PB98-963147
EPA 541-R98-161
March 1999
EPA Superfund
Record of Decision Amendment:
Petro-Chemical Systems
(Turtle Bayou)
Liberty County, TX
4/30/1998
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RECORD OF DECISION
AMENDMENT
PETRO-CHEMICAL SYSTEMS, INC.
(TURTLE BAYOU)
SUPERFUND SITE
REGION 6
APRIL 1998
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DECLARATION
PETRO-CHEMICAL SYSTEMS, INC.
AMENDED RECORD OF DECISION
Statutory Preference for Treatment as a
Principal Element is Met
and Five-Year Review Is Required
SITE NAME AND LOCATION
Petro-Chemlcal Systems, Inc. (Turtle Bayou)
Liberty County, Texas
STATEMENT OP RAgIS AMD PURPOSE
This decision document presents the amended Record of Decision (ROD
Amendment) for the second operable unit (OU2) for the Petro-Chemlcal Systems,
Inc. (aka Turtle Bayou) site (the site) in Liberty County, Texas. The amended
remedy was chosen 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, to the
extent practicable, the National OH and Hazardous Substances Pollution
Contingency Plan (NCP). This ROD Amendment Is based on the administrative
record file for this site.
The public was provided an opportunity to provide comments on the
Proposed Plan during the public comment period. The public comment period
began on October 22,1997 and ended on November 20,1997. A public meeting
was held at the site to provide the local community an opportunity to provide
verbal and/or written comments on the Proposed Plan. The United States
Environmental Protection Agency (USEPA) has reviewed all written and verbal
comments submitted during the public comment period. Upon review of these
comments, the USEPA has determined that no significant changes to the amended
remedy identified in the Proposed Pian are required.
The State of Texas concurs with the ROD Amendment.
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ASSESSMENT OF THP SITP
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in the Amended Record
of Decision, may present an imminent and substantial endangerment to public
health, welfare, or the environment.
DFSrmPTIQN QE THE RQP AMENDMENT
This ROD Amendment addresses a modification to the soil cleanup criteria
for benzene identified in the September 6, 1991 ROD. The 1991 ROD'S benzene
soil cleanup criteria was based on numerical model predictions of the allowable
benzene concentrations in soils that, when attained, would not result in exceeding
the federal drinking water standards in the underlying shallow aquifer via leaching.
The benzene soil cleanup criteria modification is based on the following:
• rerunning the numerical model using site specific data (e.g., soil moisture
profiles, field permeability test results) collected during the recently
completed field pilot study activities; and
• consideration of the Texas Natural Resource Conservation Commission's
residential exposure standard for benzene in soil from zero to two feet
below ground surface.
All other 1991 ROD performance standards, including the benzene ground water
cleanup criteria, remain unchanged.
This ROD Amendment also addresses the remedy for the site's
contaminated soils and contaminated ground water. The remedy for the soil
contamination addresses the principal threats (i.e., areas of the site where soil is
known or suspected to contain high concentrations of dissolved and/or free non-
aqueous phase liquid) as well as low level threats at the site by minimizing
potential exposure by way of ingestion, inhalation or direct contact with
contaminants and by reducing the potential for the contaminated soil to act as a
continued source for ground water contamination. The remedy for the ground
water contamination addresses the principal risk at the site by minimizing potential
exposure by way of direct contact and ingestion with contaminants and by
eliminating the potential for migration of contaminants to deeper ground water
zones.
This ROD Amendment enhances the site's remedy by identifying additional
soil and ground water remedy components which can be used in combination with
1991 ROD remedy components to achieve the site's performance standards in
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compliance with all Federal, state and local applicable or appropriate requirements.
The identification of the additional remedy components which will be used to
achieve the site performance standards is based upon further site characterization,
results of field pilot studies, and the ongoing operation of the pilot systems. The
additional soil and ground water remedy components include:
• in-situ aquifer bioremediatlon;
• bioventing;
• aqueous phase soil bloremediation;
• soil excavation and off-site treatment and/or disposal;
• soil excavation and biotreatment;
* thermal desorption;
*
0 soil washing;
* containment (e.g., living cap);
• monitored natural attenuation; and
• institutional controls.
Remedy components identified In the 1991 ROD which will continue to be
implemented include:
• soil vapor extraction;
• containment (e.g., traditional synthetic liner cap);
• selected directional containment (e.g., slurry wall);
• installation of storm water management controls;
• monitoring ground water; and
• the restoration of the site surface upon completion of the remedial action.
The primary remedy treatment components addressing site contamination
are soil vapor extraction and In-situ aquifer bioremediatlon. The field pilot studies
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have shown that a flexible approach is an effective means of addressing the
varying geologic conditions at the site and area specific problems. It is anticipated
that to attain the performance standards, the use of the various remedy
components in succession will be required. The use of multiple remedy
components maximizes the efficiency of remedial operations: over time, treatment
technologies such as soil vapor extraction become less effective in removing
contamination, at which point it is more efficient to change to another, more
passive, technology (e.g., bioventing). The transition from one remedy component
(e.g., soil vapor extraction) to a subsequent remedy component (e.g., bioventing)
will generally be determined by progress sampling. In general, benzene will be the
main chemical of concern; the levels of benzene will be measured over time; a
significant decrease in the time rate removal of benzene will indicate a remedy
component change. The ROD Amendment describes in more detail the use of
various technologies in different areas of the site.
Within this ROD Amendment, EPA is narrowing the site boundary from
approximately 500 acres to include only the contaminated portions of property
(and all suitable property in very close proximity to the contamination necessary
for implementation of the remedial design and remedial action). This redefinition
of the site boundary is based upon several years of field investigations and
contamination data which has been gathered since the site boundary was
originally defined.
STATUTORY DETERMINATIONS
The amended remedy is protective of human health and the environment,
complies with Federal and State requirements that are legally applicable or relevant
and appropriate to the remedial action, and will be cost-effective. This remedy will
utilize permanent solutions and alternative treatment technology, to the maximum
extent practicable, and will satisfy the statutory preference for remedies to employ
treatment that reduces toxicity, mobility, or volume as a principal element.
Because this remedy will leave hazardous substances remaining on-s'rte, a
review will be conducted five years after commencement of remedial action to
ensure that the remedy continues to provide adequate protection of public health
and welfare and the environment.
Date
Acting Regional Administrator
Region 6
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RECORD OF DECISION AMENDMENT
PETRO-CHEMICAL SYSTEMS, INC.
SUPERFUND SITE
TABLE OF CONTENTS
PAGE
DECLARATION i
1.0 INTRODUCTION . 1
1.1 Site Background 1
1.2 Lead and Support Agencies 7
1.3 Statute that required ROD Amendment 7
1.4 Circumstances that led to the need for a ROD Amendment 7
1.5 Administrative Record 9
2.O REASONS FOR ISSUING THF ROD AMENDMENT 9
2.1 Performance Standards 10
2.2 Remedy Selected in 1991 ROD 14
2.3 Rationale for Amending Remedy Selected in the 1991 ROD 14
2.4 Amended Remedy 15
2.5 Remedy Component Description 21
3.0 COMPARATIVE ANALYSIS 25
3.1 Treatment Components 26
3.2 Containment Components 27
3.3 Ground Water Components 28
3.4 General Components 29
3.5 Major Applicable or Relevant and Appropriate 30
Requirements (ARARs)
3.5.1 Source Control (Soil Remediation) ARARs 30
3.5.2 Ground Water Remediation ARARs 32
3.5.3 ROD Amendment ARARs 34
3.6 To Be Considered Requirements (TBCs) 35
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RECORD OF DECISION AMENDMENT °
PETRO-CHEMICAL SYSTEMS, INC.
SUPERFUND SITE
TABLE OF CONTENTS
PAGE
4.0 EVA1 NATION OF ALTERNATIVES 35
4.1 Overall Protection of Human Health and the Environment 37
4.2 Compliance with Applicable Relevant and 38
Appropriate Requirements (ARARs)
4.3 Long-Term Effectiveness and Permanence 38
4.4 Reduction of Toxicity, Mobility, or Volume Through Treatment 39
4.5 Short-term Effectiveness 40
4.6 Implementability 40
4.7 Cost 40
4.8 State Acceptance 41
4.9 Community Acceptance 41
5.0 REDEFINITION OF RITE ROUNDARY 41
6.0 STATUTORY DETERMINATIONS 42
6.1 Protection of Human Health and the Environment 42
6.2 Attainment of Applicable or Relevant and 43
Appropriate Requirements of Environmental Laws
6.3 Cost Effectiveness 43
6.4 Utilization of Permanent Solutions and Alternative 43
Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practical
6.5 Preference for Treatment as a Principal Element 44
7.0 nnn IMPUTATION OF SIGNIFICANT CHANGES 44
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RECORD OF DECISION AMENDMENT
PETRO-CHEMICAL SYSTEMS, INC.
SUPERFUND SITE
TABLE OF CONTENTS
PAfiE
FIGURES
1 Petro-Chemical Systems, Inc. Site Map 2
2 Site Reference Areas 4
TARl PS
2-1 1991 ROD Site Contaminant Cleanup Levels 11
2-2 Revised Benzene Soil Remediation Criteria 12
2-3 Contaminated Soil Remedial Components 17
2-4 Soil Hot Spot Remedial Components 18
2-5 Contaminated Ground Water Remedial Components 19
2-6 Petro-Chemical Systems, Inc. (Turtle Bayou) Surface 19
Water Discharge Criteria
2-7 Other Effluent Limitations 20
APPENDICES
A State of Texas Letter
B Responsiveness Summary
C Administrative Record Index
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1.0 INTRODUCTION
This Record of Decision Amendment (ROD Amendment) is the culmination
of over two years of extensive Remedial Design (RD) field pilot studies, further site
characterization, and the ongoing operation of pilot systems. Within this ROD
Amendment, the United States Environmental Protection Agency (USEPA)
documents the Federal Government's rationale for changing the benzene soil
cleanup criteria and for enhancing the remedy approach to address contamination
at the Petro-Chemical Systems, Inc. site. This ROD Amendment includes a
comparison of the enhanced remedy to the 1991 ROD remedy and discusses how
the enhanced remedy satisfies the statutory requirements. The enhanced remedy
includes additional soil and ground water remedy components (i.e., bioventing, in-
situ bioremediation) which will be used instead of or in combination with the 1991
ROD remedy components to achieve the site's performance standards. The
enhanced remedy also modifies the 1991 ROD remedy for the site's Bayou
Disposal Area from an engineered soil and synthetic liner cap to a "living cap."
The living cap consists of a graded clay cap (infiltration barrier), with selected
vegetation planted and developed so as to minimize infiltration of rainwater. The
USEPA is also narrowing the current site boundary of nearly 500 acres to more
precisely reflect only those areas where soil and/or ground water contamination
has been defined. Because this action modifies the 1991 ROD'S soil benzene
cleanup standard and enhances the 1991 ROD's remedial approach, it constitutes
a fundamental change to the remedy, and thus USEPA solicited public input before
issuing this ROD Amendment.
1.1 Site Background
The Petro-Chemical Systems, Inc. Superfund site is located in Liberty
County approximately 15 miles southeast of Liberty, Texas. The site is
approximately six miles north of Interstate 10 along Farm to Market Road (FM)
563. which borders the site to the west. County Road 126 (CR 126 was
previously known as Frontier Park Road) provides access to the site from FM 563.
CR 126 traverses the middle of the site, ending approximately % mile east of
Turtle Bayou and 2Yi miles east of FM 563. The site Is sometimes referred to as
the Turtle Bayou site because Turtle Bayou, a tributary to Lake Anahuac. forms
the eastern site boundary (See Figure 1).
Unpermitted waste disposal activities appear to have started in the late
1960's. Disposal of waste at the site is documented in the Texas Water Quality
Board records as early as 1970. Records indicate the dumping of waste oils in
unlined pits and on Frontier Park Road. Since the site was never an authorized
waste disposal facility, the exact nature of the disposal activities at the site is
uncertain. However, it appears that the waste was dumped indiscriminately
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FIGURE 1
PETRO-CHEMICAL SYSTEMS, INC. SITE
LIBERTY COUNTY, TEXAS
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KTRO-CMEMCAL
•WldM WTC
VtCMTYMAP
LOCATION MAP
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from trucks at numerous locations. In some areas, it appeared as if the waste
were tilled into the soil. In addition to Frontier Park Road, five areas of the site
have been identified as waste disposal areas. These areas are the West Road
Area, the Main Waste Area, the Office Trailer Area, the Easement Area, and the
Bayou Disposal Area (See Figure 2).
In 1971, an application for a commercial industrial waste disposal permit
with the name of Petro-Chemical Systems, Inc., was filed with the State of Texas.
The application included a detailed site development plan. In response to the
application, local citizens organized to oppose the application. After public
hearings were held and additional information was evaluated in response to a
citizen's suit, the State's approval for the application was withheld indefinitely. In
1974, Petro-Chemical Systems, Inc., withdrew the application. The site has since
been subdivided into five-acre and fifteen-acre plots and sold for residential
development. Residential use of the site has been continuous since 1974, except
during previous remedial activity on Frontier Park Road. At that time, EPA
temporarily relocated the site residents. Four families live within the site
boundaries as of November 1997. No residents live on any of the identified waste
disposal areas; however, two families live adjacent to waste disposal areas
(Easement Area and the Bayou Disposal Area). The current land use (i.e.,
residential), is not anticipated to change in the foreseeable! future.
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With the passing of CERCLA in 1980, interest in th
1982, personnel from the Texas Department of Water Re
sent to investigate the site. [Note: In September 1985 the
Texas Water Commission (TWC)J. TDWR personnel colle
in the pits formerly used for waste disposal. As a result
the TDWR determined that the site constituted a "dischari
as well as the creation and maintenance of a nuisance as
Administrative Code (TAC) 335.4.' The TDWR recom
responsible party can be determined and corrective actioi
should be considered for CERCLA funding." In May 19
represented by the TDWR, requested that the site be incl
Priorities List for funding under CERCLA.
In 1984 the USEPA proposed the site for inclusion on the National Priorities
List (NPL). The site was placed on the NPL in 1986. Thn Texas Water
Commission (TWO (predecessor to the Texas Natural Resource Conservation
Commission - TNRCC) and the USEPA decided to first address contamination along
Frontier Park Road (Operable Unit 1 - OU1) and conducted a remedial investigation
(Rl) and feasibility study (FS) from January to November 11986. The Rl found that
site was renewed. In
urces (TDWR) were
TDWR became the
ted several soil samples
the site investigation,
e or imminent discharge,
rohibited by the Texas
ided that "unless a
taken, the subject site
the State of Texas,
ided on the National
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FIGURE 2- SITE REFERENCE AREAS
PETRO-CHEMICAL SYSTEMS, INC. SITE
LIBERTY COUNTY, TEXAS
V-MAINWASTE
\ AREA
^WESTROAD
.AREA I;'
BAYOU DISPOSAL
AREA
OFFICE TRAILER
AREA
'•—^EASEMENT
AREA
SCALE IN FEET
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several sections of Frontier Park Road were contaminated with volatile organic
compounds (VOCsHe.g., benzene) and polynuclear aromatic hydrocarbons
(PNAs)(e.g., naphthalene). The Frontier Park Road RI/FS Report (Lockwood,
Andrews & Newnam, Inc., November 1986) stated that the potential risks to local
residents, particularly those living on the site, from the road contamination was
high. Local residents could be exposed to PNA and VOC contamination through
multiple routes (i.e., direct contact, ingestion. inhalation). To address these risks
to local residents from exposure to road contamination, the report evaluated
various remedial alternatives. Stated remedial goals were to:
• Improve access for equipment to the site to facilitate necessary remedial
investigation sampling and monitoring and future remedial actions;
• prevent direct contact with highly contaminated soils (greater than 100
parts per million [ppm] total PNAs or 100 ppm total VOCs); and
• minimize direct exposure to moderately contaminated soils (between 10 and
100 ppm total PNAs or 10 and 100 ppm total VOCs).
On March 27, 1986, the USEPA issued a Record of Decision for Frontier
Park Road (OU1 ROD) which called for the excavation and on-site consolidation of
approximately 5,900 cubic yards of highly contaminated soils (containing greater
than 100 ppm total PNAs or 100 ppm total VOCs). The OU1 ROD stated that
excavated soils were to be placed in a temporary, above ground landfill in the
site's Main Waste Area until such time that a remedy for the entire site could be
implemented. The excavated areas of Frontier Park Road were backfilled with
clean soil. Additionally, the entire length of Frontier Park Road was also paved to
minimize direct exposure to the moderately contaminated soils (between 10 and
100 ppm total PNAs or 10 and 100 ppm total VOCs) and to improve site access
for future investigations and response actions.
In June 1988 the TWC and USEPA initiated the second RI/FS which defined
the nature and extent of contamination throughout the rest of the she (Operable
Unit 2 - OU2), evaluated risks associated with the contamination, and developed
potential remedial alternatives to address the risks. Soil contamination identified
during the second RI/FS primarily included VOC's (e.g., benzene up to 7.OOO ppm)
and PNA's (e.g., naphthalene up to 6,700 ppm). Beneath the contaminated soils,
significant shallow ground water contamination was detected and primarily
included VOC's (e.g., benzene up to 480 ppm) and PNA's (e.g., naphthalene up to
13.000 ppm). The shallow ground water zone is located approximately 18-20
feet below the ground surface. Additionally, small Isolated areas with lead
contaminated soils up to 5,000 ppm were also identified. The RJ Report
(Lockwood, Andrews & Newnam, Inc., November 1990) identified the primary
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site risk as exposure to cont?minated ground water. To address this risk, the FS
Report (Lockwood, Andrews & Newnam, Inc., March 1991} evaluated various
potential alternatives which could reduce contaminant levels in the ground water
and the overlying contaminated soils which act as a continuing source for the
ground water contamination.
In March 1991, ARCO Chemical Company and the USEPA signed an
Administrative Order on Consent to conduct a supplemental remedial investigation
and focused feasibility study (SRI/FFS) at the site. The objective of the SRI/FFS
was to collect additional site data and further evaluate possible remedial
alternatives. Based on information gathered during this effort, the site's
estimated volume of contaminated soil and ground water significantly increased.
