PB96-963102
                              EPA/ESD/R06-96/097
                              June 1996
EPA  Superfund
       Explanation of Significant Difference
       for the Record of Decision:
       Bailey Waste Disposal,
       Bridge City, TX
       2/8/1996

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EPA   Superfund
       Explanation of Significant
       Differences for the
       Record of Decision:
       Bailey Waste Disposal Superfund Site
       Orange County, Texas
       02/08/96

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                 EXPLANATION OF SIGNIFICANT DIFFERENCE
I.     INTRODUCTION
Site Name and Location:

Bailey Waste Disposal Superfund Site
Orange County, Texas
Lead and Support Agencies:

U.S. Environmental Protection Agency (EPA) - Lead Agency
Texas Natural Resource Conservation Commission (TNRCC) -- Support Agency
Statute that required Explanation of Significant Difference (ESD):

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA),
Section 117(c) and National Oil and Hazardous Substances Contingency Plan (NCP),
Section 300.435{c)(2)(i).
Purpose of ESD

      The purpose of an ESD is to describe changes in the remedial action due to
unforeseen conditions encountered at the site during implementation of the Record of
Decision (ROD).  Changes found in the conditions at the Bailey Waste Disposal site
require the EPA to modify the remedial action described in the June 28, 1988, ROD.
As discussed in the ROD, affected marsh sediments (North Marsh Waste) were to be
relocated to the site's Waste Channel Area, stabilized and capped. The North Marsh
Waste constitutes approximately four percent (6,000 cubic yards) of the estimated total
site waste volume of 156,000 cubic yards and is distinct from the rest of the site waste
because of its location  in a marsh.  The purpose of this ESD is to inform the public
that the-North Marsh Waste will be taken offsite for disposal in a Class 1 industrial
waste landfill.  Circumstances that gave rise to the need for this ESD include:

•     the opportunity to expedite the North Marsh Waste remedy component by
      taking this waste offsite for disposal during  this current winter construction
      season;

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       remediation activities within the Waste Channel Area, which was to have
       received the marsh affected sediments, are currently being reevaluated due to
       waste stabilization problems encountered at the she;

       expediting the excavation of the North Marsh Waste, which is the only site
       waste not contained within a levee, will remove this  waste from direct contact
       with the marsh surface waters; and

       an estimated $900,000 in costs savings when compared to previous
       construction bids for the North Marsh Waste remedy component.
Administrative Record:

      This ESD will become part of the Administrative Record of the Bailey Waste
Disposal Super-fund site.  The administrative record is available to the public for review
during regular business hours at the following locations:

          U.S. Environmental                    Nederiand Public Library
      Protection Agency, Region 6                      1903 Atlanta
           12th Floor Library                     Nederiand, Texas 77627
          1445 Ross Avenue                           (409)722-1255
       Dallas, Texas 75202-2733
    (214)665-6427 or (214)665-6424

II.    SUMMARY OF SFTE HISTORY, CONTAMINATION PROBLEMS, AND
      SELECTED REMEDY

      The Bailey Waste Disposal Superfund site is an inactive waste disposal site
located approximately three miles southwest of Bridge City in Orange County, Texas.
The site was  part of a tidal marsh near the confluence of the  Neches River and
Sabine Lake.  Two ponds, A and B, were constructed on the  property as part of the
Bailey Fish Camp in the early 1950's by dredging the marsh and piling the sediments
to form levees which  surround the ponds (see Figure 1). The fish camp was active
until September 1961, when it was destroyed by Hurricane Carla which introduced
saline waters  into the ponds, killing  the freshwater fish.  The site, including the two
rectangular ponds, occupies approximately 280 acres.

      Industrial waste (e.g., sludge from local petrochemical  industries) was disposed
of within the levees along the north and east margins of Pond A during the  1950s and
1960s. This waste contains a wide variety of volatile organic compounds, aromatic
hydrocarbons (i.e., ethylbenzene, styrene, benzene), and heavy metals (i.e., lead,
arsenic, chromium, zinc).  The site was also used to dispose  of residential trash.  The
Bailey Waste Disposal site was closed in 1971.

