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CRYSTAL CHEMICAL COMPANY
SUPERFUND SITE
TABLE OF CONTENTS
PAGE
SECTION
I. STATEMENT OF PURPOSE 1
H. INTRODUCTION 1
m. SITE HISTORY AND ORIGINALLY SELECTED REMEDIES 4
IV. DESCRIPTION OF AND BASIS FOR THE SIGNIFICANT DIFFERENCE 4
V. PUBLIC PARTICIPATION ACTIVITIES 8
VI. STATE COMMENTS 9
VII. STATUTORY DETERMINATION 9
FIGURES
1 SITEAREAMAP 2
2 GEOLOGIC CROSS-SECTION 6
3 AREAL EXTENT OF TI ZONE AND ESTIMATED 7
LOCATION OF SLURRY WALL
APPENDICES
A RESPONSIVENESS SUMMARY
B STATE OF TEXAS CONCURRENCE LETTER
C ADMINISTRATIVE RECORD INDEX
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EXPLANATION OF SIGNIFICANT DIFFERENCES
TO THE SEPTEMBER 1990 RECORD OF DECISION
CRYSTAL CHEMICAL COMPANY SUPERFUND SITE
HOUSTON, TEXAS
L STATEMENT OF PURPOSE
This document explains the differences between the ground water remedy being implemented
and the ground water remedy identified in the September 1990 Record of Decision (1990 ROD) for
the Crystal Chemical Company Superfund Site.
During the course of the design for the extraction and treatment of arsenic-contaminated
ground water remedy identified in the 1990 ROD, the U. S. Environmental Protection Agency (EPA)
and the Texas Natural Resource Conservation Commission (TNRCC) determined that restoration of
the ground water is technically impracticable for portions of the Crystal Chemical Company
Superfund site. Therefore, EPA has determined that the applicable or relevant and appropriate
requirement (ARAR) for ground water restoration to the Maximum Contaminant Level (MCL) of
SO ng/l for arsenic will be waived and a slurry wall will be constructed around the portions of the site
where ground water cannot be restored. The extraction and treatment of arsenic-contaminated
ground water remedy will be implemented on the remainder of the site, as specified in the 1990 ROD.
EL INTRODUCTION
The Crystal Chemical Company Superfund site (Crystal Chemical site) is located at 3502
Rogerdale Road, in southwestern Houston, Harris County, Texas. The Crystal Chemical site is
bound on the west by the Harris County Flood Control Channel and lies immediately south of the
Westpark Drive extension (Figure 1).
EPA is the lead agency for the Crystal Chemical site, and the State of Texas, through
TNRCC, has been involved in all aspects of s:te activities. Southern Pacific Transportation Company
has been identified as one of the potentially responsible parties for the Crystal Chemical site, and EPA
has authorized Southern Pacific Transportation Company through an Administrative Order on
Consent and an Unilateral Administrative Order to design and implement the ground water remedy
for the Crystal Chemical site, as set forth in the 1990 ROD.
This Explanation of Significant Differences (BSD) is prepared in accordance with Section
117(c) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA),
as amended by Superfund Amendments and Reauthorization Act, 42 U.S.C. § 9617(c), which
provides that, after adoption of a final remedial action plan, if any remedial action is taken and if such
action differs in any significant respects from the final plan, EPA shall publish an explanation of the
significant differences and the reasons such changes were made.
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FIGURE 1
SITE AREA MAP
o
o
HARWIHOWVt
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This ESD is necessitated by the findings made during the course of the remedial design of the
ground water extraction and treatment remedy. The results of the design investigations and the
findings are presented in the Assessment of the Technical Impracticability of Ground-Water
Remediation, February 1996 for the Crystal Chemical site (TI Assessment). Specifically, it has
been determined that restoration of the arsenic-contaminated ground water is technically
impracticable due to hydrogeologic as well as contaminant-related factors for portions of the Crystal
Chemical site. Therefore, EPA has determined that the ARAR for the ground water restoration to
the MCL of SO ug/1 for arsenic will be waived and a slurry wall will be constructed to protect human
health and the environment on the portions of the site that cannot be restored. These alternative
remedial strategies were selected from the list of ground water contingency measures identified in the
1990 ROD (pages 95 and 96). The ground water extraction and treatment remedy will be
implemented on the remainder of the site, as specified in the 1990 ROD.