This increase in contaminant volume was addressed in the 1991 ROD. The
SRI/FFS Report (Weston, August 1991) recommended soil vapor extraction and
shallow aquifer sparging as major components of the site's remedy, and the
USEPA in the 1991 ROD included soil vapor extraction and shallow aquifer
sparging as components of the selected remedy. Section 2.2 (Remedy Selected in
1991 ROD) of this ROD Amendment discusses the specific components of the
1991 ROD.
In December 1993, after extensive efforts to identify site Potentially
Responsible Parties (PRPs) and attempting to negotiate an agreement with the
PRPs to participate in the site's remedial design and remedial action (RD/RA), the
USEPA issued a Unilateral Administrative Order (UAO - Docket No. CERCLA 6-05-
94) to identified PRPs. ARCO Chemical Company and Atlantic Richfield Company
(herein collectively referred to as ARCO) are the only PRPs currently complying
with the UAO. As directed by the UAO, ARCO has been working with the USEPA
and the TNRCC in performing the site's RD. As part of the RD, an extensive field
pilot study program was undertaken. The overall goals of the field pilot study
were as follows:
• evaluate the effectiveness of the soil vapor extraction (SVE) and other
remediation technologies (i.e., bioventing, soil washing) for remediating the
contaminated soils above the site's first permeable unit,, and in-situ
bioremediation (ISB) for the contaminated water bearing zone(s); and
• develop the data required to design and build a remedial response system
for each medium (soils and ground water).
The specific objectives for the SVE field pilot tests were:
• confirm the effectiveness of SVE as a component of a remedial system for
the affected soils at the site;
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» generate design data for full-scale construction and operation of SVE for
affected soils; and,
• project the duration of full-scale SVE operation to achieve site clean-up
criteria for affected soils;
The specific objectives for the ISB pilot tests were:
• confirm the effectiveness of delivering chemical amendments (i.e., nutrients
and oxygen) through the upper water bearing unit to stimulate in-situ
bioremediation;
• confirm the effectiveness of ISB in reducing concentrations of chemicals of
concern in soils and ground water in the upper water-bearing unit;
• generate design data for full-scale construction and operation of ISB for the
upper water-bearing unit; and,
• project the duration of full-scale ISB operation to achieve site clean-up
criteria for the upper water bearing unit.
1.2 Lead and Support Agencies
U.S. Environmental Protection Agency - Lead Agency
Texas Natural Resource Conservation Commission - Support Agency
1.3 Statute Requiring ROD Amendment
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), §117, as implemented by the National Oil and Hazardous Substances
Contingency Plan (NCP) i300.435(c)(2)(li).
1.4 Clrcumatancaa that ted to tha Naed for a ROD Amendment
The ROD Amendment Is necessary to document a fundamental change in
the remedy, here a change in the soil cleanup criteria for benzene. This change
will reduce the concentration of benzene remaining at the surface (including the
surface through two feet below the ground surface), maintain the 1991 ROD's
benzene soil cleanup criteria between two and four feet below ground surface, and
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increase the concentration of benzene which can remain in the soil below four
feet. The 1991 ROD's benzene soil cleanup criteria were based on numerical
model predictions of the allowable benzene concentrations in soils that, when
attained, would not result in exceeding the Federal drinking water standards in the
underlying shallow aquifer via leaching. This modeling effort was performed as
part the remedial Investigation and used the SESOIL model. SESOIL is a one-
dimensional vertical transport model for the unsaturated soil zone. The SESOIL
model was used during a recent re-modeling effort which utilized site specific data
generated from recent site characterization sampling and field testing. Results of
this effort indicate that the benzene soil cleanup criteria can be raised above
values in the 1991 ROD without adversely impacting the quality of ground water
beneath the site. The benzene ground water cleanup criteria identified in the 1991
ROD is the Maximum Contaminant Level (MCL) of five parts per billion (5 ppb) and
will remain unchanged. Additional information regarding the change in the
benzene soil cleanup criteria is provided in Section 2.1 (Performance Standards) of
this ROD Amendment.
This ROD Amendment also will enhance the site's remedy by identifying
additional remedy components which will be used instead of or in combination
with 1991 ROD remedy components to achieve the site's performance standards.
For example, the 1991 ROD identified aquifer sparging as the major ground water
remedy treatment component. Aquifer sparging would primarily address volatile
organic contamination (i.e., benzene). This ROD Amendment enhances the ground
water remedy by identifying in-situ bioremediation as the major ground water
remedial treatment component. In-situ bioremedation will directly address both
volatile and semivolatile organic contamination (e.g., benzene, naphthalene) in the
ground water. To address soil contamination, the 1991 ROD identified soil vapor
extraction as the major soil remedy treatment component. Soil vapor extraction
would primarily address volatile organic contamination. This ROD Amendment
enhances the soil's remedy by identifying additional in-sftu soil treatment
technologies such as bioventing, thermal desorption, and soil washing which may
be used with soil vapor extraction to reach the remedial goals within three years.
Bioventing, thermal desorption, and soil washing will directly address both volatile
and semivolatile organic contamination (e.g., benzene, naphthalene) in the soil. In
general, the remedy components will be applied in sequence (e.g.. soil vapor
extraction, bioventing, monitored natural attenuation) In order to attain the
performance standards.
The ROD Amendment also modifies the 1991 ROD remedy for the site's
Bayou Disposal Area from an engineered soil and synthetic liner cap to a living
cap. The Irving cap will consist of a graded clay cap (infiltration barrier), with
selected vegetation (e.g., pine trees) planted and developed so as to minimize
infiltration of rainwater. Further discussion of the amended remedy is provided In
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Section 2.3 (Amended Remedy) of this ROD Amendment.
The USEPA is also narrowing the site boundary to include only that property
within the area) extent of contamination, as well as all suitable property in very
close proximity to the contamination necessary for implementation of the remedial
design and remedial action. This redefinition of the site boundary is based upon
several years of field investigations and contamination data which have been
collected since the boundary was originally defined.
1.5 Administrative Record
The Administrative Record is available to the public for review during regular
business hours at the following locations:
Liberty Public Library
1710 Sam Houston
Liberty, Texas 77575
(4O9) 336-8901
Monday • Thursday 9:OO am - 6:OOpm;
Friday 1:OO pm - 5:OO pm; Saturday 10:00 am - 4:00 pm
USEPA. Region 6
7th Floor Reception Area
1445 Ross Avenue
Dallas, TX 75202-2733
toll free 1-800-533-3508
Monday - Friday 8:00 am - 4:00 pm
Texas Natural Resource Conservation
Commission - Central Records
12100 Park 35 Circle. Building D, Room 190
Austin, Texas 78753
(512) 239-2920
Monday - Friday 8:00 am • 5:00 pm
2.0. REASONS FOR ISSUING THE ROD AMENDMENT
A primary reason for issuing this ROD Amendment is to document a
fundamental change in the remedy (i.e., a change in the soil cleanup criteria for
benzene). The ROD Amendment also enhances the remedial approach by
identifying additional soil and ground water remedy components which will be
used instead of or in combination with 1991 ROD remedy components to achieve
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the site's performance standards in compliance with all Federal, state, and local
applicable or appropriate requirements. Further discussion of the site performance
standards, the remedy selected in the 1991 ROD, the rationale for modifying the
remedy, and the amended remedy for each of the site areas is provided below.
2.1 Performance Standards
The Performance Standards remain unchanged from those identified the
1991 ROD, with the exception of the benzene soil cleanup criteria. The
Performance Standards include remediation goals, cleanup levels, remedial action
objectives, standards of control, and other substantive requirements (e.g.,
Applicable or Relevant and Appropriate Requirements - ARARs), criteria, and
limitations set forth in the 1991 ROD and this ROD Amendment. The 1991 ROD
site contaminant cleanup levels selected for the contaminated soils and ground
water are listed in Table 2-1.
The 1991 ROD benzene soil cleanup criteria were based on numerical model
predictions of the allowable benzene concentrations in soils that when leached
would not result in exceeding the Federal drinking water standards in the
underlying shallow aquifer. As discussed above, this modeling effort was
originally performed as part of the OU2 remedial investigation and used the
SESOIL model. SESOIL is a one-dimensional vertical transport model for the
unsaturated soil zone and was recently used to re-assess the soil cleanup criteria.
The remodeling effort utilized post-1991 ROD site-specific data. The results of the
remodeling suggest that the soil cleanup criteria for benzene can be raised above
the 1991 ROD values without adversely impacting the quality of site ground
water. The revised benzene soil remediation criteria are summarized in Table 2-2.
The results of the remodeling effort are documented in the Turtle Bayou
Superfund Site Soil Criteria Assessment Report (ARCO, March 1997). This report
and supporting information were reviewed by USEPA's National Risk Management
Research Laboratory, Subsurface Protection and Remediation Division out of Ada,
Oklahoma; Ruor Daniel (USEPA's project oversight contractor); and USEPA Region
6 personnel. Operational and long-term monitoring data will be collected to ensure
that the soil standards are protective of human health and the environment. If any
operational or long-term monitoring data indicate differences from the modeling
assumptions, the models will be adjusted as necessary, and the standards may be
re-evaluated.
It is important to note that the revised benzene soil cleanup criteria are in
part based on having a soil permeability in the upper clay unit greater than 1x10"*
10
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TABLE 2-1
1991 ROD SITE CONTAMINANT CLEANUP LEVELS
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CONTAMINANT
Benzene
Ethylbenzene
Lead
Naphthalene
Xylene
SOIL
CLEANUP
LEVEL
(ppm)*
10 (from 0 to 10
feet)
0.35 (> 10 feet)
500
70
SOIL
CLEANUP
CRITERIA
Seec
below
See6
below
Health
Based
Value
GROUND
WATER
CLEANUP
LEVEL (ppb)*
5.0
700
15
327
10.000
GROUND
WATER
CLEANUP
CRITERIA
MCL°
MCL
Action
Level
Health
'Based
Value
MCL
ppm - parts per million
ppb - parts per billion
The remedial goal for benzene in the soil was determined based on the
potential of the benzene contamination in the soil to leach into the
underlying ground water aquifer, resulting in benzene contamination of the
ground water exceeding the benzene MCL for drinking water. The SESOIL
model was used to do this determination. It should also be noted that if
detectable concentrations of benzene are found at depths greater than 10
feet, the entire soil column (from the ground surface to the maximum
depth of contamination) will be remediated to a contaminant level of 0.35
ppm.
Maximum Contaminant Level (MCL)
Highest permissible concentration of a substance allowed in
drinking water, as established by EPA.
The lead concentration goal was based on the Interim Guidance on
establishing Soil Lead Cleanup Levels at Superfund Sites, September 7,
1989.
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TABLE 2-2
REVISED BENZENE SOIL REMEDIATION CRITERIA
Depth
Interval
(feet BGS)
0-2
2-4
4-10
> 10
1991
ROD
Standard
(ppm)
10
10
10
0.35
Amended
ROD
Standard
(ppm)
1.33
10
200
20
Rationale
TNRCC residential exposure standard for
benzene in soil from 0 to 2 feet below
ground surface.
Standard unchanged.
Additional site data and revised SESOIL
modeling. See A below.
Additional site data and revised SESOIL
modeling. See * below.
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The basis for the 200 ppm benzene soil remediation criteria (from 4 to 10
feet BGS) was presented in Section 3.4 of the Turtle Bayou Superfund
Site So// Criteria Assessment Report (ARCO, March 1997). The 200 ppm
value was based in part on the SESOIL model calculated infiltration rate
(in the absence of organic fluid) and the effect of intrinsic bioremediation
processes such as microbial fermentation on residual benzene
concentrations. The soil criteria assessment report concluded that the
post-active remediation residual benzene would not reach the aquifer,
unless present as NAPL (Non-Aqueous Phase Liquid). Therefore, the 4 -
10 feet BGS soil cleanup criteria was based on the potential for NAPL to
occur. The report concluded that NAPL is not likely to be present where
soil benzene concentrations are less then 200 ppm. Where NAPL is
identified on site, it will be removed either by focused in-situ remediation
and/or excavation and onsite biotreatment or offsite treatment/disposal.
The basis for the 20 ppm benzene soil remediation criteria (below 10 feet
BGS) was presented in Section 3.3 of the Turtle Bayou Superfund Site
Soil Criteria Assessment Report (ARCO, March 1997). The 20 ppm value
was based in part on the SESOIL model calculated infiltration rate and the
migration of benzene dissolved in infiltrating water through the base of
the upper clay unit to ground water, where it would be subject to aerobic
in-situ bioremediation.
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centimeters per second (cm/sec). The site's upper clay unit is comprised almost
entirely of clay to a depth of 12 to 15 feex below ground surface. In some
isolated areas of the site (i.e., hot spots), disposal of chemicals has resulted in
high chemical concentrations that have elevated the permeability in present-day
soils. The site's background soil permeability for the upper clay unit was generally
constant around 7.6 x 10'7 cm/sec. The increase in permeability in clay soil above
this value is attributed to the effect of chemicals on clay chemistry and soil
structure. Several potential hot spots were identified and clay soil permeability
testing was performed at each site. After testing, the only remaining hot spot
exceeding the soil permeability criteria of 1 x 10'° cm/sec was the MW-6
(Monitoring Well • 6} location in the Main Waste Area. The MW-6 hot spot covers
an area of approximately 30 feet by 30 feet (900 square feet). In areas with high
chemical concentrations, additional remedial steps such as thermally-enhanced
focused soil vapor extraction may be conducted to expedite the cleanup.
Additional remedial steps for the MW-6 hot spot may include excavation and/or
the installation of a synthetic permeability barrier and graded cap or other
infiltration control system. Information on soil permeability and site hot spots can
be found in the Soil Criteria Assessment Summary Report (ARCO Chemical
Company. September 1997).
A primary goal of this remedial action is to restore the shallow ground water
to its beneficial use, which is, at this site, use as a potential source of drinking
water. The shallow aquifer is not currently being used as a source of drinking
water on site but does have the potential to be used as a drinking water in the
future and is considered a class 2-B aquifer. A class 2-8 aquifer has water quality
such that it is a useable aquifer but for other reasons (i.e., low water yield
capacity) is not currently used.
Ground water contamination may be especially persistent in the immediate
vicinity of the contaminants' source, where concentrations are relatively high. The
ability to achieve remedial levels at all points throughout the site's contaminated
ground water plumes cannot be determined until the remedial system has been
implemented, modified as necessary, and plume response is monitored over time.
If the selected remedy cannot meet the remediation goals for both soils and
ground water, at any or all of the monitoring points during the implementation,
then contingency measures and goals may be necessary to replace the selected
remedy and remediation goals. For example, if after attaining the soil benzene
remediation criteria (i.e., 20O ppm (4-10 feet BGS) and 20 ppm (greater than 10
feet BGS)], the benzene ground water remediation criteria of 5 ppb can not be
attained and/or maintained, additional remedial action will be taken to attain and/or
maintain the 5 ppb benzene ground water remediation criteria. These additional
actions may include more stringent soil benzene remediation criteria in certain
areas of the site. If contingency measures constitute a significant or fundamental
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change to what is discussed it this ROD Amendment, an Explanation of Significant
Differences (ESD) or subsequent ROD Amendment will be required. Changes to
the remediation goals (i.e., performance standards) would constitute a
fundamental change and would require a ROD Amendment.
2.2 Remedy Selected in 1991 ROD
The remedy selected in the September 6, 1991 ROD included the following
remedy components:
• soil vapor extraction to remove volatile organics from affected soils;
• air injection below affected soils to enhance removal of volatile organics;
• air injection at the base of the shallow water bearing zone to remove volatile
organic contaminants from the ground water;
• vapor collection and transport system;
• catalytic thermal destruction of volatile organic compounds from tile soil and
ground water;
• vertical air infiltration control by an engineered soil and synthetic liner cap;
• horizontal migration control via slurry wall;
• installation of structures to control and treat surface water run-on/run-off;
• monitoring ground water; and
• the restoration of the site surface upon completion of the remedial action.
2.3 RntinniiU for Am«nd)ng tha Ramady S«tlaetad in tha 1991 ROD
Amending the 1991 ROD remedy to include additional remedy components
will help achieve the site's performance standards in a more cost effective and
more timely manner while still being protective of human health and the
environment and attaining site performance standards. The field pilot studies have
demonstrated the effectiveness of soil vapor extraction in removing volatile
contamination (i.e., benzene from subsurface sirty soils). The field pilot studies
have also demonstrated the effectiveness of additional remedial components
identified in this ROD Amendment (e.g., bioventing, in-situ aquifer remediation,
etc.) in addressing both volatile contaminants (e.g., benzene) and semivolatile
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contaminants (e.g., naphthalene). This information has been used to develop area
specific remedial systems. The systems are designed to be flexible so that they
can be redefined in response to sampling data and in response to field conditions.
The field pilot studies have shown this flexible approach to be an effective means
of addressing varying geologic conditions at the site and area specific
contamination profiles.
2.4 Amended Remedy
The amended remedy includes the use of various remedy components, used
independently or in combination to achieve the site's performance standards.
When the application of remedial components is sequenced, the transition from
one remedy component to the following component will generally be determined
by progress sampling. In general, benzene will be the primary chemical of
concern; the levels of benzene will be measured periodically over time; a
significant decrease in the time rate removal of benzene will indicate a remedy
component change.
As part of the field pilot study program, a vapor collection and transport
system has been constructed whereby the extracted vapors are piped to either the
site's Main Waste Area or the Easement Area for treatment (thermal oxidation).
Similarly, a ground water collection and transport system has been constructed
whereby all extracted ground water is piped for treatment to a central wastewater
treatment plant. The wastewater treatment plant is located within the site's Main
Waste Area. These systems will continue to be used during the full-scale site
remediation.
In general, contaminated soils in the West Road Area, Main Waste Area,
Office Trailer Area, and the Easement Area will be remediated by the sequenced
application of soil vapor extraction, bioventing, and monitored natural attenuation.
The contaminated soils contained within the above ground landfill located in the
Main Waste Area will be remediated by a combination of soil vapor extraction and
aqueous phase bioremediation. As discussed in Section 1.1 (Site Background),
approximately 5,900 cubic yards of highly contaminated soils were excavated
from Frontier Park Road and consolidated within the above ground landfill. The
implementation of soil vapor extraction system and aqueous phase bioremediation
(APB) system will be cycled (i.e., two weeks SVE only, followed by two weeks
APB). Sumps of the above ground landfill be dewatered during both the SVE and
APB functions to prevent the SVE vacuum from becoming water-logged from the
APB injection. If necessary, additional remedial components (i.e., bioventing, soil
washing, etc.) could be implemented if necessary to achieve the performance
standards for the soils in the above ground landfill. In summary, Table 2-3 lists
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the anticipated soil remedial components to be used to achieve the site's soil
performance standards.