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                              FIGURE 1

                            VICINITY MAP
                   BAILEY WASTE DISPOSAL SFTE
                      ORANGE COUNTY, TEXAS

f- U;  -C^-v - * *- ^-.^-JL:
•^n-rC"-»-'^"v-.J!*T?*"-?' •
              TOM • uaurtHM* u »as OUMOMMU •**»
    
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      In October 1984, the site was proposed for the National Priorities List (NPL) of
Federal Superfund sites.  The site was placed on the NPL in 1986. A remedial
investigation was completed for the site in October 1987, and a feasibility study was
completed in April 1988.  On June 28, 1988, the site's Record of Decision was signed.
The remedial action requirements are discussed below.

Remedy Set Forth in the Record of Decision

      The overall site remedy, as originally described in the ROD, addressed the
environmental threat at the site by consolidating, stabilizing and capping all site waste
to prevent human contact and future migration. The specific ROD remedy component
pertaining to the affected marsh sediments called for relocation of the affected
sediments from the marsh to the Waste Channel, followed by stabilization  and capping
of the Waste Channel.

III.    DESCRIPTION OF THE SIGNIFICANT DIFFERENCES AND THE BASIS FOR
      THOSE DIFFERENCES

      This ESD changes one component of the original remedy-  The affected
sediments from the site's North Marsh Waste Area {marsh waste - tarry waste and
underlying-affected sediments) will be taken offsite for disposal in a Class  1 industrial
waste landfill rather than being relocated, stabilized and capped onsite.  By taking the
marsh waste offsite to a landfill, excavation of the marsh waste can take place during
this current winter construction season when the waste handling properties are optimal
(due to lower ambient air temperatures, waste is less viscous and less volatile).  The
excavation of the marsh waste, which is the only site waste not contained  within a
levee, will remove this waste from direct contact with the marsh surface waters.

      Onsite disposal of the marsh waste would require making improvements to Pit
A (located adjacent to the Waste Channel)  prior to placement of marsh waste into Pit
A. These improvements would require significant lead time and would postpone the
North Marsh Area waste excavation activities until at least the 1996/1997 winter
construction season.  Remediation activities within the Waste Channel Area, which
were to have received the marsh affected sediments, are currently being reevaiuated
due to waste stabilization problems encountered at the site.

      In addition to being more timely, implementation of this ESD will result in
approximately  $900,000 in cost-savings.  These projected savings are based on a
review of original construction bids for making improvements to Pit A, placement of
waste into the pit, and capping the pit (estimated specific costs of $1,400,000) versus
the estimated transportation  costs and disposal fees of $500,000 for taking the marsh
waste to a offsite landfill. Additional savings will be found in not having to perform
specific long-term maintenance activities associated with keeping the marsh waste
onsite  (See Table 1 for comparison of the original remedy versus offsite disposal).

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                                  TABLE 1
            SIGNIFICANT DIFFERENCES - NORTH MARSH WASTE
          ORIGINAL REMEDY
         OFFSITE DISPOSAL
Description:
0     Consolidate waste on site,
      stabilize and cap.
Description:
0     Offsite disposal of North Marsh
      Area waste in a Class 1 industrial
      waste landfill.
Economic Considerations:
Both alternatives contain certain common elements that are considered baseline
costs.  These include excavation and handling of waste.
Specific Costs Items:
0     Improvements to receiving cell.

0     Placement of materials in
      receiving cell (Pit A).

0     Capping of receiving cell.

Estimated specific costs = $1,400,000.*
Specific Costs Items:
0     Transportation of waste material
      to Class 1 industrial waste landfill.

0     Disposal fees.
Estimated specific costs = $500,000."
Other Considerations:
      North Marsh waste would remain
      onsite and would require long-
      term maintenance.

      Unlikely that work could be
   •   completed during  1995/1996
      winter construction season,
      thereby causing the waste to
      remain in the North  Marsh until
      the 1996/1997 winter construction
      season.
Other Considerations:
0     North Marsh waste removed from
      site, therefore  no long-term
      maintenance requirements and
      costs specifically for the North
      Marsh waste.

