2020 RCRA GPRA Corrective Action Work Plan
EPA Region 6
Regional Strategy to Complete Corrective Action by 2020
January 30, 2009
Updated: September 9, 2009; April 6, 2010; November 11, 2010; June 29, 2011; August 24, 2011;
November 16, 2011; December 19, 2011; February 1, 2012; March 21, 2012: October 29, 2012;
January 22, 2013; April 29, 2013; May 6, 2013; September 30. 2013; September 30, 2014;
Most Recent Update is for data as of September 30, 2015 (End of FY15).
RCRA Program
Multimedia Planning and Permitting Division
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Executive Summary of Regional Strategy to Complete Corrective Action by 2020 from the
Updated 2020 RCRA GPRA Corrective Action Work Plan - EPA Region 6
Goal: Achieve 2020 GPRA Corrective Action goals by September 30, 2020. It is projected that 95% or more of sites will
attain the Human Exposures Controlled (CA725) Ground Water Controlled (CA750), and Remedy Construction Complete
(CA550) milestones provided that there are no negative changes to conditions such as funding and disasters.
Baseline/Background: At the start in 2009, the baseline was 412 total facilities: The goal was 391 facilities with site-wide
CA550-Construction Complete determinations documented starting with127 facilities with construction complete at the
beginning of 2009 leaving 264 sites to complete in 12 years or 22 sites per year. Presently, there is a baseline of 423 sites
with a goal of 391. For Remedy Constructed, there are 108 facilities needed to complete the 95% goal in 5 years or less
than 22 per year on an average. For Human Exposures only 13 total facilities are required and 58 total for Ground Water.
Strategy: Region 6 employs a multifaceted approach to address the major challenges of attaining the 2020 goals. The
major elements of the strategy have been used successfully since 1999 allowing the Region to always meet or exceed the
GPRA yearly Annual Commitment System (ACS) targets and achieve the final 2005 and 2008 national OSW goals.
Additions and modifications are made to the strategy as is found convenient or necessary.
Grant Negotiations for 2020: First, Region 6 states were asked to provide 2020 corrective action planning information
and projections and secondly, they were asked to make key commitments for FY09 that if sustained, would result in
achieving the corrective action 2020 goals. States responded positively and the initial results indicate that the goals are
achievable as long as conditions remain the same. This approach of has been continued in FY10, FY11, FY12, FY13,
FY14, FY15, and FY16 resulting in consistently good progress toward the 2020 goals.
Review. Analyze, and Categorize Sites: All planning information provided by the state and Region was reviewed to
determine an individual site's present status and then the 412 total facilities categorized into A, B, and C categories based
on technical and resource requirements. In 2013, the baseline was modified by adding 12 sites in Texas and deleting 1 site
in Arkansas. With 129 total facilities remaining to complete the construction complete milestone, presently there are 14 A
sites and 23 B sites will require the most EPA and state resources to address corrective action. 92 C sites are state lead
sites that require mainly EPA oversight. A sub-category of state sites, 30 C-D sites were identified as state lead sites that
are having some type of difficulties in the clean-up process. Also, 15 C-E/C-D-E sites were identified as some of the sites
that Region 6 has since the start of the 2020 Challenge spent time, money, or other resources in the corrective action
process and are now considered state lead.
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For further planning purposes, 16 sites are identified in orange in the work plan as problematic and not likely to achieve
construction complete unless EPA and the states find innovative solutions. These sites are underfunded, bankrupt, or
abandoned, as well as large, complex sites that may not achieve the goal. 3 of the 16 are CA550OF (operating facilities)
that are not presently being counted by headquarters. Another 21 facilities are identified in yellow in the work plan as
requiring extra attention (overlap with some oranges sites) in that they are presently under an EPA order or EPA is partnering
with the state by providing resources to the state. Many times resources are leveraged and innovative approaches to
corrective action are successfully used. Some examples of these case studies are summarized in the work plan.
Provide Resources to Assist or Partner with States: In addition to grant funding, the Region assists in numerous ways
to move sites toward the construction complete goal.
EPA Contract Assistance or EPA Technical Assistance: Help to assess sites with sampling and analysis, perform
ground water surveys, review documents, select remedies, perform modeling, etc.
EPA Training: Numerous trainings have been provided In the past to assist the state programs with different
corrective action topics.
Development and Updating of Corrective Action Strategy (CAS): Accelerate cleanups and encourage the use of
risk-based approaches, flexibility, and performance based remedies.
Enforcement Resources: Enforcement staff to perform inspections at some baseline sites and issue new orders
as necessary to expedite site assessment and remediation.
Superfund Resources: Occasionally used for site assessments and removal actions to assist with underfunded
and bankrupt sites.
Increased Planning and Communication: The Region 6 states submit projections for sites on the baseline that have not
achieved the GPRA milestones. A team approach is used in order to solve corrective action issues. State managers,
coordinators, and site project managers are met with in order to obtain more details regarding the individual facilities in
order to develop individual plans for sites where the Region's technical, contractor, or other resources are needed.
Adjustments to the information in this 2020 work plan will be made as new information is obtained.
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Updated 2020 RCRA GPRA Work Plan - EPA Region 6
Regional Strategy to Complete Corrective Action by 2020
Goal: Achieve 2020 GPRA goals by September 30, 2020. By the end of FY2020, the cleanup of existing contamination at RCRA regulated
GPRA facilities will be completed, though some long-term remediation work may be ongoing {e.g. groundwater pump and treat, etc.) The
stated goal is that 95% of GPRA baseline sites will attain the Human Exposures Controlled (CA725), Ground Water Controlled (CA750),
and Remedy Construction Completed (CA550) milestones for site-wide RCRA corrective action. A new measure has
been added which is the Performance Standards Attained (CA900/CA999) milestone of completion of corrective action.
Baseline/Background: The Region 6 2020 Baseline in 2009 consisted consists of 412 facilities (258 TX, 64 LA, 36
OK, 31 AR and 23 NM). Presently, in 2015, the baseline has been adjusted to 423 facilities (See insert to right). Since
2009, Texas added 12 facilities to the baseline and Arkansas deleted 1 facility which was listed for Superfund cleanup.
This is a net of 11 new sites or 423 total.
Region 6 has direct corrective action lead or is assisting the states at 35 sites that are either EPA enforcement lead
sites or those facilities where States have requested EPA to take the lead or assist because of staffing or other issues.
EPA is or has provided technical assistance to States in cases where: 1) facilities that are BRAC or 2) where sites
have been determined to be bankrupt, underfunded or have new ownership with undetermined resources or 3)
expertise to complete complex technical problems or 4) corrective action obligations are at large mega-sites.
Strategy: Region 6 has developed a multifaceted approach to address major challenges to achieving corrective action goals for the GPRA
2020 baseline facilities. The elements of the strategy have been used successfully since 1999 allowing the Region to always meet or exceed
the GPRA yearly goals. The final 2005 and 2008 goals were met or exceeded as well as the interim goals on the trail to the final 2020 goals.
Additions and modifications are made to the strategy as is found convenient or necessary.
Of the 412 original 2009 baseline facilities in Region 6, 127 of these sites had construction complete determinations documented at the
beginning of FY09. At the end of FY15, 294 (70%) had achieved this milestone indicating excellent progress toward the 2020 goal of 95%.
167 sites were completed in 7 fiscal years or an average of nearly 24 per year which is slightly ahead of the 22 per year projected. There
are 108 facilities needed to complete the 95% goal in 5 years or less than 22 per year on an average.
To better track and manage progress of the facilities on the 2020 baseline, the Region has sorted all 423 facilities into three manageable
categories (and two subcategories) based on the expected workload requirement for an EPA project manager. The classification of each
State
Facilities
AR
30
LA
64
NM
23
OK
36
TX
270
Total
423
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site is changed as conditions change. For example as the work is completed or the milestone is completed by EPA, the category is changed
from an 'A' or 'B' to a C-E. Table 2. is a list of problem sites that have not achieved the CA550: Construction Complete goal and are a
priority to the Region along with the category and status. These are of priority for the Region to track because of the amount of resources
spent on the sites and/or because of the difficulty the site poses in order to attain the corrective action goals. Facilities that are state lead
and do not pose a problem in the cleanup process are not listed here.
The categories are:
1) Category A Sites: 14 facilities that are: i) 6PD lead sites that were transferred from the Enforcement Division for case closure; ii)
bankrupt or underfunded facilities; iii) facilities with questionable technical or financial resources; or iv) EPA lead federal facilities.
2) Category B Sites: 23 facilities that are: i) State lead sites where the Region is providing the State significant technical assistance and
expects to provide future assistance; ii) sites that Texas identified where they had no project manager assigned and were given to EPA
as project lead; iii) BRAC sites, iv) some large complex sites.
3) Category C Sites: 47 facilities that are State lead sites where EPA assistance is expected to be minimal. EPA involvement is expected
to be limited to oversight and tracking progress.
4) Category C-D Sites: 30 facilities that are State lead sites where EPA assistance is expected to be minimal. EPA involvement is
expected to be limited to oversight and tracking progress. However, these are sites that are slow moving in the corrective action process
or present other difficulties to the state. These are sites identified by states in their individual plans as requiring extra work. These are
problematic 'C' Sites that especially need to be monitored for progress.
5) Category C-E Sites (or C-D-E): 15 facilities that EPA has previously contributed significant technical and/or contractor assistance
and returned the site to State lead sites. In other words, the facilities are no longer requiring EPA significant resources but have in the
past.
