Superfund Record of Decision Amendment: Texarkana Wood Preserving Co., Texarkana, TX (3/13/1998)


                              PB98-963148
                              EPA 541-R98-162
                              March 1999
EPA Superfund
     Record of Decision Amendment:
      Texarkana Wood Preserving Co.
      Texarkana, TX
      3/13/1998

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TEXARKANA WOOD PRESERVING COMPANY
  SUPERFUND SITE - OPERABLE UNIT ONE
         RECORD OF DECISION
          AMENDMENT NO. 1
             February 1998

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    TEXARKANA WOOD PRESERVING COMPANY

        SUPERFUND SITE - OPERABLE UNIT ONE

      RECORD OF DECISION AMENDMENT NO. 1
                          February 1998
INTRODUCTION	1
  Site Background	1
  Original Cleanup Remedy Selected In the ROD	1
  Summary of the Circumstances Requiring an Amendment	2
  Selecting the New Cleanup Remedy 	3  r'
  Description of the New Cleanup remedy	4
  Explaining the Differences	S
  Ground Water Affects	5

EVALUATION OF ALTERNATIVES 	6
  Overall Protection of Human Health and the Environment 	7
  Compliance With Applicable or Relevant and Appropriate Requirements 	7
  Long-Term Effectiveness and Permanence	8
  Reduction of Toxichy, Mobility or Volume Through Treatment	8
  Short-Term Effectiveness 	8
  State Acceptance	9
  Community Acceptance	9

STATUTORY FINDINGS	9

LEAD AND SUPPORT AGENCIES	9

ADMINISTRATIVE RECORD	10

APPENDIX A - CORRESPONDENCE

APPENDIX B - RELATIVE POTENCY FACTORS FOR CARCINOGENIC POLYNUCLEAR
  AROMATIC HYDROCARBON (AS BENZO(a)PYRENE) TOXICITY EQUIVALENCY
  FACTORS (TEF) FOR CDD's AND CDPs

APPENDIX C - WINSTON BRYANT, ATTORNEY GENERAL, STATE OF ARKANSAS v.
  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

APPENDIX D - RESPONSIVENESS SUMMARY

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DECLARATION
FOR THE TEXARKANA WOOD PRESERVING COMPANY
SUPERFUND SITE - OPERABLE UNIT ONE
AMENDED RECORD OF DECISION NO. 1
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SITE NAME AND LOCATION.
Texarkana Wood Preserving Company
Lubbock St.
Texarkana, TX

STATEMENT OF BASIS AND PURPOSE. This decision document presents an amendment to the
selected remedial action for the Texarkana Wood Preserving Co. Superfund Site which was chosen in
accordance with the Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by (he Superfund Amendments and Reauthorization Act of 1986 (SARA) (42
U.S. Code, Section 9501, et soq.), and, to the extent practicable, the National Contingency Plan (NCR) (40
CFR Pan 300). This decision is based on the Administrative Record for this site. The State of Texas
concurs with this amended remedy.

ASSESSMENT OF THE SITE. Actual or threatened releases of hazardous substances from this site, if
not addressed by implementing the response action selected in this Amended Record of Decision, present an
imminent and substantial endangerment to public health, welfare or the environment

DESCRIPTION OF THE REMEDY. This amendment fundamentally changes the Record of Decision
(ROD) executed by the Regional Administrator on September 25, 1990. This amended remedy will seal
and contain soils contaminated with greater than 3 ppm (parts per million) benazo(a)pyrene equivalents,
2450 ppm total poly aromatic hydrocarbons (PAH), 20 ppb (parts per billion) as 2, 3, 7, 8 TCDD
equivalents and 1 50 ppm pentachlorophcnol beneath a soil cap.