0     Could be completed within the
      next few months.
 Based on review ot construction DIGS for this work.

 Based on the following assumptions:
 •   6,000 cubic yards of material;
 •   10 percent increase when stabilized;
 •   predisposal stabilization of the excavated material will occur onsite (cost
     savings will be realized if all or part of the excavated material does not require
     predisposal stabilization; and
 •   potential cost savings  may be realized if the predisposal stabilization occurs at
     the  disposal facility.

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       All current applicable federal and state regulations will be met for the transport
 of the marsh waste to the receiving Class 1 industrial waste landfill. In accordance
 with EPA's Offsite Policy (40 C.F.R. Section 300.440), and specifically with regards to
 the receiving landfill (Browning Ferris Industries Anahuac Landfill), the TNRCC in an
 October 27, 1995, Current Assessment of Compliance Summary stated:

 •     in general, the facility appears to be operating within the limitations  set in its
       permit;

 •     Compliance Evaluation Inspections performed in the last five years at the
       subject facility noted no alleged violations;

 •     there have not been any spills reported at the subject facility in the last five
       years;

 •     no enforcement action  is pending; and

 •     no prior enforcement action has occurred in the last five years for this facility.

       The EPA has determined that the Resource Conservation and Recovery Act
 (RCRA) land disposal restrictions are not applicable for the offsite disposal of the
 North Marsh Area waste.  EPA's rationale supporting this determination are described
 in an October 31, 1995,  EPA memorandum.  Specifically, the following were discussed
 in the memorandum:

 •     Based on currently available information, the site's North Marsh Area waste is
       not a RCRA listed waste as defined  in Subpart D of 40 C.F.R. Section 261; and

 •     Based on information provided in the Technical Memorandum  Supplemental
       North Marsh Area Site  Investigation and Evaluation of Original Remedy
       (GeoSyntec Consultants, October 1995), the site's North Marsh Area waste
       does not exhibit a hazardous characteristic as defined  in 40 C.F.R. Section 261
       (i.e., ignitabitity, corrosivity, reactivity, or toxicity).
IV.    SUPPORT AGENCY COMMENTS

      The Texas Natural Resource Conservation Commission found no objections to
the draft of this ESO and concurs with the proposal, as evidenced by the attached
letter dated December 15, 1995.

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V.    PUBLIC PARTICIPATION ACTIVITIES

      This ESD will become part of the Administrative Record for the Bailey Waste
Disposal Superfund site, will be made available to the public, but will not be distributed
for public comment.  For additional information regarding this ESD, please contact the
EPA Project Manager for the Bailey Waste Disposal Superfund site:

                                Chris Villarreal
                      U.S. Environmental Protection Agency
                         1445 Ross, Avenue (6SF-AT)
                          Dallas, Texas 75202-2733
                                (214) 665-6758
VI.    STATUTORY DETERMINATIONS

      Considering the new information developed during the remedial action and the
resulting changes from the selected remedy described in the ROD, the EPA believes
that the remedy remains protective of human health and the environment.  The
revised remedy utilizes permanent solutions to the maximum extent practicable for this
site and is cost-effective.  It complies with the NCP and other federal and state
requirements that are applicable or relevant and appropriate to this remedial action.
                                          FES OS 1996
                                          Date

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Barry R. Me Bee, Chairman                       /  -'&\ ;V- ~'-\
                                        i- •£-   >"• '.*
R. B. "Ralph" Marquez, Commissioner               \ — jt.,'.  >'.- •
John M. Baker, Commissioner                    \ :'S»^*"
Dan Pearsoa Executive Director                     "-•—

             TEXAS NATURAL RESOURCE  CONSERVATION COMMISSION
                           Protecting Texas by Reducing and Preventing Pollution

                                     December 15, 1995
   SENT VIA FAX & CERTIFIED MAIL -
   RETURN RECEIPT REQUESTED
   Mr. Chris Villarreal
   Remedial Project Manager                                                      ;  :
   Bailey Waste Disposal Superfund Site                                              "
   U.S. Environmental Protection Agency                                             •-
   Region 6, 6H-ET                                                                j
   1445 Ross Avenue                                     .                        - -     :
   Dallas, TX  75202-2733                                                     .    ::   \:

   Re:    Draft Explanation of Significant Differences                              :     jj
         Bailey Waste Disposal Superfund Site, Orange County, Texas

   Dear Chris:

   I am writing to provide Texas Natural Resource Conservation Commission (TNRCC) comments to
   the referenced draft document.