Of the sites listed in Table 2. sixteen (16) sites are identified in orange as problematic meaning that these facilities are not likely to achieve
construction complete unless EPA and the states to find innovative solutions. These sites are underfunded, bankrupt or abandoned as well
as large complex sites that may not achieve the goal. Another twenty one (21) facilities are identified in yellow in Table 2. of the work plan
as requiring extra attention in that they are presently under an EPA order or EPA is partnering with the state by providing resources to the
state in the form of technical assistance and/or contract assistance. The two categories overlap. Many times resources are leveraged and
innovative approaches to corrective action are successfully used. Some examples of these case studies are summarized in this work plan
in Appendixes 1, 2, and 3.
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EPA project managers are assigned, as appropriate, to a subset of the 423 facilities for either direct implementation of project management,
technical assistance to the state as needed, or state oversight responsibilities depending upon the workload as described in project
categories. Project managers are also responsible for providing and inputting EPA data into the RCRAinfo national database. Table
2.categorizes the more time consuming or difficult sites in a couple of ways to depict future challenges which require additional resources.
Additional Significant Efforts to Achieve 2020 GPRA Goals Including Providing Resources to Assist or Partner with States:
All Region 6 States are authorized for RCRA corrective actions and are recognized as critical partners in meeting GPRA goals. The Region
is collaborating with States and assisting them in managing many projects. The following is a summary of other additional resources that
have been dedicated to achieving the goals as well as specific activities that the Region is undertaking to ensure we meet the 2020 goals.
• Understanding The Universe - Where are the facilities in the corrective action process, and what do they have left to complete? This
is very important to further this process. We have done the following in conjunction with our states:
o All Region 6 States sent letters to each of their facilities requesting information and have received good responses;
o This information was used to help plan site-specific activities to meet 2020 goals; and
o EPA staff and contractors have also conducted extensive file reviews at Texas and Louisiana State offices to obtain information
to complete CA725/750 forms and CA400/CA550 memorandums where interim remedies could be considered as final actions,
o As explained below, all five in Region 6 states have submitted plans and projections regarding the 2020 facilities corrective
action status and typically update their projections twice a year.
• Improving Data Quality - to help plan and track 2020 milestones:
o EPA Region 6 has been working closely with each of its States on RCRAinfo data cleanups over the past several years; and
o EPA staff and contractor support has been used to conduct file reviews to assist in data cleanup activities on hundreds of
facilities to date.
• GPRA Team Approach To Meeting Corrective Action Goals - EPA staff and government contractors work closely with State project
managers to provide technical assistance on difficult sites (i.e., large and complex, underfunded, abandoned, bankrupt, etc).
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Assistance is in the form of developing conceptual site models, data gap identification, conducting sampling and analysis, laboratory
support, detailed file reviews, Environmental Indicators form completion, and other relevant tasks.
• Grant Restructuring - Region 6 began restructuring performance based grants with each state in 1997 to focus on corrective action
final results over the process and in 1999 focused on achieving GPRA commitments (CA725 and CA750). Beginning with the RCRA
grants in 2006, specific language was added to require state grant commitments to obtain the site-wide remedy selection (CA400)
and construction complete (CA550) determinations.
• Grant Requirements for 2020 Projections and Plans - Grants also require the states to develop specific 2020 plans for meeting the
2020 corrective action goals. All five states have provided projections and information regarding specific sites. Region 6 states
indicate that they plan to achieve the targets. The ability to successfully meet the plan cannot be as certain if resources available to
EPA and the states are significantly less than when the initiative was started. This appears to be the trend in these difficult financial
times.
• Grant Negotiations for the 2020 Challenge - New grant commitment numbers were negotiated for FY09 for each of the corrective
action measurements (CA400, CA550, CA725, and CA750). If the states are able to sustain the number of sites committed to in FY09
for future years, then the 2020 goal will be met. The projections and plans submitted for all of the Region 6 states support this
approach. See Chart 1. and Table 1. below. Grant progress is tracked through RCRAinfo reports as well as monthly calls, mid and
end of the year grant reviews.
• Risk-Based Approach - Region 6 is employs streamlined risk-based performance based corrective action approaches (Texas Risk
Reduction Program (TRRP), Oklahoma Risk-based Decision Making guidance, Louisiana Risk Evaluation Corrective Action Program
(RECAP), Region 6 Corrective Action Strategy (CAS) and use of innovative investigations and cleanup technologies.
• Performance-Based Remedies - The 2008 edition of Corrective Action Strategy (CAS) emphasizes performance-based remedies
using media-specific corrective action objectives to support the performance standards of source removal, treatment or containment,
achievement of regulatory cleanup values or risk-based values. The emphasis is on attaining the Corrective Action Objectives (CAOs)
- not on choosing a technology. This approach can assist in promoting flexible remedies at some sites. Examples are: Altus Air
Force Base in Oklahoma, Formosa Plastics in Texas, and the PPG (Axial) site in Lake Charles, Louisiana. Region 6 has updated
the 2008 CAS in FY15. See http://www.epa.gov/sites/production/files/2015-09/documents/r6-cas2Q15.pdf.
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• Flexibility - We are promoting programmatic flexibility through the use of alternative authorities and facility lead agreements to speed
up site investigation and cleanups.
• Training - Region 6 conducts training for States and industry on: RCRA fundamentals, completion of Environmental Indicator
evaluations, development of conceptual site models, vapor intrusion evaluations, use of innovative technologies for investigation and
cleanup, permitting modifications, and moving from interim measures to final corrective actions. The ORCR training "RCRA
Corrective Action Training: Getting to YES! Strategies for Meeting the 2020 Vision" was presented in Austin, Texas, in April 2009,
and was presented by EPA Region 6 staff in Baton Rouge, Louisiana, in April 2010. Examples of more recent training provided by
Region 6 staff include "Institutional and Engineering Controls" and "RCRA Corrective Action Groundwater Remedies". The latter
training was provided to Louisiana in May 2013, Arkansas in December 2013, and New Mexico in 2014. Additional training is provided
by the Region as needed or requested pending available resources. Lack of travel funding has curtailed some of these efforts.
• Superfund - Superfund staff/resources are occasionally utilized where focused site assessments and/or removals are needed
(bankrupt facilities, under-funded sites, or where our recommendations can help prioritize site clean-ups).
• Enforcement and Permitting Coordination including the National Enforcement Strategy for Corrective Action (NESCA) - In 2010, the
National Enforcement Strategy for Corrective Action (NESCA) was finalized which encourages the need for robust communication
with our state counterparts. Some examples of NESCA ideas used by Region 6 include: 1) issuance of RCRA 3007 letters to near-
bankrupt sites to attain financial status of the corporations (i.e., Benton Creosote), 2) issuance of 3013 Orders to gather information
on closure/NFA status (International Shoe, Motiva), 3) incorporation of "hard schedules" for corrective action milestones ( Formosa
Plastics 2012 Amendment 2 to the 3008(h) AOC), 4) inclusion of a financial assurance review as part of our annual Region 6 oversight
review of the corrective action and permitting programs, and 5) prioritizing our oversight reviews of state corrective action and
permitting program based on environmental justice ratings used in Region 6.
• Environmental Justice (EJ) - The Region 6 RCRA Program Environmental Justice (EJ) strategy describes the goals and methods
for incorporating EJ into the day to day operations of our program. The strategy is found in Appendix 4. This will incorporate EJ into
the setting of priorities for oversight reviews of EPA and state lead corrective action activities at facilities. Coordination with each of
our states will occur to ensure that appropriate actions are taken for all sites and that disproportionately burdened populations are
included to the extent practicable in the decision making process. Staff will be assigned to sites given priority because they are
located in areas of concern. Referrals to enforcement or requests for additional support will be prioritized based impact to the areas
of concern.
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• Increase Communication - In addition to above listed calls and meetings, the Region has increased communication with states and
facilities (conference calls, meetings, site visits) to closely track progress, identify potential impediments (technical, financial,
regulatory, etc ), and identify need for support. Region 6 staff traveled to Lake Charles, LA to visit three GPRA sites (Axiall [PPG],
Sasol and Citgo Refinery in January 2014. Region 6 traveled to Baton Rouge, Louisiana, in April 2014 to perform a site visit at the
Exide site.
• Continue Planning - As mentioned, close communication with state counterparts is a key factor. A team approach is used in order
to solve corrective action issues. State managers, coordinators, and state site project managers are met with or conference calls are
held to obtain more details regarding the individual facilities in order to develop individual plans for sites where the Region's technical,
contractor, or other resources are needed. Communication, tracking, and oversight are continuing processes. Adjustments to the
information in the 2020 work plan are made as new information is obtained.
Achievement of the 2020 GPRA Corrective Action Goals: The Achievement of the 2020 GPRA goals for corrective action is
dependent on the availability of sufficient resources to undertake the required tasks. This is true for both the state and EPA regional
organizations. At present, state and Federal budgets are being cut meaning that the number of staff working on the investigation and
cleanup of RCRA facilities on the GPRA baseline are significantly reduced. State and EPA staff have other tasks and non-GPRA sites
that are part of their workload that they must address as well which stretches resources even further. The two largest Region 6 states,
Texas and Louisiana, have both seen significant reductions in corrective action and other staff in the recent past. Any reductions in grant
money to the states will also hamper the progress of investigations and cleanup of sites as well as any reduction in EPA staff and/or
corrective action contract monies. It is essential that sufficient funding be available at all levels in order to meet the 2020 GPRA corrective
action goals to progress 95% of the baseline sites to the site-wide construction complete stage
CA900/999: Performance Standards Attained Goal Added in FY14:
In FY14, the CA900/999: Performance Standards Attained milestone was added as a GPRA measurement to the Annual Commitment
System (ACS) parameters. In FY14, a project was undertaken and completed to correct RCRAinfo errors where the Performance
Standards Attained measurement had been entered erroneously entered into the RCRAinfo database system as being attained site-
wide. In FY15, a second project was undertaken to enter into RCRAinfo instances where the CA900/999 code needed to be entered but
had not been completed. Four states completed the data entry. The Texas data correction project, because of the number of sites to
considered, was continued into FY16 and the site reviews are in progress.