The 1991 ROD did not provide for treatment in the Bayou Disposal Area
because of the low levels of contamination in the soil in this area. The remedy
addressing the contaminated soils within the Bayou Disposal Area, as identified in
the 1991 ROD, was "vertical infiltration control by engineered soil and synthetic
liner cap." The amended remedy for the Bayou Disposal Area is a living cap. The
living cap will consist of a graded clay cap (vertical infiltration barrier) planted with
selected vegetation (e.g., pine trees). The living cap will fulfill the goal of the
engineered soil and synthetic liner cap by minimizing the infiltration of rain water,
thereby reducing the potential migration of soil contaminants into the underlying
shallow ground water.
There are several advantages of the living cap over the traditional
engineered soil and synthetic liner cap. Vegetation is aesthetically pleasing; it can
provide information on the health of the site and a desirable habitat for wildlife.
Vegetation can be managed inexpensively. A traditional engineered soil and
synthetic liner cap would require the removal of deep rooted vegetation (i.e.,
saplings) to maintain its effectiveness. This is important to note given the fact
that the Bayou Disposal Area is in a heavily wooded area.
Soil contamination data collected at the Bayou Disposal Area indicate that
these soils already meet the soli cleanup criteria. However, within the ground
water beneath these soils, benzene concentrations (up to 11 ppb benzene) which
slightly exceed the benzene ground water MCL of 5 ppb benzene have been
detected. In order to ensure long-term protectiveness of the Bayou Disposal Area
remedy, a ground water monitoring program will occur. The purpose of the
ground water monitoring program will be to ensure that contaminant levels in the
ground water do not Increase and are in fact being reduced by natural remediation
processes (i.e., biodegradation, dilution/dispersion, adsorption). For the living cap
to achieve long-term effectiveness, ft will be necessary to maintain the vegetation
and make repairs as necessary to correct the effects of settling, subsidence,
erbsion, or other events.
As previously noted, some areas of the site have been identified as hot
spots. Within these hot spots, high contaminant concentrations of dissolved
and/or free phase non-aqueous phase liquids (NAPLs) were found during
contaminant investigations. Hot spots have been identified within the Main Waste
Area, Office Trailer Area, and the Easement Area which have benzene soil
concentrations in excess of 100,000 ppb at depths greater than 10 feet.
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TABLE 2-3
CONTAMINATED SOIL REMEDIAL COMPONENTS
SOIL REMEDIAL
COMPONENTS
Soil vapor extraction*
Bioventing
Soil washing
Aqueous phase
bioremediation
Containment *
Storm water
manaeemant controls *
Monitored natural
attenuation
Institutional controls
WEST
ROAD
AREA
MAIN
WASTE
AREA
ABOVE
GROUND
LANDFILL
OFFICE
TRAILER
AREA
EASEMENT
AREA
BAYOU
DISPOSAL
AREA
THE NUMBERING BELOW INDICATES THE
ANTICIPATED APPLICATION SEQUENCE OF
REMEDIAL COMPONENT PER AREA
i
2
3
4
5
6
1
2
3
4
5
6
7
1
3
4
2
5
6
1
2
3
4
5
6
1
2
3
4
6
1 - Living Cap
2
3
4
* 1991 ROD Remedy Component
The average hot spot surface dimension is 18 feet by 30 feet with an average
maximum depth of 14 feet below ground surface. In order to expedite soil
cleanup in these areas, additional remediation components such as focused
thermally-enhanced soil vapor extraction may be conducted. Focused thermally-
enhanced soil vapor extraction is currently planned for hot spots within the
Easement Area and Main Waste Area. For the MW-6 hot spot located whhin the
Main Waste Area, excavation with on-site or off-site treatment and disposal may
be necessary. Additionally, the installation of a synthetic impermeable barrier and
graded cap or other infiltration control system may also be necessary to ensure
remedy protectiveness in the MW-6 area. Table 2-4 lists remedial components
which may be used in addition to the remedial components listed in Table 2-3 to
address and expedite cleanup of site hot spots. With the exception of the Bayou
Disposal Area and possibly the isolated areas with soil lead concentrations above
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TABLE 2-4
SOIL HOT SPOT REMEDIAL COMPONENTS
Remedial Components Listed in
Anticipated Application Sequence
Focused Soil Vapor Extraction *
Thermal Desorption
Focused hot spot excavation and on site
Focused hot spot excavation and off-site
biotreatment
disposal/treatment
Containment/infiltration control *
* 1991 ROD Remedy Component
Note 1) The excavation of soils from "hot spots* and on-site or off-site
treatment/disposal will be done only if the "hot spots" are negatively
affecting remedial progress in specific areas (e.g., the MW-6 area
where the soil permeabilities exceed 1x10"* cm/sec).
2) Hot spot remedial components may be performed in addition to the
components listed in Table 2-3.
500 ppm, remedy components emphasizing treatment are required for all areas of
the site soils.
Contaminated ground water from the West Road Area, the Main Waste
Area, the Office Trailer Area, and the Easement Area will be remediated by In-situ
bioremediation. If necessary, selected directional containment could be used to
direct the flow of contaminated ground water to facilitate treatment and/or
removal of the contaminated ground water. Table 2-5 lists the remedial
components to be used to remediate contaminated ground water. Contaminated
ground water pumped from the production wells is treated at the site's
wastewater treatment plant to meet TNRCC's surface water discharge standards
(See Tables 2-6 and 2-7) and discharged on-site.
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TABLE 2-5
CONTAMINATED GROUND WATER REMEDIAL COMPONENTS
GROUND WATER REMEDIAL
COMPONENTS
In-Situ Bioremediation
Selected Directional Containment *
Monitored Natural Attenuation
Institutional controls
WEST ROAD
AREA
MAIN •
WASTE
AREA
OFRCE
TRAILER
AREA
EASEMENT
AREA
THE NUMBERING BELOW INDICATES THE
ANTICIPATED APPLICATION SEQUENCE OF
COMPONENT PER AREA
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
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1991 ROD Remedy Component
TABLE 2-6
SURFACE WATER DISCHARGE LIMITATIONS
PARAMETER
Carbonaceous Bicshemical Oxygen
Demand (5-day)
Ammonia as Nitrogen (NH,-N)
Total Suspended Solids (TSS)
Total Organic Carbon (TOO
Total BTEXn)
Total Lead
Naphthalene
Total Chlorinated Organics
Daily Maximum
mg/1
20
10
20
10O
0.5
0.6
0.047
0.6
Measurement
Frequency
I/week
1/week
I/week
I/week
2/month
2/month
2/month
2/month
Sample
Type
Composite
Composite
Composite
Composite
Grab
Grab
Grab
Grab
(*1) Tots! of benzene, toluene, ethyl benzene, and total xytene
1. The daily average flow of effluent ehaR not exceed 0.20 minion gallons per day
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TABLE 2-7
OTHER EFFLUENT LIMITATIONS
The water discharge must also comply with the following effluent limitations.
Poflutant
Aldrin
Aluminum
Arsenic
Cadmium
Carbaryl
Chlordane
Chtorpyrifos
Chromium (3 + }
Chromium (6 + )
Copper
Cyanide
4-4-DOT
Dicofol
Dieldrin
Oiuron
Endosulfan 1 (alpha)
Endoaulfan II (beta)
Endosulfan Sulfate
Endrin
Heptachlor
Hexachlorocydohexana
Mercury
Nickel
PCB, Total
Parathion
Phenanthrene
Pantachlorophanol
Selenium
Silver, Total Equivalent
Toxaphana
Tributyttin
2-4-5 Trichtorophenol
Zinc
Daily Maximum (mg/1)
0.005
1.785
1.300
0.185
0.003
0.004
0.0001
13.50
0.028
0.092
0.081
0.002
0.105
0.004
0.374
0.0004
0.0004
0.0004
0.0003
0.0009
0.004
0.004
S.792
0.004
0.0001
0.053
0.024
0.038
0.016
0.0014
0.0002
0.242
0.709
Not*: The Hat of pollutants above ara expected to be below the effluent limitation* specified and no
monitoring of these pollutants la required. However, if the quality of the discharge water waa to
approach the affluent limitation for a specific pollutant, than the discharge water should be monitored
for that parameter at a frequency of twice par month by grab sample.
D*HnMone:
*"***" ~m»»M«™ti«i«« . the maximum concentration measured on a single day by composite
sample
average of all grab samples taken during a single day.
- a sampla made up of .a minimum of three effluent portions collected in a
continuous 24-hour period or during the period of dally discharge if lass than 24 hours, and combined in
volumes proportional to flow collected no closer than two hours; or a sample continuously collected,
proportional to flow, in a continuous 24-hour period or during the period of dsily discharge if less than
24-hours.
umpui - an individual sample collected in lesa than 15 minutes.
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2.5 Rp-mndy Component Description
The following are brief descriptions of the various remedy components
anticipated for the site.
Soil Vapor Extraction (SVE)
SVE involves the use of vapor extraction wells which induce air flow
through the contaminated soils above the water table. The air flow facilitates the
removal of volatile contaminants in the extracted vapor form from contaminated
soils. The extracted vapor can then be captured or/and destroyed. During the
field pilot study program, in addition to traditional SVE wells, dual media (soil
vapor and ground water) extraction wells were used to enhance the recovery rate
of affected ground water, lower the water table, and remove organic vapors from
the expanded unsaturated zone. The extracted vapors were either captured in
carbon units or destroyed in a on-site thermal oxidizer. The extracted ground
water was initially shipped off-site for disposal prior to construction of the on-site
water treatment plant. The existing SVE systems (extraction wells, transport
systems, catalytic oxidation destruction unit) will continue to be used during the
full-scale remediation effort.
Soil Fyrav/ntinn anH Dff-Sitfl Trtnant and/nr i
Soil excavation and off-site treatment and/or disposal may be used to
address site "hot spots* and/or possibly the isolated site areas with lead
contamination. Hot spots are defined as areas with high contaminant
concentrations often containing dissolved and/or free phase non-aqueous phase
liquids (e.g., oils). Hot spots have been identified within the Main Waste Area,
Office Trailer Area, and the Easement Area which have benzene soil
concentrations in excess of 100,000 ppb at depths greater than 10 feet.
Excavation will only be utilized in site hot spots where in-situ treatment is not
practicable. As shown in Table 2-4. only after the application of focused soil
vapor extraction and thermal desorption, is the possible use of soil excavation
anticipated. If soil excavation occurs, the excavated soil would be transported to
a licensed off-site treatment and/or disposal facility. Clean soil would be brought
to the site for use as backfill in the excavated areas. These areas would then be
seeded to provide a vegetative cover and restored to their original conditions.
SfM pyftumitinn unH Bintraatmont
Soil excavation and on-site btotreatment may be used to address site 'hot
spots." Biotreatment is a technology that uses bacteria to degrade organic
contaminants in soil. These bacteria are capable of degrading organic compounds
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into water and carbon dioxide. Contaminated soil requiring treatment would be
excavated and placed in a treatment cell. The treated soil would be used as
backfill for the excavated areas or transported to a licensed off-site disposal
facility.
Binvanting
Bioventing is the process whereby SVE is operated intermittently to aerate
soils so that the oxygen supplied stimulates the in-situ degradation of
contaminants.
Soil
The use of soil washing refers to the in-place treatment of contaminated
shallow soils by flushing these soils with wash solution. No excavation or removal
of contaminated soils is required. Injection wells are used in combination with
extraction wells such that wash solution flow cells are developed which flush
injection water through the contaminated soils. The flushing cell is essentially a
closed system. However, the extraction rate is normally slightly higher than the
injection rate, to ensure capture of all wash solution. The contaminants most
amenable to removal by this method are those that can readily be dissolved. The
extracted water would be taken off-site for disposal or pumped to the site's water
treatment plant, treated to standards developed by the TNRCC, and discharged.
Tharmal Qaaorptinn
Thermal desorption is a commonly used separation process for volatile
organic compounds in which contaminated soils, sludge, or other waste are heated
so that volatile and semivolatile organic compounds are driven off as gases. The
thermal desorption process is design to separate organics from the matrix, but not
destroy them (although some thermal destruction may occur). Air, combustion
gas, or inert gas (such as nitrogen, which may be introduced to impede
combustion) is introduced to the waste stream and carries volatilized contaminants
to air pollution control equipment. At the site, contaminated soils would be heated
in place (in-situ). and volatile organics would be extracted and treated using the
existing SVE systems (e.g., extraction wells, transport systems, catalytic oxidation
destruction unit).
PKano
Aqueous phase bioremediation is an in-situ process that floods contaminated
soils and circulates oxygenated water with nutrients, stimulating bacteria and
other microbial forms of life to help clean up soil contamination. No excavation or
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removal of contaminated soils is required. Injection wells are used in combination
with extraction wells such that oxygenated water flow cells are developed in the
contaminated soil zone. The flow cell is essentially a closed system. However,
the extraction rate normally is slightly higher than the injection rate, to ensure
capture of all injected water. The extracted water may be suitable for re-injection,
or may be more appropriately discharged elsewhere and an alternative injection
water supply used. During the field pilot study, extracted water from the pilot
study in-situ aquifer bioremediation systems was pumped to the site's water
treatment plant, treated to standards developed by the TNRCC, and discharged.
The site water treatment plant will continue to be used during the full-scale site
remediation. It is anticipated that this technology will be used to help remediate
contaminated soils within the site's above ground landfill.
Containment
Containment involves isolating the contaminated soils and/or ground water
to prevent direct contact and minimize the potential for contaminants to migrate.
Containment often involves the construction of a cap and/or slurry wall. At the
Bayou Disposal Area, a living cap will be constructed. The living cap will consist
of a graded clay cap with selected vegetation (e.g., pine trees) planted and
developed so as to minimize infiltration of rain water. In areas where high
chemical concentrations that have elevated the permeability in present-day soils
above 1 x 10*cm/sec (e.g., MW-6 hot spot), the installation of a synthetic
impermeable barrier and graded cap or other infiltration control system may be
necessary.
Storm water management controls
Storm water management controls include the installation of barriers and/or
grading to divert storm water run-off from disturbed areas and/or completed areas
of the site.
In-situ Aquifer Bioremediation
In-situ aquifer bioremediation refers to the in-place treatment of a
contaminated aquifer using bacteria and other microbial forms of life to help clean
up contamination. No excavation or removal of contaminated soils is required.
Injection wells are used in combination with extraction wells such that
groundwater flow cells are developed which flush Injection water through the
intervening aquifer zone. The flushing cell is essentially a closed system.
However, the extraction rate normally is slightly higher than the injection rate, to
ensure capture of all injected water. The injected water Is normally amended with
oxygen and nutrients (I.e., nitrogen, phosphate) which help to stimulate the natural
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bioremedation process. During the field pilot study, extracted water from the pilot
study in-situ aquifer bioremediation systems was pumped to the site's water
treatment plant, treated to standards developed by the TNRCC, and discharged.
The site water treatment plant will continue to be used during the full-scale site
remediation.
Selected Directional Containment
Selected directional containment involves the use of an in-situ barrier (i.e.,
slurry wall) to direct the flow of contaminated ground water in order to facilitate
treatment and/or removal of the contaminated ground water.
Monitored Natural Attenuation
Natural attenuation is an approach that focuses on the verification and
monitoring of natural remediation processes (i.e., biodegradation,
dilution/dispersion, adsorption) rather than relying totally on "engineered"
processes. The selection of monitored natural attenuation as a component of the
Site remedy Will be based on its ability to achieve remediation goals in a reasonable
time frame (e.g., within e 15-year period) and be protective of human health and
the environment. Monitored natural attenuation, just as any remedy, must comply
with state groundwater use classification and cleanup standards. While monitored
natural attenuation alone may be unable to achieve cleanup standards within a
reasonable time, a combination of monitored natural attenuation and active
remediation (e.g., source reduction. SVE, in-sltu aquifer bioremediation) often will
be able to attain the cleanup standards in a reasonable time. It is currently
anticipated that the soil remediation goals will be attained by the active
remediation phase by January 2000. In regards to ground water contamination, it
is also anticipated that most areas will be able to meet the ground water
remediation goals by active remediation (e.g., in-situ aquifer bioremediation) by
January 2000. However, in one or two areas of the she, the monitored natural
attenuation remedy component may be necessary to ensure that the ground water
contamination will decrease to Federal Drinking Water Standards over a 15-year
period.
Institutional Controls
Institutional controls are legal and administrative measures that prevent
exposure to contaminants at concentrations above health-based risk levels that
may remain at a site. Usually institutional controls limit activities et or near sites.
The objective of Institutional controls are to ensure the long-term protectlveness of
completed remedial actions. Institutional controls include requirements for
providing notice (i.e.. Deed Recordatlon) in the real property records for properties
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where residual contamination (contamination below the performance standards)
will remain. Specific examples of institutional controls which will be appropriate
for this site are: depth limitations on excavating soils in certain areas, restrictions
on locations for potable water wells, specified foundation design for dwellings in
certain locations, and specific design and construction details for potable water
wells. Institutional controls at the Petro-Chemical site will supplement
containment and treatment remedies to reduce potential threats to human health
and the environment.
At the completion of the active remediation phase in each area of the site,
concentrations of certain chemicals will exist in the soils and ground water at
specific locations. It is anticipated that the concentrations of the chemicals in the
shallow ground water, the water bearing unit (18 feet to 28 feet below ground
surface) will decrease to Federal Drinking Water Standards over a 15-year period
via natural attenuation. The concentrations of chemicals in soils at the completion
of active remediation will not change significantly over time due to natural
processes, but the concentrations of chemicals in the soils wilt be such that the
soils are not a significant ongoing source of chemicals to the shallow ground
water. Since concentrations of chemicals will be left on-site, it will be necessary
to establish the institutional controls described above to insure no excess risk to
human hearth or the environment.
At this time, site residents obtain their water from wells screened in a deep
water-bearing zone located about 125 feet below ground surface. There is no
natural vertical migration from the shallow water-bearing zone (18 feet to 24 feet
below ground surface) to the deeper water-bearing zone. Care must be taken to
insure that water wetls into the deeper zone (deeper than 125 feet) do not create
an artificial pathway for chemical migration.
