with and inges-
tion of the soil, sludge and the ground water. The remedial
objectives for the soil and sludge are to prevent current or
future exposure to the contaminated soil and sludge through
treatment and to reduce the migration of contaminants to
ground water. The remedial objectives for the contaminated
Gravel Zone ground water are to reduce the amount of
contamination,'to return the ground water to its beneficial
use and to prevent adverse impact to lower ground water zones.
This ground water remediation will be accomplished with the
installation and operation of a pumping and carbon adsorption
treatment system. This system will remove the contaminants
from the Gravel Zone ground water after the source
contamination in the soil and sludge is removed.
"
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v. SUNMARY O~ SXTB CHARACTBRISTICS
Both the pre-1972 and the post-1972 treatment areas have
heavily contaminated process areas, consisting of a number of
treatment, chemical storage and water retention ponds. The
soil in these areas and the Gravel Zone ground water are
contaminated with wood preserving wastes, PCP, and creosote.
For Operable Unit Two, the TWC initiated studies under an EPA
Superfund cooperative agreement primarily to assess current
ground water quality in the Silty Sand Zone and the Lignite
Zone. This investigation involved the installation of two
additional monitoring wells in the Silty Sand Zone, one
additional well in the Gravel Zone and one aquitard monitoring
well. Figure 6 indicates the locations of the previously
installed monitoring wells that were tested during Operable
Unit Two work. Figure 7 indicates the locations of the
monitoring wells installed and tested during Operable Unit Two
work. Water from these four new wells, the five wells
previously installed during Operable unit 1 in the Silty Sand
Zone, one well previously installed in the Lignite Zone and
seven wells previously installed in the Gravel Zone was
sampled. This sampling confirmed a limited presence of Site
contaminants at only one Silty Sand Zone well. site
contaminants were not detected at any other Silty Sand Zone or
Lignite Zone well. Monitoring Well-16, located northwest of
the post-1972 process area, was the only silty Sand Zone well
which detected Site contaminants. Non-carcinogenic
polynuclear aromatic hydrocarbon (PAH) compounds (~
acenaphthylene, acenaphthene, anthracene, fluorene,
fluoranthene, naphthalene, phenanthrene, and pyrene) and other
semivolatile compounds (~ 2,4-dimethylphenol and phenol)
were detected. The presence of many of these compounds was
detected throughout the time series sampling event also. The
maximum total concentration of semivolatile compounds found in
the Silty Sand Zone is 2.2 milligrams per liter (mg/L) of
water. Naphthalene accounted for 1.4 mg/L of this
concentration. The contaminant concentration decreased over
the time series test and becomes asymptotic near 0.33 mg/L
within 24 hours.
To prevent the potential for contamination of the Silty Sand
Zone during th~ Operable Unit Two investigation, no other
exploratory wells were installed through the contaminated soil
or contaminated Gravel Zone in the vicinity of Monitoring
Well-16. Therefore, the closest monitoring well to Monitoring
Well-16 is 170 feet away. since contamination was not
detected in any Silty Sand Zone monitoring well other than
Monitoring Well-16, neither the size of the contamination
plume nor the volume of contaminated water in this Zone is
known. It is known that the plume does not extend to any of
the other monitoring wells. It is believed that Silty Sand
Zone ground water contamination does not extend beyond the
Site boundaries because the direction of ground water movement
in the Silty Sand Zone is to the southwest toward Days Creek.
11
-------
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FIGURE 6
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TEXARKANA . WOOD PRE!ERWiIc co
SRI PHASE '~
-------
VI. SUJlMARY OP SITB RISItS AND REMEDIATIOB GOALS
.'
A risk assessment is a scientific procedure which uses facts
and assumptions to estimate the potential for adverse effect
on human health from exposure to chemicals. Risk is
determined by evaluating known chemical exposure limits and
actual chemical concentrations on a site. The actual chemical
concentrations are compared to the exposure to a known amount
of the chemical shown to cause harm. The risk potential is
expressed in terms of the chance of a disease occurring.
Conservative assumptions that weigh in favor of protecting
human health are made in these calculations. To protect human
health, the EPA is most concerned with the probability that
exposure to specific chemicals may result in cancer or in non-
cancer health effects.
,.
The risk in the United states of developing some form of
cancer from everyday sources over a seventy-year life span is
estimated to be three in ten. Activities such as too much
exposure to the sun, occupational exposures, or smoking habits
contribute to this high risk. The three in ten probability is
the "natural incidence" of cancer. A risk level of one in one
million means that one additional person out of one million
people exposed could develop cancer as a result of long-term
exposure to a remediated site. This can be described by
scientific notation as 10.6. To protect human health, the EPA
has set the risk range of less than 10.4 to 10.6 excess cancer
risk as a goal for remediated Superfund sites.
."
As stated in the Operable Unit One ROD, the future use of this
site will most likely be industrial. Therefore, an industrial
exposure scenario was developed. This exposure scenario is
based on an individual working on the Site eight hours a day,
five days a week for forty years.
The risk assessment for Operable unit One source contaminants
in soil and shallow ground water was conducted during the
operable unit One work and is located in Appendix B of the
operable unit One FS. The risk assessment indicated that the
chemicals which pose the greatest health threat to workers are
carcinogenic polynuclear aromatic hydrocarbons (~
components of creosote), PCP, chlorinated dibenzo-p-dioxin and
dibenzofuran. Under the future use evaluation, if site
condi tions were not changed by the planned remedy selected for
Operable Unit One, the increased chance of cancer for a long-
term worker on the site would be one in one hundred (10.2).
The remediation levels the EPA selected for Operable unit One
will reduce this risk to one in one million (10.6), ten
thousand times lower.
"
Sampling of all the silty Sand Zone and Lignite Zone wells
during the Operable Unit Two investigation indicated that all
PAH contaminants and other semivolatile compounds found were
non-carcinogenic. Consequently, the Silty Sand or Lignite Zone
ground waters do not present a risk of an increase in cancer.
-------
A Hazard Index was calculated to evaluate non-carcinoqenic
health effects of a person working on this site and drinking
ground water from the Silty Sand Zone. A Hazard Index of less
than 1 indicates that adverse health effects are not
anticipated from the potential contact with or exposure to the
chemicals with concentrations existing at the site. The
Hazard Index is the total of the comparisons of the potential
contact with or exposure to all the known ground water
contaminants to the Reference Dose (RfD).
The Reference Dose is a function of the long-term contact for
individuals, including sensitive subpopulations, such as
children, with a chemical that is not anticipated to cause
adverse health effects. Table 1 lists RfD values for all
contaminants detected in the Silty Sand Zone ground water.
These RfD values were used in the calculations for this ROD.
EPA's Integrated Risk Information System (IRIS) is the source
for all but two RfD values. The RfD for naphthalene is 0.04
mg/kg/day but is currently being reevaluated and will probably
be increased. In order to be protective of human health, the
more conservative RfD value of 0.004 mg/kg/day listed in EPA's
Drinking Water Regulations and Health Advisories, May 1993, is
used for the Hazard Index calculations for this ROD. IRIS
does not list a RfD for phenanthrene. Therefore, a value
developed by Region 3 of EPA was used.
.,
: ;,
The ground water exposure pathways used for a person at the
site are ingestion, inhalation and dermal absorption of water
extracted from Monitoring Well-16 on the Site. The Reasonable
Maximum Exposure (RME) values used in the risk assessment
calculations for Operable Unit One represent the upper end of
the distribution curve. Exposure assumptions discussed to
this point in this ROD are based on RME values. The RME
values are used to estimate the baseline risks and ultimately
the remedial action goals at sites. However, most people are
likely to be exposed to lower doses than this calculated
value. Therefore, EPA now evaluates both RME and "central
tendency" in the risk assessment at Superfund sites. The
"central tendency" scenario represents the risk from more of
an "average" exposure, compared to a "reasonable maximum"
exposure. See Table 3 for the central tendency risk
assumption comparison wi th the RME. Table 2 presents the
final remediation levels for each contaminant when the
corresponding . risk level is 1. Naphthalene is the only
contaminant in the Silty Sand Zone ground water with an actual
concentration greater than the corresponding final remediation
level.
'"
Before the start of the time series sampling event for the
SRI, the maximum total concentration of semivolatile
compounds, including non-carcinogenic PABs, found in the Silty
Sand Zone was 2.2 milligrams per liter (mgjL) of water;
naphthalene accounted for 1.4 mg/L of this concentration. At
this concentration of naphthalene, the calculated Hazard Index
is 3.4 using RME rates and 0.9 using Central Tendency rates.