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TABLE 1: ORIGINAL (2009) PROJECTED NUMBER OF FACILITIES ACHIEVING RCRA GPRA AND
ACTUAL NUMBER AND PERCENT OF 100% (423 FACILITIES) GOAL COMPLETED LISTED BY FISCAL
YEAR-
UPDATED 09/30/15
MEASUREMENT
START
FY09
FY09
FY10
FY11
FY12
FY13*
FY14
FY15
CA725:
246 (60%)
261 (63%)
276 (67%)
291 (71%)
309 (75%)
324 (79%)
339 (82%)
352 (83%)
HUMAN EXPOSURES
ACTUAL
262(64%)
ACTUAL
313 (76%)
ACTUAL
328 (80%)
ACTUAL
346 (84%)
ACTUAL
362 (86%)
ACTUAL
375(89%)
ACTUAL
389 (92%)
CA750:
216 (52%)
231 (56%)
246 (60%)
261 (63%)
294 (71%)
309 (75%)
324 (79%)
337 (80%)
GROUND WATER
ACTUAL
ACTUAL
ACTUAL
ACTUAL
ACTUAL
ACTUAL
ACTUAL
233 (57%)
251 (61%)
266 (65%)
290 (70%)
309 (73%)
325(77%)
344(81%)
CA400:
145 (35%)
165 (40%)
185 (45%)
205 (50%)
248 (60%)
267(65%)
289 (70%)
311 (74%)
REMEDY
ACTUAL
ACTUAL
ACTUAL
ACTUAL
ACTUAL
ACTUAL
ACTUAL
173 (42%)
199 (48%)
228 (55%)
257(62%)
281 (66%)
306 (72%)
325(77%)
CA550:
127 (31%)
149 (36%)
171 (42%)
193 (47%)
226 (55%)
248 (60%)
270 (66%)
292 (69%)
CONSTRUCTION
ACTUAL
151 (37%)
ACTUAL
177(43%)
ACTUAL
199 (48%)
ACTUAL
226 (55%)
ACTUAL
248 (59%)
ACTUAL
272 (64%)
ACTUAL
294(70%)
* El even (11) new sites were added changing percentages.
/-N^ Q /V/
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CHART 1: CONSTRUCTION COMPLETE (CA550) TOTAL NUMBER OF FACILITIES PROJECTED
AND ACTUAL NUMBER OF TOTAL FACILITIES ACHIEVED LISTED BY FISCAL YEAR -
UPDATED 09/30/15
450
I Projected Number of Total Facilties to be Accomplished at End of Fiscal
Year to Complete 402 Sites (95%) by 2020
400
350
300
250
200
150
100
50
I Actual Number of 423 Total Facilities Completed at End of Fiscal Year
Showing Progress toward 2020 Goal; Note that a net of 11 sites (12-1)
were added to baseline in FY13.
10
11
12
13
14
15
16
17
18
19
20
Fiscal Year
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EXPLANATION OF TABLE 2. BELOW:
Table 2. is not an all-inclusive list. It is meant to depict mainly sites where EPA has the lead, is assisting the state in some capacity, or is
doing close oversight of the cleanup. Also included are the facilities which the states have designated as difficult and/or not being
projected to meet the CA550 goal in 2020 or beyond. All projections are subject to revision as they are estimated. As facilities in the table
achieve the CA550 goal, they are moved to the bottom of the list. Numbers below reflect only the listed sites that have not achieved
construction complete. Note that EPA Region 6 has other tables and charts to track the progress of the 2020 facilities toward the goal.
1. Category A Sites: 14 facilities that are: i) 6PD lead sites that were transferred from Enforcement for case closure; ii) bankrupt or
underfunded facilities; iii) facilities with questionable technical or financial resources; or iv) EPA lead federal facilities. These are the
most resource intensive for both technical expertise and EPA contractor work.
2. Category B Sites: 23 facilities that are: i) State lead sites where the Region is providing the State significant technical assistance and
expects to provide future assistance; ii) sites that Texas identified where they had no project manager assigned and were given to EPA
as project lead; iii) BRAC sites, iv) some large complex sites. These sites also require significant EPA resources.
3. Category C Sites: 47 facilities remain (not listed here) that are State lead sites where EPA assistance is expected to be minimal. EPA
involvement is expected to be limited to oversight and tracking progress.
4. Category C-D Sites: 30 facilities that are State lead sites where EPA assistance is expected to be minimal. EPA involvement is
expected to be limited to oversight and tracking progress. However, these are sites that are slow moving in the corrective action process
or present other difficulties to the state. These are sites identified by states in their individual plans as requiring extra work. These are
problematic 'C' Sites that especially need to be monitored.
5. Category C-E Sites (or C-D-E): 15 facilities that EPA previously contributed significant technical and/or contractor assistance and
returned the site to State lead sites. In other words, the facilities are no longer requiring EPA resources.
6. Orange designates the most difficult sites that are unlikely to achieve the goals. Presently, 16 facilities. Pink depicts 9 sites
projected to achieve the CA550 milestone in the last year of the 2020 time period. These latter sites could 'slip' and not
achieve the goal and thus are of concern and will require more oversight.
7. 21 Yellow sites require extra attention from the Region in that they are being cleaned up under an order or EPA is assisting
the state. Note that there is some overlap between colors, i.e. categories.
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TABLE 2: FACILITIES OF CONCERN TO BE ADDRESSED FOR COMPLETION OF REMEDY
CONSTRUCTION (CA550): THE A, B, C-D, C-D-E AND C-E SITES
CA550
PROJECTED
FY
CATEGORY
BASELINE FACILITIES
EPA ID
COMMENTS
2016
A
Formosa Plastics (Point Comfort)
TXT490011293
EPA LEAD under EPA order. Remedy decision effective
March 11, 2010. State is working on newer part of site.
Corrective action Order settled June 2012. Groundwater
pilot studies in 2013-2014 for ISCO showed promising
results. Formosa will complete remedy implementation
under a TCEQ Post Closure Order effective in FY 2016.
2016
A
Benton Creosoting Works
LAD008056632
EPA ASSISTANCE: Small site but underfunded. EPA
assistance with waste disposal using USACE contractors.
.EPA assisted LDEQ with an LDEQ Compliance Order
issued February 2013. Settlement negotiations are underway
pending an appeal.
2016
A
Oklahoma Pole & Lumber
OKD007335524
EPA ASSISTANCE: An underfunded site. EPA used EPA
staff and contractors to assess site and advance site. Moving
toward remedy selection. EPA will work with ODEQ and
property owner to implement a final remedy in 2016, which
will consist of capping and groundwater monitoring.
2016
B
American Brownfields Mountain Creek
Industrial Center (ABMCIC) was U.S.
Naval Weapons Ind. Reserve (Dallas)
CA 400 and CA550 codes have not been achieved due to
ecological issues in sediment contamination in Cottonwood
Bay and Mt. Creek Lake. ABMCIC just submitted a
Monitored Natural Recovery demonstration to TCEQ for the
sediments in Cottonwood Bay and Mt. Creek Lake. This is a
change from the remedy that was originally approved by
TCEQ when ABMCIC obtained the property from the Navy.
As for the groundwater, there is a PMZ remedy for the
onsite groundwater, which is contaminated with chlorinated
~ 12 ~
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solvents. ABMCIC conducted a pilot test for the
chlorinated groundwater plume located offsite on the NAS
Dallas property. ABMCIC has interpreted the results of the
pilot test and just recently (10/15) submitted a Technical
Impracticability demonstration to TCEQ for the offsite
groundwater plume.
2016
B
U.S. Dept Of Army- Lone Star Army
Ammunition Depot
TX7213821831
BRAC 2005; TCEQ is the lead regulatory Agency. Majority
of the Site was transferred to TexAamericas and Day and
Zimmerman in 2010 via a FOSET.
2016
B
Sandia National Lab
NM5890110518
Large complex site; Investigation of the groundwater
contamination remains in the characterization stage at the
Tijeras Arroyo and Burn Site. The Permit tee has proposed
interim measures for TA-V to NMED. A work plan for an
interim measure will be submitted to NMED in November
2014. all three sites where groundwater contamination
occurs. Final remedies have not been selected or
implemented for any of the three sites to date. Mixed waste;
public interest. Facility has a RCRA permit for cleanup of
SWMUs.
2016
C-D
Occidental Chemical
TXD007325111
CA400 and CA550 has not been achieved yet due to off-site
access issues and off-site deed recordation problems.
Facility is also pursuing an MSD with the city.
2016
C-D
Koppers Co or Magellan Terminal Holdings
TXD008089021
The Magellan site still has not achieved CA550 due to the
construction of a number of large above ground bulk storage
tanks at the site. Due to the locations of the new tanks,
Magellan is revising the existing response action plan for
addressing soil and groundwater contamination at the site.
The projected dates are estimated when the RAP will be
approved for implementation.
2016
C-D
Motiva Enterprises (Port Arthur)
TXD008097529
CA400 and CA550 codes have not been achieved yet due to
facility expansion which has also changed final remedies for
the facility.
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2016
C-D
Age Refining
TXD049754047
Site has resumed assessment activities (only) after
apparently reaching resolution on a division of liability
dispute. Lawyers for both sides are currently cooperating,
but no sure what future will hold.