In accordance with the National Oil and Hazardous Substances Pollution Contingency Plan,
40 CFR §300.82S(aX2), this ESD and the supporting information EPA relied upon in preparing the
ESD, including the TI Assessment, will become part of the Administrative Record for the Crystal
Chemical site. The Administrative Record file for the Crystal Chemical site is available at the
following locations:
U.S. EPA, Region 6
Library, 12th floor (6MD-II)
1445 Ross Avenue
Dallas, Texas 75202-2733
(214) 665-6424 or 665-6427
facsimile (214) 665-2146
Hours of Operation: Monday through Friday 7:30 am-4:30 pm
Judson Robinson-Westchase Library
3223 Wilcrest
Houston, Texas 77042
(713) 784-0987
Hours of Operation: Monday 12:00 pm-9.00 pm; Tuesday 10:00 am- 9:00 pm; Wednesday
10:00 am-6:00 pm; Thursday 12:00 pm-9:00 pm; and, Friday/Saturday 10:00 am-6.00 pm
Texas Natural Resource Conservation Commission
12118 North ffl 35
Technical Park Center, Room 190, Building D
Austin, Texas 78753
(512)239-2920
Hours of Operation: Monday through Friday 8:00 am-5.00 pm
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ffl. SITE HISTORY AND ORIGINALLY SELECTED REMEDIES
Crystal Chemical Company produced arsenical, phenolic, and amine-based herbicides from
1968 to 1981. Operation and maintenance problems at the Crystal Chemical facility during the late
1970s resulted in several violations of the State of Texas' environmental standards, and in September
1981, Crystal Chemical Company filed for bankruptcy and abandoned the site. In 1983, the Crystal
Chemical property was added to the National Priorities List, qualifying the site for investigation and
remediation under CERCLA, more commonly known as Superfund.
In September 1990, EPA issued the ROD that addressed soil and ground water
contamination. The selected remedy for soil called for the excavation of offsite soils contaminated
with arsenic greater than 30 parts per million (ppm), treating all the soils contaminated with arsenic
greater than 300 ppm with a process called in-situ vitrification, and capping the entire site after the
soils treatment had been completed. Due to the unavailability of the in-situ vitrification technology,
EPA selected a new soil remedy in a ROD amendment issued in June 1992. The soil consolidation
and capping remedy was completed in September 1995.
The remedy selected in the 1990 ROD for ground water called for the extraction and
treatment of arsenic-contaminated ground water. The remediation goal specified in the 1990 ROD
for the affected ground water zones is SO ug/1, the MCL for arsenic. The 1990 ROD also included
several contingency measures that could be implemented if an extraction and treatment system would
not produce the remediation goals set for the Crystal Chemical site.
IV. DESCRIPTION OF AND BASIS FOR THE SIGNIFICANT DIFFERENCE
The 1990 ROD states that the goal of the ground water remedy is to restore the ground water
to a useable state, i.e., removing the arsenic to the MCL of 50 ug/1. However, the 1990 ROD
indicates that due to the uncertainty as to whether the remedy will be cble to meet the remediation
goal of the MCL for arsenic, contingency measures and goals may replace the selected remedy and
goals. The contingency measures specified in the 1990 ROD were:
1) discontinuing operation of extraction wells in areas where remediation goals have
been attained;
2) alternating pumping at wells to eliminate stagnation points; and/or,
3) establishing an Alternative Concentration Limit for arsenic provided compliance with
CERCLA Section 121 (d)(2)(BXii) can be demonstrated;
4) waiving the ground water ARAR for those portions of the aquifer based on the
technical impracticability of achieving further contaminant reduction;
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5) implementing low level pumping as a long-term gradient control or construction of
a containment measure such as a slurry wall; and/or,
6) implementing additional source control treatment to further reduce arsenic migration
to ground water.
At the time of the 1990 ROD, EPA called for investigations and evaluations necessary to
design the extraction and treatment system for the ground water remedy. Through an Administrative
Order on Consent, EPA authorized Southern Pacific Transportation Company to undertake, with
EPA oversight, the investigations and evaluations necessary to design an efficient and effective
ground water extraction and treatment system.
During the course of the design investigations and evaluations, data indicated that portions
of the site's contaminated ground water zones could not be restored. The portions of the site that
cannot be remediated (the technical impracticability (TI) zone) consists of splay deposits, or off-
channel deposits. These splay or off-channel deposits consist of sandy material with an abundance
of fine-grained material (clay and/or silt). The other portion of the site, which is not part of the TI
zone and is therefore not affected by this ESD, consists of a subsurface stream channel. The
subsurface stream channel contains more sand and less fine-grained material, aid this portion of the
site can likely be restored through the extraction and treatment remedy based on the information
collected and evaluated (Figures 2 and 3).
The findings of the investigations and evaluations are presented in the TI Assessment for the
Crystal Chemical site. Factors providing the basis for the TI waiver include the following:
1) The complexity of the site geology;
2) the majority of the arsenic is in the fine-grained splay or off-channel deposits;
3) lab and field testing indicates that the arsenic has adsorbed on to the fine-grained
sediments of the splay or off-channel deposits;
4) over 700 million gallons of water would have to be extracted to try to achieve the
remediation goal;
S) the slow release of arsenic from the fine-grained sediments will limit the rate and
quantity of arsenic that can be removed by extracting the ground water; therefore,
6) a range from 200 to 650 years is the minimum time estimated to restore the ground
water zones, if they could be restored at all.