. .
-------
TABLE 1
REFERENCE DOSB VALUES
Oral RfD,
Chemical Name ma/ka/dav Source
Acenaphthene 0.060 (1)
Anthracene 0.300 (1)
Dimethylphenol, 2,4- 0.020 (1)
Fluoranthene 0.040 (1)
Fluorene 0.040 (1)
Naphthalene 0.004 (2)
Phenanthrene 0.029 (3)
Phenol 0.600 (1)
(1) IRIS, EPA's Integrated Risk Information System, september,
1993.
(2) Drinking Water Regulations and Health Advisories, May, 1993,
us EPA.
(3)
Value obtained from Region 3, EPA.
TABLE 2
REMBDDTIOB GOALS an4 CORRBSPOHDIBG USKS
Remediation Corresponding Risk Levels
Chemical Name Level. ma /L Cancer Non-Cancer
Acenaphthene 6.1 NIA 1.0
Anthracene 30.7 NIA 1.0
Dimethylphenol, 2,4- 2.0 N/A 1.0
Fluoranthene 4.1 N/A 1.0
Fluorene 4.1 N/A 1.0
,;.'
Naphthalene 0.4 N/A 1.0
Phenanthrene 3.0 NIA 1.0
Phenol 61.3 MIA 1.0
The point of compliance is Monitoring Well 16. RfD's are the basis of he
Goals.
-------
TABLB 3
CBftDL TBHDDtCY V8 RBASOHABLB HAXIKUK BZPOSURB ASSUHPTIONS
0.7L/day 1 L/day
70 kg 70 kg
9 years 25 years
250 days/year 250 days/year
ED ED
Average or
Central Tendency
Contact Rates (CR)
Worker Water Ingestion Rates
Worker Body Weiahts (BW)
Worker EXDosure Duration (ED)
Worker EXDosure Freauencv (EF)
Averaaina Time (AT)
Noncarcinogenic effects
References For ExPosure Parameters
Average or
Central Tendency
Concentration Term (C)
site-specific value .:.
Contact Rates (CR)
Worker Water Ingestion Rates
US EPA, 1992
50% Adult's
Ingestion Rate
US EPA, 1991
US EPA, 1991
Worker Body Weiahts (BW)
Worker EXDosure Duration (ED)
US EPA, 1989b
US EPA, 1991
Worker Exposure Freauency (EF)
Averaaina Time (AT)
Noncarcinogenic effects
US EPA, 1989b
17
Reasonable
Maximum EXDosure
Reasonable
Maximum EXDosure
US EPA, 1992
US EPA, 1991
Average Value,
US EPA, 1991
US EPA 1991
Average value,
US EPA, 1991
US EPA, 1989b
'"
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.. -- ..-
."
After three hours of pumping, the concentration of naphthalene
was 0.41 mg/L. At this reduced concentration of naphthalene,
the Hazard Index is calculated to be 1 using RME rates.
The maximum concentration value for naphthalene in ground
water for residential exposure condi tions in the TWC Risk
Reduction Standards (promulgated under the Texas Water Code
S5.103 and S26.011) is 1.46 mg/L. This value slightly exceeds
the 1.4 mg of naphthalene/L initially detected in the ground
water. Naphthalene is not included by TWC in the 1993 TWC
list of 59 new or revised maximum contaminant levels for
drinking water. Maximum contaminant Levels (MCLs) do not
exist for any of the contaminants detected. Therefore,
extensive remediation is not warranted based strictly on the
Hazard Index value.
The Drinking Water Regulations and Health Advisories, issued
by EPA's Office of Drinking Water in May 1993, present
limiting values for ingestion concentration for many organic
compounds. Of the organics listed, naphthalene is the only
organic present in the ground water at a concentration
exceeding the limiting value. The drinking water equivalent
level advisory value for naphthalene is 1 mg/L for an adult
for longer term exposure.
Based on the Hazard Index, the lack of MCLs, the drinking
water health advisories limiting values, the expected
industrial future use of this Site, and the fact that the
ground water zone is Class II, the remediation goal for the
Silty Sand Zone is established as the removal and treatment of
ground water with a total naphthalene concentration greater
than 0.41 mg/L. This concentration is equivalent to a Hazard
Index of 1 and was obtained during the timed pumping test.
Remediation goals for the other contaminants are listed in
Table 2.
No significant risks to terrestrial vegetation or wildlife,
due to contaminants in the Silty Sand Zone, were identified.
VII. DESCRIPTION OP ALTBRH&TIVBS
The following' is a tabulation and description of the three
alternatives for the Silty Sand Zone remediation considered by
the EPA:
0"
Alternative 1-A: No Action
Alternative 1-B: Extraction and Treatment (This alternative is
. designated "Limited Action" in the Proposed Plan and in the
SRI/FFS. There is no change in the remedy.)
Alternative 2: Pump, Treatment and Injection
-------
CO_OD Bleaeat.
The qoal of this remedial action is to restore the Class II
qround water to its beneficial use. However, studies suqqest
that qround water extraction and treatment are not in all
cases completely successful in reducinq contaminants to the
remedial qoals in the aquifer. EPA recoqnizes that operation
of an extraction and treatment system may reveal the technical
impracticability of reachinq the qoals usinq this approach.
Therefore, continqent remedial activities may be implemented,
such as, discontinue pumpinq when cleanup qoals have been
attained or install additional extraction wells to facilitate
or accelerate cleanup of the contaminant plume.
All qround water remedial action will occur after the
contaminant source (contaminated soil and sludqe) removal
portion of the Operable unit One remedial action. The carbon
adsorption water treatment unit discussed here will be
installed as part of Operable unit One prior to Operable unit
Two remediation activities.
Recordinq of notice in public land records will be undertaken
to warn of potential danqers from future use of qround water
on the site. The state of Texas does not have a mechanism to
force a landowner to record anythinq on the deed. In the
state of Texas, the. water riqhts belonq to the land owner. As
such, the state has no mechanism to prohibit use of a stream
or qround water. Therefore, it is particularly important that
the qround water be remediated to protect public health.
Costs
All costs and time required to implement the alternatives are
estimates. As explained in the January 1993 SRI/FFS, the
costs have an expected deqree of accuracy of +50% to -30%.
Alternative i-AI 110 ACTIOII
Present Worth: $ 266,000
Capital Costs: $ 39,000
Operation and Maintenance (O&M): $ 227,000
Years to Implement: 30 years after completion
unit One soil and sludqe remediation
The Superfund proqram requires that a no action alternative be
considered at every site as a basis of comparison when
evaluatinq other alternatives. "No Action" would consist of
future monitorinq of the aquifer only. This alternative would
not decrease the toxicity, mObility, or volume of contaminants
or reduce public health or environmental risks throuqh
treatment.
of Operable
".
,.
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Alternative 1-BI BftRACTJ:OR UD ' RBATKBR'l'
."
Present Worth: $ 320,000
Capital Costs: $ 93,000
operation and Maintenance (O&M): $ 227,000
Years to Implement: 30 years after completion
Unit One soil and sludge remediation
This alternative would reduce site risk by decreasing ground
water contamination present in the area surrounding Monitoring
Well-l6. All other wells in the silty Sand Zone tested clean
and would be used as monitoring wells. FOllowing the source
removal,. the Operable unit One extraction system and water
treatment system for the Gravel Zone ground water would be
installed and operated until steady state conditions are
reached for that unit. As the water in the Gravel Zone above
is being remediated, contaminated water would be pumped from
Monitoring Well-l6 on an intermittent basis. The withdrawal
rate would be restricted so that a downward gradient would not
be sustained between the Gravel Zone and the silty Sand Zone.
A temporary (not more than a few days) downward gradient would
be acceptable immediately following the withdrawal of water.
The gradient between the aquifers would be monitored by
observing the water levels in the nearby extraction sumps.
The extracted contaminated water would be mixed with Gravel
Zone contaminated water and treated in the Operable Unit One
carbon adsorption water treatment system. Carbon adsorption
is a process where contaminants are removed from water by
adsorption onto carbon in a treatment unit. These
contaminants are retained on the carbon. As discussed in the
operable unit One ROD, these contaminants on the carbon can
then be thermally destroyed (on- or off-site), recycled or
placed in a landfill. The decontaminated water will be
injected into the Gravel Zone aquifer.
of Operable
"
Based on the rapid decline in contaminant concentration
experienced during the SRI/FFS, treatment of this water is
expected to be complete before the Gravel Zone water treatment
is complete. Thus, it would not add to the time already
required to remediate the ground water on this Site.