2016
C-D
National Oilwell
TXD05 7425 662
Difficulty assessing site due to off-site access issues and in
the area of an existing superfund site
2016
C-D
Amarillo Copper Refinery (Amarillo)
TXD087491973
Updated projected dates as ASARCO is conducting
additional delineation and they also received some cleanup
funds from bankruptcy proceedings..
2016
C-D
Dow Chemical (Texas City) was Union
Carbide
TXD000461533
Offsite plume still needs to be stabilized for documentation
of CA750 and CA550. Still on track for achievement.
2016
C-D
BNSF or Burlington Northern
(Sommerville)
TXD000778621
Facility is still conducting assessment activities and working
on baseline risk assessment. Public interest.
2016
C-D-E
Wood Industries, PA (San Antonio)
TXD027070655
Difficulty achieving CA400 and CA550 codes as waste is
still onsite. Site is involved with state enforcement program
and entity is experiencing financial difficulty paying for
cleanup/possible bankruptcy issues. EPA conducted soil and
groundwater site assessment in 2012 and will work with
EPA Superfund and TCEQ on evaluating cleanup options.
2016
C-E
Texas Instruments Incorporated
TXD982551806
EPA Oversight of VCP Cleanup by State. Site has achieved
CA550 but not CA725/CA750.
2016
C-E
NIBCO, Inc.
TXD008092306
The facility completed the requirements for a facility
assessment and response action plan conducted under a
RCRA 3013 Order. They now plan to conduct remediation
through the TCEQ voluntary cleanup program. EPA will
continue to monitor progress to ensure GPRA goals are met
at the site.
2016
C-E
MCKINNEY SMELTING INC
TXR000025387
Previously EPA 6PD CASE - State (TCEQ) PM providing
direction to the facility. Cleanup activities have been
completed, final reports are pending contingent on owner's
payments. On track for completion.
/-V/ ^ zji /V/
-------
2017
A
Plains Terminals Corpus Christi LLC
(Encycle Texas)
TXD008117186
EPA ORDER 1999, part of ASARCO Bankruptcy,
TCEQ lead overseeing bankruptcy
Trustee. Bankruptcy funding ($9 million) was utilized
between 2010 and 2014 to demolish buildings on site
and to address contaminated soils. The bankruptcy
trustee sold the property to Plains Terminals in March
2014. Plains Terminals placed funds in escrow ($5
million) to complete remaining regulatory concerns
including additional soil removal and to address the
sediment in the ship channel.
2017
B
TXI Operations LP
TXD007349327
EPA LEAD - On track to achieve goal.
2017
B
Rhodia, Inc.
TXD008099079
EPA LEAD - On track to achieve goal.
2017
B
Parkans International, LLC
TXD008105959
EPA LEAD - On track to achieve goal.
2017
2017
B
B
Schenectady International, Inc.
Albemarle Catalysts Company, LP
TXD0107973 89
TXD073920399
EPA LEAD - On track to achieve goal.
EPA LEAD - On track to achieve goal.
2017
C-D
Phillips Components Mineral Wells
TXR000030205
ACTIVE IHWCA PROJECT. FACILITY USED K MN04
INJECTIONS TO ADDRESS CONTAMINATED GW
BUT LOST HYDRODYNAMIC CONTROL OF THE
PLUME. THE FACILITY IS RE-DELINEATING THE
PLUME. 12/09 UPDATE .FACILITY IS COMPLETING
DELINEATION OF OFFSITE GW PLUME..
2017
C-D
Fort Bliss
TX4213720101
Project includes the Castner Range Area (munitions cleanup)
currently in initial assessment phase and expected to take
several years to complete. Achievement of CA400/550 will
be achieved when final response action plan is
submitted/approved for this area.
2017
C-D
Laughlin AFB
TX2571524105
CA750, CA400 AND CA550 not yet achieved as Laughlin
is still assessing (in RI phase) for some sites. Also will need
to finalize remedies via submittal of an application to modify
the compliance plan.
2017
C-D
Exxon Company (Baytown)
TXD000782698
Facility unable to achieve CA400/550 codes at this time as
they are still in the facility wide assessment stage (step 2).
~ 15 ~
-------
2017
C-D
Tronox/Kerr McGee(Texarkana)
TXD057111403
CA400 AND CA550 CODES HAVE NOT BEEN
ACHIEVED AT THIS FACILITY DUE TO
ECOLOGICAL ISSUES INVOLVING IMPACTED
SEDIMENTS IN DAYS CREEK. ECO PCLS ARE
LOWER THAN HUMAN HEALTH PCLS AND ARE THE
CLEANUP DRIVER FOR THE SITE. APAR
CURRENTLY INHOUSE FOR REVIEW WITH NRDA
TRUSTEES TO EVALUATE ECO ASSESSMENT.
FACILITY HAS AN INTERIM GW REMEDY SYSTEM
INPLACE. CA400 AND CA550 ACHIEVEMENT IS
ALSO DEPENDANT ON PERMIT/CP MODIFICATION
APPLICATION AND ISSUANCE FOR FINAL
CORRECTIVE MEASURES. (EW 8/08) Bankruptcy
judgement, may take state funds to complete CA400 and
CA550. May lose CA725 and CA750 codes in 3 years,
money will run out and pump and treat may have to shut
down. (AAS 8/12)
2017
C-D
Asset Funding also HW Burbank LLC was
Evans Harvey Corp, LLC
LAD008158289
LDEQ is finalizing an order requiring investigation.
2017
C-E
U.S. Altus Air Force Base
OK9571824045
PREVIOUS EPA LEAD; unilateral 3008(h) 1996;
remedy was selected (CA400 Dec 2007) and site was
progressing toward construction complete under the
order. HSWA-only state permit effective January 21,
2010, for remedy implementation. EPA Order
terminated March 23, 2010. EPA continues to oversee
for CA550. Low concentrations of TCE exceeding the
MCL have migrated beyond property under control of
Altus AFB. Altus secured offsite property under an
institutional control, where the property owner has
surface rights only. At present there is no human or
ecological exposure on this private property and the
landowner has been notified. Installed ERD remedies
(bioreactors, biowalls, injection wells) are being
evaluated/rehabilitated and additional source area
treatments are being implemented.
~ 16 ~
-------
2017
C-E
England Economic Industrial Development
was England Air Force Base
LA9572124452
BRAC property transfers completed September 2011.
Remediation on three sites with petroleum
contamination only remains to be completed under
RCRA permit. POL yard remediation completed Oct.
2015. - Has not achieved CA400/CA550.
2018
A
Westlake Vinyls (Borden) Momentive
Specialty Chemicals, Inc.
LAD003913449
EPA LEAD: Being cleaned up under a joint EPA/state
consent decree. Field scale pilot studies are currently being
implemented. The Site is on track to achieve goals.
2018
A
U.S. Dept. Of Army-Camp Stanley
TX221002073 9
EPA LEAD under RCRA 3008(h) Order. Continuing site
wide remediation including: source removal of contaminated
soil, ISCO and in-situ Bioreactor for groundwater
restoration. Groundwater plume has migrated off-site at
levels slightly above the MCL. The VI pathway has been
investigated and there is not a VI issue at the Site. On track
to meet GPRA 2020 goals early.
2018
A
Exxon Chemical (Former Houston Chemical
Plant)
TXD082684002
EPA LEAD. EPA order (3013) issued Aug" 12 to complete
site-wide investigation including off-site groundwater.
ExxonMobil conducts semi-annual groundwater monitoring
activities on and off site. They have installed several
recovery wells and will be installing two recovery trenches
along with an on-site groundwater treatment system. These
systems are planned to prevent the off-site migration of
additional contamination. No final remedy has been selected
at this time.
2018
A
Rogers Delinted (Robstown)
TXD980873160
EPA LEAD. The EPA Region 6 used REPA contract
funds to delineate contamination at the site in 2013
including groundwater sampling, installing soil borings
into a capped pond, and performing surface soil
sampling for pH analysis. Currently working with
TCEQ to define protective pH level for soils for reuse
by site owner, RIDC. Statement of Basis to PN in 2015.
Additional sampling planned for 2016.
2018
B
Neches River Treatment Corp.
TXD074204991
EPA LEAD - On track to achieve goal.
2018
B
P Chem, Inc.
TXD098874308
EPA LEAD - On track to achieve goal.
~ 17 ~
-------
2018
B
Eurecat U.S. Incorporated
TXD106829963
EPA LEAD - On track to achieve goal.
2018
B
Rogers Delinted Cottonseed Co.
TXD981055486
EPA LEAD - On track to achieve goal.
2018
B
Safety-Kleen Systems, Inc.
TXD981056690
EPA LEAD - On track to achieve goal.
2018
B
Big Lake Nash
TXD981150923
EPA LEAD - On track to achieve goal.
2018
B
Clean Harbors Laporte, Lp
TXD982290140
EPA LEAD - On track to achieve goal.
2018
B
Schlumberger Technology Corp.
TXD987988318
EPA LEAD - On track to achieve goal.
2018
B
Dai-Tile Corporation
TXD988032751
EPA LEAD - On track to achieve goal.
2018
B
BOC Group, Inc.
TXR000052175
EPA LEAD - On track to achieve goal.
2018
B
INEOS
TXD086981172
EPA LEAD - On track to achieve goal.
2018
C-D
TAFT-STARwas Union Carbide-Taft Plant
LAD041581422
Facility currently undertaking a facility-wide investigation
and remediation.
2018
C-D-E
Western - was Giant Refining Co-
Bloomfield
NMD089416416
Clean up was being addressed under 2 orders (State and
EPA); slow to progress; release to river was addressed.
Orders consolidated into one new State Order in 2007 . EPA
continues oversight..