Not all of the above mentioned institutional controls will be necessary for
every area of the site. Some controls may be interim until specified milestones are
achieved; other controls may be permanent. The effectiveness of the institutional
controls and of natural attenuation will be tracked as part of the long-term
monitoring program. If monitoring results indicate an increased risk to human
health or the environment, then further active remediation and/or modifications of
the institutional controls may be necessary. If these modifications constitute a
significant change to what is discussed in this ROD Amendment, an Explanation of
Significant Differences (ESD) may be required.
3.Q COMPARATIVE ANALYSIS
A comparative analysis of the 1991 ROD remedy and the ROD Amendment
remedy is presented in the following sections.
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3.1 TrMtmnnt Qt
The contaminated soil treatment component identified in the 1991 ROD is
soil vapor extraction, in addition to the basic SVE configuration, various
modifications to the basic SVE configuration were evaluated during the field pilot
study efforts including: using air injection wells, running the test with and without
land surface cover (i.e., cap), running a SVE system as long-term bioventing
system, etc. The results of the soil vapor extraction pilot study were positive (i.e.,
vacuum propagation was quicker than expected). The SVE extraction wells and
control equipment have been effective in removing site volatile contamination.
This ROD Amendment expands the current list of 1991 ROD soil remedy
components available for implementation at the site. These additional soil remedy
components include bioventing, thermal desorption, aqueous phase
bioremediation, soil washing, soil excavation and biotreatment, and soil excavation
and offsite treatment and/or disposal. The anticipated application sequence of
various soil remedial components for each site area is shown in Tables 2-3 and
Table 2-4. In general, in-situ active soil remediation technologies (i.e., soil vapor
extraction) will be implemented first followed by less active in-situ treatment
technologies (e.g., bioventing}. Soil treatment technologies involving excavation
and treatment (e.g., soil excavation and biotreatment) may be necessary if the in-
situ technologies are unable to achieve the performance standards. The existing
pilot study treatment systems (i.e., pilot study SVE systems) will continue to be
used and expanded during full-scale remediation activities. On-site treatment
technologies will be utilized on all areas of the site soils except the Bayou Disposal
Area and possibly the isolated areas with elevated lead concentrations (greater
than 500 ppm).
The treatment component in the 1991 ROD for addressing contaminated
ground water included in-situ air stripping of volatile organic contaminants. This
technology basically consists of injecting air into a contaminated aquifer. The
injected air facilitates the mobilization of volatile organic compounds which can
then be extracted by SVE wells located above the water table.
This ROD Amendment identifies in-situ aquifer bioremediation as the primary
ground water treatment component. This component was not identified in the
1991 ROD but was evaluated during the pilot study. In-situ bioremediation pilot
tests have achieved steady state conditions and have shown good distribution of
oxygen and nutrients. Significant remediation progress has occurred in these pilot
areas. The existing in-situ aquifer bioremediation pilot study treatment systems
will continue to be used and expanded during full-scale remediation activities.
During the field pilot studies, the extracted water from various pilot study
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treatment systems (e.g., in-situ bioremediation systems, aqueous phase
bioremediation system) was pumped to the site's water treatment plant, treated to
the standards developed by the TNRCC, and discharged on site. The site water
treatment plant will continue to be used during the full-scale site remediation.
Catalytic thermal destruction of volatile organics was identified as the
treatment component in the 1991 ROD for addressing the extracted volatile
organic vapors from the SVE and in-situ air stripping systems. During the field
pilot study program, two catalytic thermal oxidizers were used to destroy
extracted vapor from the pilot SVE and in-situ bioremediation systems. These
units have been field tested to determine their destruction efficiencies. The
destruction efficiency for volatile organic compounds exceeded 99.87% through
the Easement Area oxidizer and exceeded 99.98% through the Main Waste Area
oxidizer. The test runs were consistent and reproducible. Both oxidizers are
operating within design ranges. Prior to the operation of the catalytic thermal
oxidizer, extracted vapors from the SVE pilot tests were routed through a carbon
adsorption system (CAS) consisting of two carbon canisters connected in series.
The CAS has also proven to be effective in removing the organic vapors from the
extracted vapor.
The amended remedy requires destruction and/or control of extracted
volatile organic vapor to the extent necessary to protect health and the
environment. The two catalytic thermal oxidizers will be used to the maximum
extent practicable during the full-scale site remediation. It may be necessary to
include an air stripper with the thermal oxidizer unit to remove chlorinated
compounds if these compounds are present in concentrations detrimental to the
thermal oxidizer unit. Both units will be operated in compliance with 30 TAC
Chapter 106.533 (formerly TNRCC Standard Exemption No. 68). 30 TAC Chapter
106.553 states that for treating ground water or soil contaminated with petroleum
hydrocarbons, the total emissions of petroleum hydrocarbons shall not exceed 1 .0
pound per hour (Ib/hr), except that benzene emissions also must meet the
conditions of §106.262(3) and (4) of that title (relating to Facilities (Emissions end
Distance Limitations) (previously TNRCC Standard Exemption No. 118)). Based
upon an evaluation of the estimated emissions, the requirements of 30 TAC
Chapter 106.553, and the benzene conditions of §106.262(3) and (4), the
maximum allowable emission rate is 6 Ibs/hr for acetone, 0.375 ib/hr for benzene,
and 1 Ib/hr for all remaining chemicals.
3.2 CMHtntwumtipt Cnmpnrmnt*
The containment components identified in the 1991 ROD include the use of
engineered soil and synthetic liner cap to minimize storm water infiltration and the
use of slurry walls to prevent the spread of contamination in ground water. As
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stated previously, the cap system for the Bayou Disposal Area has been amended
from an engineered soil and synthetic liner cap to a living cap. For the living cap
to achieve long-term effectiveness, it will be necessary to maintain the vegetation
and make repairs as necessary to correct the effects of settling, subsidence,
erosion, or other events. Long-term operation and maintenance (O&M) wilt be
conducted to ensure the integrity of the cap consistent with federal regulations
(i.e., 40 C.F.R. §264.117 - Post-closure care and use of property). For other
areas of the site, treatment technologies will primarily be used to address
contamination. However, the use of containment components (i.e., caps, slurry
walls) may be used as warranted in conjunction with treatment technologies for
vertical infiltration control, horizontal migration control, and/or directional migration
control.
3.3 Ground Water Compon«nt«
The ground water components in the 1991 ROD include the removal of
volatile organic compounds from ground water using vapor extraction (in-si»u air
stripping), a vapor collection and transport system, catalytic thermal destruction of
volatile organics, and horizontal migration control via slurry wall. The 1991 ROD
also noted that the need for remedial action in the shallow aquifer around
monitoring well MW 12R (located on the west side of the Easement Area} and
around monitoring well MW 19 (completed within the deep aquifer beneath the
Office Area Trailer Area) would be based upon the results of subsequent sampling
events. Previous sampling at these locations found benzene and lead
contamination at concentrations near their respective ground water cleanup levels.
For example, previous ground water samples from MW12R obtained in 1989 and
1991 slightly exceeded the lead ground water cleanup criteria of 15 jig/l (52.4 Aig/l
in 1989 and 18 /*g/l in 1991). Similarly, previous ground water samples from
MW19 slightly exceeded the benzene ground water cleanup criteria of 5 /jg/l (7
/*g/l in 1990). MW19 was installed as a replacement well for an improperly
installed residential well. The residential well was believed to be acting as a
conduit for contaminated ground water to migrate from the shallow ground water
zone to the deeper 100 foot zone. The 1991 ROD stated that if subsequent
sampling indicated that remedial action in these areas was necessary, the
following will be implemented:
Extract contaminated ground water by wells and/or trenches and
store in surface tanks. Sample the extracted ground water. If the
samples showed contaminant concentrations above surface water
discharge levels - treat to below surface water discharge criteria and
discharge. If the samples showed contaminant concentrations below
surface water discharge criteria - the water would be discharged.
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The amended remedy's ground water component specifies treatment of
affected ground water using in-situ bioremediation. As stated previously.
extensive in-situ bioremediation pilot tests have been conducted and have been
shown to be an effective approach of addressing ground water contamination.
The amended remedy will be required to meet the 1991 ROD'S ground water
performance standards.
If it appears that after a sufficient period of implementation that the selected
ground water remedy will not be able to achieve the remedial goals set for the
site, some or all of the following contingency measures may be implemented:
• Discontinuing operation of the in-situ remediation system and using
extraction wells and/or trenches to remove contaminated ground water in
areas where cleanup goals have not been attained.
• Establishing an Alternative Concentration Limit for the contaminants
throughout the areas of attainment, provided compliance with CERCLA
Section 121 (d)(2)(B)(ii) can be demonstrated;
• Waiving of the ground water ARAR for those portions of the aquifer based
on technical impracticability of achieving .further contaminant reduction1;
• Containment of the contaminated soil and ground water by caps and slurry
waits;
• Implementing additional source control treatment to further reduce
contaminant migration to ground water.
If these contingency measures constitute a significant or fundamental
change to this ROD Amendment, an ESD or subsequent ROD Amendment will be
required. Changes to the remediation goals would constitute a fundamental
change and would require a ROD Amendment.
3.4 Qenaral Comopnents
The general components in the 1991 ROD include:
• she preparation and installation of office, storage, and security facilities;
1 Technical impracticability waivers need to be done consistent with OSWER
Directive 9234.2-25 (Guidance of Evaluating the Technical Impracticability of
Ground Water Restoration).
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• installation of structures to control and treat surface water run-on/run-off;
• monitoring ground water;
• dismantling of the on-site landfill with a determination and (if warranted)
remedial action for the potentially contaminated soils underlying the vault;
and restoration of the site surface upon completion of the remedial action.
The general components of the Amended ROD are the same as in the 1991
ROD except as discussed below:
• The ROD Amendment allows for the optimal use of natural trends and
passive systems to achieve the performance standards.
• The ROD Amendment identifies Monitored Natural Attenuation and
Institutional Controls as remedy components.
3.5 Major Applicable of Ralavant and Appropriate RaqniranMintK (ARARa)
CERCLA section 121(d){2) requires remedial actions to at least attain
applicable or relevant and appropriate requirements {ARARs) of Federal and State
environmental laws. Applicable requirements are those cleanup standards,
standards of control, and other substantive environmental protection requirements,
criteria, or limitations promulgated under Federal or State lew that specifically
address a hazardous substance at a Superfund site. Relevant and appropriate
requirements are standards which address problems or situations sufficiently
similar to those encountered at the Superfund Site which warrant their use.
3.6.1 Sn'irfM* Control {Snll RamoHbitiftn) ARAB*
The 1991 ROD identified the following source control (soil) ARARs:
Sourea Control C.hamlr.ftl Spnr.ifir ARARa
• The site wastes were examined to determine if they qualified as Resource
Conservation and Recovery Act (RCRA) hazardous waste. Some site
wastes were identified as being RCRA characteristic hazardous wastes.
Because the site wastes are RCRA waste, RCRA land disposal restrictions
(LDRs) are applicable for the remedial alternatives that involve removal and
placement of contaminated soils (e.g. excavation and off-site disposal). As
discussed in the Office of Solid Waste and Emergency Response Superfund
Publication 9347.3-05FS, for in situ treatment and consolidation of waste, if
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• Fugitive emissions monitoring, as specified in TNRCC 30 TAG Chapter 115
(Regulation V) or USEPA's New Source Performance Standards (40 CFR Part
60) or USEPA's National Emission Standards for Hazardous Air Pollutants
(40 CFR Part 61) will apply.
• Since contaminants will be left on site, the RCRA Closure and Post Closure
requirements may be relevant and appropriate. CERCLA establishes that
remedial actions must be reviewed should contaminants be left on site.
Other substantive requirements will be necessary, including monitoring and
deed recordation.
• Offsite disposal of waste will need to comply with USEPA's Offsite Rule (40
C.F.R. Part 300.440), the RCRA land disposal restrictions, and all current
federal and state regulations for transport of waste to the receiving facility.
* The Solid Waste Disposal Act, Contingency Plan for Emergency Procedures,
Subpart D, will also be applicable since on-site treatment has been selected.
Sniirna Control I nrfltinn-Spflr.ifir ARARs
• Resource Conservation and Recovery Act (RCRA) requirements for location
of a Treatment, Storage or Disposal facility in a 100-year floodplain, 40 CFR
Part 264.18, and also general requirements for the protection of floodplains,
40 CFR Part 6, Appendix A, are relevant and appropriate because the site's
Bayou Disposal Area is within a 100-year flood plain.
3.5.2 QrnunH Wntur Bunuidiiition ARARa
The 1991 ROD identified the following ground water remediation ARARs:
Ground Wptar RamaHiatinn Chftmiefll Spafiifir ARARc
• The National Primary Drinking Water Standards establish health-based
standards for public drinking water systems (maximum contaminant levels -
MCLs). MCU are ARARs for the she since the affected ground water may
be potentially used as a future drinking water source.
• Sections of the Clean Water Act and regulations concerning Water Quality
Criteria (WQC) and Ambient Water Quality Criteria (AWQC), 40 C.F.R. Part
131 set criteria for water and ambient water quality based on human health
and toxicrty to aquatic organisms, respectively. WQCs and AWQCs for site
chemicals are ARARs if the selected alternative calls for discharge to a
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surface water. Because activities will be performed on-site, permits may not
be required, but the technical standards of the permits must be met.
• The Drinking Water Standards for Public Water Supply Systems establish
health-based standards for a specific list of contaminants for public water
supply systems. These are identical to federal standards promulgated under
the Safe Drinking Water Act and are site ARARs.
• Under the State of Texas Rules, Surface Water Quality Standards (30 T.A.C.
Chapters 307.1 - 307.10), criteria are established for surface water quality
and criteria and control procedures for specific toxic substances. These are
ARARs since the selected alternative calls for discharge to a surface water.
Action Spacififi Ground Water Remftftiation ARARs
• Resource Conservation and Recovery Act (RCRA) requirements for Post-
Closure and Monitoring, 40 CFR Part 264.117{a) (1), will be requirements
for at least 30 years.
• The source control action-specific ARARs previously discussed (i.e., 30 TAG
Chapter 106.533, 30 TAG Chapter 101.4, and 40 CFR Part 61), which
relate to the use of equipment to reclaim or destroy chemicals removed from
contaminated ground water for the purpose of remedial action are also
action specific ground water ARARs.
• The National Pollutant Discharge Elimination System (NPDES), 40 CFR Part
125, requires permits for the discharge of pollutants for any point source
and storm-water runoff for specific standard industrial classification (SIC)
codes into waters of the United States. Substantive requirements for a
permit must be met for discharge to a surface water body at the Petro-
chemical Systems, Inc. site.
• The Safe Drinking Water Act, Underground Injection Control Regulations (4O
CFR Parts 144-147), provides for protection of underground sources of
ground water. This will be an ARAR if ground water remediation involves
injection to enhance remediation.
• Standards for Owners and Operators of Hazardous Waste Treatment,
Storage and Disposal (TSD) Facilities, Subpert I (Use and Management of
Containers), and Subpart J (Tanks) are also ARARs. These will be ARARs
for ground water because the selected alternative involves storage of
containers of hazardous waste or involve the use of tanks to treat or store
hazardous materials.
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• The State of Texas Rules. Waste water Permitting, Texas Water Code
Section 26.027, 30 TAG 305, allow TNRCC to issue permits for the
discharge of waste into or adjacent to waters of the state. The substantive
requirements of permits may be an ARAR since the remedy includes
discharge of treated wastewater or storm-water.
• Under 30 TAG 115.132, volatile organic compound water separators must
apply one of the following control measures:
Sealed vessel (vapor tight), or
Floating roof or internal floating cover, or
Vapor recovery systems which meets requirements of 30 TAG 115.131 (a).
Exemptions are provided in 30 TAG 155.137. This will be an ARAR if
volatile organic compound water separators are used.
I r>r;atirtrt-Spaeific Ground Water Remediation ARARs
• Under the State of Texas Rules, Ground Water Protection Act, Texas Water
Code Section 26.401, ground water is required to be restored, if feasible.
This is an ARAR because ground water is effected.
• RCRA requirements for location of a Treatment, Storage or Disposal facility
in a 100-year floodplain, 40 CFR Part 6, Appendix A and 40 CFR Part
264.18, are applicable since the eastern end of the site is within the 100-
year flood plain of a Turtle Bayou tributary.
3.5.3 BQP Atnandmant AHARS
The ARARs previously identified in sections 3.5.1 and 3.5.2 are also
applicable or relevant and appropriate for the amended remedy. While not
identified in the 1991 ROD, the effluent limitations (Tables 2-6 and 2-7) for the
ground water treatment plant's surface water discharge are also ARARs. These
effluent limitations were derived from the following regulatory rules and guidelines:
Texas Surface Water Quality Standards (TSWQSH30 TAG Chapter 307), General
Regulations Incorporated Into Permits (30 TAG Chapter 319, Subchapter B:
Hazardous Metals), and 40 CFR 414 Subpart J. Additionally, the TNRCC in a
letter dated January 22,1998 stated, the Texas Natural Resource Conservation
Commission (TNRCC) Risk Reduction Standards, Subchapter S, 30 TAG 335.551-
569, do constitute a State ARAR for the Federal Superfund Program in Texes."
This ROD Amendment meets the substantive provisions of the Texes Risk
Reduction Standards.
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3.6 To-Be-Considareri Requirements (TBCs)
Many Federal and State environmental and public health agencies develop
criteria, advisories, guidance, and proposed standards that are not legally
enforceable but contain information that would be helpful in carrying out, or in
determining the level of protectiveness of, selected remedies. In other words, "to
be considered" (TBCs) materials are meant to complement the use of ARARs, not
to compete with or replace them. The following were identified as TBCs:
• Under 44 CFR Part 9 (Floodplain Management and Protection of Wetlands),
Federal agencies are required to evaluate the potential effects of actions
they may take in a floodplain to avoid, to the extent possible, the adverse
impacts associated with direct and indirect development of a floodplain.
This is applicable since the eastern end of the site is within the 100-year
floodplain of the Turtle Bayou tributary.
• The Archeological and Historic Preservation Act, 16 USC 469, 40 CFR Part
6301 (c) provides for preservation of historical and archeological data which
might be destroyed through alteration of terrain as a result of Federal
construction projects or Federally licensed activities or programs. No
historical or archeological data is known to exist at the site, but could be
encountered during remediation.