Monitoring of the silty Sand Zone and Lignite Zone aquifers
would occur concurrently with the monitoring of the Gravel
Zone ground water for Operable unit One. Although natural
attenuation is not specified as a part of the remedy, it would
occur during the 30 year monitoring period. Real estate
notice recordation would be undertaken.
During the rem~diation of the contaminated soil and sludge,
water from Monitoring Well-l6 and other wells in the Silty
Sand Zone would be sampled and analyzed. Thus, any change in
the extent of contamination in the Silty Sand Zone would be
detected. If Site contaminants are detected above action
levels in any of the wells presently testing clean, the wells
would be added to the pump and treatment system.
-------
reduce public health or environmental risks by removing and
treating the contaminated ground water in the Silty Sand Zone.
Alternative 21 B%TOCTIO., TRBATllBft ABD IBJBCTIO.
Present Worth: $ 2,250,000
capital Costs: $ 1,252,000
Operation and Maintenance (O&M): $ 998,000
Years to Implement: 30 years after completion
Unit One soil and sludge remediation
The contaminated ground water within the Silty Sand Zone would
be removed via existing wells and additional wells that would
have to be installed for this alternative. The required
number of wells is uncertain due to the lack of information
regarding the size of the affected ground water plume in the
Silty Sand Zone down gradient of Monitoring Well-16. The
contaminated ground water plume does not appear to extend off
the site.
of the Operable
Water from these wells would be pumped to the water treatment
system to be installed to treat the contaminated water in the
Gravel Zone. After treatment, the water would be injected
into either the Gravel Zone or the Silty Sand Zone through new
wells. The remedy of the Gravel Zone conflicts with this
alternative. The start of this alternative treatment would
have to be delayed until treatment of the Gravel Zone water is
completed or there would be the possibility of additional
contamination of the Silty Sand Zone with untreated
contaminated water from the Gravel Zone. Based on the rapid
decline in contaminant concentration observed during the
SRI/FFS, treatment of the Gravel Zone water is expected to be
complete within two to five years. Thus, additional time
would be required to remediate this Site. Monitoring of this
aquifer would occur concurrently with the monitoring of the
Gravel Zone ground water for Operable Unit One. Al though
natural attenuation is not specified as a part of the remedy,
it would occur during the 30 year monitoring period. Real
estate notice recordation would be undertaken.
During the remediation of the contaminated soil and sludge,
water from Monitoring Well-16 and other wells in the silty
Sand Zone would be sampled and analyzed. Thus, any change in
the extent of contamination in the Silty Sand Zone would be
detected. If site contaminants are detected above action
levels in any of the wells presently testing clean, the wells
would be added to the pump and treatment system.
This alternative would decrease the volume of contaminants and
reduce public health or environmental risks by removing and
treating the contaminated ground water in the Silty Sand Zone.
However, it could increase the mobility of the contaminants,
albeit below the treatment level, remaining in the Gravel Zone
after completi9n of Operable Unit One activities.
'"
"0
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,"
,>
."
VIII SUJlHARY 01' COKPAUTIVB ANALYSIS 01' ALTERNATIVES
criteria
EPA is required to evaluate the remedial alternatives it
considers for a Superfund site against 9 criteria to determine
which alternative provides the best balance between the
criteria and which should be implemented at the site. An
explanation of the criteria follows:
The first two criteria are criteria which the remedial action
must meet.
.
OVerall Protection of Human Health and Environment addresses
whether or not a remedy provides adequate protection and
describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls
or institutional controls.
.
ComDliance with ADDlicable or Relevant and ADDroDriate
Reauirements (ARAR) addresses whether or not a remedy will
meet all of the applicable or relevant and appropriate
requirements of other Federal and State environmental statutes
and/or provide grounds for invoking a waiver.
The next five criteria are analyzed to determine how the
alternatives compare to one another and to identify tradeoffs
between them.
.
Lana-term effectiveness and Dermanence refers to the magnitude
of residual risk and the ability of a remedy to maintain
reliable protection of human health and the environment over
time once cleanup goals have been met.
Reduction of toxicity. mobility. or volume through treatment
is the anticipated performance of the treatment technologies
that may be employed in a remedy. The specific factors to be
considered are the amount of waste to be destroyed or treated:
the expected degree of reduction in volume, mObility or
toxicity: the degree to which the remediation will be
irreversible: and the nature and quanti ty of treatment
residuals that will remain on the site.
.
.
Short-term effectiveness refers to the speed witb which the
remedy achieves protection, as well as the remedy's potential
to create adverse impact on human health and the environment
during the construction and implementation period.
ImDlementability is the technical and administrative
feasibility of implementing a remedy, including the
availability of materials and services needed to implement the
chosen solution.
.
.
~ includes capital and operation and maintenance costs.
-------
.
The final two criteria are modifying criteria.
state ACceDtance indicates whether, based on its review of the
~/FS and Proposed Plan, the state concurs with, opposes, or
has no comment on the preferred alternative.
.
Communitv ACceDtance will be assessed in the Record of
Decision following a review of the public comments received on
the RI/FS report and the Proposed Plan.
Table 4 presents a symbolic ranking of the comparative
analysis for the ground water al ternati ves. The symbolic
ranking is based on the narrative analysis that follows.
ADaly.i.
OVerall Protection. OVerall protection of human health and
the environment is provided by Alternatives l-B and 2. These
alternatives utilize active treatment to prevent further
migration of the contaminant plume, thus minimizing the
potential for establishing an exposure pathway which might
endanger human health and the environment. However,
Alternative 2 might increase contaminant mObility. The
potential for downward migration of contaminated ground water
is deemed to be too
great a risk for even the most stringent of well installation
protocols, especially in view of the very limited
contamination present. Alternative l-A does not provide any
protection to human health and the environment.
Compliance with Applicable or Relevant an4 Appropriate
Requirements, AURa. ARARs are the federal and state require-
ments that a selected remedy must meet. However, there are no
specific remediation levels defined for the silty Sand Zone
contaminants in state or federal regulations. Alternatives 1-
Band 2 would treat water from the Silty Sand Zone to at least
the same standards used for the Gravel Zone water.
Alternative l-A does not provide for any treatment.
Long-tera Bffectivene.. u4 Permu.nce. The qoals for all of
the remedial alternatives are to prevent human exposure to
contaminated ground water and prevent contamination of the
underlying aquifer. The preferred Alternative l-B and
Alternative 2 both meet these goals by requiring the removal
and treatment of the contaminated ground water using the
carbon adsorption unit provided for Operable Unit One. This
method of treatment has proven satisfactory in reducing the
contaminant levels in qround water to backqround level and,
thus is effective and permanent. Therefore, the risk from
ingestion of, or direct contact with, the contaminated ground
water will be eliminated. In addition, these alternatives
provide that contingency measures be implemented if
contaminant concentrations or extent of contamination increase
over time. Alternative l-A does not provide any long-term
effectiveness or permanence other than by natural attenuation.
"
".
23
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TABLB 2
comparative ADalysis of Ground water Alternative.
Based on the Bine criteria
Effectiveness and Permanence:
Most Effective Alternatives
Extraction
Extraction,
Injection
Alternative 1-A,
.'
OVerall Protection:
Most Protective
.'
Least Protective
ComDliance with ARARs:
Most Compliance
Least Compliance
Long-term
Least Effective
Reduction of Toxicitv. Mobilitv.