2018
C-E
BARKSDALE AIR FORCE BASE,
LOUISIANA
LA9571924050
STATE LEAD/EPA ASSISTANCE
2018
C-E
GTX. Inc. was Marine Shale
LAD981057706
Large site being cleaned up under a joint order. Should
progress. EPA and DOJ were involved.
2019
A
Hale Dusting Service, Inc.
TXD057573438
EPA ASSISTANCE: Entity has no funds to support
cleanup. EPA Region 6 has been using REPA contract
funds to delineate the extent of arsenic contamination. The
most recent downgradient well installed in July 2013 also
detected hydrocarbon contamination, most likely from the
former aviation gas USTs. The EPA was planning to use the
US ACE contract to cap the HWMU surface impoundment,
but the US ACE subcontractor cost proposal was much more
than anticipated. Once a new IA is in place with the
US ACE, we may once again consider capping the surface
impoundment, which is the source of the arsenic
contamination.
~ 18 ~
-------
2019
A
Motiva Enterprises (Port Neches)
TXD980626022
EPA LEAD under EPA Order. The Order has not been
closed out due to a DNAPL plume extending from the
Motiva/Huntsman property line beneath Motiva. The
adjacent facility, Huntsman Petrochemical, also has a
DNAPL plume originating from a SWMU, NOR No. 1
Landfill burn pits. Huntsman/Chevron recently
performed an investigation between the Huntsman
DNAPL plume and the Motiva DNAPL plume to
determine if the Motiva plume also originates from the
Huntsman SWMU. EPA is reviewing the Hunstman's
investigation report and may issue a new corrective
action order in 2016 based on the sampling report
results. EPA Region 6 conducted a corrective action
inspection in July 2014.
2019
B
Heat Treatment Services
TXD980624035
EPA ASSISTANCE: EPA is providing state with Vapor
Intrusion Assistance. Facility has submitted APARs for
both onsite and offsite areas and a RAP for the onsite
remedy. RAP includes hydraulic barrier preventing offsite
migration of contaminated groundwater and vapor
mitigation of onsite buildings. RAP for offsite areas
expected in 2016.
2019
C-D-E
Ethyl Corp - Baton Rouge
LAD079460895
2019 Projection: EPA provided ground water modeling
assistance.
2019
C-E
HELENA CHEMICAL COMPANY
ARD030414494
STATE/EPA ASSISTANCE
2019
C-E
AEROJET-GENERAL CORP
ARD091688283
STATE/ EPA ASSISTANCE
2020
C-D
White Sands Missile Range
NM2750211235
2020 Projection: Remedy selection will be based on
investigation results and the final work plan is due
2015. Delays and extensions are likely to extend the 2015
date for submittal of the final work plan. In November 2015,
NMED issued a draft permit modification for five SWMUs
as corrective action complete.
2020
C-D
Cannon Air Force Base
NM7572124454
2020 Projection: Cannon Air Force Base continues to
investigate potential contamination, initiate contaminant
removal actions, and conduct long-term ground water
monitoring at the facility.
/-V/ ^ Q /V/
-------
2020
C-D
Western Refining Southwest - Gallup
NMD000333211
2020 Projection: Gallup is currently investigating several
SWMUs and AOCs with some in second and third phases of
investigation. A compliance schedule and new AOCs
included the permit are the subject of an appeal.
2020
C-D
Navajo Refining Company
NMD048918817
2020 Projection: Gallup is currently investigating several
SWMUs and AOCs with some in second and third phases of
investigation. A compliance schedule and new AOCs
included the permit are the subject of an appeal.
2020
C-D
Tinker AFB
OK1571724391
2020 Projection: Ground water not delineated as of yet.
2020
C-D
Wynnewood Refining
OKD000396549
2020 Projection: Offsite ground water. Order to address by
2018.
2020
C-D
Holly Refining - Tulsa
OKD990750960
2020 Projection: Offsite ground water to south and west still
being assessed.
2020
C-D
Safety-Kleen Systems, Inc.
TXD077603371
2020 projection: Encountering offsite access problems
which are hampering assessment activities.
2020
C-D
Safety-Kleen Systems, Inc.
TXD083145656
2020 Projection: Active ihwca project (response due late
letter issued by tceq 11/24/2003 required information
verifying assessment of off-site soil contamination
associated with release investigation of an inactive waste
solvent tank. Facility experiencing problems obtaining
offsite access to verify extent of contaminated soils/also
bankruptcy problems. New pm assigned to obtain current
status of investigation (8/08). Active rcra permit.
~ 20 ~
-------
2021
B
Fort Wingate Depot
NM6213 820974
BRAC - Large site; transfer to tribes in future. RFI
work ongoing under NMED RCRA closure-post-
closure permit. To date, 8353 acres (40% of facility)
have been approved for No Further Action; another
30% is under current reuse by the Missile Defense
Agency. Groundwater plumes (explosives and nitrates)
are being delineated. Major munitions removal project
began Spring 2013. Facility remediation plan was
accelerated by Army in late 2014, with 2020 goal for
completion. Legal dispute over munitions magazines
RCRA authority remains unresolved.
2021
C-D
Citgo Petroleum Corp., Lake Charles
Refinery
LAD008080350
EPA site visit in January 2014: Large highly contaminated
complex site.
2021
C-D
Detrex Corporation
TXD980626154
Entity experiencing cleanup funding problems. Potential
vapor intrusion issues.
State Lead. EPA technical support including ground water
modeling assistance for the fuel spill. Corrective action
required in RCRA permit. Characterization and remediation
efforts for Sites ST-106 and SS-111 (Bulk Fuels Facility
Spill) lag behind those for other sites at KAFB. It is
anticipated that these particular SWMUs will control
completion of corrective action at this facility. The fuel spill
is estimated to be between 6 and 24 million gallons in
volume and reached the regional aquifer -500 feet deep.
Interim measures have been implemented including soil
vapor extraction, soil excavation and groundwater pump and
treat. The interim pump and treat system will be expanded to
three wells by the end of 2015 and up to eight wells by the
end of 2016 for a total of up to -800 gpm. Other interim
measure pilot tests are planned to target the LNAPL source
area including air sparging, bioventing and biological
treatment. NMED does not expect final remedy selection to
be completed until 2019 and anticipates substantial public
comment and a public hearing.
2021
B
Kirtland AFB
NM9570024423
~ 21 ~
-------
2022
A
The Dow Chemical Company
LAD008187080
EPA ASSISTANCE: Large complex site with complex
issues. Permit renewal was appealed. Off site vinyl chloride
plume addressed under an EPA and LDEQ and Dow
Cooperative Agreement.
2024
C-D
Chevron Oronite Co.
LAD034199802
Still under investigation: Batture area next to Mississippi
River contaminated.
2029
C-D-E
U.S. NASA Michould Space Systems
LAD800014587
Investigation completed, facility will do thermal desorption
pilot study for the TCE plume. State requested EPA
assistance with plan and report which was provided.
>2020
A
Parker Solvents Company (Little Rock)
ARD035565068
EPA ENF LEAD: Large offsite plume; EPA and ADEQ
investigated vapor intrusion issues and found not to exist;
underfunded site. State referred to EPA Enforcement. EPA
issued a RCRA 3013 AO in September 2013 to conduct
sampling to identify current status of contamination. Initial
sampling has been completed and a site wide sampling event
will be completed on November 6th 2014. Parker Solvents"
consultants will complete and submit the final report within
60 days of final sampling event.
~ 22 ~
-------
>2020
A
Lazarus Refinery was Gregg County
Refining was Longview Refining
(Longview)
TXD045586187
EPA LEAD; EPA Region 6 used its REPA contractor to
conduct an investigation (April 2014) at the site which
included groundwater, soil, and sediment sampling and
groundwater monitoring well installation. The sampling
results indicated that further investigations will be needed to
delineate the contamination. The RCRA permits/corrective
action branch has forwarded all sampling results (plus other
historical site information) to the RCRA enforcement branch
to be used in additional enforcement actions. In June 2015,
Gregg County Refining quitclaim deeded the property to
Lazarus Refining. The RCRA enforcement division has
drafted a corrective action administrative order. This draft
order specifies all corrective actions needed to be conducted
by Lazarus. Currently, the Region 6 RCRA enforcement
division is negotiating with Lazarus on the scope and
cleanup schedule for the final order on consent. The
timeframe to complete these negotiations is December 15. If
negotiations are unsuccessful, then a unilateral order will be
issued by DO J.
>2020
A
Elementis Chromium LTP
TXD098818339
EPA ENF LEAD: Corrective action conducted via EPA
CONSENT DECREE and state orders to address chromium
contamination. The CA725 checklist was completed by
TCEQ; EPA order covers eastern portion. A barrier wall
was installed in December 2009 to prevent releases to the
ship channel. Additionally, a Unilateral Administrative
order was issued in October 2011 to address chlorinated
solvent contamination. Elementis, has defined the extent of
contamination, based on communications with the company
as late as 11-12-2014. Interim measures consisting of a
sheet pile barrier wall tied into the substrate, withdrawal
wells for contaminated groundwater, recovery wells for
hydrocarbons, and a waste water treatment system are in
place. A revised timeline and status report are planned for
future actions.
~ 23 ~
-------
>2020
B
DOE Los Alamos National Lab
NM0890010515
Mega site, over 1000 SWMUs; mixed waste; great public
interest. The site has a RCRA permit and a State Corrective
Action Order for the cleanup of the SWMUs. The site has a
hexavalent chromium groundwater plume that is being
investigated/delineated. LANL originally installed pilot
pumping wells to hydraulically control the plume; however
these wells are currently not operating. In October 2015,
LANL completed an offsite monitoring well on San
Ildefonso property. Sampling results indicated no chromium
contamination. However, it should be noted that this well is
actually located cross-gradient to the plume, as the best
locations for a down gradient monitoring well were located
on culturally sensitive areas of the Pueblo.