4.0. EVALUATION QF ALTERNATIVES
The USEPA uses nine criteria, or standards, to evaluate alternatives for addressing
a Superfund site. These nine criteria are categorized into three groups: threshold,
primary balancing, and modifying. The threshold criteria must be satisfied in order
for an alternative to be eligible for selection. The primary balancing criteria are
used to weigh major tradeoffs among alternatives. The modifying criteria are
taken into account after public comment is received on the Proposed Plan of
Action.
The nine criteria used in evaluating all of the alternatives identified ere as follows:
Thr««hnM
Overall Prntartion of Human Health and Fn\/iypnm«nt
This criterion addresses the way in which a potential remedy would reduce.
eliminate, or control the risks posed by the site to human health and the
environment. The methods used to achieve an adequate level of protection may
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be through engineering controls, treatment techniques, or other controls such as
restrictions on vhe future use of the site. Total elimination of risk is often
impossible to achieve. However, a remedy must minimize risks to assure that
human health and environment are be protected.
Compliance with ARARs
Compliance with ARARs. or "applicable or relevant and appropriate
requirements," assures that a selected remedy will meet all related Federal, state,
and local requirements. The requirements may specify maximum concentrations of
chemicals that can remain at the site; design or performance requirements for
treatment technologies; and restrictions that may limit potential remedial activities
at a site because of its location.
Primary Balancing Criteria
Long-Term Effectiveness and Permanence
This criterion addresses the ability of a potential option to reliably protect
human health and the environment over time, after the remediation goals have
been accomplished.
Reduction of Toxiclty. Mobility, or Volume of Contaminants
This criterion assesses how effectively a remedy will address the
contamination problem. Factors considered include the nature of the treatment
process; the amount of hazardous materials that will be destroyed by the
treatment process; how effectively the process reduces the toxicity, mobility, or
volume of waste; end the type and quantity of contamination that will remain after
treatment.
Short-Term Effectiveness
This criterion addresses the time factor. Remedies often require several
years for implementation. A potential remedy is evaluated for the length of time
required for implementation and the potential impact on human health and the
environment during implementation.
Implementabllltv
This criterion addresses the ease with which a potential remedy is put in
place. Factors such as availability of materials and services are considered.
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Cost °
This criterion includes capital costs required for design and construction,
and projected long-term maintenance costs. Cost is considered and compared to
the benefit that will result from implementing the remedy.
Modifying Criteria
State Anraptanra
This criterion addresses state concerns, comments on ARARs, and
concurrence or lack of concurrence on the selected remedy.
During the 30-day public comment period from October 22, 1 997 through
November 20, 1 997, interested persons or organizations were provided the
opportunity to comment on the Proposed Plan. The USE PA considered these
comments in making its final selection. The comments are addressed in a
document called a responsiveness summary, which is included as Appendix B of
this Amended ROD.
The remedial alternatives originally considered for the Retro-Chemical
Systems, Inc. site are described in detail in the March 1991 Feasibility Study
report. An additional evaluation of the remedial alternatives based upon a
supplemental remedial investigation are described in detail in the August 1991
Supplemental Remedial Investigation Focused Feasibility Study report. Documents
concerning the ongoing field pilot studies can be found in the updated
Administrative Record file. A copy of the updated Administrative Record Index is
provided in Appendix C. A comparison of the 1991 ROD remedy to the ROD
Amendment remedy follows:
4.1 Qunmlt Protection af Human Hnnlfti ftnri ttw> J-nwironmant
The original selected remedy, if successfully implemented, would be
protective of human hearth and the environment by reducing levels of
contaminants in the soils and ground water through extraction and treatment. The
USEPA expected that the contaminants in the site soils and ground water could be
reduced to the remedial levels within five years by implementing the 1991 ROD'S
remedy. However, the ability to achieve the remedial goals throughout the areas
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of contamination could not be fully determined until the treatment components of
remedy had been tested in the field pilot studies, modified as necessary, and
monitored over time. Together with the containment components (cap and slurry
wall), the threat of exposure currently posed to residents from contaminated soils
and from contaminated ground water would be significantly reduced if not
eliminated. A engineered cap would specifically deal with the estimated 700 cubic
yards of elevated lead contamination (lead concentrations greater than 500 ppm)
found in the upper 6.5 feet in two areas of the Main Waste Area.
The amended remedy is required to achieve the Performance Standards
identified in the 1991 ROD, as slightly modified in this ROD Amendment. The
amended remedy also reduces levels of contaminants in the site soils and ground
water through treatment, although, like the remedy in the 1991 ROD, it also has
containment components for certain areas of the site. Attainment of the
Performance Standards (which include MCLs, contaminant specific action levels,
and calculated health-based values) will insure the following: soil contaminants will
cease to act as a source of ground water contamination, such that any potential
leaching of the remediated soils will not result in ground water contaminant
concentrations above the MCLs; and, exposure to the ground water will not pose
adverse effects to the potentially exposed future site population. The amended
remedy will include several components of the original remedy (i.e., soil vapor
extraction, containment, vapor control, ground water monitoring, etc.) along with
additional or modified remedial action components (e.g., in-situ aquifer
bioremediation, bioventing, etc.). Approximately 13.2 million dollars have been
expended for the extensive field pilot study program and subsequent detailed
design activities in order to develop the amended remedy. The amended remedy
will provide the same or better overall protection to human health and the
environment as the remedy selected in the 1991 ROD.
4.2 CampUmiftA With Appliftafrla Ralavant and Appropriate Raqiilramanta
The amended remedy will be performed in full compliance with all chemical,
location, and action-specific ARARs and other criteria, advisories and guidelines
which are applicable (i.e., surface water discharge limits established by the
TNRCC) or considered relevant and appropriate. ARARs are identified in Section
3.5 (Major Applicable or Relevant and Appropriate Requirements).
4.3 Lang-farm PtliMtttyftrnt** itntt Pf»mu
The 1991 ROD'S remedy provides for permanence by removing and
destroying volatile organic contaminants from soils and ground water by in-situ
remedies (soil vapor extraction and aquifer air sparging). The addition of
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containment remedy components (i.e., caps and slurry walls) in the 1991 ROD
provide additional effectiveness for certain areas of the site, although the
containment components must be maintained.
The amended remedy will also provide for permanence by treatment of soils
and ground water and also requires attainment of the site's Performance
Standards. The limited use of containment remedy components will provide
additional effectiveness, as long as maintenance of the containment components
(e.g., cap) is continued. Results of the field pilot study program indicate that soil
vapor extraction and in-situ bioremediation followed by less-active remedial
components (e.g., bioventing) have a high likelihood of success (i.e., achieving
performance standards). The amended remedy will provide long-term
effectiveness by removing and/or bioremediating both volatile (i.e., benzene) and
semivolatile contaminants (e.g., naphthalene) from the affected media (soil and
ground water) and will provide permanence by destroying and/or degrading these
compounds. In contrast, the treatment components of the 1991 ROD addressed
primarily volatile organic compounds. The amended remedy has a higher likelihood
of achieving the performance standards than the 1991 ROD remedy.
4.4 Rjxiturrion of Toitlt*ltyr Mlohllity,. or Vohima Through Tr«>»«tnrw»r>t
The original remedy included soil vapor extraction and aquifer sparging
treatment components. Both components would remove volatile organic
contaminants from the affected media (soil and ground water) followed by
catalytic thermal destruction of the volatile organic contaminants. Because
catalytic thermal destruction destroys the volatile organic contaminants, the
treatment is irreversible for these contaminants. The mobility and toxicity of the
extracted volatile organic contaminants from the affected media is essentially
eliminated.
The amended remedy also includes the use of in-situ treatment components
(e.g., soil vapor extraction and in-situ aquifer bioremediation) to treat volatile
organic contamination. Contaminant-laden extracted vapor from these treatment
components will be treated in catalytic thermal destruction units. As stated
previously, catalytic thermal destruction destroys the volatile organic
contaminants, and the mobility and toxicity of the extracted volatile organic
contaminants from the affected media will be essentially eliminated. The amended
remedy will require destruction and/or control of volatile organics from the
extracted vapor to the extent necessary to achieve Performance Standards,
ground water remediation to the extent necessary to achieve Performance
Standards, and treatment of affected ground water.
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4.5 Short-term Effectiveness
In-situ remedies (discussed in the 1991 ROD and this Amended ROD) which
do not require the excavation of contaminated soils are favored over remedy
components which require excavation. This is due to the increased potential for
worker accidents during excavation activities as well as the potential for fugitive
emissions resulting during the excavation of soils containing volatile contaminants
(i.e., benzene). It is possible, however, that some excavation of hot spots may
occur if in-situ treatment is unable to attain the performance standards.
The 1991 ROD remedy included the use of engineered soil and a synthetic
liner cap for vertical infiltration control for the Bayou Disposal Area. The amended
remedy identifies a living cap for the Bayou Disposal Area. Both alternatives can
be implemented quickly (within a year) and have a low potential for generating
emissions.
Occupational Safety and Health Administration (OSHA) Regulations shall be
followed for all site activities. In addition, community protection will be provided
by air quality monitoring and engineering controls to regulate air emissions
produced by on-site treatment processes and any excavation activities. Dust
control may also be necessary during any excavation and can be accomplished
with water or foam sprays.
The estimated time required to implement the 1991 ROD'S remedy was five
years. Field pilot study data indicates that the active remediation phase of the
project may be completed by January 2000.
4.6 ImplementabllltY
An overall goal of the field pilot study program was to confirm the
effectiveness of in-situ remedy components discussed in the 1991 ROD (i.e., soil
vapor extraction) as well as potential amended remedy components (i.e., in-situ
bioremediation). As demonstrated by the field pilot studies, the necessary
materials and services required to implement the remedy are readily available.
4.7 Cost
The 1991 ROD cost estimate to implement the remedy selected in the 1991
ROD is $26,430,000. An overall goal of the field pilot study program was to
develop data required to design and build the most effective response system for
each medium (soils and ground water). Current data indicates that the amended
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remedy will cost approximately $20 million dollars. This amount does not include
the long-term monitoring cost beginning after completion of active remediation.
To date, approximately $13.2 million dollars have been expended during the
extensive field pilot study program.
4.8
The State's letter expressing its concurrence with the ROD Amendment is
attached.
4.9
The USEPA recognizes that the community in which a Superfund site Is
located is the principal beneficiary of all remedial actions undertaken. The USEPA
also recognizes its responsibility to inform interested citizens of the nature of
Superfund environmental problems and solutions, and to learn from the community
what Its desires are regarding these sites. The Amended Proposed Plan of Action
was released for public comment in October 1997. The public comment period
began on October 22. 1997 and ended on November 22. 1997. A public meeting
was held on November 3, 1997 at the site to provide the local community an
opportunity to provide verbal and/or written comments on the Amended Proposed
Plan of Action. A court reporter was present to record a transcript of the meeting.
Verbal questions asked at the public meeting were in regards to the estimated time
frame for completing work at the site and In regards to County Road 126. During
the 30-day public comment period, one written comment was received. None of
the questions or comments received expressed concerns with what was Identified
In the Amended Proposed Plan of Action. The questions received during the public
comment period and EPA'* responses to these questions are provided in the
Responsiveness Summary (Appendix B).
In an effort to keep the public apprised, remedial design documents will be
made available to the public in a timely manner. Additionally, community relation
activities (I.e., generation of site fact sheets, open houses) will be performed
throughout the remedial process.
5.0 ppnpnMrnnM OF THE SITE not IMOARY
The USEPA is herein redefining the site, originally defined to encompass
approximately 500 acres (as depicted In Rgure 1), to Include only that property
which includes the areal extent of contamination and all suitable property In very
close proximity to the contamination necessary for implementation of the remedial
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design and remedial action. This property includes the areas designated as the
West Road Area, the Main Waste Area (including the above ground landfill), the
Office Trailer Area, the Easement Area, the Bayou Disposal Area, and County Road
126 (formerly Frontier Park Road)(See figure 2). Maps and metes and bounds
descriptions have been generated by a State of Texas professional land surveyor
for each of the areas mentioned above. Copies of the professional land surveyor's
maps and metes and bounds descriptions are included in the administrative record
for this ROD Amendment. The redefinition of the site is based upon several years
of field investigations and contamination data which has been gathered since the
site boundary was originally defined in the 1980s.
6.0. STATUTORY DETERMINATIONS
The USEPA's primary responsibility at Superfund sites is to select remedial
actions that are protective of human health and the environment. Section 121 of
CERCLA also requires that the selected remedial action for the site comply with
applicable or relevant and appropriate environmental standards established under
Federal and state environmental laws, unless a waiver is granted. The selected
remedy must also be cost-effective and utilize permanent treatment technologies
or resource recovery technologies to the maximum extent practicable. The statute
also contains a preference for remedies that include treatment as a principal
element. The following sections discuss how the amended remedy at the site
meets the statutory requirements.
6.1 Protection of Human flaalth and the Environment
In order to protect human health and the environment, the contaminated
soils and contaminated ground water that exceed remedial action goals will
undergo a combination of treatment and containment. These media will be treated
and contained to meet the Performance Standards set forth in the 1991 ROD. and
modified in this ROD Amendment. The area where containment is a principal
element of the remedial action is the Bayou Disposal Area. At all other areas,
treatment by one or more of the specified technologies will be the primary means
of attaining the Performance Standards. Attainment of Performance Standards will
assure that the site risks fall within the target cancer risk range of 10"4 to 1O'e and
the non-carcinogenic hazard index will be reduced to, equal to, or less than one.
Attainment of the Performance Standards will insure that: 1) soil contaminants will
cease to act as a source of ground water contamination, such that any potential
future leaching of the remediated soils would not result in ground water
contaminant concentrations above the MCLs; and 2) exposure to the ground water
will not pose adverse effects to the potentially exposed future site population. No
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unacceptable short-term risks or cross-media impacts will be allowed during
implementation of the amended remedy.
6.2 Attainment of Applicable or Rulftvant and Appropriate R»quir»m»nta of
Environmental I awu«
The amended remedy will be performed in full compliance with all chemical,
location, and action-specific ARARs and other criteria, advisories and guidelines
which are applicable (i.e., surface water discharge limits established by the
TNRCC) or considered relevant and appropriate. ARARs are identified in Section
4.5 (Major Applicable or Relevant and Appropriate Requirements).
6.3 Coat Effaetl*i«>nns«
The USEPA believes that the amended remedy is cost-effective in mitigating
the principal threat waste and low level threat waste at the site. Section
300.430(f)(ii)(D) of the NCP requires the USEPA to determine cost-effectiveness
by evaluating the following three of the five balancing criteria to determine overall
effectiveness: long-term effectiveness and permanence; reduction of toxicity,
mobility or volume through treatment; and short-term effectiveness. Overall
effectiveness is then compared to cost to ensure that the remedy is cost effective.
The current estimated cost for the amended remedy is $20 million dollars. This
amount includes the $13.2 million dollars already expended during the extensive
remedial design field pilot study program. This represents a cost savings of $6.43
million dollars over the 1991 ROD.
6.4 UtiflyiiHon of P»mmrw*nt Solution* *r\ri Alfornativo Troiitmftnt
or Rn«ftiirca R«|oov«try Taohtiolonln* to thti Mft^r^tum Fittnnt
The USEPA believes the amended remedy includes to the maximum extent
practical permanent solutions and treatment technologies which can be utilized in
a cost-effective manner for the site. The USEPA is certain that the amended
remedy will provide the bast balance in considering long-term effectiveness and
permanence; reduction in toxicity, mobility or volume through treatment; short-
term effectiveness; implementability; and cost, as well as considering the statutory
preference for treatment as a principal element and considering State and
community acceptance.
•
The Amended ROD'S remedial treatment technologies in combination with
appropriate containment components (i.e.. living cap), complies with ARARs and
reduces the toxicity, mobility, and volume of the contaminants in the site soils and
ground water. The in-situ aspect of these alternatives was critical in choosing
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these alternatives based on the estimated volume of contaminated soils and
ground water requiring remedial action and the volatile nature of the site
contaminants. Short-term effectiveness and protection of human health and the
environment, as well as site remedial costs criterion, will be satisfied by the
amended remedy.
6.5 Prflfftranrn fnr Trflatnrumt «« a Principal
The amended remedy will satisfy the statutory preference for treatment as a
principal element. The primary risk to human health is from ingestion of and direct
contact with contaminated ground water. The amended remedy reduces levels of
site contaminants in ground water through treatment (in-situ aquifer
bioremedlation). The amended remedy also addresses the source areas by treating
the contaminated soils (the principal threat waste) by soil vapor extraction,
bioventing, aqueous phase bioremediation, biotreatment of excavated soils, soil
washing, and thermal desorption. Extracted contaminate-laden vapor from the In-
situ remediation systems will be treated by the catalytic thermal oxidation units.
Extracted contaminated ground water will be treated in the site's water treatment
plant. These remedy components will be combined with the containment
alternatives to contain the low level threat waste.
Because the amended remedy will result in hazardous substances remaining
on-site. a review will be conducted five years after commencement of the remedial
action to ensure that the remedy continues to provide adequate protection of
public health, welfare and the environment.
7.0 PQC1IMPMTAT10M OP S1QMICICAMT CHAMQCS
The State of Texas Is in concurrence with the selected amended remedy.
The Proposed Ran for the Petro-Chemlcal Systems, Inc. site ROD Amendment was
released for public comment In October 1997. The public comment period began
on October 22. 1997 and ended on November 20. 1997. A public meeting was
held at the site to provide the local community an opportunity to provide verbal
and/or written comments on the Proposed Plan. A court reporter was present to
record a transcript of the meeting. In addition to the court reporter, the USEPA
personnel, and TNRCC personnel, 16 persons attended the public meeting. The
USEPA has reviewed all written and verbal comments submitted during the public
comment period. Upon review of these comments, the USEPA has determined
that no significant changes to the amended remedy identified in the Proposed Plan
are necessary. Comments received during the public comment period are
addressed In the Responsiveness Summary (Appendix B).
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APPENDIX A
PETRO-CHEMICAL SYSTEMS, INC.