Most Reduction
Least Reduction
Short-term Effectiveness:
Most Effective
Least Effective
ImDlementabilitv:
Easiest to
Implement
Hardest to
Implement
"
&Q.et :
Least Costly
""
Most Costly
Alternative 2, Extraction,
Treatment and Injection
Alternative 1-B, Extraction and
Treatment
Alternative 1-A, No Action
Alternatives
Extraction
Extraction,
Injection
Alternative
1-B and 2,
and Treatment;
Treatment and
1-A, No Action
1-B and 2,
and Treatment;
Treatment and
No Action
and Volume:
Alternative 2, Extraction,
Treatment and Injection
Alternative l-B, Extraction and
Treatment
Alternative l-A, No Action
Alternative 2, Extraction,
Treatment and Injection
Alternative 1-B, Extraction and
Treatment
Alternative I-A, No Action
Alternative 1-A, No Action
Alternative 1-B, Extraction and
Treatment
Alternative 2, Extraction,
Treatment and Injection
Alternative l-A, No Action
Alternative 1-B, Extraction and
Treatment
Al ternati ve 2, Extraction,
Treatment and Injection
\
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aeduction of Toxicity, lIobility, or Volume of the Contaminants
through Treatment. Alternatives 1-B and 2 meet the EPA's
preference that the toxicity, mobility and volume of the con-
taminants be reduced through active treatment. The treatment
technology to be used for Alternatives 1-B and 2 is carbon
absorption. Carbon adsorption is well proven and fully
capable of removing the contamination from the ground water to
the manageable activated carbon. For Alternative 2 however,
the potential for downward migration of affected ground water
and/or dense, non-aqueous phase liquids is a risk. Monitoring
will detect any movement of the waste volume laterally or
vertically. Alternative 1-A does reduce toxicity, mobility or
volume of the contaminants in the ground water.
Short-tera Bffectiveness. The No Action Alternative would
present no additional risks to the public or on-site workers.
During the construction of the extraction wells for
Alternative 2 and the monitoring of the ground water for
Alternatives 1-B and 2, precautions would be taken to
eliminate any risk from contact with the drilling spoils and
well water. The actual time required to address the ground
water contamination is expected to be two to five years. Air
emissions from any water treatment action will be addressed
and, therefore, should not constitute a threat.
Implementability. There are no implementability concerns
posed by either Alternative 1-A or 1-B. The construction
techniques associated with installing additional wells would
not hinder implementation of Alternative 2, but there is a
possibility of increasing the mobility of any contaminants
remaining in the Sil ty Sand Zone after treatment. The
potential for downward migration of contaminated ground water
is deemed to be too great a risk for even the most stringent
of well installation protocols, especially in view of the very
limited contamination present. The water treatment system for
Operable Unit One has sufficient capacity to handle the water
resulting from either Alternative 1-B or Alternative 2.
C08t. The cost of 1-B is estimated to be $320,000. The cost
of No Action Alternative I-A is estimated to be $54,000 less,
but the opportunity to reduce the volume of contaminants would
be lost. Alternative 2 would cost at least seven times that
of Alternative 1-B.
state Acceptance. The state of Texas through the
Natural Resource Conservation Commission supports
decision of limited pumping and treating the ground
identified as Alternative I-B.
Texas
EPA's
water
""
Community Acceptance. Judging from the comments received
during the public meeting and public comment period, the
community supports EPA's decision of limited pumping and
treating the ground water identified as Alternative 1-B. All
the comments received during the public meeting and the public
comment period and EPA responses are in Appendix A.
'.
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IX. SELECTED RBMBDY
.'
Based on consideration of the requirements of CERCLA as
amended, the detailed analysis of the alternatives, and public
comments, the EPA has determined that Alternative I-B:
Extraction and Treatment (of ground water for a period of 2 to
5 years) is the most appropriate remedy for the deep ground
water remediation. The criteria that weighed the heaviest in
this selection are Compliance with ARARs: Long-term
Effectiveness and Permanence: Reduction of Toxicity, MObility,
and Volume: and Cost.
.0
The remediation goal for the silty Sand Zone is the removal
and treatment of ground water with a concentration of
naphthalene greater than 0.41 mg/L. This goal is protective
of human health and the environment. The goal was selected to
reduce or eliminate the risks associated with potential
exposure to the contaminants via ingestion of contaminated
ground water.
The goal of this part of the remedial action is to restore the
ground water to a useable state. Based on information
obtained during the remedial investigation, and the analysis
of all remedial alternatives, the EPA and the State of Texas
believe that the selected remedy will achieve this goal.
However, studies suggest that it may not be possible to reduce
contaminants to the remediation goals established for the
Silty Sand Zone within the desired time frame. Ground water
contamination may be persistent. The practicability of
achieving cleanup goals in the Silty Sand Zone aquifer cannot
be determined until the extraction system has been implemented
and plume response monitored over time. It may become
apparent, during the implementation or operation of the ground
water extraction systems and its modifications, that
contaminant levels will have ceased to decline and will remain
constant at levels higher than the remediation goal over some
portion of the contaminated plume. In such a case, the system
performance standards and/or the remedy may be reevaluated.
If site contaminants are detected above action levels in any
of the wells presently testing clean, the wells will be added
to the pump and treatment system.
v'
statutory Determinations
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, section 121 of CERCLA establishes several other
statutory requirements and preferences that the remedy
selected must meet. section 121 of CERCLA specifies that when
complete, the selected remedial action for a site must comply
with applicable or relevant and appropriate environmental
standards ("ARARsn) established under federal and state
environmental laws unless a statutory waiver is justified.
-------
The selected remedy also must be cost-effective and utilize
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent
practicable. Finally, this statute includes a preference for
remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mObility of
hazardous wastes as their principal element. The following
sections of this ROD discuss how the selected ground water
remedy meets these statutory requirements.
ProteotioD of BumaD Health aDd the BDvironmeDtl
The selected ground water remedy protects human health and the
environment by pumping contaminated ground water from the
Silty Sand Zone, blending it with contaminated Gravel Zone
ground water and then treating the blended contaminated ground
water by carbon adsorption. The treated ground water will be
injected into the Gravel Zone aquifer. The currently planned
ground water monitoring system will be maintained or an
additional system will be designed and installed during
Operable Unit One activities to ensure that the remedial
action goals for the ground water are met.
The capture and treatment of the contaminated ground water
will eliminate threats of direct contact and ingestion posed
by the Site. By maintaining a ground water monitoring program
in conjunction with the pump and treatment system, elimination
of the threats posed by possible ingestion or direct contact
can be assured. There are no short-term threats associated
with the se~ected remedy that cannot be readily controlled.
Also, no adverse cross-media impacts are expected from the
selected ground water remedy.
CompliaDoe with App~ioabl. or RalavaDt aDd Appropriate Require-
.eDtsl
As stated previously, the wastes on this Site are not RCRA
hazardous wastes. Accordingly, all regulations which govern
the disposal of these wastes are not applicable, rather they
may be considered re~evant and appropriate.
The selected Silty Sand Zone ground water remedy of extraction
and treatment, followed by inj ection into the Gravel Zone will
comply with all applicable or relevant and appropriate
action-specific and location-specific requirements (ARARs).
There are no chemical-specific requirements. However, one
chemical-specific advisory was considered. The ARARs and
chemical-specific advisory follow:
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..
Aotion-speoifio Ground Water Remediation ARARs:
Resource Conservation and Recovery Act (RCRA) require-
ments, 40 CPR 264.117(a) (1) post-closure and monitoring
requirements for 30 years or another period determined by
the Regional Administrator;
RCRA requirements, 40 CPR 264.190-198, tanks used in
hazardous waste treatment, storage and disposal
facilities for the Ground Water Treatment unit; and
""
RCRA requirements, 40 CPR 264.190-192, 40 CPR 264.601
treatment of hazardous waste in the Ground Water
Treatment Unit.
Looation-speoific Ground Water Remediation ARARs:
RCRA requirements, 40 CPR 264.18 for location of the
Ground Water Treatment Unit in the 100-year floodplain,
40 CPR 6, Appendix A.
To Be Considered:
Drinking Water Regulations and Heal th Advisories by
Office of Water, U. S. Environmental Protection Agency,
dated May 1993.
Cost Bffectiveness:
The remedial action satisfies the threshold criteria set forth
in 40 CPR !300.430(f)(I)(i) (A) and (B). The selected ground
water remedy is cost effective, its present worth value being
$320,000. The estimated cost of the selected remedy is less
than the cost associated wi th installation of addi tional
extraction and reinjection wells ($2.25 million) but is more
than the cost associated with no action.
utilization of Permanent Solutions and Alternative Treatment
Technologies (or Resource Reoovery Teohnologies) to the Maximum
Extent Praotioable:
~.
EPA has determined that the selected ground water remedy
represents the maximum extent to which permanent solution and
treatment technologies can be utilized in a cost-effective
manner for deep ground water remediation at the Site. Of
those alternatives that are protective of human health and the
environment and comply with ARARs, EPA determines that the
selected ground water remedy provides the best balance of
trade-offs in terms of reduction of mobility, toxicity or
volume achieved through treatment, short-term effectiveness,
implementability and costs and due to the statutory preference
for treatment as a principal element and considering state and
community acceptance.
: .