STATUTORY DETERMINATION. The selected 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 is cost-effective. Since contamination at the site presents only a low
level threat, EPA determined permanently treating contaminated soil at this site to reduce toxicity, mobility
and volume of the contamination was unnecessary. However, this remedy will permanently contain the soil
contamination. Therefore there is no need for this remedy to satisfy the statutory preference for remedies
that employ treatment as a principal element. Because this remedy will result in hazardous substances
remaining on-site above health-based levels, Environmental Protection Agency (EPA) will review the
remedy within five years after commencement of remedial action to ensure it continues to adequately
protect public health, welfare, and the environment.
Jerry Clifford '' V
Acting Regional Administrator (6RA)
Date
?,/f?f

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IWtt Superfund S.ic
KOI) AmendlKcm No I
Fehnj»iy2V IMS
Pane I
I. INTRODUCTION. This is an amendment to
the September 1990 Record of Decision (ROD) for
the Texarkana Wood Preserving Company (TWPC)
Superfund Site. This amendmenl changes the
remedy to clean up contaminated soil from
incinerating contaminated soils to containing them
beneath a cap. It discusses site background, the
original remedy, circumstances requiring an
amendment and rationale for selecting the new
remedy. This amendment also describes the new
remedy and evaluates the new remedy in accordance
with the nine criteria set forth in the National
Contingency Plan (NCP). Note, this amendment
affects only the soil remedial action whereas the
remedy to clean up ground water through an on-site
carbon adsorption treatment system remains
unchanged.
a. Site Background. Creosote and
pentachlorophenol (PCP) wood treating operations
began at the TWPC plant site sometime between
1946 and 1954 and ceased in 1984. The
Environmental Protection Agency (EPA) estimates
that these operations contaminated 77,000 cubic
yards of soil and 16,000,000 gallons of ground
water with creosote, PCP and dioxin.1 The TWPC
Superfund site (Figure I) is located in Bowie
County, Texas along Lubbock Street between the
Union Pacific Railroad and Days Creek about one
half mile from the Texas - Arkansas border. The
Texarkana, Texas city limit divides the site into
approximately a northern third within the city
limits, leaving the southern two thirds under Bowie
county jurisdiction. As seen in Figure I, the site is
within the Days Creek 100 year flood plain and
nearby land uses include cemetery, residential, cattle
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pasture and industrial activities such as a cattle ~
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auction bam, sawmill and rail yard (see Figure 2). ^
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These land uses were considered when EPA
evaluated the overall protection of human health and
the environment provided by the new cleanup
remedy.
b. Original Cleanup Remedy Selected In the
ROD.
i. tn September 1990 EPA decided to use
thermal destruction to incinerate cr-osote
pentachlorophenol and dioxin contaminated soils at
the site. The circumstances and analysis to support
the original decision are recorded in the "Record of
Decision, Texarkana Wood Preserving Company
Superfund Site," September 1990. The ROD is part
of the Administrative Record discussed later in
Section 4. The soil cleanup remedy chosen in the
ROD was alternative A-3, Thermal Destruction and
Backfilling.1 To implement the soil cleanup.
contaminated soil was to have been excavated and
stored on the site as it waited to be fed into the
thermal destruction unit. Once the contamination
was burned, the clean soil was to have been buried
on-site, covered with top soil and revegetated. All
the contaminants above the soil remediation goals
shown in Figure 3 were to have been treated to
reduce the excess cancer risk below a I chance in
100,000 for an individual routinely exposed to the
site. Thermal destruction would have eliminated the
source of ground water contamination and prevented
further shallow ground water degradation as well as
the potential for offsite migration.
ii. Many types of thermal destruction units
were suitable for this alternative, however, the cost
estimate for alternative A-3 was based on two rotary

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Texarkana Wood Preserving Co.

            Superfund / NPL Site
               Texarkana, Texas
                                    FIGURE 1
            FEMA100 Y^. Rood Zone

            Superfund Boundary

            Residential Structures


            Non-Residential Structures

            Hydrology


            Railroad


            2000 ft radius  	
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Texarkana  Wood Preserving  Co.
                Superfund / NPL Site
                     Texarkana, Texas
                                                 FIGURE 2
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                                        >nt»d by
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vogttotion. Outer sfndes Mctta dense vegttetion am/ thidaw*. Colors wen tddad to Bustntt tntfor fottms.