   The TNRCC finds no objections to the draft Explanation of Significant Differences and concurs with
   the proposal.  Please contact me with any questions you may have concerning these comments or
   any other issues at the Bailey site at (512) 239-2030.
  Sincerely,
  E.R. (Trey) Collins, ID
  Project Manager
  Superfund Engineering Section
  Pollution Cleanup Division

  TC/tc

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                 Prepared for

  United States Environmental Protection Agency

                  Region 6
      ADMINISTRATIVE RECORD INDEX
 BAILEY WASTE DISPOSAL SUPERFUND SITE
EXPLANATION OF SIGNIFICANT DIFFERENCES

          EPA ID No. TXD 980864649

                   ESS VI
        Work Assignment No. ESS06014
               Chris Villarreal
           Remedial Project Manager
              U.S. EPA Region 6
                 Prepared by

              DPRA Incorporated
           717 North Harwood Street
                 Suite 1300
              Dallas, TX 75201
                 P. 6114.0677
                March 7, 1996

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                                 INTRODUCTION
Section  113(j)0) of the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), 42  U.S.C. Section 9613(j)(l), provides  that judicial  review  of any  issues
concerning  the adequacy  of a response action shall be limited to the administrative record
compiled for the site. CERCLA, as amended by the Superfund Amendments and Reauthorization
Act (SARA), requires the  U.S. Environmental Protection Agency (EPA)  to compile documents
that form the basis for the selection of the remedial CERCLA and SARA response actions.
These supporting documents form  an "administrative record" (AR), which  the Agency must
provide  for public review.  The ARs are maintained at relevant EPA Regional Offices as well
as "at or near the facility at issue."

The following Administrative Record Index was compiled in accordance with OSWER Directive
Number 9833.3A-1, "Final Guidance on Administrative Records for Decisions on Selection of
CERCLA Response Actions" (December 3, 1990). Documents listed as bibliography sources in
response decision documents may not be listed in the AR Index. An index to the  "Compendium
of CERCLA Response Selection Guidance Documents"  is enclosed in the AR.  The AR Index
file is compiled as documents related to the response action are being generated.  All documents
that are  clearly relevant and nonprivileged are placed in the record file, entered into the  index,
and made available to the public as soon as possible. The documents included in the index are
predominantly arranged in chronological order.  EPA may send supplemental AR volumes and
indexes to the designated repository. These supplements should be placed with the initial record
file.

The AR Index helps  readers  locate and retrieve documents in the file. It also provides  an
overview of the response action history. The index includes the following information for each
document:

•     AR  Page No. - The sequential numbers stamped on  each page of the AR.  The six digit
      numbers  are located in the upper right comer of  each page.
      Document Date -  The date the document was  published and/or released.  "Undated"
      means no date was recorded.
      No.  of Pages - Total number of printed pages in the document, including attachments.
      Author - Name and title of the originator.
      Company/Agency - Originator's affiliation.
•     Recipient - Name, title, and affiliation of the recipient
•     Document Type -  General identification, e.g., correspondence, Remedial Investigation
      Report, Record of Decision, etc.
•     Document Title - Descriptive title or synopsis.