(TURTLE BAYOU)
SUPERFUND SITE
RECORD OF DECISION AMENDMENT
STATE OF TEXAS
LETTER
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Barry R. McBcc, Chairman
R. B. "Ralph* Marque*, Commissioner
John M. Baker, Commissioner
Dan Pearson, Ereaitivt Director
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TEXAS NATURAL RESOURCE CONSERVATION COMMISSION
Protecting Texas by Rtdudng and Prtvtnting Pollution
April 23, 1998
Mr. Myron O. Knudson, P.E., Director
Superfund Division
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Re: Petrochemical Systems, Inc. (Turtle Bayou) Superfund Site
Record of Decision (ROD) Amendment • April 1998
Dear Mr. Knudson:
Your letter to the Texas Natural Resource Conservation Commission (TNRCQ dated February
9, 1998, requested our concurrence on the Petro-Chemical Systems, Inc. (Turtle Bayou)
Superfund Site, Final ROD Amendment, February 1998. This ROD amendment was subsequently
modified. We recently received a letter from Mr. Chris Vfllareal. Project Manager, Superfund
Division, U.S. Environmental Protection Agency, Region 6, dated April 10, 1998, which
included a revised ROD Amendment, April 1998.
We have reviewed the proposed April 1998 ROD Amendment for the Petto<3«mical Systems,
Inc. Superfund Site, and concur oat this ROD Amendment is the most appropriate for mis site.
This ROD Amendment attains the Federal Applicable or Relevaiit and ApproprUte Requirements
(ARARs) as well as the substantive requirements of the State Risk Reduction Standards. The
substantive requirements include the residential surface soils and the residential groundwater
cleanup levels under Risk Reduction Standard No. 2.
This ROD amendment includes a calculated site-specific Residen**^ Soil-tc-Otoundwater Cross-
Media Protection Concentration for benzene using the Seasonal Soil Compartment Model
(SESOIL). Although the modeled conctntrationi are higher man the FCTJdfrt**1 s«n-to-Qround
Water Cross-Media Protection Concentration for benane under RRS No. 2, the TNRCC believes
the substantive requirements of RRS No. 2 will be attained by this ROD Amendment This
conclusion is based upon the requirement that additional soil remedial actions will be required if
Internet address: www.tnrccjtate.tx.us
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Mi. Myron O. Knudson, P.E., Director
Page 2
conclusion is based 1900 die requirement that additional soil remedial actions will be required if
the benzene groundwaier remediation criteria of 5 n%l\ cannot be ******** and/or maintained with
the calculated soil cleanup values.
If you have any questions please contact Mr. Alvie L. Nichols, Project Manager, at (512)239-
2439 or Ms. Nancy B. Overesch, Section Manager, at (512)239-2433.
DP/AN/b
cc: Mr. Chris Villareal, EPA Region 6
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APPENDIX B
PETRO-CHEMICAL SYSTEMS, INC.
(TURTLE BAYOU)
SUPERFUND SITE
RECORD OF DECISION AMENDMENT
RESPONSIVENESS SUMMARY
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APPENDIX B
PETRO-CHEMICAL SYSTEMS, INC.
(TURTLE BAYOU)
SUPERFUND SITE
RECORD OF DECISION AMENDMENT
RESPONSIVENESS SUMMARY
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PETRO-CHEMICAL SYSTEMS, INC. (TURTLE BAYOU) SITE
AMENDED RECORD OF DECISION
RESPONSIVENESS SUMMARY
This Responsiveness Summary has been prepared to provide written
responses to comments received on the USEPA's Amended Proposed Plan of
Action. The summary is divided into two sections.
Section I - Raftlcnround of Community lnvnl\/BfT>pnt and Concerns
This section provides a brief history of the community interest and concerns
in relation to the Petro-Chemical Systems, Inc. (Turtle Bayou) Superfund site (site).
There has been a long history of citizen awareness of the site. In 1971, when an
application was made with the State of Texas for a commercial industrial waste
disposal permit in the name of Petro-Chemical Systems, Inc., local citizens
organized to oppose the application. Due in part to the community's opposition to
the permit, State approval of me permit was withheld and the permit was
eventually withdrawn in 1974. More recently, with the exception of site property
owners and residents living on the site, community interest in the site has been
low. The low general community interest is probably due in part to the site's rural
location.
Section II - Snmrpary nf Major Cnmmants
Public notice announcing the public comment period and the public meeting
was published in the Liberty Vindicator on Saturday, October 18, 1997 and in the
Liberty Gazette on Wednesday, October 22, 1997. The public comment period
started October 22, 1997 and ended November 20, 1997. The Amended
Proposed Plan of Action was distributed through the mail during the week of
October 20, 1997 to all parties on the site's mailing list. Additionally, postcard
meeting reminders were mailed the week of October 27 to all parties on the site's
mailing list. On November 3, 1997 the public meeting was held at the site's office
area. The purpose of the meeting was to discuss the major components of the
Amended Proposed Plan of Action and to provide the local community an
opportunity to provide verbal and/or written comments on the Amended Proposed
Plan of Action. In addition to USEPA personnel, TNRCC personnel, and the court
reporter, 16 persons attended the public meeting.
The USEPA received a few oral comments during the public meeting as well
as one written comment received on October 28, 1997. Comments pertinent to
USEPA's Amended Proposed Plan of Action are summarized below, followed by
USEPA's response. A full account of the public meeting can be found in the
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public meeting transcripts. The pubic meeting transcripts are included in the site's
Administrative Record for this Amended ROD.
P.nMMPMTS RECEIVED AT TUP PURI ir MPFTINIR-
1. Comment - Mr. Donnjt* Taylor (landowner)!
Mr Taylor asked, 'What is your proposed realistic timetable for getting out
of here?"
USEPA Response;
The current estimate for completion of site remedial activities is January
2000. At that time, all site contractors will demobilize from the site and the
site's long-term monitoring will begin.
2. Comment - Mr. Dannie, Taylor (landowner)-
Mr. Taylor asked, "What are you going to do with the road [County Road
126] when you're done? Are we going to have a 50-cent patch job, what
we got now or are y'all going to put the road back into ... the same
condition it was when y'all all got here?"
IISFPA Response;
At the completion of remedial action activities, the road will be restored to
its previous condition. At the public meeting, an ARCO Chemical Company
representative stated that the entire road will essentially be repaved. Please
note, areas of this site that are not currently paved will not be paved.
Additionally, please note that the road was constructed to support light
residential traffic. Any potential heavy traffic loads (e.g., from logging
operations) may impact the quality of the road.
WRITTPM r.OMMEMTJS) REr.PtVPD nilRHsifi THE PURI 1C HOMMFNT PERIOD:
3. Mr. Hari Norman - affiliation {R A Sr.hriewftr Hauling - landowner);
"I would like to know exactly what areas are "Hot Spots* to determine how
my property is affected. Certainly my property has been de-valued due to
this action. Is tax abatement available & or enumeration because of my
potential loss?"
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USEPA Response: O
Site "Hot Spots" have been identified within the Main Waste Area, Office
Trailer Area, and the Easement Area. These areas are not on or adjacent to
the R.A. Schriewer Hauling Property. The ROD Amendment provides further
definition of what has been classified as a "hot spot.* In fact, as the R.A.
Schriewer Hauling property is not an area where soil and or ground water
contamination has been identified, this property will no longer be identified
as part of the Petro-Chemical Systems, Inc. (Turtle Bayou) Superfund site.
In regards to any tax abatement & or the enumeration of the taxable
property values, the USEPA has no authority to grant such relief.
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Prepared for
United States Environmental Protection Agency
Region 6
ADMINISTRATIVE RECORD INDEX
RECORD OF DECISION AMENDMENT
FOR
PETRO CHEMICAL/TURTLE BAYOU SUPERFUND SITE
OPERABLE UNIT 2
EPA DD No. TXD980873350
ESS VI
Work Assignment No. ESS8033
Chris Villarreal
Remedial Project Manager
U.S. EPA Region 6
Prepared by
TechLaw Incorporated
750 N St. Paul Street, Suite 600
Dallas, Texas 75201
April 30,1998
P. 6833.0681
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INTRODUCTION °
Section 113(j)(l) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), 42 U.S.C. Section 9613G)0)> 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
which 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 AR Index was compiled in accordance with Office of Solid Waste and
Emergency Response Directive Number 9833.3A-l, "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 file is compiled as documents related to the response action are being
generated. All documents that are clearly relevant and non-privileged 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 predominately 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. Documents attached to or referenced in the Proposed
Amended Record of Decision are incorporated by reference into the AR.
The AR file must be indexed. The index plays a key role in enabling both lead agency
staff and members of the public to help locate and retrieve documents included in the record file.
In addition, the index can be used for public information purposes or identifying documents
located elsewhere, such as those included in the compendium of guidance documents. The index
also serves as an overview of the history of the response action at the site. 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-hand 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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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
PETRO CHEMICAL/TURTLE BAYOU
TXD980873350
000001 - OOOOS8
12/22/93
58
Allyn M. Davis, Director, Hazardous Hast* Management Division
0.8. EPA Region 6
Jack Kramer, Director, Pollution Cleanup Division, Texas
Natural Resource Conservation Commission (TNRCC), et al.
Administrative Order
Remedial Design/Remedial Action (RD/RA) for Turtle Bayou
Superfund site
O
O
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000059 - 000087
08/12/94
29
John M. Cotterell, Inc.
Project Manager and Supervising Contractor for Respondents to
Unilateral Administrative Order (UAO)
U.S. EPA Region 6 Superfund Site Files
Work Plan
RD
DOCUMENT NUMBER:
DOCUMENT DATEi
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000088 - 000089
07/05/95
2
Community Involvement Section
U.S. EPA Region 6
Petro Chemical/Turtle Bayou Site Mailing Liet
Fact Sheet
EPA update on site activities
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000090 - 000092
07/19/95
3
Allyn M. Davis, Raxardous Waste Management Division Director
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site Files
Administrative Order
Administrative Order for Remedial Design and Remedial Action,
CERCLA Docket No. CERCLA 6-05-94
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SITE NAME:
SITE NUMBER«
DOCUMENT NUMBERi
DOCUMENT DATE:
NUMBER OP PAGESI
AUTHORt
COMPANY/AGENCYt
RECIPIENTS
DOCUMENT TYPE:
DOCUMENT TITLEt
ADMINISTRATIVE RECORD INDEX
FINAL
PETRO CHEMICAL/TURTLE BAYOU
TXD9808733SO
000254 - 000291
09/12/95
38
John M. Coterell, Inc.
Project Manager and Supervising Contractor for Respondents to
UAO
Petro Chemical Site Group and U.S. EPA Region 6 Super fund Site
Piles
Work Plan
Ambient Air Monitoring Plan
o
o
DOCUMENT NUMBERS
DOCUMENT DATBt
NUMBER OP PACES:
AUTHORS
COMPANY/AGENCYi
RECIPIENTi
DOCUMENT TYPE:
DOCUMENT TITLES
000292 - 000343
09/12/95
52
John M. Coterell, Inc.
Project Manager and Supervising Contractor for Respondents to
UAO
Petro Chemical Site Croup and U.S. EPA Region 6 Superfund Site
Files
Work Plan
Health and Safety Plan
DOCUMENT NUMBERS
DOCUMENT DATEs
NUMBER OP PAGESs
AUTHOR:
COMPANY/AGENCYs
RECIPIENTS
DOCUMENT TYPE!
DOCUMENT TITLE:
000344 - 000408
09/30/95
65
Petro Chemical Site Croup
Respondents to UAO
U.S. EPA Region 6
work Plan
Quality Assurance Project Plan
DOCUMENT NUMBERS
DOCUMENT DATE:
NUMBER OP PAGESi
AUTHORS
COMPANY/AGENCYs
RECIPIENTS
DOCUMENT TYPE:
DOCUMENT TITLE:
O00409 - 000528
09/30/95
120
John M. Coterell, Inc.
Project Manager and Supervising Contractor for Respondents to
UAO
Petro Chemical site Group and U.S. EPA Region 6 Superfund Site
Piles
Work Plan
Soil Vapor Extraction (SVB) and In-Situ Bior•mediation (ISB)
Field Pilot Tests
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DOCUMENT DATEt
NUMBER OP PAGESt
AUTHOR>
COMPANY/AGENCYi
RECIPIENT*
DOCUMENT TYPBt
DOCUMENT TITLEt
DOCUMENT NUMBERl
DOCUMENT DATBs
NUMBER OP PAGESt
AUTHORt
COMPANY/AGENCY>
RECIPIENT!
DOCUMENT TYPEt
DOCUMENT TITLEt
ADMINISTRATIVE RECORD INDEX
FINAL
PETRO CHEMICAL/TURTLE BAYOU
TXD980873350
000559 - 000560
03/30/96
2
Petro Chemical Sit* Group
RBBpondenti to DAO
U.S. EPA Region 6 and TNRCC
Report
March Progress Report is not physically included in the admin.
record (AR) located at Liberty Public Library, Liberty, TX,
due to the large amount of data generated for report. (Contact
Chris Villarreal, RPM, for further information about the
report.)
000561 - 000609
04/17/96
49
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chela VillarMl, RPM, U.S. EPA Region 6
Correspondence; Notice; Map
Request review and approval of refinement notices for
improving scope and results of field pilot study program
OO061O - 000611
04/30/96
2
Petro Chemical Site Group
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Report
The April Progress Report is not physically included in the AR
located at Liberty Public Library, Liberty, Texas due large
amount of data generated for the report. (Contact Chris G.
Villarreal, RPM, for further information about the report.)
000612 - 000615
05/30/96
4
Petro Chemical Site Group
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Report
The May Progress Report is not physically included in the AR
located at Liberty Public Library, Liberty, Texae due to large
amount of data generated for the report. (Contact Chris G.
Villarreal, RPM, for further information about the report.)
O
o
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ADMINISTRATIVE RECORD INDEX
FINAL
O
e>
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
PETRO CHEMICAL/TURTLE BAYOU
TXD9808733SO
000616 - 000619
06/30/96
4
Petro Chemical Site Croup
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Report
The June Progress Report ie not physically included in the AR
located at Liberty Public Library, Liberty, Texas due to large
amount of data generated for the report. (Contact Chris C.
Villarreal, RPM, for further information about the report.)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000620 - 000627
07/19/96
B
Alvie L. Nichols, Pollution Cleanup Division
TNRCC
Chris O. Villarreal, RPM, U.S. EPA Region 6
Facsimile Transmittal; Permit
Standard exemptions
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT!
DOCUMENT TYPE:
DOCUMENT TITLE:
000628 - 000649
07/25/96
22
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Application
Application for Standard Exemption Number 68 for emissions
from SVE Test Unit
DOCUMENT NUMBER*
DOCUMENT DATE:
NUMBER OP PACKS:
AUTHORI
COMPANY/AGENCY:
RECIPIENT!
DOCUMENT TYPE:
DOCUMENT TITLE:
000650 - O006S6
07/30/96
7
Terry Gulliver
Applied Hydrology Associates, Inc.
R.L. Sloan, Manager, Remediation, ARCO Chemical Company, Jim
Thomson and Mark Collins, ARCO Chemical Company
Memorandum
Work Plan: Resource Conservation Recovery Act Vault Hells
-------
ADMINISTRATIVE RECORD INDEX
FINAL
o
o
SITE NAMB:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATEs
NUMBER OF PAGES:
AUTHORi
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPBs
DOCUMENT TITLE:
PETRO CHEMICAL/TURTLE BAYOU
TXD980873350
000657 - 000660
07/30/96
4
Patro Chemical Site Group
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Report
The July Progress Report is not physically included in the AR
located at Liberty Public Library, Liberty, Texas due to large
amount of data generated for the report. (Contact Chris C.
villarreal, RPM, for further information about the report.)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR*
COMPANY/AGENCYt
RECIPIENTi
DOCUMENT TYPE:
DOCUMENT TITLEi
000661 - 000661
08/05/96
1
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence
Use of thermal oxldirer during SVE field pilot study program
DOCUMENT NUMBER:
DOCUMENT DATEl
NUMBER OF PAGESi
AUTHOR:
COMPANY/AGENCYi
RECIPIENTS
DOCUMENT TYPE:
DOCUMENT TITLES
000662 - 000663
08/14/96
2
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris 0. Villarreal, RPM, U.S. EPA Region 6
Correspondencei Sampling t Analysis
Analytical results on collected TO-1 (Tenax) and TO-14 (S
Canister) samples
DOCUMENT NUMBER:
DOCUMENT DATBs
NUMBER OF PAGES:
AUTHORS
COMPANY/AGENCY:
RECIPIENT!
DOCUMENT TYPE:
DOCUMENT TITLEt
000664 - 000670
08/14/96
7
Steven G. Stance1
Applied Hydrology Associates, Inc.
R.L. Sloan, Manager, Remediation, ARCO Chemical Company
Memorandum; Maps
Deep soils characterization
-------
(N
ADMINISTRATIVE RECORD INDEX
FINAL
o
o
SITE NAME: PBTRO CHEMICAL/TURTLE BAYOU
SITE NUMBER: TXD980873350
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PACKSt
AUTHORS
COMPANY/AGENCY:
RECIPIENT*
DOCUMENT TYPES
DOCUMENT TITLEi
000671 - 000677
08/28/96
7
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris O. Villarraal, RPM, U.S. EPA Region 6
Memorandum; Maps
Mape showingi 1) extent of affected soil; 2) existing cleanup
area; and 3) proposed cleanup area
DOCUMENT NUMBER:
DOCUMENT DATE.
NUMBER OP PAGESs
AUTHORi
COMPANY/AGENCYt
RECIPIENT:
DOCUMENT TYPEI
DOCUMENT TITLEi
000678 - 000682
08/30/96
5
Petro Chemical Site Group
Respondent* to UAO
U.S. EPA Region 6 and TNRCC
Report
The August Report is not physically included in the AR located
at Liberty Public Library, Liberty, Texas due to large amount
of data generated for the report. (Contact Chris G.
Villarreal, RPM, for further information about the report.)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PACES:
AUTHORl
COMPANY/AGENCYi
RECIPIENT!
DOCUMENT TYPEI
DOCUMENT TITLE:
000683 - 000686
09/30/96
4
Petro Chemical Site Group
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Report
The September Report is not physically included in the AR
located at Liberty Public Library, Liberty, Texas due to large
amount of data generated for the report. (Contact Chris. 0.
Villarreal, RPM, for further information about th» report.)
DOCUMENT NUMBERJ
DOCUMENT DATE!
NUMBER OP PAGESi
AUTHOR!