               Superfund Boundary

               Residential Structures

               Non-Residential Structures

               Hydrology

               Railroad

               2000 ft radius
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                                                                                 t'At'C NutKrl.cKil SiM
                                                                               ROD Amendment No I
kiln incinerators operating at 24 hours per day.  The
incinerator could have reduced the toxicity, mobility
and volume of contaminated  soil by destroying at
least 99.99% for the non dioxm contaminants and
99.9999% of the dioxin.
    c.     Summary  of  the   Circumstances
Requiring an Amendment.
    Soil Remediation Goals, Parts Per Million (ppm)
  Carcinogenic Polymiclear Aromatic
      Hydrocarbons (cPAH) As 3enzo(a)pyrene
      Equivalents*	3
  Total Polynuclear Aromatic
      Hydrocarbons (tPAH)	2450
  Chlorinated Dibcnzo-p-dioxin and
      Dibenzofuran as 2,3,7,8 TCDD
      Equivalents* * 	' 0.02
  Pentachlorophenol	  150
  * The cPAH benzo(a)pyrene equivalents are found
  in this amendment. Appendix B. Replace Table 2 in
  the ROD with (he table found in Appendix B.
  "TCDD equivalents are found in this amendment.
  Appendix B. Replace Table 3 in the ROD with the
  table found in Appendix B.
Figure 3.
       i.  After  the  ROD   was  signed  on
September 25, 1990, the community attempted1 to
persuade  EPA to  change the cleanup  remedy
because  it feared   thermal destruction  "could
endanger public health and the environment."4 The
community solicited aid from then Congressman
Jim Chapman because it believed "that EPA had
already  identified  incineration  as the  cleanup
remedy when the proposed plan was released and
that nothing  could have been done to change the
Agency'sdecision."' In other words the community
did not believe EPA followed the two step cleanup
remedy selection process described in the NCP*
which  requires  EPA  to  consider  community
concerns when  deciding  the  most  appropriate      r^>
cleanup remedial action.'   Although opposition      S
continued, EPA proceeded to design the incineration
cleanup remedy making several design changes to
accommodate community concerns.  However, by
June of 1994  Congressman Chapman received a
petition signed by "thousands of Bowie and Miller
County residents  who opposed any  form of
incineration at the site."' The petition made it clear
that design changes alone could not "put to rest" all
the community's fears and that the community was
organized to oppose the selected cleanup9.  Its
opposition   focused on two  beliefs: 1) thermal
destruction could endanger public health and the
environment; and, 2) EPA did not reach  out to
understand public concerns.10  Since EPA received
no comments during the  1990  public comment
period  addressing   poor  public  outreach,  the
community's concern is inforrnp'ion which was not
available to EPA at the time the Record of Decision
(ROD) was approved."
        ii.  Once it became clear to  EPA that all
community fears could not be put to rest, and that
the community desired a greater role in deciding the
cleanup remedy, EPA  requested Texas  Natural
Resource Conservation Commission (TNRCC) halt
all efforts to award a thermal destruction contract to
 incinerate soil.  As a result, TNRCC allowed the
thermal destruction bids  it  received  to expire
without award.'2 The public's concern with thermal
 destruction caused EPA to suspend further remedial
 action at the site in 1994 and re-analyze remedies
 available for treating contaminated soils with wood
 preservatives.
        iii.  Meanwhile,  Congressman Chapman