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                  ADMINISTRATIVE RECORD  INDEX
                              ESD
SITE NAME:
SITE NUMBER:
BAILEY WASTE DISPOSAL SITE
TXD 980864649
DOCUMENT NUMBER:
DOCUMENT DATE :
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000001  - 000027
12/21/90
027
Harding  Lawson Associates  (HLA)
Consultant for Bailey Site Settlors Committee  (BSSC)
BSSC
Work Plan
Work Plan for Sediment Bioassays and Benthic Community
Character!zat ion
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000028 - 000147
10/09/91
120
HLA
Consultant for BSSC
BSSC
Quality Assurance Project Plan  (QAPjP)
QAPjP
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000148 - 000457
01/03/92
310
HLA
Consultant for BSSC
BSSC
Sampling Plan
Final Sampling and Monitoring Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000458 - 000459
02/18/92
002
Community Relations Staff
U.S. EPA Region 6
Public
EPA Update
Superfund Site Update  - Remedial  Design near Completion

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                  ADMINISTRATIVE RECORD INDEX
                             ESD
SITE NAME:
SITE NUMBER:
BAILEY WASTE DISPOSAL SITE
TXD 980864649
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000460 - 000461
08/05/92
002
Community Relations Staff
U.S. EPA Region 6
Public
Fact Sheet
Superfund Site Fact Sheet
Selected
-  Remedial Action Contractor
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000462 - 000477
09/25/92
016
HLA
Consultant for BSSC
BSSC
Evaluation Plan
Final Waste/Oil Interface Evaluation Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000478 - 000541
11/11/92
064
HLA
Consultant for BSSC
BSSC
Report
Report on Sediment Bioassays and Benthic  Community
Characterizations
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
 000542 - 000546
12/17/92
005
Debra L. Baker, Counsel for BSSC
Mayor, Day, Caldwell  & Keeton,  L.L.P.
Sam Becker, Chief,  Superfund  Enforcement Branch, U.S. EPA
Region 6, et al.
Letter w/Enclosure
Information from  HLA  about materials in marsh area north of
Pond A

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                  ADMINISTRATIVE RECORD  INDEX
                              ESD
SITE NAME:
SITE NUMBER:

DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
BAILEY WASTE DISPOSAL SITE
TXD 980864649

 000547  -  000548
02/12/93
002
Community  Relations Staff
U.S. EPA Region 6
Public
Fact Sheet
Superfund  Site Fact Sheet
Underway
-  Remedial Action Field Activities
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:

COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000549  -  000550
02/23/93
002
Chris Villarreal, Remedial Project Manager  (RPM),  Superfund
Enforcement Branch
U.S. EPA Region 6
U-.S. EPA Region 6 Site File
Record of  Communication
Summary of meeting with BSSC representatives
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000551 - 000591
03/29/93
041
Unspecified
U.S. EPA Region 9
U.S. EPA Region 6 Site File
Bibliography Index
Index for Compendium of CERCLA Response Selection Guidance
Documents
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
 000592  -  000598
04/19/93
007
Debra L. Baker, Counsel for BSSC
Mayor, Day,  Caldwell  & Keeton, L.L.P.
Sam Becker,  Chief,  Superfund  Enforcement Branch, U.S. EPA
Region 6
Letter w/Enclosure
Confirmation of 04/12/93 meeting  between BSSC  representatives
and EPA.   Letter  requests modification of  water  structure
plans.

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                  ADMINISTRATIVE RECORD INDEX

                             ESD
SITE NAME:
SITE NUMBER:
BAILEY WASTE DISPOSAL SITE
TXD 980864649
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
 000599 - 000601
05/11/93
003
Debra L. Baker, Counsel for BSSC
Mayor, Day, Caldwell & Keeton, L.L.P.
Chris Villarreal, RPM, Superfund Enforcement Section, U.S. EPA
Region 6,  et al.
Letter
Notification of styrene-like material from the site on
05/11/93
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
 000602 - 000604
06/11/93
003
Debra L. Baker, Counsel for BSSC
Mayor, Day, Caldwell & Keeton, L.L.P.
Chris Villarreal, RPM, Superfund Enforcement Section, U.S. EPA
Region 6, et al.
Letter
Notification of styrene-like material from site on  06/11/93
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000605 - 000608
07/08/93
004
Community Relations Staff
U.S. EPA Region 6
Public
EPA Update
Superfund Site Update  - Remedial Action Field Activities
Progressing
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
 000609 - 000611
07/09/93
003
Debra L. Baker, Counsel  for BSSC
Mayor, Day, Caldwell  & Keeton, L.L.P.
Chris Villarreal,  RPM, Superfund  Enforcement Section,  U.S.  EPA
Region 6, et  al.
Letter
Notification  of sighting of styrene-like  material from site on
07/09/93