-------
The selected ground water remedy satisfies the long-term
effectiveness and permanence, reduction of toxicity, mobility,
or volume through treatment, and implementability criteria
better than all of the other alternatives investigated. The
remedy is more expensive than discharging the extracted ground
water on the ground or into a publicly owned water treatment
works. The short-term risks associated wi th the selected
ground water remedy are possible exposure of workers and the
community to the ground water treatment system; however, these
potential risks are easily controlled and, therefore, all but
eliminated.
Preterence tor Treatment a. a Principal Blementz
The ground water alternative uses treatment as the primary
remediation technology for the principal threat posed by the
contaminated water. Therefore, the statutory preference for
remedies that employ treatment as a principal element is
satisfied.
x. DOCUJlBftATIOB 01' BO 8IGBII'ICAJI'l' CBABGB8
The Proposed Plan for the site was released for public comment
on January 21, 1993. The Proposed Plan identified Alternative
1-8 (extraction of contaminated water from Monitoring Well-16,
treatment 0 this water in the Operable Uni t One water
treatment system and reinjection of the treated ground water)
as the preferred alternative. The name/of this alternative
has been changed from' Limi ted Action', as used in the SRI/FFS
and the Proposed Plan, to 'Extraction and Treatment' in this
ROD. EPA reviewed all written and oral comments submitted
during the public comment period and determines that no
significant changes to the remedy, as it was originally
identified in the Proposed Plan, were necessary.
'''"
".
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....~\
.'
APPENDIX B
THE STATE OF TEXAS, LETTER OF CONCURRENCE
..
-------
.'
. .
John Hall, ChaIrman
Pam Reed, CommissloDer
Pear Garner, Comm1ss1oner
,,~ ~ t .,.. t,.
...; ,'U:~ I r) h'i i2: i~D
",;:\ i F:::'~:"; Iij ;,:- :!.
TEXAS WATER COMMi~SIt)N;:j ;':"':~l;: /;C:'iT. CA',
I'JlOfrCf7NfJ 2IlAM' H6Al.77I NiD WEI7 .r l'J/tVlIf1IN(1 AND UDUClNt11OJ.UJ71ON
August 10, 1993
Allyn M. Davis, Ph.D., Director
Hazardous Waste Manaqement Division
u. S. Environmental Protection Aqency'
Reqion VI:
1445 Ross Avenue
Dallas, Texas 75202-2733
Texarkana Wood preservinq Company superfund site
Draft Record of Decision, Second Operable unit
Dear Dr. Davis:
Re:
The proposed Record of Decision (ROD) has been reviewed for the
referenced site. We concur on the ~emedy selection, as described
in the draft ROD of Auqust 1993. The selected remedy calls for
ground water in the Silty Sand Zone aquifer to be extracted at MW-
16 and treated with the ground water for the First Operable Unit.
We anticipate that state matchinq funds will be available to allow
our required assurance prior to a fund-financed r~edial action.
- . "__n . -. -sincerely; .
.. ... _..
ACG/STC/ls
f~
P.O. Box 13087 . 1700 North Congress Avenue. Austin, Texas 78711-3087 . 512/463-7830
.- -..---.---.-
&
. .
..
.
""
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.~. .. - .~_. -_. .. _~4 .--.-.-.. --. - - . .-.-
,,'
..
APPENDIX A
RESPONSIVENESS SUMMARY
-------
'1'BDRDD WOOD PRBSBRVZBG COKPUY SZ'1'B
RBSPOBSJ:VEBBSS SUHKARY
This Community Relations Responsiveness Summary has been prepared
to provide written responses to comments submitted regarding the
Proposed ,Plan at the Texarkana Wood Preserving Company Superfund
site. The summary is divided into two sections.
section I: Background of Communi tv Involvement and Concerns. This
section provides a brief history 'of community interest and concerns
raised during the remedial planning activities at the site.
Section II: Summarv of Maior Comments Received. The comments
(both oral and written) are summarized. EPA's responses are
provided.
II.
I.
Backaround of Communitv Involvement and Concerns
. The community of Texarkana is acutely aware of the problems
associated with this site. This awareness is evident by the
number of community environmental action groups and residents
in Texarkana expressing concerns that thermal destruction
during Operable Unit One remediation will cause adverse health
affects to those who live in the area. Similar concerns were
not expressed regarding the remedy for the deeper groundwater.
Summarv of Maior Comments Received
Public notice announcing 'the public comment period and
invitation to a public meeting was given on January 21, 1993,
in the Texarkana Gazette, a widely circulated local newspaper.
The Proposed Plan Summary was released to the general public
on January 21, 1993. The public comment period began on
January 21, 1993, and ended on March 24, 1993. A public
meeting was held on January 26, 1993, at the Texarkana
Regional Arts Center, 4th & Texas Boulevard, Texarkana, Texas.
The purpose of this meeting was to discuss the proposed
alternatives and the preferred alternative.
Approximately fifteen people were in attendance and four
people asked questions or made comments. One letter was
received with comments.
The comments and questions received during the public comment
period follow.
1.
Comment:
I agree with your choice of soil treatment and limited
water treatment. However, I would recommend careful
moni toring of the aquifer and reserving the option of
more aggressive pumping and air sparging later if the
residual risks appear to be excessive. Keep options
open.
'.
".
Response:
Residual contamination in the aquifers will be monitored
and more aggressive pump and treatment will be
implemented if warranted. However, treatment will be by
carbon adsorption; air sparging would release the
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2.
c'
3.
..
"
v'
Comment:
I feel like I have not had ample time to review this
study.
Response: .
The EPA extended the 30-day public comment period an
additional 30 days to provide ample time for the public
to review and comment on the proposed remedy.
Comment:
I do not see that anything is being done on the western
side of Lubbock street.
Response:
The contamination in the silty Sand Zone at Monitoring
Well-16 is west of Lubbock Street and that is where the
remediation of the silty Sand Zone will occur.
Additionally, remediation of the Gravel Zone will occur
on both the east and west sides of Lubbock Street.
Because no contaminants were found in the Lignite Zone,
no remediation will occur in that Zone.
4.
Comment:
At what level is the Lignite Zone?
Response:
The Lignite Zone is about 90 feet to 115 feet below the
surface at the site.
5.
Comment:
Was contamination found in any of the other wells?
Response:
No contaminants above action levels were found ~t any
other well in either the Lignite Zone or the silty Sand
Zone.
6.
Comment:
How many other wells are there in the Lignite and Silty
Sand Zones?
Response:
There are five other monitoring wells in addition to
Monitorinq Well-16.
7.
Comment:
If we could pump our product under 100 pounds pressure
for about 12 hours into the contaminated well, we could
kill the contaminants. There would be no reason to pump
those wells for 30 years.
Response:
The EPA Risk Reduction Laboratory in Cincinnati, Ohio has
been requested to investigate and test the benefits and
applicability of this product to Superfund remediation.
The time required for remediation of the Silty Sand Zone
water is expected to be no more than several months.
Monitoring of the remediated Zone will continue for 30
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9.
10.
11.
8.
Comment:
Have you tested for migration of contaminants from the
Site?
Response:
Yes, we have in the Gravel Zone, about 400 feet east
toward Days Creek. The contaminated ground water plume
has not reach Days Creek, as evidenced by the testing of
several monitoring wells located east of the Site but
west of Days Creek.
Comment:
You're not allowing us enough time to comment on your
recommended alternative.
....
Response:
EPA extended the 30-day public comment period an
additional 30 days in order to give the public time to
study the several alternatives and to comment on them.
Comment:
How much liability insurance
contractor required to have?
is
.construction
the
Response:
The contractor is required to have full comprehensive
public liability, contractual, property damage and
automobile insurance. In addition, the contractor is
required to have performance and payment bonds. A full
listing of all required insurance is contained in TWC's
bid and contract documents. (At the time of this
response, these requirements are detailed in Article 19,
Insurance, of the TWC bid specifications.)
Comment:
Who monitors the testing of the soil and water during the
remediation?
Response:
After TWC awards the remediation contract, the selected
contractor will prepare a Quality Assurance/ Quality
Control Plan for TWC's review and approval. This plan
will specify all sampling and handling procedures and
analyses required. During the remediation of the
contaminated soil, TWC's contractor will take soil
samples and have them analyzed by a laboratory approved
by the TWC. TWC's oversight engineer will specify where
the samples are to be taken and will split samples with
the contractor. TWC will have some of these split
samples analyzed at a different approved laboratory. To
determine the reliability of the contractor's selected
laboratory, the resul ts from the two different
laboratories will be compared. After the completion of
the soil remediation and after the water treatment
facilities are constructed, both the TWC and the
construction contractor will collect and analyze water
samples to determine that the treatment system operates
properly before the contractor is released from
obligations concerning the Site. Thereafter, during the
"
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12.