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SupcrfunJ Si;c
ROD ^mendfltenl No I
FtlxxiK) 25. I99S
requested the Office of Technology Assessment
(OTA) study remedies which could have been
alternatives to thermal destruction. The OTA report
concluded that, although there was a range of
technologies that have been selected at other sites to
clean up wood treating wastes, the applicability of
a technology to a particular Superfund site has to be
based on many site-specific factors."
iv. In 1996, after considering the
community's concern and OTA's aforementioned
conclusion, EPA returned to the Texarkana
community to listen to its concerns and find a
cleanup remedy to satisfy the stakeholders, EPA,
TNRCC and the community. Consequently, EPA
began reanalyzing the available remedial action
alternatives and began working with the TNRCC
and the Texarkana community to find a cleanup
acceptable to each stakeholder. This cleanup
remedy selection approach is encouraged by the
October 1995, "Superfund Administrative Reforms
Overview," reform item C.I. "Establish Greater
Stakeholder Role in Remedy Selection."
d. Selecting the New Cleanup Remedy.
i. EPA began the new cleanup remedy
selection by addressing the concern that there was
insufficient community involvement with the
original decision. In response to that concern EPA
and TNRCC held various meetings with the
Texarkana community to announce its plan to
reconsider the original cleanup remedy. During
these meetings EPA also encouraged the community
to form a Community Advisory Group (CAG)
representing the Texarkana Community. A CAG
was formed in the fall of 1996 and held it's first
meeting in December 1996 beginning in earnest a
quest to find an acceptable cleanup remedy.
ii. From December 1996 through July
1997 the CAG met monthly to Icam about the site,
presumptive remedies and the Superfund process.
EPA provided the CAG a site tour and seminars
regarding presumptive remedies for contaminated
soils at wood treating sites, site risk and the
Superfund legal process. During the June 1997
meeting the CAG determined it was ready to decide
what it would consider an acceptable cleanup
remedy. After a discussion, the membership
decided it should vote during the July meeting to
determine if capping the contaminated soils would
be an acceptable cleanup remedy." When the CAG
convened again in July, it voted unanimously to
recommend a cap as a soil cleanup remedy. The
CAG sent EPA a letter on July 20, 1997 confirming
that a cap would be an acceptable cleanup remedy.
This letter is included in Appendix A,
"Correspondence.*'
iii. Upon receipt of the letter, EPA completed
its analysis of the remedial action alternatives
selected in the ROD to determine if a cap could be
an alternative cleanup remedy upon which EPA,
TNRCC and the CAG could agree. This analysis
was conducted in accordance with the cleanup
remedy selection procedures described in the
National Contingency Plan (NCP) §300.430,
"Remedial Investigation / Feasibility Study and
Selection of Remedy." Through this analysis (see
"Evaluation of Alternatives.") EPA determined
capping contaminated soils is an appropriate
response to prevent dermal contact and ingestion
threats from site soils. However, leaving
contaminated soil in place poses a significantly
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different circumstance from incinerating all
contaminated soils. This difference is discussed
further in the "Explaining the Differences" section
of this amendment.
iv. Since capping contamination changes
the remedial approach originally selected in the
ROD, EPA considers this a "fundamental" change;
consequently it must amend the ROD in accordance
with the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA),
Section 117(c), 42 U.S.C. § 9617(c), and the 1990
National Contingency Plan (NCP) at 40 CFR §
300.435(cX2Xii). However, as explained in the
"Evaluation of Alternatives," EPA believes this
change will continue to protect human health within
the acceptable excess cancer risk range (1 chance in
10,000 to 1 chance in 1,000,000) defined in the NCP
at 40 CFR § 300.430(eX2XiXAX2)].
e. Description of the New Cleanup remedy.
i. The Alternative to Incineration. In lieu
of thermal destruction, EPA will cap all soils above
the remediation goals and construct a fence around
the capped area similar to the alternative proposed
in the ROD as "Soil Alternative A-2." The primary
objective of this cap is to provide an engineered
control to protect human health from the risks posed
by dermal adsorption or ingestion of contaminated
soil." However, the secondary objective of the cap
is to prevent further ground water contamination, so
the final cap design depends upon the performance
requirements imposed by the final ground water
cleanup remedy design. Therefore, as discussed
further in the "Explaining the Differences" section
EPA will investigate and evaluate the contaminant
transfer effects before proceeding with the final cap
TVkTC Superfund Sue
ROD \menilnitnl So 1
J. l<)98
design and construction.
ii. Design Criteria. For this amendment. EPA
assumes the cap will have to meet both
aforementioned objectives, thus the final design will