>2020
C-D
VALERO REFINING CO NEW ORLEANS
LAD062644778
CODED AS CA550OF: Headquarters not giving credit.
>2020
C-D
Olin Chlor Alkali Products
LAD062666540
CODED AS CA550OF: Headquarters not giving credit.
>2020
C-D
US Air Force Melrose Ranage
NM5 5 72124456
POTENTIAL TO BE CODED AS CA550OF: Deferred as
an active military range. NMED deferred the submittal of a
facility-wide investigation work plan in a letter dated June
19, 2007. Headquarters may not give credit.
>2020
C-D-E
Marshall Holdings (Monarch Tile)
(Marshall)
TXD008041048
WAS EPA LEAD. Site referred to EPA informally in April
2004. Formerly Monarch Tile. Underfunded. Sent back to
TCEQ. State Superfund is conducted a PA/SI at the Site.
There are signs posted at the site about the potential heavy
metal contamination in soils. There is a state Superfund Site
downgradient of the Site.
>2020
C-D-E
Walker Wood Preserving Co.
TXD026042168
EPA ASSISTANCE: EPA is providing state with Vapor
Intrusion Assistance. Facility has submitted APARs for
both onsite and offsite areas and a RAP for the onsite
remedy. RAP includes hydraulic barrier preventing offsite
migration of contaminated groundwater and vapor
mitigation of onsite buildings. RAP for offsite areas
expected in 2016.
/-v/ 2 4 ^
-------
X-
COMPLETED
A
Chalmette Refining, LLC
LAD008179707
EPA LEAD AGENCY; being cleaned up under an EPA
order. Proposed remedy selection to Public Notice Aug
2012. EPA issued 3008(h) for remedy implementation in
2013. A Construction Complete determination has been
completed. The 3008(h) order for the implementation of the
remedy was signed on September 15, 2014. The first
Corrective Action Report has been approved by EPA and the
annual requirement that sufficient financial assurance for
corrective actions has also been approved. It should be
noted that Exxon Mobil (50% shares) and the country of
Venezuela (50 % shares) sold their Chalmette Refining
shares to PBF Holding Company, LLC. A revised financial
assurance document for the corrective actions has recently
been submitted to EPA for approval.
X-
COMPLETED
B
Safety-Kleen Systems, Inc.
TXD000747402
X-
COMPLETED
B
South Texas Redi-Strip
TXD980879076
X-
COMPLETED
C-D
Force
TXD000633453
X-
COMPLETED
C-D
Equistar Chemicals, LP
TXD058275769
X-
COMPLETED
C-D
Wright Way Spraying Service
TXD981605868
X-
COMPLETED
C-D
Phillips 66 - ConocoPhillips Refinery
(Alliance)
LAD056024391
X-
COMPLETED
C-D
Baker Petrolite incl. Cook
TXD000807875
~ 25 ~
-------
X-
COMPLETED
C-D
Flint Hills was Huntsman Petrochemical
Corp (Port Arthur)
TXD000820928
X-
COMPLETED
C-D
Delek Refining was LaGloria Oil
TXD007333800
X-
COMPLETED
C-D
EI DuPont de Nemours
TXD008079212
X-
COMPLETED
C-D
Arkema, Inc. (Total)
TXD008085185
X-
COMPLETED
C-D
Ethyl Corp (Pasadena)
TXD008096158
X-
COMPLETED
C-D
EI DuPont de Nemours
TXD063101794
X-
COMPLETED
C-D
Bell Helicopter (Hurst)
TXD980626006
X-
COMPLETED
C-D
The Premcor Refining (Port Arthur)
TXD008090409
~ 26 ~
-------
X-
COMPLETED
C-D-E
Huffman Wood Preserving
OKD053128492
Site was abandoned and cleaned up with limited financial
assurance money and innovative approaches. EPA assistance
was provided by staff, contractor, and EPA laboratories.
Construction complete was accomplished in 2013.
X-
COMPLETED
C-D-E
Greenway Environmental, Inc.
OKD089761290
Site was abandoned and was investigated with limited
financial assurance money. EPA assisted with contract
funds, grant funds, and technical assistance using EPA staff.
Site was found not to be RCRA contaminated. EPA and
ODEQ are made a Ready for Reuse Determination for
Wagoner County to aid in the future redevelopment of the
property. The property has now been leased by the county
and is being reused as a commercial operation.
X-
COMPLETED
C-E
REMINGTON ARMS CO
AR0000064311
STATE/EPA ASSISTANCE
X-
COMPLETED
C-E
THE COLONELS FACTORY OUTLET OF
ARK INC
ARD035663301
STATE/EPA ASSIST/BANKRPT
X-
COMPLETED
C-E
THE COLONEL FACTORY OUTLET OF
ARINC
ARD980621288
STATE/EPA ASSIST/BANKRPT
X-
COMPLETED
C-E
Sparton Technologies
NMD083212332
[Joint EPA/NMED oversight of Consent Decree] - CA400
1996; groundwater remediation system upgraded 2010 and
operating well. GW modeling predicts remediation to
extend to 2027
X-
COMPLETED
C-E
SHEFFIELD- GERDAU AMERISTEEL
SAND SPRINGS WAS SHEFFIELD
STEEL CORP.
OKD007219181
STATE/EPA ASSISTANCE
X-
COMPLETED
C-E
U.S. DeptNavy - Carswell
TX05 71924042
BRAC - CA550 Achieved 7/21/2006.
X-
COMPLETED
C-E
Red River Army Depot
TX3213820738
BRAC - CA550 achieved 10/11/2009
~ 27 ~
-------
X-
COMPLETED
C-E
U.S. DOE Pantex Plant
TX4890110527
Part federal superfund: achievement of CA400 and CA550
was dependent on issuance of ROD and permit
modification.. Facility has achieved goal.
X-
COMPLETED
C-E
U.S. DeptOf AF-DRMO
TX6570024939
BRAC - CA550 Achieved 2/10/2006.
X-
COMPLETED
C-E
U.S. Dept Of AF-Reese
TX8571524091
BRAC-COMPLETED TRANSFER, Groundwater
remediation complete under State compliance plan, but
continues under EPA 7003 Order. AF expects to finish
remediation by the end of 2014. Facility has achieved goal.
X-
COMPLETED
C-E
Safety-Kleen Systems, Inc.
TXD000729400
EPA LEAD - CA550 Achieved
X-
COMPLETED
C-E
Safety-Kleen Systems, Inc.
TXD000747378
EPA LEAD - CA550 Achieved.
X-
COMPLETED
C-E
Safety-Kleen Systems, Inc.
TXD000747394
EPA LEAD - CA550 Achieved
X-
COMPLETED
C-E
Safety-Kleen Altair, Inc.
TXD000747410
EPA LEAD - CA550 Achieved
X-
COMPLETED
C-E
Air Force Base Conv-Eaker
AR8571924473
BRAC - CA550 achieved 09/13/2002.
X-
COMPLETED
C-E
Base Transition Team - Ft Chaffee
AR9210020187
BRAC - CA550 achieved 11/20/2003
X-
COMPLETED
C-E
MicroChemical Company
LAD008181927
EPA WAS LEAD AGENCY; cleaned up under an EPA
order. Remedy selection/ Construction complete under EPA
order in 2012. EPA order closeout and post closure
monitoring and maintenance to begin under LDEQ permit or
order in 2015.
X-
COMPLETED
C-E
Dixie Metals Corp
LAD055792097
EPA ENFORCEMENT/STATE : Site achieved goals due to
EPA technical and contractor assistance.
X-
COMPLETED
C-E
AMAX METALS RECOVERY, INC
LAD05 8472721
STATE/EPA ASSISTANCE: Achieved goals.
~ 28 ~
-------
X-
COMPLETED
C-E
General Electric Company Apparatus
Service
NMD047140256
EPA ENFORCEMENT/STATE CA 400/550 complete
September 2007.
X-
COMPLETED
C-E
US AIR FORCE PLANT #3 MCDONNELL
DOUGLAS
OK9570000001
STATE/EPA DELISTING OF WASTE FOR REMOVAL.
Facility has achieved goal.
X-
COMPLETED
C-E
Mixon Brothers Wood Preserving
OKD007336258
. EPA-assisted permit renewal issued by State. New permit
includes corrective action, which is in place. Site has
achieved goal.
X-
COMPLETED
C-E
US GOVERNMENT NAVY FACILITY-
McGREGOR
TX9170024708
STATE/EPA ASSISTANCE: There is an ongoing
perchlorate cleanup using permeable reactive barriers .
Facility achieved CA550 goal.
X-
COMPLETED
C-E
Tm Deer Park Services, LLP
TXD000719518
EPA LEAD - achieved goal.
X-
COMPLETED
C-E
Safety-Kleen Systems, Inc.
TXD000747428
EPA LEAD - Achieved goal
X-
COMPLETED
C-E
AK Steel Corporation
TXD000802959
EPA LEAD - achieved goal.
X-
COMPLETED
C-E
Gulf Coast Waste Disposal Authority
TXD000835249
EPA LEAD - achieved goal.
X-
COMPLETED
C-E
International Shoe Co. (Bryan)/Furniture
Brands
TXD008071227
EPA LEAD under EPA order. 1990 Consent Order was
terminated in May 2012. 2009 Administrative Order on
Consent (3013) was terminated in July 2012. Site wide
remedy of No Further Action was selected. Facility has
achieved all GPRA goals.