13.
14.
15.
< '
v'
remediation of the ground water, TWC may contract with a
certified laboratory to collect and analyze the water
samples or TWC may collect the water samples themselves
and have them analyzed by an approved laboratory.
Comment:
How about using evaporation to remove the contaminants
from the ground water?
Response:
Evaporation was not one of the alternatives considered
during the Operable unit One investigation. There are
16,000,000 gallons of contaminated water in the Gravel
Zone. The cost to evaporate this much water would be
considerably more than treating the water by carbon
adsorption. Also, several of the contaminants are
volatile and would evaporate with the water1 thus, they
would not be treated but rather would be released to the
atmosphere. For Operable unit Two, it is far less
expensive to use the same water treatment unit already
supplied for Operable unit One than to bring another unit
onto the site.
Comment:
since the TWC has to pay for 10 percent of the cost, how
much input does TWC have in selecting the remedy?
Response:
The decision is made by EPA, not TWC. We requested their
comments; . they were the lead agency for developing the
alternatives which were considered for remediation. They
do have the same right to comment on all the al ternati ves
and the proposed remedy just as each citizen does.
Comment:
Is there a geologist present at this meeting?
Response:
Yes. The TWC has a geologist present.
Comment:
In the index to the Administrative ~ecord, the printed
index, the page numbers do not match with the microfiche
numbers. You use subcontractors for incinerators and
remedial investigations and feasibility studies and I
don't believe you're any more competent to oversee the
work of those subcontractors as you are to oversee the
work of a simple microfiche worker.
Response:
The Agency places much emphasis on sound contract
management. Because the Agency has limi ted Communi ty
Relations staff, subcontractors are utilized to address
extensive community Relations work. For this project, a
subcontractor, at EPA's direction, places copies of Site
reports and documents in the information repositories.
To save space, much of this information is provided on
microfiche. Based on our investiqation, part of
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16.
17.
18.
19.
placed in the files of other Superfund projects that use
the same repository. We are workinq with the public
library to correct this situation.
Comment:
When will you be coming back with the final decision?
Response:
TWC and EPA
information
finalized.
will release to the press for distribution
as future plans for this project are
Comment:
will the citizens of Texarkana be notified of all of the
eligible contractors?
Response:
The TWC will review the qualifications of all contractors
interested in bidding for the remediation of this Site
and select only those found to be qualified to submit
bids for the remediation work. Bids will be received and
opened and read aloud by the TWC in Austin, Texas at a
meeting open to all. TWC will then review the bids and
select the lowest bidder that is both responsive and
responsible.
Comment:
In other words, the public will not know who the
successful bidder is until after the award has been made.
Response:
Correct. However, by attendinq the bid opening meetinq,
anyone can learn the amount of each contractor's bid and
determine which contractor has the lowest bid. However,
the announcement of the selected bidder is made at a
later meetinq and is announced to all at the same time.
This is consistent with standard procurement procedures
on public projects using the sealed bid process.
Comment:
will the public have an input on blocking some of the
possible bidders from gettinq the contract?
Response:
By federal and state procurement procedures, the public
can not block any bidder from getting the contract.
However, both the TWC and EPA will review the financial
and technical qualifications of the bidders. Also, the
contract will not be awarded to any firm that is on a
current list of debarred or suspended bidders or is in
tax arrears to the State of Texas.
"
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- - .. -. .. -.- ~. -- .. --. - -- - -. . - - -- -. . -. .
'"
APPENDIX C
ADMINISTRATIVE RECORD INDEX
-------
SITH NAB:
SITH Nt1MBBR:
DOCCMBN'l' NUMBER:
DOCmmN'1' DATB:
NCMBER 01' PAGES:
AD'l'HOR:
COMPANY /AGrmc:'i :
RECIPIENT:
DOCCMBN'l' TYPE:
DOCtJHBN'l' TITLE:
DOCtIMBNT NUMBER:
DOCCMBN'l' DATS:
NCMBER 01' PAGES:
AD'l'HOR:
COMPANY /AGEBCY:
RECIPIEm':
DOCtJMBNT TYPE:
DOCUMBNT TITLE:
DOCDMBNT mnmER:
DOCtJMBNT DATB:
NUMBER 01' PAGES:
AD'l'HOR:
COMPANY /AGBNCY:
RECIPIENT:
DOCUHBNT TYPE:
DOCtJMBNT 'l'ITLB:
DOCtJHBN'l' mnmER:
DOCUHBNT DATB:
NtDmER 01' PAGES:
AD'l'HOR:
COMPANY/AGENCY :
RECIPIEm':
DOCCMBNT TYPE:
DOCtJHBN'l' TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
TBXARKANA WOOD PRESERVING SITH
TXD 008056152
000001 - 000002
02/28/91
002
Scott Crouch, Project Manager
Texas Water Canmission ("TWC")
U.S. EPA Region 6 Site Piles
Monthly Progress Report
"Pederal Superfund Monthly Progress Report"
sUllllDarizing work completed at the site
000003 - 000004
03/30/91
002
Scott Crouch, Project Manager
TWC
U.S. EPA Region 6 Site Piles
MOnthly Progress Report
"Pederal Superfund Monthly Progress Report"
summarizing work completed at the site
000005 - 000005
04/30/91
001
Scott Crouch, Project Manager
TWC
U.S. EPA Region 6 Site Piles
Monthly Progress Report .
"Pederal Superfund Monthly Progress bport n
summarizing work completed at the site
000006 - 000008
09/30/91
003
Scott Crouch, Project Manager
TWC
U.S. BPA Region 6 Site Piles
MOnthly Progress Report
"Federal Superfund Monthly Progress Report"
summarizing work completed at the site
A-1
for February 1991
for March 1991
for April 1991
"
",
-------
,..
SITE NAME:
SITE N'CMBER:
-r
"
DOCtJMBNT N'CMBER:
DOCCMBNT DATE:
N'CMBER OP PAGES:
AO'l'HOR:
COMPANY/AGENCY:
RECIPIENT:
DOCCMBNT TYPE:
DOCCMBNT.TITLE:
DOCCMBNT N'CMBER:
DOCCMBNT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY :
RECIPIENT:
DOCCMEN'l' TYPE:
DOCUMENT TITLE:
DOCDMBNT NDHBER:
DOCCMBNT DATE:
N'CMBER OP PAGBS:
ADTHOR:
COKPANY /AGENCY:
RECIPIENT:
DOCDMBNT TYPE:
DOCUMEN'l' TITLE:
...
DOCCMBNT NUMBBR:
DOCCMBNT DATE:
NUMBBR OP PAGES:
ADTHOR:
COMPANY/AGBNCY:
RECIPIENT:
DOCCMBNT TYPB:
DOcmmNT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDCH
TBXARKANA WOOD PRESBRVING SITE
'l'XD 008056152
000009 - 000010
10/30/91
002
Scott Crouch, Project Manager
TWC
U.S. EPA Region 6 Site Piles
MOnthly Progress Report
"Pederal Superfund MOnthly Progress Report"
summarizing work completed at the site
for October 1991
000011 - 000011
10/30/91
001
Bryon Heineman, Remedial Project Manager ("RPM")
u.S. EPA Region 6
U.S. BPA Region 6 Site Piles
Status Summary
MOnthly site status summary of work completed in October 1991
(The November 1991 date listed in the heading is incorrect.)
000012 - 0000~2
10/30/91 .