The timing of this TI decision is consistent with EPA's current program guidance on such
waivers, "Guidance for Evaluating the Technical Impracticability of Ground Water Restoration
(OSWER Directive 9234.2-25. September, 1993). The guidance states that a TI decision may be
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FIGURE 2
GEOLOGIC CROSS-SECTION
1
CH
CH
(20.400^/L)
MW-1A
SW.TS. CLA>S, AND
OCCASIONAL SANDS
AflCVt THE JS-FOOT
ZONC
to- _
TRANSECT 1
35 - FOOT ZONE
CHANNEL AND LEVEE AND BAR
DISTRIBUTARY-MOUTH BAR
EXPLANATION
•• SC-CLAYEY SANDS
SM • SILTY SANDS
[""-• -I SP. POORLY GRADED SANDS
> ,••« »J
BgBfej CL-CLAYS
m ML-INORGANIC SILTS AND VERY FINE SANDS
[ | DISTRIBUTARY MOUTH DEPOSIT (SP/SM)
H| NO RECOVERY
(10.400 ui/L) CONCENTRATION OF ARSENIC IN WATER
Sh HORIZONTAL BEDDED SANDS
SI LAMINATED SANDS
] FINING-UPWARD SEQUENCES
0 20 ft
NO VERTICAL EXAGGERATION
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FIGURE 3 - AREAL EXTENT OF TI ZONE
AND ESTIMATED LOCATION OF SLURRY WALL
[ |
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made prior to implementing the remedy provided such a TI decision is adequately supported by
detailed site-specific data and analyses.
The detailed technical demonstration that serves as the basis for the TI decision at the Crystal
Chemical site is provided in the TI Assessment,, prepared by Southern Pacific Transportation
Company. The TI Assessment presents a detailed analysis of information collected prior to the
issuance of the ROD, as well as information collected during the design investigations.
During the course of the. implementation of the soil remedy (completed in September 1995),
contaminated soils associated with two of the three onsite wastewater storage/treatment ponds were
excavated and placed under the engineered, low permeability cap that was constructed over the entire
Crystal Chemical she. Based on the depth of contamination, excavation from the third pond was not
necessary. All source control measures that could reduce the migration of arsenic to the ground
water have been implemented at the Crystal Chemical site. Therefore, according to the ROD, the
ground water contingency measure calling for the implementation of additional source control (ROD
ground water contingency measure #6) has been carried out.
As a result of EPA's conclusion that restoration of the ground water is technically
impracticable for portions of the Crystal Chemical site, EPA has determined that the ARAR for
ground water restoration will be waived (ROD ground water contingency measure #4) and a slurry
wall will be constructed around the portions of the site where ground water cannot be restored (ROD
ground water contingency measure US). See Figure 3 for the illustration of the TI zone and location
of the shiny wall. The extraction and treatment of arsenic-contaminated ground water remedy will
be implemented on the remainder of the site.
Although the 1990 ROD indicates that there will be operation and monitoring of the
extraction and treatment system for 10 years prior to consideration of the contingency measures,
implementation of the extraction and treatment remedy and monitoring for a 10-year period is not
necessary to determine that the remedy is incapable of achieving the remediation goal in the TI zone.
EPA already has adequate information to support its determination that a TI waiver is appropriate.
The Texas Natural Resource Conservation Commission (TNRCC) has reviewed the TI
Assessment and agrees that the data support the findings that ground water restoration on portions
of the Crystal Chemical site is technically impracticable. TNRCC has also concurred with EPA
regarding the construction of the slurry wall around the TI zone.
V. PUBLIC PARTICIPATION ACTIVITIES
During the preparation of the ROD, EPA held a public comment period from June 11,1990
through July II, 1990. Informal open houses were held in the Houston area on two separate
occasions: April 10 and June 5,1990. Additionally, a public meeting was held on June 21,1990.
EPA responded to comments received during the public meeting as well as the public comment period
in the Responsiveness Summary, which is an attachment to the ROD.
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During the preparation of the ROD amendment for the soil remedy, EPA held a public
comment period from February 24, 1992 through March 24, 1992. An informal open house was held
on February 20, 1992, with the public meeting being held on March 19, 1992. EPA responded to
comments received during the public meeting as well as the public comment period in the
Responsiveness Summary, which is an attachment to the June 1992 ROD amendment for the soil
remedy.
An open house was held on October 13, 1994 to update the community on the remedial
designs for the soil and ground water remedies for the Crystal Chemical site.
A notice of this Explanation of Significant Differences and a summary of the differences
between the ground water remedy being proposed and the ground water remedy identified in the 1990
ROD was published in the Houston Chronicle on July 12, 1996. Approximately 1300 fact sheets
summarizing the proposed changes and requesting public participation were mailed, and EPA invited
public comment from July IS, 1996 until August 15, 1996. All written comments submitted have
been responded to in the attached Responsiveness Summary.