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SITE NAME:
SITE NUMBER:

DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF  PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX

           BSD

 BAILEY WASTE DISPOSAL SITE
 TXD 980864649

  000612 - 000614
 07/12/93
 003
 Debra L. Baker, Counsel for BSSC
 Mayor, Day, Caldwell & Keeton, L.L.P.
 Chris Villarreal, RPM,  Superfund Enforcement Section, U.S. EPA
 Region 6, et al,
 Letter
 Notification of sighting of styrene-like material from site on
 07/12/93
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
  000615 - 000617
 07/14/93
 003
 Debra L. Baker,  Counsel for BSSC
 Mayor, Day, Caldwell & Keeton,  L.L.P.
 Chris Villarreal,  RPM, Superfund Enforcement Section, U.S. EPA
 Region 6
 Letter
 Notification of sighting of styrene-like material from site on
 07/14/93
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
  000618 - 000687
 09/14/93
 070
 John Wilder, Field Investigator,  Region 10,  Beaumont, Texas
 Texas Natural Resource Conservation Commission (TNRCC)
 Stennie Medours, Manager,  Emergency Response and Assessment,
 Pollution Cleanup Division,  TNRCC
 Memorandum
 Summary report of sampling conducted on 07/21/93
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
  000688 - 000692
 09/21/93
 005
 John Lindsey, Chief Coastal Resource Coordinator
 National Oceanic & Atmospheric Administration  (NOAA)
 Debra L. Baker, Mayor, Day, Caldwell & Keeton, L.L.P., Counsel
 for BSSC
 Letter
 Natural Resource Trustees'  (NRT) comments on "Report  on
 Sediment Bioassays and Benthic Community Characterizations"

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                  ADMINISTRATIVE RECORD INDEX

                             ESD
SITE NAME:
SITE NUMBER:
BAILEY WASTE DISPOSAL SITE
TXD 980864649
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
 000693 - 000696
09/21/93
004
Ron Gouguet, Coastal Resource Coordinator
NOAA
Chris Villarreal, RPM, Superfund Enforcement Section, U.S. EPA
Region 6
Letter w/Enclosure
NOAA requests additional investigations to characterize
releases of hazardous substances to marsh environment
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:

COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
 000697 - 000705
11/09/93
009
Debra L. Baker, Counsel for BSSC
Mayor, Day, Caldwell t Keeton, L.L.P.
Sam Becker, Chief, Superfund Enforcement Branch, U.S. EPA
Region 6, et al.
Letter w/Enclosure
Requested information about proposed repair of East Dike and
to obtain EPA's agreement for use of 4-foot dike elevation to
repair East Dike

 000706 - 000708
11/24/93
003
E.R. Collins III, Project Manager, Superfund Engineering
Section, Pollution Cleanup Division
TNRCC
Chris Villarreal, RPM, Superfund Enforcement Section, U.S. EPA
Region 6
Letter
TNRCC's comments on .EPA's draft memorandum explaining the
basis for invoking an interim Applicable or Relevant and
Appropriate Requirements  (ARARs) waiver

 000709 - 000712
12/09/93
004
Chris Villarreal, RPM, Superfund Enforcement Branch
U.S. EPA Region  6
Debra L. Baker,  Mayor, Day,  Caldwell & Keeton,  L.L.P.,  Counsel
for BSSC
Letter w/Enclosure
EPA will invoke  interim measure ARARs waiver for 300-foot
segment of East  Dike

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                  ADMINISTRATIVE RECORD INDEX
                             BSD
SITE NAME:
SITE NUMBER:
BAILEY WASTE DISPOSAL SITE
TXD 980864649
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT. DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
 000713 - 000720
01/10/94
008
Chris Villarreal, RPM, Superfund Enforcement Branch
U.S. EPA Region 6
Ingrid K. Hansen, Natural Resource Damage Assessment Team,
Texas General Land Office
Cover Letter w/Enclosure
Enclosure of analytical summary tables from recent North Marsh
Waste Evaluation sampling that occurred on 11/11/93 and
11/18/93