require layers of clay fill, a high density
polyethylene synthetic liner, and topsoil with a
vegetative cover above the synthetic liner similar (o
the ROD Soil Alternative A-2. However, if EPA
determines that meeting only the first objective is
necessary, the design could be as simple as a
topsoil cover. In fulfilling either objective, EPA
will design the cap in accordance with local flood
Main ordinances and design it to minimize the need
for further maintenance, as well as to prevent the
post-closure escape of hazardous constituents,
contaminated run-off, or hazardous decomposition
products to surface water or the atmosphere.16
Lastly, EPA may require a soil treatment, such as
stabilization, before the site is capped if the ground
water investigation and evaluation demonstrates
such treatment is necessary to prevent further
contamination transfer from the soil to the ground
water. Once EPA determines the cap design
necessary to protect human health and the
environment, it will explain the rationale for the
final design through an explanation of non-
significant differences.
iii. Size and Cost. The ROD estimates that
77,000 cubic yards will require capping, however,
prior to finalizing a cap design, EPA will define
with a 90% confidence those areas of the site where
the mean contaminant concentration is below those
soil remediation goals defined in Figure 3. The cap
will cover all other areas on site. When the cap is
completed, a professional land surveyor will survey
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K()t) Amendment No I
Fchnjir\ _'V IWS
the cap boundaries and prepare a plat showing (lie
boundaries and elevations of each capped area with
respect to permanently surveyed benchmarks. EPA
will place a copy of the plat in each repository and
EPA will include the plat with the deed notice
discussed in the following paragraph. EPA
estimates the cap may cost $7,300,000. The
estimate was taken from the "Soil Alternative A-2"
estimate in the 1990 ROD."
iv. Institutional Controls. In addition to
providing a cap as an engineered control to mitigate
the risk posed by contaminated soils, EPA will also
pursue institutional controls to ensure the integrity
of the cap is not violated. Although EPA
encourages future industrial site use, property
development is not the design objective for the cap.
Therefore, EPA will use institutional controls to
ensure future property development is coordinated
with EPA and TNRCC. Institutional controls are
necessary to ensure that future development does
not damage the cap to the extent that it no longer
protects human health and the environment. At a
minimum EPA will file a deed notice to subsequent
purchasers stating:
• Contaminated soils remain beneath various
capped areas shown on a site plat.
• Disturbing a capped area could release
hazardous substances;
• The party responsible for any release from a
capped area will incur liability for the response
actions required to restore the protection of
human health and the environment; and
• EPA recommends the site be used for nothing
other than industrial purposes.
In addition to the deed notice, warning signs will be
placed on the fence surrounding the site stating that
it encloses subsurface contamination and anyone
disturbing the fence or the grounds enclosed by the
fence may incur liability under Federal law.
v. Upon completion of (he cap the TNRCC
will assume responsibility for its operation and
maintenance. Prior to completing the remedial
action, TNRCC will cooperate with the local
community to develop a plan describing operation
and maintenance activities. The operation and
maintenance activities will at a minimum include
routine mowing as necessary to protect the integrity
of the cap and periodic inspections to ensure there is
no surface erosion or other destruction to the cap or
the surrounding fence.
f. Explaining the Differences. The capping
alternative described in "The New Cleanup remedy"
will leave contaminated soil in place, thus
differences between the original and new cleanup
remedy affect ground water and the principal threat
determination.
i. Ground Water Affects. Because ground
water on site is contaminated, EPA assumes ground
water flow transfers contamination from the soil to
the ground water. Consequently, EPA will
investigate and evaluate the contaminant transfer
effects and explain these effects in an explanation of
non-significant differences. If this evaluation
determines the current ground water remedial action
is no longer applicable, EPA will amend the ROD to
ensure an appropriate ground water cleanup remedy
will protect human health and the environment.
ii. Principal Threat. As described in the
NCP, 40 CFR § 300.430.(aX 1 X»iXA), EPA prefers
permanent solutions to reduce thetoxicity, mobility,
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                                                                                ROD Amendment N.i  1
                                                                                   frtxiuo M. '•>••»
or volume of the wastes and the treatment of all
principal threats. In 1991, a year after the ROD was
signed, EPA published guidance defining principal
threats to be:

    those source materials considered to be highly
    toxic or highly mobile that generally cannot be
    reliably  contained  or  would  present  a
    significant  risk  to  human health  or  the
    environment should exposure occur.    They
    include liquids and other highly mobile material
    (e.g..  solvents)  or  materials having  high
    concentrations of toxic compounds.... However,
    •whtre toxicity and mobility or source material
    combine to pose a potential risk of Iff' or
    greater, generally treatment alternatives should
    be evaluated....
         Determinations  as to whether a source
    material is a principal or low  level threat
    should be based upon the inherent toxicity as
    well as a consideration of the physical state of
    the material (e.g., liquid), the potential mobility
    of the wastes in  the particular environmental
    setting....
        The identification of principal and low level
    threats is made on a site specific basis."
In accordance with this guidance, even though the
 1990 ROD considered the soil to be a principal
threat," EPA re-evaluated the soil with respect to
the  aforementioned guidance  and no longer
considers it a principal threat since the base line risk
assessment10 did not identify any health risk from
dermal contact or inadvertent ingestion of dioxin or
pentachlorophenol contaminated soil  to be greater
than 1 chance 1000.  Although PAH's in soil pose a
nsk greater than  I in 1000, they arc immobile and
can therefore be reliably contained beneath a cap.'1'
In accordance with the EPA guidance "...low level
threat  wastes  are  those  source materials  that
generally can be reliably contained and that would
present only a low risk  in the event of a release.""
Therefore, PAH  contaminated soil is considered a
low level threat because it can be reliably contained
and would present only a low risk in the event of
release.   Since  EPA  no  longer  considers  the
contaminated soil on site a principal threat, the NCP
40 CFR § 300.430.(aXlXiiiXB) allows EPA Co
use "... engineering controls, such as containment
for contamination that poses a relatively long term
threat."*1 EPA believes a cap will provide  reliable
containment as well as reduce toxic ity by severing
the exposure pathway.  Substances arc toxic when
they  reach a  target organ through an exposure
pathway in a  prescribed dose.  Therefore, a cap
reduces  toxicity  by  severing  the most likely
potential exposure pathways, dermal adsorption and
ingest ion,  thus  preventing  a  target organ  from
receiving a toxic dose.   A cap will contain the
contaminants and thus reduce their mobility into the
air and surface runoff, and since water is the only
medium to most likely mobilize the contaminant,
EPA will ensure the cap is designed to minimize the
amount  of water available  to mobilize    the
contaminant.
2.    EVALUATION OF ALTERNATIVES. To
 properly consider a ROD amendment EPA  has
 traditionally  evaluated  the  originally  selected
 cleanup remedy and the amended cleanup remedy
 by comparing each of them against the nine criteria
 identified in Figure 4 to ensure the amended cleanup
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iwn/Siipciruiij sue
ROD Amcndmtm No 1
l-rhruarj J5. IWH
icmcdy reflects the scope, purpose and a long term
comprehensive response for the site after
discovering significant new information to require
an amendment. In this case the community's
concern that it was not given enough opportunity to
affect the decision was the new information that was
not available at the time of the original decision.
EPA used this new information as the reason to
reconsider incineration as the cleanup remedy for
the site." In addition, in the case of this ROD
amendment, EPA also considered the other