VL STATE COMMENTS
The State's letter expressing its concurrence with this ESD is attached.
VIL STATUTORY DETERMINATION
Considering the new information developed during the remedial design for the ground water
remedy described in the ROD, specifically the technical impracticability of restoring the ground water
on portions of the site, EPA believes that the remedy remains protective of human health and the
environment. Furthermore, the 1990 ROD remains protective and continues to meet ARARs
identified in the 1990 ROD that are not being waived. The revised remedy utilizes permanent
solutions to the maximum extent practicable for this site and is cost-effective. It complies with the
National Oil and Hazardous Substances Pollution Contingency Plan and other federal and state
requirements that are applicable or relevant and appropriate to this remedial action.
aw '/ Date
Iministrator
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APPENDIX A
EXPLANATION OF SIGNIFICANT DIFFERENCES FOR THE
CRYSTAL CHEMICAL COMPANY SUPERFUND SITE
RECORD OF DECISION
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY FOR
EXPLANATION OF SIGNIFICANT DIFFERENCES
TO THE SEPTEMBER 1990 RECORD OF DECISION
CRYSTAL CHEMICAL COMPANY SUPERFUND SITE
HOUSTON, TEXAS
The public comment period for the Explanation of Significant Differences to the Crystal
Chemical Company Superfund site September 1990 Record of Decision was held from July IS,
1996 to August IS, 1996. The EPA received no requests for a public meeting during the public
comment period. The only comments received during the public comment period were submitted
by Vinson & Elkins, Attorneys at Law, on behalf of their client Mr. Theodore Levy. Mr. Levy,
now deceased, owned property north of the site. These comments are being addressed in this
Responsiveness Summary.
Comment 1: EPA must use the [Record of Decision] Amendment process to grant the
[tc :hnica! impracticability] waiver.
The "Guidance for Evaluating the Technical Impracticability of Ground-Water
Restoration" (OSWER Directive 9234.2-25, September 1993) identifies an Explanation of
Significant Differences (BSD) as a mechanism by which a technical impracticability (IT) waiver
can be invoked. The directive does state that public notice and opportunity for comment should
be provided if an BSD is used to grant the TI waiver. Pursuant to the directive, the EPA has
provided public notice and opportunity for comment since an ESD is being used to invoke the TI
waiver.
The requirements for issuing an ESD and issuing a Record of Decision (ROD)
Amendment pursuant to the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP) differ essentially in that a ROD Amendment is subject to public comment. The ROD issued
in September 1990 for the Crystal Chemical Company Superfund site identified several ground
water contingency measures that could be implemented if an extraction and treatment system
would not attain the remediation goals set for the Crystal Chemical Company site, and
opportunity for public comment was provided for the ground water contingency measures
identified in that 1990 ROD. The contingency measures in the 1990 ROD included containment
through use of a slurry wall. The EPA also issued a notice of availability and brief description of
the proposed ESD for the Crystal Chemical Company site ground water remedy in the Houston
Chronicle, a major local newspaper of general circulation. Approximately 1300 fact sheets
summarizing the changes and requesting public participation were mailed. The proposed ESD
and supporting information were available to the public in the administrative record.
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Unfortunately, property adjacent to the site has been affected by the ground water
contamination associated with the Crystal Chemical Company site. Regardless of whether the TI
waiver was invoked or the 1990 ROD extraction and treatment remedy was implemented on all
portions of the site, the adjacent property would be affected by the remedial action for the ground
water contamination. Under the design plan for the extraction and treatment remedy, installation
of two or three extraction wells were planned on the adjacent property for long-term operation.
During the development of this design, however, it was determined that the extraction and
treatment remedy would be unable to attain EPA's goal of restoring contaminated ground water
at the Crystal Chemical Company site within a reasonable time frame. Therefore, after careful
consideration, the EPA has selected an alternative remedial strategy that is technically practicable,
protective of human health and the environment, and satisfies the statutory and regulatory
requirements of the Superfund program. This alternative remedial strategy includes the
construction of a slurry wall across Westpark Drive and onto the adjacent property. The slurry
wall will contribute to the long-term management of contaminant migration by limiting the further
contamination of ground water. Effective source containment will permit restoration of the
portion of the aqueous plume that lies outside the containment area.
Comment 2; The TI waiver cannot be granted because EPA has not demonstrated that an
enhancement or augmentation of the selected remedy could not attain the
groundwater cleanup standard.
With the issuance of this ESD, the EPA concludes the culmination of approximately
thirteen years of investigations and studies in connection with the Crystal Chemical Company site.