001
Bryon Heineman, RPM
U.S. EPA Region 6
U.S. EPA Region 6 Site
Status Summary
Site status BUIIIII&%'Y of
planned in Py 1992
Piles
work completed. in Py 1991 and of work
000013 - 000014
11/30/91
002
Scott Crouch, Project Manager
U.S. EPA Region 6
U.S. BPA Region 6 Site Piles
MOnthly Progress Report
"Pederal Superfund MOnthly Progress Report"
summarizing work completed at the site
for November 1991
-------
SITE mum:
SITH NUMBER:
DOC:O!1BN'1' NUMBER:
DocmmNT DATH:
NUMBER OF PAGES:
AUTHOR:
COMPANY /AGDCY:
RBCIPIBln':
DOCmmNT TYPE:
DOC:mmNT TITLE:
DOCtJMBN'l' NUMBER:
DOCtJMBN'l' DATE:
NUMBER OF PAGES:
ADTHOR:
COMPANY /NJBBCY:
RBCIPIBln':
DOCmIBNT TYPE:
DOCmIBNT TITLE:
DOC:mmNT NmlBER:
DOCmmNT DATH:
NmlBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RBCIPIBN'l':
DocmmNT TYPE:
DOCCHBNT TITLB:
DocmmNT NmlBBR:
DOCmIBNT DATH:
NUMBER OF PAGES:
AUTHOR:
COMPANY /NJBBCY:
RBCIPIENT:
DOCmmNT TYPE:
DOCUMBNT TITLE:
ADlaNISTRATIVB RBCORD INDEX
ADDBNDtIH
TBXARKANA WOOD PRBSERVING SITE
TXD 008056152
000015 - 000015
11/30/91
001
Bryon Heineman, RPH
U.s. SPA Regian 6
U.S. SPA Regian 6 Site Files
Status Summary
Monthly site status summary of work completed
(The December 1991 date listed in the beading
in November 1991
is incorrect.)
000016 - 000017
12/30/91
002
Scott CrouCh, Project Manager
TWC
U.S. SPA Region 6 Site Files
Monthly Progress Report
"Federal Superfund Monthly Progress Report"
summarizing the work completed at the site
for December 1991
000018 - 000018
12/30/91
001
Bryon Heineman, RPH
U. S . SPA Regian 6
U.S. BPA Regian 6 Site Files
Status Summary
MOnthly site status summary of work completed in December 1991
000019 - 000020
01/30/92
002
Scott Crouch, Project Manager
TWC
U.S. SPA Region 6 Site Files
MOnthly Progress Report
"Federal Superfund Montly Progress Report"
summarizing work complet,d at the site
o
'\.
for January 1992
-------
..
SITE NAME:
SITE NUMBBR:
l'
;p
DOcmmNT NUMBBR:
DOcmmNT DATE:
NUMBBR OF PAGBS:
AUTHOR:
COMPANY /AGBNCY:
RBCIPIBNT:
DOCCMBNT TYPB:
DOcmmNT TITLE:
DOCCMBNT NUMBBR:
OOcmmNT DATE:
NUMBBR OF PAGBS:
AUTHOR:
COMPANY /AGBNCY:
RECIPIBNT:
DOCUMBN'I' TYPE:
DOcmmNT TITLE:
DOCCMBN'I' NUMBBR:
DOCDMBNT DATE:
NUMBBR OF PAGBS:
ADTHOR:
COMPANY /AGENCY:
RBCIP:IBNT:
DOCm1Bln' TYPB:
DOCmmNT TITLE:
~-I '
."
DOCm1Bln' NCMBBR:
DOcmmN'I' DATE:
NCMBBR OF PAGBS:
At11'HOR:
COMPANY /AGENCY:
RBCIP:IBNT:
DOCm1Bln' TYPE:
DOCtJHBNT TITLE:
.. ..'" 1
ADMINISTRATIVE RECORD INDEX
ADDENDUM
TEXARKANA WOOD PRESBRVING SITE
TXD 008056152
000021 - 000021
01/30/92
001
Earl Hendrick, RPM
U.S. BPA Region 6
U.S. BPA Region 6 Site Files
Status Summary
Monthly site status summary of
work completed in January 1992
000022 - 000023
02/28/92
002
Scott Crouch, Project MAnager
TWC
U.S. BPA Region 6 Site Files
Monthly Progress Report
"Federal Superfund Monthly Progress Report"
summarizing the work completed at the site
for February 1992
000024 - 000024
02/28/92
001
Barl Hendrick, RPM
U.S. BPA Region 6
U.S. BPA Region 6 Site Files
Status Summary
Monthly site status SUIIID8.rY of work caapleted in Pebruary 1992
000025 - 000026
03/30/92
002
Scott Crouch, Project Manager
'l'WC
U.S. BPA Region 6 Site Files
Monthly Progress Report
"Federal Superfund Monthly Progress Report"
summarizing work completed at the site
for !!arch 1992
-------
SITE NAMB:
SITB NUMBBR:
DOCDMBN'1' mnmBR:
DOCtJMBNT DATE:
NUMBBR OF PAGBS:
AD'I'HOR:
COMPANY /AGDCY:
RBCIPIENT:
I)()Ct]MBNT TYPB:
DOC'DMBN'l' TITLE:
DOCtJMBN'l' NmmBR:
DOCCMBlfl' DATB:
NUMBER OF PAGBS:
AD'I'HOR:
COMPANY /AGDCY:
RBCIPIENT:
DOCCMBNl' TYPB:
DOCUMBN'l' TI'l'LB:
DOCUMBN'l' NmmBR:
DOCOMBN'l' DATE:
NUMBBR OF PAGBS:
AD'I'HOR:
COMPANY/AGENCY:
RBCIPIENT:
DOCCltmNT TYPB:
DOCDMBm' TI'l'LB:
DOCUMBN'l' NmmBR:
DOCtIMBNT DATE:
NUMBBR OF PAGBS:
AD'I'HOR:
COMPANY/AGBNCY:
RBCIPIENT:
DOCtJMBNT TYPB:
DOCUMBN'l' TI'I'LB:
..
ADMINIS'l'RATIVB RBCORD INDBX
ADDBNDUH
'I'BXARXANA WOOD PRBSBRVJ:NG SI'1'B
'l'XD 008056152
000027 - 000027
03/30/92
001
Barl Hendrick, R.PH
U.S. BPA Region 6
U.S. BPA Region 6 Site Files
Status Summary
Monthly site status summary of work completed
in March 1992
000028 - 000031
04/09/92
004
TWC Staff
'!'WC
U.S. BPA Region 6 Site Files
Superfund Fact Sheet
Fact Sheet for MarCh i992 summarizing site
activities
000032 - 000057
04/13/92
026
Donald R. Ripley, P.B., Project Director
Roy F. Weston, :Inc.
Scott CrouCh, Project Manager, Superfund Investigation
Section, Pollution Cleanup Division, TWC
Cover Letter and Attachment
Groundwater sample data for semi volatiles and dioxins/furans
000058 - 000059
04/30/92
002
Scott CrouCh, Project Manager
'!'WC
U.S. BPA Region 6 Site Files
Monthly Progress Report
nFederal Superfund MOnthly Progress Reportn'for ~ril 1992
summarizing the work completed at the site
"
-------
,
o
SITE NAMB:
SITE NUMBER:
1"
:;
DOCDMBNT NUMBER:
DOCtJMBNT DATE:
NUMBER OF PAGES:
AD'1'HOR:
COMPANY /AGBNcr:
RECIPIENT:
DOCDMBNT TYPE:
DOcmmNT TITLE:
DOCDMBNT NUMBER:
DOCtJMBNT DATE:
NUMBER OF PAGES:
AD'1'HOR:
COMPANY /AGBNcr:
RECIPIENT:
DOCDMBNT TYPE:
DOCUMBNT TITLE:
DOCDMBNT NUMBER:
DOCDMBNT DATE:
NUMBER OF PAGES:
AD'1'HOR:
COMPANY /AGBNcr:
RECIPIENT:
DOCtJMBNT TYPE:
DOCtJMBNT TITLE:
,.?
DOCDMBNT NUMBER:
DOCtJMBNT DATE:
NUMBER OF PAGES:
AD'1'HOR:
COMPANY/AGENcr:
RECIPIENT:
DOCOMBNT TYPE:
DOCtJMBNT TITLE:
ADMJ:NJ:STRATIVB RECORD INDEX
ADDENDUM
TBXARKANA WOOD PRESERVING SITE
TXD 008056152
000060 - 000060
04/30/92
001
Earl Hendrick, RPK
U.S. EPA Region 6 .
U.S. EPA Region 6 Site Files
Status Summary
Monthly site status summary of work completed in April 1992
000061 - 000116
05/18/92
056
Staff Consultants
Roy P. Weston, Inc.
U.S. EPA Region 6 Site Piles
Project Plan
"Supplemental Remedial Investigation Quality Assurance Project
Plan"
000117 - 000120
OS/20/92
004
Cliff MCIntyre, Bowie County Environmental Officer
Bowie County, 'l'X
Bryon Heineman, RPH, U.S. BPA Region 6
Cover Letter and Attachment
Attached letter addressed to Hr. Owen Douglas (Roy P. Weston,
IDc.) regarding site operations obserVed by Hr. Cliff McIntyre
on Jfay 12, 1992
000121 - 000129
OS/29/92
009
Donald R. Ripley, P . E ., proj ect Director
Roy P. Weston, IDc.