presumptive remedies (thermal desorption,
bioremediation and immobilization) described in
"Presumptive Remedies for Soils, Sediments, and
Sludges at Wood Trcater Sites," EPA/540/R-
95/128. Two presumptive remedies were not
considered and a third has not been ruled out. The
community did not favor thermal desorption for the
same reasons that it opposed thermal destruction,
and EPA rejected bioremediation because it will not
remediate dioxin. As for immobilization, it has not
been ruled out since soil stabilization may still be
necessary to prevent the soil from contaminating the
ground water.
a. Overall Protection of Human Health and
the Environment. Current surrounding land uses
include a cemetery, residential, cattle pasture and
industrial activities such as a cattle auction bam,
sawmill and rail yard. With these land uses in mind
both EPA and the CAG consider an industrial use to
be the most probable future land use for this site."
EPA considered the current surrounding land uses
and the most probable future land use in its decision
to cap the contaminated soil in accordance with
EPA's "Land Use in the CERCLA Remedy
Selection Process," Office of Solid Waste and
Emergency Response Directive No. 9355.7-04. So,
because there are no principal threats from
contaminated soil at the site, EPA determined that a
cap with institutional controls will protect human
health and the environment by preventing dermal
adsorption and inadvertent ingestion exposures to
future on-site industrial occupants. EPA determined
the originally selected cleanup remedy would treat
contaminants to below the remediation goals shown
in Figure 3 with a high degree of certainty.26
b. Compliance With Applicable or Relevant
and Appropriate Requirements. CERCLA,
Section !21(dX2) requires remedial actions to at
least attain applicable, relevant and appropriate
requirements (ARAR's), 42 U.S.C. § 962l{dX2).
Applicable requirements are those cleanup
standards, standards of control, and other
substantive environmental protection requirements,
criteria, or limitations promulgated under Federal or
State law that specifically address a hazardous
substance at a Superfund site. Relevant and
appropriate requirements are standards, which while
not 'applicable" at a CERCLA site, address
problems or situations sufficiently similar to those
encountered at the site such that their use is
warranted. EPA recognizes the three ARAR
categories defined in Figure 5. While EPA does not
believe there are any requirements applicable to the
cleanup remedy outlined in this ROD amendment,
the requirements in Figure 6 are relevant and
appropriate. Since the site is located in a 100 year
flood plain EPA included location standards as a
relevant and appropriate standard to ensure the cap
is designed, constructed and maintained to prevent
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a washout during a 100 year flood. EPA included
post closure notice as a relevant and appropriate
standard to ensure local officials understand where
contamination is left on site. EPA included relevant
and appropriate post closure care standards to
identify expected operation and maintenance
standards. It is possible to construct a cap which will
meet the requirements of the ARAR's identified in
Figure 6. The originally selected cleanup remedy,
could have met the required ARAR's.27
40 CFR, Part 264 - Standards for
Owners and Operators of
Hazardous Waste Treatment,
Storage, and Disposal Facilities
» Subpart B - General Facility Standards,
Location Standards, §264.18(b)
• Subpart G - Closure and Post Closure,
Post Closure Notices, §264.119(bXIXui).
• Subpart N • Landfills, Closure and Post
Closure Care:
-§264.310(aXl)
-§264.3IO(aX2)
--§264.3 !0(aX3)
--§264.310(aX4)
-§264.3lO(bXI)
»§264.310(bXS)
Figure 6. Relevant and Appropriate Requirements.