Pursuant to the "Guidance for Evaluating the Technical Impracticability of Ground-Water
Restoration " (OSWER Directive 9234.2-2S, September 1993), the Assessment of the Technical
Impracticability of Ground-Water Remediation for the Crystal Chemical Superfund Site,
February 1996 (TI Assessment) was drafted by Southern Pacific Transportation Company in
consultation with EPA, and was ultimately approved by the EPA. EPA representatives from this
regional office as well as from EPA's headquarters in Washington, D.C., participated in the
evaluation and review of the Crystal Chemical Company site and of this document.
Representatives from EPA's Office of Research and Development, Technical Support Project at
the Robert S. Kerr Environmental Research Laboratory also fully participated in the evaluation
and review of the site, the ground water remedy, the ground water contingency measures, and the
TI waiver request.
In pursuit of the statutory preference for treatment and a permanent solution to the Crystal
Chemical Company site, EPA has been receptive to new technologies as well as innovative
approaches to addressing the contamination at the Crystal Chemical Company site during the past
thirteen years. In portions of the site where it has been determined that restoration of the ground
water is technically practicable, a contaminated ground water extraction and treatment system has
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been constructed and is operational. It is estimated that to reach the ground water remediation
goals for areas outside the proposed slurry wall, the water treatment plant will be treating the
extracted ground water (at approximately 5-10 gallons per minute) for the next 15 years.
During the development of the TI Assessment for areas of the site where groundwater
restoration is not technically practicable, initial bench tests (e.g., soil column leaching tests) to
assess the viability of aquifer extraction enhancement were conducted. In fact three methods for
the in-situ treatment of arsenic-bearing ground water were postulated: 1) a soluble ferric iron
complex would be injected into the contaminated aquifer; breakdown of the complex would allow
precipitation of ferric hydroxide at near-neutral pH, and arsenic would be coprecipitated; 2)
ground water pumped from the aquifer would be treated on the surface to produce a ferric
hydroxide precipitate containing arsenic; the ferric hydroxide, if present as a colloidal suspension
(a hydrosol), could be injected into the contaminated aquifer; and 3) aqueous ferric sulphate
would be injected into the aquifer in a geometric pattern with compressed air to oxidize resident
arsenite to arsenate while reacting with both inorganic and organic arsenic species. The testing
and studies concluded that arsenic could not be recovered from saturated soils to any significant
degree. A multi-year testing program (from further lab and bench scale tests to actual field pilot
tests) would be needed in order to design a full-scale aquifer remediation program using
chemically enhanced desorption or dissolution and mobilization of the arsenic at the Crystal
Chemical Company site. Even after designing a full scale system, uncertainties regarding the
ability of this remedial strategy to achieve the ground water remedial goals in the field would
remain due to hydrogeologjc factors (i.e., subsurface heterogeneities and abundance of fine grain
materials [clay and/or silt]) and contaminant-related factors.
As an attachment to the comments, a contractor provided a document which discussed the
possibility of similar enhancements to the extraction and treatment remedy for the Crystal
Chemical Company site. The contractor indicated that its "analysis and groundwater-flow
modeling of the Crystal Chemical situation clearly showed that hydraulic control of ground water
flow and transport could be achieved at the Crystal Chemical site through proper design, number,
and placement of wells." Previous modeling done for the Crystal Chemical Company site in
relation to the TI evaluation showed that a range from 200 to 650 years is the minimum time
estimated to restore the ground water zones, if they could be restored at all. Although the
modeling done in relation to the TI evaluation did not include the addition of a chemical agent to
aid in the extraction of contamination, the fact that it predicted very long restoration time frames
(e.g., longer than 250 years) seems to indicate the presence of hydrogeologic and/or contaminant-
related constraints to remediation. In addition, nowhere in the contractor's document is a single
example cited where arsenic of any form has been successfully removed from an aquifer to the
Crystal Chemical Company site remediation goal or to any other goal. Therefore, until the
conclusion and evaluation of a multi-year testing program as discussed above, the ability of the
contractor's proposed insitu extraction enhancements to attain the ground water remediation
goals would not be known. The EPA has determined that it is more appropriate to go forward
with a remedy which has been demonstrated to be effective.
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Comment 3; The administrative record does not support the action EPA proposed
because it does not include any evidence indicating an enhanced desorption
remedy is impracticable.
The administrative record does contain [as required in CERCLA § 113(k)(l)] the
documents that form the basis for the selection of the response action. As discussed in the Office
of Solid Waste and Emergency Response Directive # 9833.3 A-1 (Final Guidance on
Administrative Records for Selecting CERCLA Response Actions), the administrative record file
has been amended to include all of the comments submitted during the formal public comment
period. The information submitted during the formal public comment period does not support the
proposition that enhanced desorption is. practicable for the Crystal Chemical Company site. The
speculative nature of the technology and the lack of specific and/or demonstrated application to
the Crystal Chemical Company site does not justify the additional time and resources needed to
pursue enhanced desorption, especially given the thirteen years already expended in studying the
Crystal Chemical Company site in pursuit of a remedy. The EPA has selected an alternative
remedial strategy that is technically practicable, protective of human health and the environment,
and satisfies the statutory and regulatory requirements of the Superfund program.