X-
COMPLETED
C-E
Disposal Properties, LLC
TXD052649027
EPA LEAD - Achieved goal
X-
COMPLETED
C-E
Set Environmental, Inc.
TXD055135388
EPA LEAD - achieved goal.
X-
COMPLETED
C-E
Chaparral Steel Midlothian, LP
TXD066362559
EPA LEAD - achieved goal.
X-
COMPLETED
C-E
UT Southwestern Medical
TXD071378822
EPA LEAD - achieved goal.
~ 29 ~
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X-
COMPLETED
C-E
ISO-TEX INC
TXD072206311
STATE/EPA ASSISTANCE; Site achieved goal because of
EPA technical and contractor assistance.
X-
COMPLETED
C-E
PPG Industries, Inc.
TXD078552932
EPA LEAD - CA550 Achieved
X-
COMPLETED
C-E
Vopak Logistics Services USA
TXD097673149
EPA LEAD - CA550 Achieved
X-
COMPLETED
C-E
GALVESTON ENVIRONMENTAL
SERVICES INC
TXD980628028
STATE/EPA ASSISTANCE: Site achieved goals due to
EPA technical and contractor assistance.
X-
COMPLETED
C-E
Safety-Kleen Systems, Inc.
TXD980876015
EPA LEAD - achieved goal.
X-
COMPLETED
C-E
Safety-Kleen Systems, Inc.
TXD981053416
EPA LEAD - Achieved goal
X-
COMPLETED
C-E
Duratherm, Inc.
TXD981053770
EPA LEAD - Achieved goals.
X-
COMPLETED
C-E
Alpha Omega Recycling, Inc.
TXD981514383
EPA LEAD - achieved goal.
X-
COMPLETED
C-E
BP-WAS INEOS USA LLCINN0VENE
USA LLC
TXD000751172
STATE/EPA TX47: achieved goals
X-
COMPLETED
C-E
Southwestern Refining Co.
TXD000807859
EPA LEAD - Achieved goal
X-
COMPLETED
C-E
WHITE LION HOLDINGS LLC (VISION
METALS)
TX8571524091
STATE/EPA ASSISTANCE: Facility has achieved CA550
but not CA725 or CA750.
X-
COMPLETED
C-E
FMC Corporation
TXD083570051
EPA LEAD - achieved goal.
X-
COMPLETED
C-E
Heritage Environmental Services
TXD987995941
EPA LEAD - achieved goal.
X-
COMPLETED
C-E
Baylor College Of Medicine
TXD988070082
EPA LEAD - achieved goal.
~ 30 ~
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X-
COMPLETED
C-E
Lonestar Ecology was Bayport Processing-
was Houston Chemical Services,
TXDO10791184
The RCRA permit states that EPA/TCEQ co-review of RFI
related documents are required (EPA issued order) EPA
transferred to State for corrective action. CA550 acjoeved.
Needs CA750.
X-
COMPLETED
C-E
Kelly AFB (San Antonio)
TX25 71724333
BRAC - Final remedies are in place and operating
(OPS). Facility was transferred to Port San Antonio in
2010. Groundwater monitoring and remediation are ongoing
and will continue for many years. State Compliance Plan in
place. Facility has achieved goal.
X-
COMPLETED
C-D
The Lubrizol
TXD04106763 8
CA400 and CA550 achieved.
~ 31 ~
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TABLE 3: Categorization of More Difficult or Time Consuming Baseline Facilities
DIFFICULT OR TIME
CONSUMING BASELINE
FACILITIES
EPA ID
CATEGORIES
NAICS_DESCRIPTION
A
Elementis Chromium LTP
(American Chrome &
Chemicals)
TXD098818339
ENFORCEMENT CASE
ALL OTHER BASIC INORGANIC
CHEMICAL MANUFACTURING
A
Benton Creosoting Works
LAD008056632
UNDERFUNDED
WOOD PRESERVATION
A
Chalmette Refining, LLC
LAD008179707
ENFORCEMENT CASE
PETROLEUM REFINERIES
A
Encycle Texas
(Corpus Christi)
TXD008117186
ENFORCEMENT CASE
HAZARDOUS WASTE TREATMENT AND
DISPOSAL
A
Ethyl Corp
(Baton Rouge)
LAD079460895
COMINGLED DEEP AQUIFER PLUMES
ALL OTHER BASIC INORGANIC
CHEMICAL MANUFACTURING
A
Exxon Chemical
(Houston)
TXD082684002
ENFORCEMENT CASE
ALL OTHER MISCELLANEOUS
CHEMICAL PRODUCT AND
PREPARATION MANUFACTURING
A
Formosa Plastics
(Point Comfort)
TXT490011293
ENFORCEMENT CASE
PLASTICS MATERIAL AND RESIN
MANUFACTURING
A
Greenway Environmental
OKD089761290
UNDERFUNDED/ABANDONED
HAZARDOUS WASTE TREATMENT AND
DISPOSAL
A
Hale Dusting Service, Inc.
TXD057573438
UNDERFUNDED
SOIL PREPARATION, PLANTING, AND
CULTIVATING ( Crop dusting)
A
Heat Treatment Services
TXD980624035
VAPOR INTRUSION ISSUES
HAZARDOUS WASTE TREATMENT AND
DISPOSAL
A
Huffman Wood Preserving
OKD053128492
UNDERFUNDED/ABANDONED
WOOD PRESERVATION
A
International Shoe Co.
(Bryan)/Furniture Brands
TXD008071227
ENFORCEMENT CASE
GENERAL FREIGHT TRUCKING, LOCAL
A
Longview Refining (Longview)
TXD045586187
UNDERFUNDED/ABANDONED
PETROLEUM REFINERIES
A
McKinney Smelting
TXR000025387
PAST ENFORCEMENT CASE
IRON FOUNDRIES
A
Motiva Enterprises
(Port Neches)
TXD980626022
ENFORCEMENT CASE
PETROLEUM REFINERIES
A
NIBCO, Inc.
TXD008092306
ENFORCEMENT CASE
INDUSTRIAL VALVE MANUFACTURING
A
Oklahoma Pole & Lumber
OKD007335524
UNDERFUNDED
WOOD PRESERVATION
A
Rogers Delinted (Robstown)
TXD980873160
UNDERFUNDED/ABANDONED
POSTHARVEST CROP ACTIVITIES
(EXCEPT COTTON GINNING)
~ 32 ~
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DIFFICULT OR TIME
CONSUMING BASELINE
FACILITIES
EPA ID
CATEGORIES
NAICS_DESCRIPTION
A
Parker Solvents Company
(Little Rock)
ARD035565068
ENFORCEMENT CASE
. ALL 01 Hbk MiyCbLLANbOUy
CHEMICAL PRODUCT AND
PREPARATION MANUFACTURING
A
The Dow Chemical Co.
LAD008187080
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP.
ALL OTHER BASIC ORGANIC CHEMICAL
MANUFACTURING
B
Walker Wood Preserving
TXD026042168
UNDERFUNDED/ABANDONED
WOOD PRESERVATION
B
Westlake Vinyls (Borden)
LAD003913449
ENFORCEMENT CASE
PETROCHEMICAL MANUFACTURING
B
Fort Wingate Depot
NM6213820974
FEDERAL FACILITY - BRAC - COMPLEX:
WIDESPREAD CONTAMINATION AND/OR
NUMEROUS SWMUs TO CLEAN UP: TRANSFER
TO NATIVE AMERICANS IN FUTURE.
NATIONAL SECURITY
C-D
Sandia National Lab
NM5890110518
FEDERAL FACILITY -COMLEX LARGE SITE WITH
MIXED WASTE AND PUBLIC INTEREST.
NATIONAL SECURITY
C-D
U.S. NNSA/DOE Los Alamos
National Lab
NM0890010515
FEDERAL FACILITY -COMLEX LARGE SITE WITH
MIXED WASTE AND PUBLIC INTEREST.
NATIONAL SECURITY
C-D
Age Refining
TXD049754047
LIABILITY DISPUTE IN PAST.
PETROLEUM REFINERIES
C-D
Amarillo Copper Refinery
(Amarillo)
TXD087491973
PREVIOUS BANKRUPTCY ISSUES: COMPLEX
WIDESPREAD CONTAMINATION AND/OR
NUMEROUS SWMUs TO CLEAN UP:
PRIMARY SMELTING AND REFINING OF
COPPER
C-D
Arkema, Inc.
(Total)
TXD008085185
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP:
OFFSITE PLUME
ALL OTHER MISCELLANEOUS
CHEMICAL PRODUCT AND
PREPARATION MANUFACTURING
C-D
Baker Petrolite incl. Cook
TXD000807875
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP.
ALL OTHER MISCELLANEOUS
CHEMICAL PRODUCT AND
PREPARATION MANUFACTURING
C-D
Bell Helicopter (Hurst)
TXD980626006
ECOLOGICAL ASSESSMENT ISSUES
AIRCRAFT MANUFACTURING
C-D
BNSF or Burlington Northern
(Sommerville)
TXD000778621
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP.
WOOD PRESERVATION
C-D
Chevron Oronite Co.
LAD034199802
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP.
PETROLEUM REFINERIES
C-D
ConocoPhillips Refinery
(Alliance)
LAD056024391
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP.
PETROLEUM REFINERIES
C-D
Delek Refining
was LaGloria Oil
TXD007333800
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP
ALL OTHER BASIC ORGANIC CHEMICAL
MANUFACTURING
C-D
Detrex Corporation
TXD980626154
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN
UP.VAPOR INTRUSION ISSUES
PETROCHEMICAL MANUFACTURING
~ 33 ~
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DIFFICULT OR TIME
CONSUMING BASELINE
FACILITIES
EPA ID
CATEGORIES
NAICS_DESCRIPTION
C-D
Dow Chemical (Texas City) was
Union Carbide
TXD000461533
COMMLbX: WIUbyPkbAL) CON IAMINAI ION
AND/OR NUMEROUS SWMUs TO CLEAN UP:
OFFSITE PLUME
INDUSTRIAL GAS MANUFACTURING
C-D
El DuPont de Nemours
TXD063101794
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP.