COMPANY/AGENCYi
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
OOO687 - 000689
10/16/96
3
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Drawing
Shallow soil remediation strategy
-------
ADMINISTRATIVE RECORD INDEX
FINAL
o
o
SITE NAME: PKTRO CHEMICAL/TURTLE BAYOU
SITE NUMBER: TXD980873350
DOCUMENT NUMBER:
DOCUMENT DATEt
NUMBER OP PACES:
AUTHORi
COMPANY/AGENCY t
RECIPIENT:
DOCDMBNT TYPBt
DOCUMENT TITLES
000690 - 000708
10/18/96
19
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chrla G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Work Plan
Wall installation plan for MH-34 ISB and SVE systems
DOCUMENT NUMBER:
DOCUMENT DATEi
NUMBER OF PAGESs
AUTHORI
COMPANY/AGENCYI
RECIPIENTi
DOCUMENT TYPEi
DOCUMENT TITLE;
000709 - 000710
10/21/96
2
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris O. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Drawing
Remediation area designation
DOCUMENT NUMBER:
DOCUMENT DATEt
NUMBER OF PAGESi
AUTHORt
COMPANY/AGENCYI
RBCIPIEMTt
DOCUMENT TTPEi
DOCUMENT TITLE*
000711 - 000719
10/22/96
9
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. XPA Region 6
Correspondence; Work Plan <
MW-10 Unit (Area J) Well Installation Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES«
AUTHORl
COMPANY/AGENCY:
RECIPIENT!
DOCUMENT TYPE:
DOCUMENT TITLEi
000720 - 000722
10/23/96
3
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, O.s. EPA Region 6
Correspondence; Drawing
Process flow diagram for groundwater treatment plant
-------
ADMINISTRATIVE RECORD INDEX
O
O
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES>
AUTHOR:
COMPANY/AGENCY:
RECIPIENTI
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
PETRO CHEMICAL/TURTLE BAYOU
TXD980873350
000723 - 000733
10/24/96
11
R.L. Sloan/ Manager, Remediation
ARCO Chemical Company
Chris O. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Work Plan; Map
Area K and Area L ISB design
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER 07 PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPSs
DOCUMENT TITLE:
000734 - 000737
10/30/96
4
Petro Chemical Site Croup
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Report
The October Progress Report is not physically included in AR
located at Liberty Public Library, Liberty, Texas due to large
aaount of data generated for the report. (Contact Chris G.
Villarreal, RPM, for further information about the report.)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHORt
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000738 - 000741
11/06/96
4
Skip Meier
Applied Hydrology Associates, Inc.
R.L. Sloan, Manager, Remediation, ARCO Chemical company
Memorandum; Sampling & Analysis
Reepirometry testing program at BS3 and MW6 SVE test areas
DOCUMENT NUMBER:
DOCUMENT DATBt
NUMBER OP PAGES:
AUTHORi
COMPANY/AGENCY:
RECIPIENTi
DOCUMENT TYPB.
DOCUMENT TITLEi
000742 - 000744
11/08/96
3
Terry Gulliver
Applied Hydrology Associates, Inc.
R.L. Sloan, Manager, Remediation, ARCO Chemical Company
Memorandum
Bayou disposal area work plan
10
-------
«0
ADMINISTRATIVE RECORD INDEX
FINAL
SITE NAME! PETRO CHEMICAL/TURTLE BAYOU
SITE NUMBER: TXD980873350
o
o
DOCUMENT NUMBER:
DOCUMENT DATEt
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENTI
DOCUMENT TYP1:
DOCUMENT TITLEt
000745 - 000756
11/13/96
12
Steven G. Stancel
Applied Hydrology Associates, Inc.
R.L. Sloan, Manager, Remediation, AROO Chemical Company
Memorandum; Drawing;
Continued MW-06 area hot epot excavation
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHORt
COMPANY/AGSMCY:
RECIPIENT>
DOCUMXNT TTPKs
DOCUMENT TITLE:
000757 - 000760
11/13/96
4
Steven C. Stance!
Applied Hydrology Associate*, Inc.
R.L. Sloan, Manager, Remediation, ARCO chemical Company
Memorandum; Map
Definition soil borings, K Zone, MW-10 area
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHORl
COMPANY/AGENCY:
RECIPIENT!
DOCUMENT TYPE:
DOCUMENT TITLE:
000761 - 000765
11/15/96
5
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chrie G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Work Plan
MW-10 (South) area definition
DOCUMENT NUMBER:
DOCUMENT DATE i
NUMBER OF PAGES:
AUTHORS
COMPANY/AGENCYi
RECIPIENT:
DOCUMENT TYPES
DOCUMENT TITLEt
000766 - 000769
11/19/96
4
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chrie O. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Work Plan
Definition borings, MW-10 South area (K zone)
11
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR*
COMPANY/ACINCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
PETRO CHEMICAL/TURTLE BAYOU
TXD980873350
000770 - 000773
11/20/96
4
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chrii 0. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Work Plan
Expansion, MW-67 Z8B system
o
o
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCYi
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000774 - 000790
11/21/96
17
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence! Sampling & Analysis; Graph
Soil remediation criteria, SESOIL modeling
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHORt
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPEt
DOCUMENT TITLEi
000791 - 000810
11/22/96
20
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report; Sampling t Analysis
Ambient air management
DOCUMENT NUMBERS
DOCUMENT DATEI
NUMBER OF PACKSS
AUTHORi
COMPANY/AGENCYi
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
OOO811 - 000815
11/25/96
s
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum; Sampling & Analysis
Biovanting/respirtMoetry test plan
12
-------
ADMINISTRATIVE RECORD INDEX
o
o
SITE NAHBi
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
HUMBKR OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLEi
FINAL
PETRO CHEMICAL/TURTLE BAYOU
TXD980873350
000816 - 00082S
11/26/96
10
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
ChriB C. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum; Map
MW-67 area (Zone P) ISB System
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT*
DOCUMENT TYPE:
DOCUMENT TITLEi
000826 - 000829
11/26/96
4
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum
SVB wella, MW-67 area (N and P Zone*)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000830 - 000832
11/26/96
3
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris O. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum; Map
Deep well sampling
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000833 - OOO841
11/27/96
9
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris O. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum
ISB system MW-10 south area (lone K)
13
-------
00
SITS NAME:
SITE NUMBERi
DOCUMENT NUMBER:
DOCUMENT DATEt
NUMBER OF PAGESi
AUTHOR:
COMPANY/AGENCYi
RECIPIENTi
DOCUMENT TYPEI
DOCUMENT TITLBt
ADMINISTRATIVE RECORD INDEX
FINAL
PETRO CHEMICAL/TURTLE BAYOU
TXD980873350
000842 - 000845
11/30/96
4
Petro Chemical Site Group
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Report
The November Progress Report Lm not physically included in the
AR located at Liberty Public Library. Liberty, Texas due to
large amount of data generated for the report. (Contact Chris
G. Vlllarreal, RPM, for further information about the report.)
O
o
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000846 - 000853
12/02/96
8
R.L. Sloan, Manager, Remediation
U.S. EPA Region 6
Chris G. Viliarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum; sampling ft Analysis
MU-34 SVB system
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGESi
AUTHOR:
COMPANY/AGENCY:
RECIPIENT!
DOCUMENT TYPE:
DOCUMENT TITLE:
000854 - 000855
12/10/96
2
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chria G. Villarreal, RPM, U.S. EPA Region 6
Correspondence
Remediation technology
DOCUMENT NUMBER:
DOCUMENT DATS:
NUMBER Or PAGES:
AUTHOR:
COMPANY/AOEMCnr t
RECIPIENTt
DOCUMENT TYPE:
DOCUMENT TITLE:
000856 - 000859
12/11/96
4
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum
RCRA vault air injection
14
-------
ON
ADMINISTRATIVE RECORD INDEX
FINAL
SITE MANX: PETRO CHEMICAL/TURTLE BAYOU
SITE NUMBERS TXD980873350
o
o
DOCUMENT NUMBERt
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHORS
COMPANY/AGENCYs
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLES
000860 - 000865
12/16/96
6
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum; Map
Easement area XSB construction
DOCUMENT NUMBERS
DOCUMENT DATEs
NUMBER 07 PAGESs
AUTHORS
COMPANY/AGENCY s
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TXTLBs
000866 - 000897
12/20/96
32
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
RCRA Vault Characterization Report
DOCUMENT NUMBERS
DOCUMENT DATEs
NUMBER OF PACESs
AUTHORS
COMPANY/AGENCYs
RECIPIENTi
DOCUMENT TYPE:
DOCUMENT TITLE:
000898 - 000901
12/30/96
4
Petro Chemical Site Group
Respondent* to UAO
U.S. EPA Region 6 and TNRCC
Report
The December Progress Report is not physically included in the
AR located at Liberty Public Library, Liberty, Texas due to
large amount of data generated for the report. (Contact Chris
G. Villarreal, RPM, for further information about report.)
DOCUMENT NUMBERi
DOCUMENT DATSs
NUMBER OF PAGESt
AUTHORS
COMPANY/AGENCYs
RECIPIENTS
DOCUMENT TYPES
DOCUMENT TITLES
000902 - 000907
01/08/97
6
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris O. Villarreal, RPM, D.S. EPA Region 6
Correspondence; Memorandum
D-Zone (MW-4S) ISB System
IS
-------
Sin NAME:
SITE NUHBBR:
ADMINISTRATIVE RECORD INDEX
FINAL
PBTRO CHEMICAL/TURTLE BAYOU
TXD9808733SO
O
o
DOCUMENT NUMBER:
DOCUMENT DATEl
NUMBER OP PAGESs
AUTHORS
COMPANY/AGENCYt
RECIPIENT!
DOCUMENT TYPE:
DOCUMKNT TITLE>
000908 - 000910
01/08/97
3
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris O. Villarraal, RPM, U.S. EPA Region 6
Corregpondancai Drawing
Piping and instrumentation drawings for injection water eyst«
DOCUMENT NUMBER!
DOCUMENT DATE:
NUMBER OP PAGESI
AUTHOR!
COMPANY/AGENCYt
RECIPIENT!
DOCUMENT TYPE!
DOCUMENT TITLE!
000911 - 000917
01/17/97
7
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris C. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum
Hell installation plan for D-Zona (B-S3)/MH-45 area) ISB
•tarter system
DOCUMENT NUMBERS
DOCUMENT DATSI
NUMBER OF PAGES:
AUTHOR!
COMPANY/AGENCY!
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
OOO918 - O00918
01/20/97
1
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence
Soil Criteria Assessment Report
DOCUMENT NUMBER I
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHORI
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
OOO919 - OOO919
01/23/97
1
Chris o. Villarreal, RPM
U.S. KPA Region 6
Terrence M. Lyons, Superfund Technical Response Team Leader,
National Risk Management Research Laboratory, U.S. SPA, Ada,
Oklahoma
Memorandum
Soil Criteria Assessment
-------
ADMINISTRATIVE RECORD INDEX
FINAL
SITE NAME: PBTRO CHEMICAL/TURTLE BAYOU
SITE NUMBER: TXD980873350
o
o
DOCUMENT NUMBBRi
DOCUMENT DATE«
NUMBER OT PAGES:
AUTHORi
COMPANY/AOKHOfi
RECIPIENTS
DOCUMENT TYPBs
DOCUMENT TITLEi
000920 - 000923
01/27/97
4
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarraal, RPM, U.S. EPA Region 6
Correspondence; Map*
Survey naps for 1) West Road area; 2) Main Haste area; 3)
Office Trailer area; and 4) Basement area
DOCUMENT NUMBER:
DOCUMENT DATEt
NUMBER OP PAGESt
AUTHORt
COMPANY/AGENCYi
RECIPIENT:
DOCUMENT TYPBs
DOCUMENT TZTLBi
OOO924 - 000943
01/28/97
20
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region
Correspondence; Report
Summary of status of Turtle Bayou project
DOCUMENT NUMBERi
DOCUMENT DATEi
NUMBER OF PAGES:
AUTHORi
COMPANY/AGENCYi
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000944 - 000950
01/29/97
7
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum ;Map
Hell installation plan for office trailer area (Cones P and H)
ISB system
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
O00951 - 000974
01/30/97
24
Unspecified
TMRCC
U.S. EPA Region 6 Superfund Site Piles
Permit
TNRCC Standard Exemption No. 68
17
-------
SITS NAME:
SITE NUMBER!
ADMINISTRATIVE RECORD INDEX
FINAL
PBTRO CHEMICAL/TURTLE BAYOU
TXD980873350
o
o
DOCUMENT NUMBER:
DOCUMENT DATBt
NUMBER OP PAGES:
AUTHORS
COMPANY/AGENCYt
RECIPIENT:
DOCUMENT TYPE*
DOCUMENT TITLEi
000975 - 000981
01/30/97
7
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum; Map
Well installation plan for main waste area (Zone B) ISB syst«
DOCUMENT NUMBERt
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHORi
COMPANY/AGENCYt
RECIPIENT:
DOCUMENT TYPE i
DOCUMENT TZTLBt
000982 - 000985
01/30/97
4
Petro Chemical Site Group
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Report
The January Progress Report is not physically included in the
AR located at Liberty Public Library, Liberty, Texas due to
large amount of data generated for the report. (Contact Chris
G. Villarreal, RPM, for further information about the report.)
DOCUMENT NUMBER:
DATES
DUMBER OP PAGESt
AUTHORi
COMPANY/AGENCYt
RECIPIENTt
DOCUMENT TYPBs
TITLES
000986 - 001338
01/30/97
353
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris O. Villarreal, RPH, 0.8. EPA Region 6
Correspondence; Report
MW-34 (Heat Road Area, Cone A) Definition/Field Study Report
DOCUMENT NUMBERi
DOCUMENT DATES
NUMBER OF PAGESs
AUTHORS
COMPANY/AOKHCYi
RECIPIENT)
DOCUMENT TYPEs
DOCUMENT TITLES
001339 - 001344
01/31/97
6
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. SPA Region 6
Correspondence i Memorandum
Work Plan for second set of respirometry tests
18
-------
ADMINISTRATIVE RECORD INDEX
o
o
SITS MAKEI
SITS NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATS:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
FINAL
PBTRO CHEMICAL/TURTLE BAYOU
TXD980673350
001345 - 001381*
02/11/97
37
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Design report for Meet Road area
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001382 - 001385
02/11/97
4
W. Jared Fuqua, Project Manager
rluor Daniel, Inc.
Chrle G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Sampling fi Analysis
Comments for Soil Criteria Assessment (January 1997 review)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001386 - 001386
02/19/97
1
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence
Registration for TNRCC Standard Exemption No. 68 (MH-67 Area)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLEi
001387 - 001391
02/19/97
5
R.L. Sloan, Manager, Remediation
ARCO chemical Company
Chrii 6. VLLlarrtal, RPM, 0.8. EPA Region 6
correspondence; Memorandum; Map
Monitoring well in vicinity of NH-13, Basement Area,
Unit, North Zone
MW-67
19
-------
3
SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
PBTRO CHEMICAL/TURTLE BAYOU
TXD9808733SO
o
o
DOCUMENT MUMBBR:
DOCUMENT DATSi
MUMBBR OF PACKS:
AUTHORt
COMPANY/AGENCY»
RECIPIENTS
DOCUMENT TYPE:
DOCUMENT TITLE:
001392 - 001396
02/20/97
S
R.I. Sloan, Manager, Remediation
ARCO Chemical Company
Chris C. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum; Map
Main Waste Area remediation
DOCUMENT NUMBER:
DOCUMENT DATE.
NUMBER OP PACES:
AUTHORI
COMPANY/AGENCY<
RECIPIENTl
DOCUMENT TYPE:
DOCUMENT TITLE:
001397 - 001627
02/21/97
231
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chria G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
KW-10 Site Characterization and Field Pilot Teat Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
3JMBMT TYPE:
DOCUMENT TITLE:
001628 - 001633
02/28/97
6
Chria G. Villarreal, RPM
U.S. EPA Region 6
R.L. Sloan, Manager, Remediation, ARCO Chemical Company
Correspondence; Memorandum
Review commenta from EPA'a National Riak Management Research
Laboratory on Soil Criteria Assessment
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLEt
001634 - O01637
02/28/97
4
Petro Chemical Site Group
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Report
The February Progress Report is not physically included in the
AR located ate Liberty Public Library, Liberty, T«ic«« du« to
large amount of data generated for the report. (Contact Chris
G. Villarreal, RPM, for further information about report.)
20
-------
ADMINISTRATIVE RECORD INDEX
FINAL
o
o
SITE NAMEi PBTRO CHEMICAL/TURTLE BAYOO
SITE NUMBERt TXD9808733SO
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACESi
AUTHOR:
COMPANY/AGENCY:
RECIPIENTt
DOCUMENT TYPE:
DOCUMENT TITLEt
001638 - 001639
03/20/97
2
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris C. Villarraal, RPM, U.S. EPA Region 6
Correspondence; Sampling & Analysis
Croundwater Treatment Plant Discharge Report
DOCUMENT NUMBER:
DOCUMENT DATE!
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT*
DOCUMENT TYPE:
DOCUMENT TITLE:
001640 - 002025
03/20/97
386
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris C. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
MH-67 Unit (Easement Area) Site Characterisation and Field
Pilot Test Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCYi
RECIPIENTl
DOCUMENT TYPE:
DOCUMENT TITLEt
002026 - 002028
03/21/97
3
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum
Focused work plan for dual media extraction system for F-Sone
of Office Trailer area
DOCUMENT NUMBERi
DOCUMENT DATE:
NUMBER OF PAGESs
AUTHORS
COMPANY/AGENCYi
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002029 - 002330
03/25/97
302
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Soil Criteria Assessment, Revised March 1997
21
-------
SITS NAME:
SITB NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY«
RECIPIENT!
DOCUMENT TYPE:
DOCUMENT TITLE»
ADMINISTRATIVE RECORD INDEX
JINAL
PBTRO CHEMICAL/TURTLE BAYOU
TXD980873350
002331 - 002334
03/30/97
4
Petro Chemical Site Group
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Report
The March Progress Report i» not physically included in the AR
located at Liberty Public Library, Liberty, Texas due to large
amount of data generated for the report. (Contact Chris G.
Villarreal, RPM, for further information about report.)
o
o
DOCUMENT NUMBERi
DOCUMENT DATEi
NUMBER OP PACKS>
AUTHOR!
COMPANY/AGENCY:
RECIPIENTi
DOCUMENT TYPSt
DOCUMENT TITLEt
00233S - 002338
04/01/97
4
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris C. Villarreal, RPM, U.S. EPA Region 6
Correspondencei Memorandum
Soil-moisture profiling
DOCUMENT NUMBER!