A4
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APPENDIX B
STATE OF TEXAS CONCURRENCE LETTER
-------
Barry R. McBee, Chairman
R. B. "Ralph" Marquez, Commissioner
John M. Baker, Commissioner
Dan Pearson, Executive Director
TEXAS NATURAL RESOURCE CONSERVATION COMMISSION
Protecting Texas by Reducing and Preventing Pollution •
June 27, 19% -
SENT VIA FArSIMIf .F. * PFRTIFIFD MAII -
Mr. Chris Villarreal : .:
Remedial Project Manager •_.-.
Crystal Chemical Superrund Site - '••'
U.S. Environmental Protection Agency
Region 6, 6H-ET
Allied Bank Tower
1445 Ross Avenue
Dallas, TX 75202-2733
RE: Explanation of Significant Differences,
Crystal Chemical Site, Houston, Texas
Dear Mr. Villarreal:
This letter serves to communicate Texas Natural Resource Conservation Commission (TNRCC) concurrence
with the Explanation of Significant Differences (ESD) for the Crystal Chemical Superfund Site in Houston,
Texas. The TNRCC believes that the remedial strategy for the ground water presented in the ESD is
supported by the contingency measures outlined in the 1990 Record of Decision. Furthermore, the TNRCC
agrees with the U.S. Environmental Protection Agency's belief that the remedy utilizes permanent solutions
to the maximum extent practicable, is cost-effective, and remains protective of human health and the
environment.
Please contact me with any questions concerning these comments or any other issues at the Crystal Chemical
site at (5 12) 239-2030.
Sincerely,
E. R. (Trey) Collins, III
Project Manager
Superfund Engineering Section
Pollution Cleanup Division
ERC/erc
cc: Ms. Lisa Marie Price, U.S. Environmental Protecton Agency (6PD-NB)
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APPENDIX C
ADMINISTRATIVE RECORD INDEX
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April 4, 1996
Mr. James Wittwer
Work Assignment Manager
TechLaw, Inc.
750 N. St. Paul Street, Suite 600
Dallas, Texas 75201
RE: Crystal Chemical Site Explanation of Significant Differences
Administrative Record Addendum Index
ESS VI Work Assignment No. ESS%014
Dear Mr. Wittwer:
Please find, enclosed, a copy of the index for the Crystal Chemical Site Explanation of
Significant Differences Administrative Record Addendum. The index will be delivered to Mr.
Chris Villarreal, Remedial Project Manager, for placement in the site files. The AR addendum
index and addendum documents were mailed to the repository on April 2, 1997.
*
This document has been reviewed according to DPRA's Quality Assurance Program Plan and
Quality Assurance/Quality Control procedures. If you have any questions or comments about
the index, feel free to contact me at (214) 969-6977.
Sincerely,
ML
Enclosure
cc: Chris Villarreal, EPA w/Enclosure
Verne McFarland, EPA Work Assignment Manager w/o Enclosure
File/6114.003-0617 w/Enclosure
Mailing Address PO. Box 727 Manhattan. Kansas 66505 Telephone 913-539-3565 FAX 913-539-5353
Courier Address 200 Research Drive Manhattan. Kansas 66503
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Prepared for
United States Environmental Protection Agency
Region 6
FINAL
Administrative Record Addendum
Index
CRYSTAL CHEMICAL COMPANY SUPERFUND SITE
EPA ID No. TXD990707010
Explanation of Significant Differences
for Record of Decision
ESS VI
Work Assignment No. ESS06014
Chris Villarreal
Remedial Project Manager
U.S. EPA Region 6
Prepared by
DPRA Incorporated
717 North Harwood Street
Suite 1300
Dallas, Texas 75201
P. 6214.0617
March 19, 1997
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
CRYSTAL CHEMICAL COMPANY SITE
TXD990707010
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
007369 - 007398
03/31/92
030
Michael C. Barra, Assistant Regional Counsel
U.S. EPA Region 6
Charlotte L. Neitzel, Attorney for Southern Pacific
Transportation Company (Southern Pacific Lines), Law Firm of
Holme Roberts & Owen
Cover Letter w/Enclosure
Signed Administrative Order on Consent, Remedial Design for
groundwater remedy (Docket No. VI-11-92)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
007399 - 007470
09/03/92
072
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
David W. Long, Assistant General Counsel, Law Department,
Southern Pacific Lines
Cover Letter w/Enclosure
Administrative Order, Docket No. VI-15-92, Remedial
Design/Remedial Action
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
007471 - 007683
07/22/94
213
Industrial Compliance
Consultant for Southern Pacific Transportation Company
Southern Pacific Transportation Company and U.S. EPA Region 6
Report - Volume 1
"Geochemical/Geohydrologic Report - Groundwater Remedial
Design"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
007684 - 008350
07/22/94
667
Industrial Compliance