Gary KcGill, TWC
Cover Letter and Attachment
Attached letter frail Roy P. Weston, IDe. addresses concerns
raised by Mr. Cliff MCIntyre (Bowie Co. Environmental Officer)
about site conditions observed on Jfay 12, 1992
-------
SITE NAMB:
SITH NCDBR:
DOCUMBNT NCMBBR:
DOCtDmN'l' DATE:
NCHBBR OF PAGBS:
ADTHOR:
COKPANY /AGDCY:
RBCIPIBN'l':
DOCDMBNT TYPB:
DOCtJ'MBNT TITLB:
DOCCHBN'l' NCMBBR:
DOCtJ'MBNT DATE:
NCHBBR OF PAGBS:
ADTHOR:
COMPANY /AGBRCY:
RBCIPIBNT:
.DOCmIBNT TYPB:
DOC'DMBN'l' TI'l'LB:
DOCm1BR'l' NCMBBR:
DOCmIBNT DATE:
NCMBBR OF PAGBS:
ADTHOR:
COKPANY /AGENCY:
RECIPIBNT:
DOCmIBNT TYPB:
DOCm1BN'1' TITLB:
DOCCHBNT NCDBR:
DOCtJHBN'1' DA'l'B:
NCHBBR OF PAGBS:
ADTHOR:
COMPANY/AGENCY :
RBCIPIBNT:
DOCtJHBNT TYPB:
DOCCMBNT TI'l'LB:
ADMINISTRATIVE RECORD INDEX
ADDBNDUM
'l'BXARXANA WOOD PRESBRVING SI'l'B
'l'XD 008056152
000130 - 000132
05/30/92
003
Scott Crouch, Project Manager
'l'WC
U.S. BPA Region 6 Site Files
Monthly Progress Report
"Federal Superfund Monthly Progress Report"
summarizing work c~leted at the site
000133 - 000134
06/30/92
002
Scott Crouch, Project Manager
'l'WC
U.S. BPA Region 6 Site Files
Monthly Progress Report
"Federal Superfund Monthly Progress Report"
summarizing work completed at the site
,
..>
for May 1992
for June 1992
000135 - 000135
06/30/92
001
Barl Hendrick, RPH
.U. S. SPA Region 6
U.S. BPA Region 6 Site Files
Statu8 Summary .
Monthly status SUIIIIII&%y of work CClDpleted in June 1992
000136 - 000136
07/30/92
001
Scott Crouch, Project Manager
'l'WC
U.S. BPA Region 6 Site Files
Monthly Progress Report
"Federal Superfund Monthly Progress Report"
summarizing work completed at the site (The
this document is missing.)
A-7
for July 1992
-------
,
o
SITE mum:
SITE NCMBBR:
9
DOCCMBNT NmmER:
DOCCMBNT DATE:
NCHBBR OF PAGES:
ADTHOR:
COMPANY /AGBNc:'l:
RECIPIENT:
Doc:mmNT TYPB:
DOCCMBNT TITLE:
DOCCMBNT NCHBBR:
Doc:mmNT DATE:
NCHBBR OF PAGBS:
ADTHOR:
COMPANY /AGBNc:'l:
RECIPIENT:
DOCDMBNT TYPE:
DOCtJHBNT TITLE:
DOCCMBNT NmmER:
DOcmmNT DATE:
RCMBER OF PAGES:
ADTHOR:
COMPANY /AGBNc:'l:
RECIPIBNT:
DOCCMBNT TYPB:
DocmmNT TITLE:
DOCmIBNT NCMBER:
DocmmNT DATE:
RCMBER OF PAGES:
ADTHOR:
.;;
COMPANY /AGENc:'l:
RECIPIENT:
DocmmNT TYPB:
DOCtJMEN'l' TITLE:
--.-...---.--- ------- . ._-_.
ADKIRISTRATIVB RECORD INDEX
ADDENDUM
TBXARKANA WOOD PRESBRVING SITE
TXD 008056152
000137 - 000137
07/30/92
001
Barl Hendrick, RPM
u.s. BPA Region 6
U.S. EPA Region 6 Site Files
Status Summary
Monthly site status summary of work completed in July 1992
000138 - 000139
08/30/92
002
Scott Crouch, Project Manager
TWC
U.S. BPA Region 6 Site Files
Monthly Progress Report
"Federal Superfund Monthly Progress Report"
summarizing work completed at the site
for August 1992
000140 - 000140
08/30/92
001
Barl Hendrick, RPM
U.S. BPA Region 6
U.S. BPA Region 6 Site Files
Status. Summary
Monthly site status 8UIIIIiIary of work completed in August 1992
000141 - 000143
09/10/92
003
Scott T. Crouch, Project Manager, Superfund Investigation
Section, Pollution Cleanup Division
TWC
Donald R. Ripley, Project Director, P.B., Roy F. Weston, Inc.
Cover Letter and Attacl1ment
COIIIIIIents on the first three (3) sections of the "Supplemental
Remedial Investigation and Focused Feasibility Study Report"
-------
.
SITE NAMB:
SITE mDlBBR:
DOCtJMImT RtIMBBR:
DOCmmNT DATE:
NCMBBR OF PAGBS:
AD'l'HOR:
COMPANY /AGB1flC:r:
RBCIPIBm':
DOCCImR'l' TrPB:
DOCtJMB1n' '1'ITLB:
DOCtD!BN'l' RmmBR:
DOCCMBN'l' DA'1'B:
NCMBBR OF PAGBS:
AD'l'HOR:
COMPANY /AGB1flC:r:
RECIPIBm':
DOCCMBN'l' TrPB:
DOCtD!BN'l' '1'ITLB:
DOCtDmN'1' RmmBR:
DOCtDmN'1' DA'1'B:
NCMBBR OF PAGBS:
AD'l'HOR:
COMPANY /AGB1flC:r:
RBCIPIBN'1':
DOCtDmN'1' TrPB:
DOCtJHBN'l' 'l'ITLB:
DOCtD!BN'l' . ROMBBR:
DOCCMBNT DA'1'B:
NUMBBR OF PAGBS:
AD'l'HOR:
COMPANY/MINCY :
RECIPIBm':
DOCCMBN'1' '1'YPB:
DOCCMBN'l' TI'l'LB:
,
ADMINISTRATIVE RBCORD INDEX
ADDBNDtJM
TKXARKARA WOOD PRBSBRVING SITE
TXD 008056152
000144 - 000145
09/30/92
002
Scott Crouch, Project Manager
'l'WC
U.S. BPA Region 6 Site Piles
Konthly Progress Report
"Federal Superfund Konthly Progress Report II
summarizing work completed at the site
'I
for September 1992
000146 - 000146
10/30/92
001
Barl Hendrick, RPH
U.S. BPA Region 6
U.S. BPA Region 6 Site piles
Status Summary
Konthly site status sUDllllary of work
completed in October 1992
000147 - 000152
11/05/92
006
Barl Hendrick, RPH
U.S. BPA Region 6
Scott Crouch, Project Manager, Superfund Investigation
Section, Pollution Cleanup Division, TWC
Hemoranc!um and Attachment
SPA camnent on "SUpplemental Remedial' Investigation and
Focused Feasibility Study Draft Report"
000153 - 000153
11/30/92
001
Barl Hendrick, RPH
U.S. BPA Region 6
U.S. BPA Region 6 Site Files
Status Summary
Konthly site status s1JDlllaX'y of work
\-->
completed in November 1992
-------
..
o
SITS NAMB:
SITS NUMBER:
DOC'CMBNl' NCMBSR:
DOCCMBln' DATE:
RCldBBR OF PAGSS:
ADTHOR:
COMPANY/AGBNC'l :
RECIPIENT:
DOCDI«BNT TYPB:
DOCCMBln' TITLE:
ADHINISTRATIVB RECORD INDEX
ADDDDOM
TBXARKANA WOOD PRESERVING SITE
TXD 008056152
000154 - 000456
12/30/92
303
Staff Consultants
Roy F. Weston, Inc.
U.S. SPA Region 6 Site Files
..Draft Report..
"Supplemental Remedial Investigation and Focused Peasibility
Study Report n (This entry is a sample of actual entry to be
placed in index when this report is final.)
-------
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