 000721 - 000731
02/14/94
Oil
Debra L. Baker, Counsel for BSSC
Mayor, Day, Caldwell, & Keeton, L.L.P.
Chris Villarreal, RPM, Superfund Enforcement Branch, U.S. EPA
Region 6
Cover Letter w/Enclosures
Enclosure of results of tests performed in north marsh at
NRTs' request

 000732 - 000733
03/08/94
002
Ron Gouguet, Coastal Resource Coordinator
NOAA
Chris Villarreal, RPM, Superfund Enforcement Branch, U.S. EPA
Region 6
Letter w/o Enclosure
NOAA requests resampling sediments to determine if chemical
components identified in tarry mass have migrated into marsh
sediments
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000734  - 000739
03/28/94
006
Chris Villarreal, RPM, Superfund Enforcement Branch
U.S. EPA Region  6
U.S. EPA Region  6 Site File
Record of Communication w/Enclosures
Conference  call  between EPA, BSSC, and NRTs to  discuss ongoing
investigation  in marsh area north of north dike area

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SITE NAME:
SITE NUMBER:

DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
•RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX

           BSD

 BAILEY WASTE DISPOSAL SITE
 TXD 980864649

  000740 - 000827
 04/18/94
 088
 HLA
 Consultant for BSSC
 BSSC
 Demonstration Report
 Final North Marsh Waste Remediation Demonstration
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
  000828 - 000837
 04/29/94
 010
 Debra L. Baker, Counsel for BSSC
 Mayor, Day, Caldwell & Keeton, L.L.P,
 Chris Villarreal, RPM, Superfund Enforcement Branch,  U.S.  EPA
 Region 6
 Cover Letter w/Enclosure
 Enclosure of "Marsh Sediment Sampling and Analysis  Plan"
 developed by BSSC in response to 03/14/94 request by EPA and
 NRTs to do additional sampling of sediments in marsh north of
 site
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
  000838 - 000850
 05/11/94
 013
 George L. Pettigrew, Senior Regional Representative
 Agency for Toxic Substances and Disease  Registry,  Region €
 Chris Villarreal, RPM, Superfund Enforcement Branch,  U.S. EPA
 Region 6
 Memorandum w/Enclosure
 Health Consultation
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
  000851 - 000870
 07/18/94
 020
 Debra L, Baker, Counsel  for BSSC
 Mayor, Day, Caldwell  &. Keeton,  L.L.P.
 Chris Villarreal,  RPM, Superfund  Enforcement Branch, U.S. EPA
 Region 6
 Cover Letter w/Enclosure
 Enclosure of "Marsh Sediment  Sampling and Analysis Plan"

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                  ADMINISTRATIVE RECORD INDEX

                             ESD
SITE NAME:
SITE NUMBER:
BAILEY WASTE DISPOSAL SITE
TXD 980864649
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
 000871 - 000877
08/23/94
007
Debra L. Baker, Counsel for BSSC
Mayor, Day, Caldwell & Keeton, L.L.P.
Sam Becker, Chief, Superfund Enforcement Section, U.S. EPA
Region 6, et al.
Letter
Request to waive dike elevation  (floodplain) ARAR for north
marsh remediation
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
 000878 - 000879
09/02/94
002
Ron Gouguet, Coastal Resource Coordinator
NQAA
Chris villarreal, RPM, Superfund Enforcement Branch, U.S. EPA
Region 6
Letter
NRTs' comments on the BSSC's request to waive dike elevation
{floodplain) ARAR for north marsh remediation.  Letter states
BSSC's request for ARAR waiver should be granted with
conditions outlined in letter.
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000880 - 000883
09/13/94
004
Chris Villarreal, RPM, Superfund Enforcement Branch
U.S. EPA Region 6
U.S. EPA Region 6 Site File
Memorandum
Documentation and explanation for basis of invoking interim
measure ARAR waiver
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:

DOCUMENT TYPE:
DOCUMENT TITLE:
 000884 - 000885
09/13/94
002
Chris Villarreal, RPM, Superfund Enforcement Branch
U.S. EPA Region 6
Bailey Task Force Administrator, c/o  Debra  L. Baker, Mayor,
Day, Caldwell  & Keeton,  L.L.P.
Letter w/o Enclosures
EPA will invoke interim  measure ARAR  waiver for north  marsh
remediation activities

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                  ADMINISTRATIVE RECORD INDEX
                             ESD
SITE NAME:
SITE NUMBER:
BAILEY WASTE DISPOSAL SITE
TXD 980864649
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000886  - 000975
10/11/94
090
Horizon Environmental Services, Inc.
Consultant for BSSC
U.S. EPA Region 6 and BSSC NRTs
Cover Letter w/Soil Sampling and Analysis Results
Results of the North Marsh Sediment and Soil Sampling and
Analysis
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000976 - 000995
08/15/95
020
GeoSyntec Consultants
Consultant for BSSC
U.S. EPA Region 6
Work Plan
Work Plan for Focused Feasibility Study, Revision 1
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 000996 - 001026
08/17/95
031
GeoSyntec Consultants
Consultant for BSSC
U.S. EPA Region 6
Sampling and Analysis Plan
Sampling and Analysis Plan for Supplemental Site Investigation
for Focused Feasibility Study, Revision 1
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 001027 - 001030
09/01/95
004
Community Relations Staff
U.S. EPA Region 6
Public
EPA update on Activities at Bailey waste  Disposal  Site
Superfund Site Update  - Current  Project Activities
                               10

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                  ADMINISTRATIVE RECORD INDEX
                             ESD
SITE NAME:
SITE NUMBER:

DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:

COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
BAILEY WASTE DISPOSAL SITE
TXD 980864649

 001031 - 001035
09/27/95
005
E.R. Collins III, Project Manager,  Superfund Engineering
Section, Pollution Cleanup Division
TNRCC
Jacqueline McKendry, Parsons Engineering Sciences,  Inc.
Letter w/Enclosures
Clarification about TNRCC's special waste requirements as they
relate to potential landfill disposal of waste to be excavated
from north marsh area
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 001036 - 001081
10/06/95
046
GeoSyntec Consultants
Consultant for BSSC
U.S. EPA Region 6
Memorandum
Technical Memorandum - Supplemental,  North Marsh Area,
Investigation and Evaluation of Original Remedy
Site
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 001082 - 001084
10/31/95
003
Chris Villarreal, RPM, Superfund Enforcement Branch
U.S. EPA Region 6
U.S. EPA Region 6 Site File
Memorandum
Documentation about applicability of Resource Conservation and
Recovery Act's land disposal restrictions to off-site disposal
alternative
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:

COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 001085  -  001086
11/06/95
002
E.R. Collins III, Project Manager, Superfund Engineering
Section, Pollution Cleanup Division
TNRCC
Jacqueline McKendry, Parsons Engineering Science,  inc.
Cover  Letter w/Enclosure
Enclosure  of TNRCC's Compliance Summary for Browning Ferris
Industries Anahuac landfill
                               11

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                  ADMINISTRATIVE RECORD INDEX

                             ESD
SITE NAME:
SITE NUMBER:

DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:

COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
BAILEY WASTE DISPOSAL SITE
TXD 9808S4649

 001087 - 001087
12/15/95
001
E.R. Collins III, Project Manager, Superfund Engineering
Section, Pollution Cleanup Division
TNRCC
Chris Villarreal, RPM, U.S. EPA Region 6
Letter
TNRCC concurs with the draft Explanation of Significant
Differences  (ESD) proposal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
 001088 - 001096
02/08/96
009
Jane N. Saginaw, Regional Administrator
U.S. EPA Region 6
Public
Decision Document
"EPA Superfund ESD for the Record of Decision: Bailey Waste
Disposal Superfund Site"
                               12

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