Consultant for Southern Pacific Transportation Company
Southern Pacific Transportation Company and U.S. EPA Region 6
Report - Volume 2, Appendices 1-9
"Geochemical/Geohydrologic Report - Groundwater Remedial
Design, Volume 2"
A-i
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
CRYSTAL CHEMICAL COMPANY SITE
TXD990707010
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:'
008705 - 009268
07/22/94
564
Industrial Compliance
Consultant for Southern Pacific Transportation Company
Southern Pacific Transportation Company and U.S. EPA Region 6
Report - Volume 3, Appendices 10-15
"Geochemical/Geohydrologic Report - Groundwater Remedial
Design, Volume 3"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
008351 - 008704
08/17/94
354
Paul Kuhlmeier, Director of Remedial Technology, Environmental
Affairs Group
Southern Pacific Lines
Lisa Price, RPM, Superfund Enforcement Branch, U.S. EPA Region
6
Cover Letter w/Report
"Treatment of Arsenic-Contaminated Groundwater from the
Crystal Chemical Superfund Site"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009269 - 009281
09/28/94
013
John G. Bins, Project Manager
Industrial Compliance (Consultant for Southern Pacific
Transportation Company)
Lisa Price, RPM, Superfund Enforcement branch, U.S. EPA Region
6
Cover Letter w/Enclosure
Revised Work Plan for Technical Evaluation of Arsenic
Extraction
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009282 - 009319
03/20/95
038
Hydrologic Consultants, Inc.
Consultant for Southern Pacific Lines
Southern Pacific Lines and U.S. EPA Region 6
Report
"Treated Groundwater Reinjection Option Report"
A-2
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
CRYSTAL CHEMICAL COMPANY SITE
TXD990707010
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009320 - 009510
03/20/95
191
Hydrologic Consultants, Inc.
Consultant for Southern Pacific Transportation Company
Southern Pacific Transportation Company and U.S. EPA Region 6
Report - Volume 1
"Soil and Groundwater Model Report"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009511 - 009843
03/20/95
333
Hydrologic Consultants, Inc.
Consultant for Southern Pacific Transportation Company
Southern Pacific Transportation Company and U.S. EPA Region 6
Report - Volume 2, Appendices A-H
"Soil and Groundwater Model Report"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009844 - 009845
04/20/95
002
E.R. (Trey) Collins III, Project Manager
Texas Natural Resource Conservation Commission (TNRCC)
Lisa Price, RPM, Superfund Enforcement Branch, U.S. EPA Region
6
Letter
TNRCC comments about Southern Pacific Transportation Company's
groundwater technical impracticability (TI) waiver for portion
of remedy presented in "Assessment of the TI Groundwater
Remediation Report"
DOCUMENT NUMBER:
DOCUMENT DATS:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009846 - 009850
04/28/95
005
Lisa Price, RPM, Superfund Enforcement Branch
U.S. EPA Region 6
David H. Long, Assistant General Counsel, Law Department,
Southern Pacific Transportation Company
Cover Letter w/Enclosed Comments
EPA's comments on the "TI Groundwater Remediation Report"
A-3
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
CRYSTAL CHEMICAL COMPANY SITE
TXD990707010
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009851 - 009852
05/18/95
002
Christopher B. Amandes, Attorney for Theodore R. Levy
Vinson & Elkins
Lisa Price, RPM, Superfund Enforcement Branch, U.S. EPA Region
6
Letter
TI waiver and public notice requirements
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009853 - 009856
05/30/95
004
Lisa Price, RPM, Superfund Enforcement Branch
U.S. EPA Region 6
Christopher B. Amandes, Attorney for Theodore R. Levy, Vinson
& Elkins
Letter
Response to Mr. Amandes' 05/18/95 letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009857 - 009860
06/19/95
004
Christopher B. Amandes, Attorney for Theodore R. Levy
Vinson & Elkins
Lisa Price, RPM, Superfund Enforcement Branch, U.S. EPA Region
6
Letter
Requests EPA reconsider submitting decision granting Southern
Pacific Lines a TI waiver for groundwater remedy
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009861 - 009868
08/30/95
008
Lisa Price, RPM, Superfund Enforcement Branch
U.S. EPA Region 6
Christopher B. Amandes, Attorney for Theodore R. Levy, Vinson
& Elkins
Letter w/Enclosures
Re: 1) EPA grants TI waiver for groundwater remedy and 2) EPA
requests access to property to perform response action for
contaminated groundwater
A-4
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
CRYSTAL CHEMICAL COMPANY SITE
TXD990707010
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009869 - 009871
09/11/95
003
Christopher B. Amandes, Attorney for Theodore R. Levy
Vinson & Elkins