c. Lone-Term Effectiveness and
Permanence. A cap can be constructed to achieve
long-term effectiveness. Caps are used effectively
throughout the nation as a cover to permanently
close hazardous waste landfills.2* Consequently
EPA believes a cap can provide a successful long
term and effective permanent cover to ensure there
is no exposure pathway for these contaminants to
threaten human health or the environment. The
T\VTC SuptrfunJ Sue
ROD AmcmlmcM No I
lrl..miy IS. IW8
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1990 ROD indicated tKe originally selected cleanup
remedy would have been (he most protective
alternative to provide long-term effectiveness and
permanence." !n accordance with the NCP
§300.430(fX4)(ii), ever) five years EPA will
review the long-term effectiveness and permanence
of this cleanup remedy to ensure it remains
protective of human health and the environment, is
functioning as designed, and necessary operation
and maintenance arc being performed.50
d. Reduction of Toxicity, Mobility or
Volume Through Treatment. Since there is no
principal threat, this criteria is not applicable
because, as discussed before, treatment is not
necessary. The ROD indicated that the originally
selected cleanup remedy would have provided the
most reduction of toxicity, mobility or volume
through treatment."
e. Short-Term Effectiveness. The original
ROD stated that neither a cap nor thermal
destruction provided an unacceptable short term
risk."
f Implementability. The original ROD stated
that "Capping is the easiest alternative to
implement" while thermal destruction's
implementability is comparable." The amended
cleanup remedy is implementable since il is easy to
construct with locally available skills and materials,
is reliable and is easy to maintain.
g. Cost. When comparing present worth cost
estimates, constructing a cap may cost S7.300.000
for which the State would have to match with ten
percent, or $730,000, whereas the thermal
destruction may have cost as much as S43.000.000
requiring $4,300,000 of State matching funds."
O
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State operation and maintenance costs for a cap are
expected to be $430,000 and for thermal destruction
to be $60,000." Although the State would incur an
additional $370,000 in operation and maintenance
costs, the savings it would save are in excess of
$3,500,000 in construction costs.
h. State Acceptance. The TNRCC reviewed
the cleanup remedy and provided its concurrence
per the attached December 30, 1997 letter."
i. Community Acceptance, EPA and
TNRCC have worked closely with the Tcxarkana
Wood Preserving Site Community Advisory Group.
The CAG prefers a cap to thermal destruction as the
soil cleanup remedy. On November 4, 1997 EPA
announced it would receive written comments
regarding the cleanup remedy from November 5,
1997 through December 5, 1997. No comments
were received during this period. On November 13,
1997 EPA held a public meeting to receive
comments regarding the proposed cleanup remedy.
During the meeting one community leader endorsed
the cleanup remedy and there were no comments
opposing the cleanup remedy.
3. STATUTORY FINDINGS. This document
presents an amendment to the selected remedial
action for the Texarkana Wood Preserving
Superfund Site. This action 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) (42 U.S. Code, Section 9601, et seq.), and,
to the extent practicable, the National Contingency
Plan (NCP) (40 CFR Part 300). This decision is
based on the Administrative Record for this site.
Actual or threatened releases of hazardous
substances from this site, if not addressed by
implementing the response action in this Amended
Record of Decision, present an imminent and
substantial endangerment to public health, welfare
or the environment. This amendment fundamentally
changes the Record of Decision (ROD) executed by
the Regional Administrator on September 25, 1990.
The selected cleanup remedy is protective of human
health and the environment, complies with ccdfcral
and State requirements that are legally applicable or
relevant and appropriate to the remedial action, and
is cost-effective. Since contamination at the site
presents only a low level threat, EPA determined
permanently treating contaminated soil at this site to
reduce toxicity, mobility and volume of the
contamination was unnecessary. However, this
cleanup remedy will permanently contain the soil
contamination. Therefore there is no need for this
cleanup remedy to satisfy the statutory preference
for remedies that employ treatment as a principal
element. Because this cleanup remedy will result in
hazardous substances remaining on-site above
health-based levels, EPA will review the cleanup
remedy within five years after commencement of
remedial action to ensure it continues to adequately
protect public health, welfare, and the environment.
4. LEAD AND SUPPORT AGENCIES. The
Texas Natural Resource Conservation Commission
(TNRCC) is the lead agency overseeing site
remedial action under the terms of a cooperative
agreement* between TNRCC and EPA. The
r-
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* EPA Cooperative Agreement Number V996096-01 -3.
This agreement is on Tile at the EPA Region 6 offices.
Dallas, TX.

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Page 10
agreement was executed in accordance with the
provisions of 40 CFR "Subpart O - Cooperative _
O
Agreements and Superfund State Contracts for O
CD
Superfund Response Actions." The EPA provides
TNRCC remedial action support on the site.
5. ADMINISTRATIVE RECORD. This
amendment will become part of the Administrative
Record file in accordance with the National
Contingency Plan (NCP), 40 CFR §300.825(aX2).
The Administrative Record -oniains documents
such as the "Remedial Investigation/Feasibility
Study" (RI/FS) and ROD that form the basis for
selecting the remedial action. The Administrative
Record is located at:
U. S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Dallas, TX 75202-2733
(214)665-6444
Texarkana Public Library
600 W. 3rd St
Texarkana, TX 7SSOI
(903)794-2149

The Administrative Record is available to the public
at EPA Region 6 on Mondays through Fridays from
8 a.m. to 4 p.m. or the Texarkana Public Library on
Mon.-Wed. 9:00-9:00, Thurs.& Fri. 9-5, Sat. 10-5.