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLEi
002339 - 002344
04/02/97
6
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Memorandum; Map
ISB System Refinements
DOCUMENT NUMBERt
DOCUMENT DATE:
NUMBER OF PACKSI
AUTBORt
COMPANY/AOKNCTI
RECIPIENTt
DOCUMENT TYPE:
DOCUMENT TITLE:
002345 - 002349
04/07/97
5
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence
Response to 03/20/97 letter requesting information on pilot
test for which standard exemption requested on 07/25/96
22
-------
ADMINISTRATIVE RECORD INDEX
SITE NAKEi
SITE NUMBERi
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER Or PACES:
AUTHORl
COKPANY/AGBHCYl
RECIPIBNTt
DOCUMENT TYPE:
DOCUMENT TITLEi
FINAL
PBTRO CHEMICAL/TURTLE BAYOU
TXD980873350
002350 - 002355
04/08/97
6
R.L. Sloan, Manager, Ranadiation
ARCO Chemical Company
Chris C. Villarreal, RPM, O.S. BPA Region 6
Corraapondence; Oraph
Soil moisture content related to aoil criteria aai
•nt
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES1
AUTHORt
COMPANY/AGENCYl
RECIPIENT:
DOCUMENT TYPE I
DOCUMENT TITLE:
002356 - 002359
04/14/97
4
Terry Gulliver
ARCO Chemical Company
R.L. Sloan, Manager, Remediation and Jim Thomson, ARCO
Chemical Company
Memorandum; Oraph
Repeated aoil profiles for Soils Criteria Assessment report
DOCU]
NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002360 - 002362
04/15/97
3
W. Jared Fuqua, Project Manager and Robert 1C. Franke, ARCS
Program Manager
Fluor Daniel, Inc.
Chris 0. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Additional review comments of Soil Criteria Assessment (March
1997 Revlaw)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY t
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002363 - 003044
04/15/97
682
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Definition report for B-53/MN-45 area (west end of Office
Trailer area)
23
-------
oo
SITS NAMEt
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
PBTRO CHEMICAL/TURTLE BAYOU
TXD980873350
o
o
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR!
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPEs
DOCUMENT TITLE:
003045 - 003784
04/23/97
740
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
MH-19/MH-42 Unit Sit* characterization and Field Pilot Study
Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003785 - 003786
04/30/97
2
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chria G. Villarreal, RPM, U.S. EPA Region 6
Correspondence
Soil remediation criteria
DOCUMENT NUMBER:
DOCUMENT DATEs
NUMBER OP PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003787 - 003790
04/30/97
4
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Graph
Repeated soil profiles for Soils Criteria Assesi
•nt Report
DOCUMENT NUMBER:
DOCUMENT DATKt
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCYi
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLES
003791 - 003794
O4/3O/97
4
Petro Chemical site Group
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Report
The April Report is not physically included in the AR located
at Liberty Public Library, Liberty, Texas due to large amount
of data generated for report. (Contact Chris Villarreal, RPM,
for further information about report.)
24
-------
O\
SITE NAMEi
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
PBTRO CHEMICAL/TURTLE BAYOU
TXD980873350
003795 - 003802
05/09/97
8
Chris G. Villarreal, RPM
U.S. EPA Region 6
R.L. Sloan, Manager, Remediation, ARCO Chemical Company
Correspondence; Memorandum; Report
Review comments on revised Soil Criteria Assessment Report
o
o
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCYi
RECIPIENTS
DOCUMENT TYPE:
DOCUMENT TITLE:
003803 - 003806
05/20/97
4
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris C. Villarrnl, RPM, U.S. EPA Region 6
Correspondence; Memorandum; Map
Work plan to install 2 additional wells in A-Zone to better
define east end and west end of active remediation area
DOCUMENT NUMBER:
DOCUMENT DATS:
NUMBER OP PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003807 - 003831
05/28/97
25
Steven G. Stancel
Applied Hydrology Associates, Inc.
R.L. Sloan, Manager, Remediation, ARCO Chemical Company
Memorandum; Table; Map; Graph
Infiltration study water level data
NUMBERt
DOCUMENT DATE:
NUMBER OP PACESi
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003832 - 003835
05/29/97
4
Terry Gulliver
Applied Hydrology Associates, Inc.
R.L. Sloan, Manager, Remediation, ARCO Chemical Company
Memorandum
Clarification of derivation of some soil parameters
25
-------
SITE NAME:
SITS NUMBER!
DOCUMENT NUMBER:
DOCUMENT DATEi
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY*
RECIPIENT:
DOCUMENT TYPEi
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
PBTRO CHEMICAL/TURTLE BAYOU
TXD980873350
003836 - 003839
05/30/97
4
Petro Chemical Site Group
Respondents to OAO
U.S. EPA Region 6 and TNRCC
Correspondence
The May Progress Report is not phyeieally included in the AR
located at Liberty Public Library, Liberty, Texas due to large
amount of data generated for the report. (Contact Chris G.
Villarreal, RPM, for further information about report.)
o
o
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHORi
COMPANY/AGENCY t
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003840 - 004127
06/03/97
288
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Design report for east section of Office Trailer Area, MN-10
area (J and K tones)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHORt
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE!
DOCUMENT TITLEt
004128 - 004307
06/04/97
180
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Design report for west end of office Trailer Area,
(D Zone)
B-53/MH-45
DOCUMENT NUMBERI
DOCUMENT DATS:
NUMBER OP PACESi
AUTHOR!
COMPANY/AGENCYt
RECIPIENT!
DOCUMENT TYPE!
DOCUMENT TITLE:
004308 - OO4765
06/06/97
458
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris O. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Design report for Basement area or MW-67 area (N and P Zones)
26
-------
SITE NAMEI
SITE NUMBER:
DOCUMENT NUMBBR:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCYi
RECIPIENTi
DOCUKBNT TYPEl
DOCUMENT TITLEI
ADMINISTRATIVE RECORD INDEX
FINAL
PETRO CHEMICAL/TURTLE BAYOU
TXD9808733SO
004766 - 004907
06/09/97
142
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence) Report
Site Characterization and Field Pilot study (Text)
o
o
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCYt
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004908 - 005734
06/09/97
827
ARCO Chemical Company
Respondent* to UAO
U.S. EPA Region 6
Report
Site Characterization and Field Pilot Test Report (Appendices
A-B)
DOCUMENT NUMBBRi
DOCUMENT DATE!
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMBNT TYPE:
TITLE:
005735 - 005739
06/16/97
5
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence
Technology sequencing
DOCUMENT NUMBER:
[NT DATE:
NUMBER OF PACES:
AUTHOR:
COKPAKY/ACKNCYt
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
OOS740 - 005996
06/30/97
257
R.L. Sloan, Manager, Rieowdiation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region
Correspondence; Report
Main Haste Area Design Report
27
-------
fS
ADMINISTRATIVE RECORD INDEX
FINAL
o
o
SITE NAME:
SITE NUMBER!
DOCUMENT NUMBER:
DOCUMENT DATEi
NUMBER Or PAGES:
AUTHORi
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE<
DOCUMENT TITLEi
PETRO CHEMICAL/TURTLE BAYOU
TXD980873350
005997 - 006000
06/30/97
4
Petro Chemical Site Group
Respondents to UAO
U.S. EPA Region 6 and TNRCC
Correspondence
The June Progress Report is not physically included in the AR
located at Liberty Public Library, Liberty, Texas due to large
amount of data generated tor the report. (Contact Chris C.
Villarreal, RPM, for further information about report.)
DOCUMENT NUMBERt
DOCUMENT DATES
NUMBER OP PAGESt
AUTHORt
COMPANY/AGENCYi
RECIPIENTi
DOCUMENT TYPE:
DOCUMENT TITLE:
006001 - 006195
07/02/97
195
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris C. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Design report for Office Trailer Area, MN-19/MW-42 unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMEMT TYPE:
DOCUMENT TITLE:
006196 - 006209
07/02/97
14
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Groundwater remediation progress sampling plan for July 1997
DOCUMENT
DOCUMENT
NUMBER:
DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006210 - 006235
07/23/97
26
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Sampling Ł Analysis
Clay permeability testing results comparing 'hot spot* areae
with 'background* areas
28
-------
m
ADMINISTRATIVE RECORD INDEX
FINAL
o
o
SITE NAMES PETRO CHEMICAL/TURTLE BAYOO
SITE MUMBERi TXD980873350
DOCUMENT NUMBER:
DOCUMENT DATEl
NUMBER OT PACESt
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006236 - 0062S4
07/24/97
19
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris O. Villarreal, RPM, U.S. BPA Region 6
Correspondence; Sampling t Analysis
Infiltration results
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006255 - 006261
07/28/97
7
R.L. Sloan, Manager, Remediation
ARCO Chemical company
Chris O. Villarreal, RPM, U.S. EPA Region 6
correspondence; Sampling & Analysis
Permeability testing. Phase 3
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER Or PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006262 - 00630S
07/30/97
44
ARCO Chemical Company
Unspecified
U.S. EPA Region 6
Report
Vault Area Design Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006306 - 006309
07/30/97
4
Petro Chemical Site Croup
Respondents to UAO
U.S. BPA Region 6 and TNRCC
Correspondence
The July Progress Report is not physically included in the AR
located At Liberty Public Library, Liberty, Texas due to large
amount of data generated for the report. (Contact Chris O.
Villarreal, RPM, for further information about the report.)
29
-------
SITE NAME:
SITK NUMBERt
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHORi
COMPANY/AGENCYl
RECIPIENTi
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
PETRO CHEMICAL/TURTLE BAYOD
TXD9808733SO
006310 - 006340
07/30/97
31
R.L. Sloan, Manager, Remediation
ARCO Chatnlcal Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence* sampling & Analysis
Flow path langtha
O
o
DOCUMENT NUMBERI
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006341 - 006369
08/13/97
29
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Sampling fi Analysis
•Hot Spot* Response Plan
DOCUMENT NUMBERt
DOCUMENT DATE:
NUMBER OF PAGESt
AUTHORI
COMPANY/AGENCY:
RECIPIENT>
DOCUMENT TYPEi
DOCUMENT TITLE:
006370 - 006373
08/13/97
4
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence
Soil parameter*
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT)
DOCUMENT TYPE:
DOCUMENT TITLE:
006374 - 006377
08/14/97
4
R.L. Sloan, Manager, Remediation
ARCO Chemical company
Chris 6. Villarreal, RPM, U.S. EPA Region 6
Correspondence
Work plan, 'hot spot* evaluation
30
-------
ADMINISTRATIVE RECORD INDEX
FINAL
f-
O
o
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPEI
DOCUMENT TITLE:
PBTRO CHEMICAL/TURTLE BAYOU
TXD980873350
006378 - 006405
08/18/97
28
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris O. Vi liar real, RPM, U.S. EPA Region 6
Correspondence
Rainfall Infiltration
DOCUMENT NUMBERI
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLEi
006406 - 006416
08/19/97
11
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chrie G. Villarreal, RPM, U.S. EPA Region 6
Correspondence
August 1997 groundwater progress sampling plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPEt
DOCUMENT TITLE:
006417 - 006426
08/20/97
10
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence
Soil vapor sampling
DOCUMENT NUMBER:
DOCUMENT DATS:
NUMBER OF PAGES:
AUTHOR]
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006427 - 006428
08/25/97
2
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM. U.S. EPA Region 6
Correspondence
Construction and maintenance cost estimate for Bayou Disposal
area cap
31
-------
ADMINISTRATIVE RECORD INDEX
FINAL
SITE NAME: PETRO CHEMICAL/TURTLE BAYOU
SITE NUMBERt TXD980873350
o
o
DOCUMENT NUMBER t
DOCUMENT DATE:
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006429 - 006433
08/26/97
S
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris C. Villarreal, RPM, U.S. EPA Region 6
Correspondence
Affected soil definition
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY t
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006434 - 006437
08/30/97
4
Petro Chemical Site Croup
Reapondente to UAO
U.S. EPA Region 6 and TNRCC
Correspondence
The August Progress Report is not physically included in the
AR located at Liberty Public Library, Liberty, Texas due to
large amount of data generated for the report. (Contact Chris
G. Villarreal, RPM, for further information about the report.)
NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENTt
DOCUMENT TYPEi
DOCUMENT TITLE:
006438 - 006461
09/02/97
24
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Air emissions testing report for the two thermal oxidizeri
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPBs
DOCUMENT TITLEt
006462 - 006484
09/12/97
23
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris G. Villarreal, RPM, U.S. EPA Region 6
orandum
»randum describing 'living cap* approach proposed for
remediation of Bayou Disposal Area
32
-------
SITS NAME:
SZTB NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCYt
RECIPIENT:
DOCUMENT TYPE!
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
FINAL
PETRO CHEMICAL/TURTLE BAYOU
TXD9808733SO
006485 - 006936
09/12/97
452
R.L. Sloan, Manager, Remediation
ARCO Cheaical Company
Chris c. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Soil criteria assessment summary, September 1997
o
o
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006937 - OO6976
09/16/97
40
R.L. Sloan, Manager, Remediation
ARCO Chemical Company
Chris O. Villarreal, RPM, U.S. EPA Region 6
Correspondence; Report
Site Characterisation and Design Report for the Bayou Diepoeal
Area
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
O06977 - 006978
10/13/97
2
Jared Fuqua
Fluor Daniel Environmental Services - Dallas
Chris G. Villareal, U.S. EPA Region 6
Fax Transmittalt Notice
Final public notice enclosed for BPA's review
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHORi
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
O06979 - 006996
10/22/97
18
Community Relations Section
U.S. BPA Region 6
U.S. BPA Region 6 Superfund Site Files
Proposal
Amended Proposed Plan of Action
33
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SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
FINAL
PBTRO CHEMICAL/TURTLE BAYOU
TXD9808733SO
OO
o
o
DOCUMENT NUMBER:
DOCUMENT DATEi
NUMBER OF PAGES:
AUTHORl
COMPANY/AGENCY»
RECIPIENT:
DOCUMENT TYPEt
DOCUMENT TITLE:
006997 - 006998
10/28/97
2
Carl Norman, (Landowner)
R.A. Schriewer Hauling
U.S. EPA Region 6
Public Comment
Conmente on tha Amandad Propoaad Plan of Action and tha
Administrative Racord Fila
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGESi
AUTHORS
COMPANY/AGENCYi
RECIPIENTI
DOCUMENT TYPE:
DOCUMENT TITLE:
006999 - 006999
11/03/97
1
Unapacified
U.S. EPA Region 6
U.S. EPA Ragion 6 Superfund Sita Filea
Notica
Public maating to diacuaa EPA'a propoaad plan
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
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DOCUMENT TITLE:
007000 - 007037
11/03/97
38
Kriata Hilliameon, Certified Shorthand Raportar
Charlotta Smith Reporting, Inc.
U. 8. EPA Ragion 6 Suparfund Sita Filaa
Public Maating Tranacript
Public maating concerning EPA'a Amended Propoaad Plan of
Action
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PACESt
AUTHOR:
COMPANY/AGENCYt
RECIPIENTS
DOCUMENT TYPIi
DOCUMENT TITLE:
007038 - 007049
12/02/97
12
R. L. Sloan, Manager, Remediation
Arco Chemical Company
Chrla G. Villaraal, RPM, U.S. EPA Region 6
Correapondance; Map*
Site mapa and metea and bounda daacriptiona for the Meat Road
Area, Main Waate Area, Office Trailer Area, Power Eaaament
Area, and Bayou Diapoaal Area
34
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8XTB NAME:
SITB NUMBER!
DOCUMENT NUMBER:
DOCUMENT DATKi
NUMBER 07 PACES:
AUTHOR!
COMPANY/AGENCY»
RECIPIENT]
DOCUMENT TYPBt
DOCUMENT TITLEi
ADMINISTRATIVE RECORD INDEX
FINAL
PETRO CHEMICAL/TURTLE BAYOU
TXD980873350
007050 - 007054
01/13/98
5
Alvie L. Nichols, project Manager, Superfund Engineering
Section •'
TNRCC
Chris G. ViUaroal, RPM, U.S. EPA Region 6
Correspondence; Memorandum
Revised Treated Water Discharge Standards
o
o
DOCUMENT NUMBER:
DOCUMENT DATEl
NUMBER OP PAGES:
AUTHORt
COMPANY/AGENCY»
RECIPIENT!
DOCUMENT TYPEl
DOCUMENT TITLEt
007055 - 007055
01/22/98
1
Alvie L. Nichols, Project Manager, Superfund Engineering
Section
TNRCC
Chris 6. Villareal, RPM, U.S. EPA Region 6
Correspondence
TNRCC Risk Reduction Standards, Final Record of Decision (ROD)
Amendment
DOCUMENT NUMBER:
DOCUMENT DATE I
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
007056 - 007060
02/24/98
5
Alvie L. Nichols, Project Manager Superfund Cleanup Section
TNRCC
Chris G. Villareal, RPM, U.S. EPA Region 6
Correspondence; Memorandum
Revised Treated Water Discharge standards. Final ROD
Amendment, February 1998
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGESt
AUTHOR*
COMPANY/AGENCYt
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DOCUMENT TYPE:
DOCUMENT TITLE:
007061 - 007062
04/23/98
2
Don Pearson, Executive Director
TNRCC
Myron O. Knudeon, Director, Superfund Division, U.S. EPA
Region 6
Correspondence
TNRCC concurs with proposed April 1998 ROD
35
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ADMINISTRATIVE RECORD INDEX
FINAL
O
VO
o
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SITE NAMEI
Sin NUMBER:
DOCUMENT MUMBER:
DOCUMENT DATBt
NUMBER OF PACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
PETRO CHEMICAL/TURTLE BAYOU
TXD980873350
007063 - 007160
04/30/98
97
Jerry Clifford, Acting Region*! Administrator
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site Pile*
ROD; Correspondence
ROD Amendment (Responsiveness summary located in Appendix B)
DOCUMENT NUMBER:
DOCUMENT DATEi
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCYi
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
007161 - 007198
04/30/98
38
TechLaw, Incorporated
Contractor for U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site Piles
Index
Administrative Record Index, Record of Decieion Amendment for
Petro Chemical/Turtle Bayou Site, Operable Unit 2
36
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