Lisa Price, RPM, Superfund Enforcement Branch, U.S. EPA Region
6
Letter
Requests EPA defer request for access to Mr. Levy's property
until the agency has granted TI waiver to Southern Pacific
Transportation Company
009872 - 009874
09/19/95
003
Lisa Price, RPM, Superfund Enforcement Branch
U.S. EPA Region 6
Christopher B. Amandes, Attorney for Theodore R. Levy, Vinson
& Elkins
Letter
Clarification of issues addressed in 09/11/95 letter about
EPA's request for access to easement portion of Mr. Theodore
Levy's property
009875 - 009876
09/28/95
002
E.R. (Trey) Collins III, Project Manager
TNRCC
Lisa Price, RPM, Superfund Enforcement Branch, U.S. EPA Region
6
Letter
TNRCC's agreement with TI waiver and with the slurry wall
009877 - 009888
10/02/95
012
Scott G. Huling, Environmental Engineer, Office of Research
and Development
U.S. EPA, Ada, Oklahoma
Lisa Price, RPM, Superfund Enforcement Branch, U.S. EPA Region
6
Memorandum
Review comments on "Geochemical/Geohydrologic Report, Volume
1", (07/22/94) and "Assessment of the TI of Groundwater
Remediation, Volume 1" (95-R06-001)
A-5
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
CRYSTAL CHEMICAL COMPANY SITE
TXD990707010
009889 - 009891
10/26/95
003
Cal James and Peter Feldman, Office of Emergency and Remedial
Response . ' .
U.S. EPA Headquarters
Lisa Price, RPM, Superfund Enforcement Branch, U.S. EPA Region
6
Memorandum
Review of the "TI of Groundwater Remediation Report"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009892 - 009901
11/11/95 '
010
Aniko Molnar, Environmental Project Manager
Southern Pacific Lines
Lisa Price, RPM, Superfund Enforcement Branch, U.S. EPA Region
6
Cover Letter w/Letter Report
"Former Evaporation Pond - Source Removal Excavations"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009902 - 009903
02/02/96
002
David W. Long, Assistant General Counsel, Law Department
Southern Pacific Lines
Lisa Price, RPM, Superfund Enforcement Branch, U.S. EPA Region
6
Letter
Submittal of "Assessment of the TI of Groundwater Remediation
Report"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY /AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009904 - 010146
02/02/96
243
Hydrologic Consultants, Inc.
Consultants for Southern Pacific Transportation Company
Southern Pacific Transportation Company and U.S. EPA Region 6
Report - Volume 1
"Assessment of the TI of Groundwater Remediation"
A-6
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
CRYSTAL CHEMICAL COMPANY SITE
TXD990707010
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010147 - 010503
02/02/96
357
Hydrologic Consultants, Inc.
Consultant for Southern Pacific Transportation Company
Southern Pacifid Transportation Company and U.S. EPA Region 6
Report - Volume 2, Appendices A-K
"Assessment of the TI of Groundwater Remediation"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010504 - 010504
06/27/96
001
E.R. (Trey) Collins III, Project Manager, Superfund
Engineering Section, Pollution Cleanup Division
TNRCC
Chris Villarreal, RPM, U.S. EPA Region 6
Letter
State concurs with Explanation of Significant Differences
(BSD)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010505 - 010515
06/27/96
Oil
EPA Staff
U.S. EPA Region 6
Public
Proposed BSD
Proposed BSD to the September 1990 Record of Decision
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010516 - 010519
07/08/96
004
Unspecified
U.S. EPA Region 6
Public
EPA Update on Activities at Crystal Chemical Superfund Site
Site Update
A-7
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
CRYSTAL CHEMICAL COMPANY SITE
TXD990707010
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010520 - 010549
08/14/96
030
Christopher B. Amandes, Attorney for Theodore R. Levy
Vinson & Elkins
Chris Villarreal, RPM, U.S. EPA Region 6
Letter w/Enclosures
Comments on behalf of Mr. Theodore R. Levy about proposed BSD
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE.
010550 - 010552
08/19/96
003
Bruce Daniel
TerraNext
Chris Villarreal, RPM, U.S. EPA Region 6
Facsimile Transmittal Cover Sheet w/Enclosures
Sworn affidavit from the Houston Chronicle that BSD notice was
published on 07/12/96.
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010553 - 010555
10/29/96
003
G.F. Shepherd, Director Environmental Projects
Southern Pacific Lines, Environmental Affairs Group
Lisa Price, RPM, U.S. EPA Region 6
Letter
Rebuttal to 08/14/96 Vinson & Elkins letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010556 - 010583
03/19/97
028
Jane N. Saginaw, Regional Administrator
U.S. EPA Region 6
Public
Decision Document
"Superfund BSD for Record of Decision: Crystal Chemical
Superfund Site, Houston, Texas"
A-8
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