POTENTIAL VAPOR INTRUSION
ALL OTHER BASIC ORGANIC CHEMICAL
MANUFACTURING
C-D
El DuPont de Nemours
TXD008079212
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP
ALL OTHER BASIC ORGANIC CHEMICAL
MANUFACTURING
C-D
Equistar Chemicals, LP
TXD058275769
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP
ALL OTHER BASIC ORGANIC CHEMICAL
MANUFACTURING
C-D
Ethyl Corp
(Pasadena)
TXD008096158
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP
PETROLEUM REFINERIES
C-D
Exxon Company
(Baytown)
TXD000782698
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP:
FOA
ALL OTHER BASIC ORGANIC CHEMICAL
MANUFACTURING
C-D
Flint Hills was Huntsman
Petrochemical Corp
(Port Arthur)
TXD000820928
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP
PETROLEUM REFINERIES
C-D
Fort Bliss
TX4213720101
FEDERAL FACILIITY: COMPLEX: WIDESPREAD
CONTAMINATION AND/OR NUMEROUS SWMUs
TO CLEAN UP. POTENTIAL VAPOR INTRUSION
NATIONAL SECURITY
C-D
HW Burbank LLC was Evans
Harvey Corp, LLC
LAD008158289
UNDERFUNDED
PAINT AND COATING MANUFACTURING
C-D
Laughlin AFB
TX2571524105
FEDERAL FACILIITY: COMPLEX: WIDESPREAD
CONTAMINATION AND/OR NUMEROUS SWMUs
TO CLEAN UP. POTENTIAL VAPOR INTRUSION
NATIONAL SECURITY
C-D
Magellan Terminal Holdings
TXD008089021
PLANT EXPANSION UNCOVERED AND SPREAD
CONTAMINATION.
PETROLEUM BULK STATIONS AND
TERMINALS
C-D
Motiva Enterprises (Port Arthur)
TXD008097529
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP
CYCLIC CRUDE AND INTERMEDIATE
MANUFACTURING
C-D
National Oilwell
TXD057425662
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP:
OFFSITE ACCESS ISSUES
PETROLEUM REFINERIES
C-D
Occidental Chemical
TXD007325111
OFFSITE DEED RECORDATION PROBLEMS
ALL OTHER BASIC INORGANIC
CHEMICAL MANUFACTURING
C-D
Safety-Kleen Systems, Inc.
TXD077603371
OFFSITE ACCESS ISSUES TO CHARACTRIZE
PLUME.
HAZARDOUS WASTE TREATMENT AND
DISPOSAL
/-v/ 2 4 ^
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DIFFICULT OR TIME
CONSUMING BASELINE
FACILITIES
EPA ID
CATEGORIES
NAICS_DESCRIPTION
C-D
TAFT-STAR
was Union Carbide-Taft
LAD041581422
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP
ALL OTHER BASIC ORGANIC CHEMICAL
MANUFACTURING
C-D
The Lubrizol
TXD041067638
COMPLEX: WIDESPREAD CONTAMINATION
AND/OR NUMEROUS SWMUs TO CLEAN UP
ALL OTHER BASIC ORGANIC CHEMICAL
MANUFACTURING
C-D
The Premcor Refining
(Port Arthur)
TXD008090409
ONGOING PROPERTY DISPUTES/LEGAL
ISSUES BETWEEN PREMCOR AND CHEVRON
PETROLEUM REFINERIES
C-D
Tronox/Kerr McGee (Texarkana)
TXD057111403
ECOLOGICAL ISSUES WITH CREEK SEDIMENTS
WOOD PRESERVATION
C-D-E
Wood Industries, PA
(San Antonio)
TXD027070655
UNDERFUNDED -PREVIOUS RECYCLER
GENERAL FREIGHT TRUCKING, LOCAL
C-D-E
Wright Way Spraying Service
TXD981605868
UNDERFUNDED-PESTICIDES
SOIL PREPARATION, PLANTING, AND
CULTIVATING ( Crop dusting)
C-D-E
Cedar Chemical Company
(W.Helena)
ARD990660649
COMPLEX SITE: IN PROCESS OF BEING LISTED
ON NPL
OTHER BASIC ORGANIC CHEMICAL
MANUFACTURING
C-D-E
Marshall Holdings (Monarch
Tile) (Marshall)
TXD008041048
UNDERFUNDED
CERAMIC WALL AND FLOOR TILE
MANUFACTURING
C-D-E
Western - was Giant Refining
Co-Bloomfield
NMD089416416
COMPLEX SITE
PETROLEUM REFINERIES
~ 35 ~
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ADDENDUM 1
Huffman Wood Preserving and Oklahoma Pole and Lumber Facilities, Broken Bow, Oklahoma
EPA Region 6 RCRA project team took two corrective action sites that were stalled in being cleaned up and used innovation in finding funds,
technology and resources to get the sites cleaned up and back in productive use in the community. Both facilities had lingered in the corrective action
pipeline for over ten years with little or no activity. EPA, ODEQ and the other stakeholders are working together to creatively leverage resources to
complete site investigation and cleanup activities at these facilities and put them back into productive use.
Huffman Wood Preserving, Inc. (HWP) and Oklahoma Pole and Lumber Company (OPLC) are two wood treating facilities located in Broken Bow,
Oklahoma, and approximately half a mile apart. Both facilities are on the GPRA RCRA 2020 baseline and bankrupt/underfunded. HWP is a 25-acre
facility that treated fence posts and other wood products with creosote and pentachlorophenol. The facility operated from 1956 until 1984. In 1989,
the now-deceased owner closed 5 unlined surface impoundments under state authority, and set aside approximately $120,000 in financial assurance
for future site work. The owner passed away in 1991 and the facility was purchased by an adjacent property owner to house his small welding shop.
Several acres of the site were used by Oklahoma Pole and Lumber as a laydown yard for untreated poles but this practice will be discontinued. The
facility sits atop a recharge zone for the Antlers Aquifer.
OPLC is a 26-acre site that was initially owned by Thomason Lumber and Timber Company, Inc. The facility operated from the late-60's to late-90's.
Thomason abandoned the site in 1999, leaving behind two closed surface impoundments, 15 wells, and possible soil contamination. The site was
purchased by OPLC, who took over the deed and liability for the property in June of 2000. In June 2002, OPLC abandoned the facility. The facility
remained abandoned through 2004. OPLC resumed treatment operations at the facility in early 2005. Currently, OPLC is operating the facility, but
has limited cash flow/resources to conduct site investigation and any cleanup.
Region 6 project team members were innovative in collaborating with numerous stakeholders to achieve investigation and cleanup at these financially
troubled sites. The culmination of the corrective action process has been the result of partnerships between EPA Region 6 (Dallas), EPA ORD's lab in
Ada, Oklahoma, EPA OSWER's Technology Innovation Office, Region 6's Houston Lab, Oklahoma DEQ, the Army Corps of Engineers, the City of
Broken Bow, and the facility owners. All investigation and cleanup activities are expected to be completed within the next year.
The specific external resources leveraged over the course of the project included the following:
• Technology Innovation Office provided funding and TRIAD technical assistance to Region 6 and ADA Lab to develop a site assessment
plan.
~ 36 ~
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• City of Broken Bow provided resources to clear brush in order for sampling to take place. In addition, the City provided heavy
equipment/operators for trenching as part of sampling activities and disposed of purge water via the City's POTW. The City also provided a
water truck for decontamination and other sampling work, and a vacuum tanker truck for purge and decon water.
• Region 6 staff and its contractors conducted soil and groundwater sampling at OPLC and HWP.
• The Houston Lab provided analysis for the soil and groundwater samples collected at HWP.
• USACE (via an IAG with Region 6) installed groundwater monitoring wells at HWP to characterize the deeper regional groundwater aquifer.
• OPLC's contractors conducted groundwater sampling and analysis of HWP's monitoring wells.
• OPLC provided equipment and manpower to conduct soil removal at both OPLC and HWP. HWP's financial assurance funds will be used
to pay for soil disposal for that site; OPLC will fund disposal of its contaminated soils.
• The balance of the HWP's financial assurance will be used for long-term monitoring and maintenance at that site
• Ada Lab personnel provided training to Region 6 and ODEQ Project Managers, and took a lead role in gathering samples to conduct
calibration testing for immunoassay field test kits that will be used during the cleanups at OPLC and HWP. The Houston Lab provided final
calibration standards. Ada Lab also assisted Region 6 in developing a gridded sampling plan following the TRIAD approach for soil and
groundwater sampling. This approach will reduce project costs due to real time field sampling and use of EPA staff/labs, while increasing
technical competency and expediting corrective action.
• Region 6 and Ada Lab characterized and performed confirmatory sampling of soils using immunoassay field test methods, along with
laboratory confirmation sampling.
• Region 6 installed four additional groundwater monitoring wells at OPLC.
• Region 6 and ODEQ will jointly issue Ready for Reuse Determinations to the facilities at the completion of their respective cleanups in order
to promote productive, protective and sustainable reuse of the properties.
~ 37 ~
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ADDENDUM 2
Micro Chemical Company, Winnsboro, Louisiana
This GPRA facility has been at a stalemate regarding site investigation and remediation efforts for approximately 10 years due to limited funding for
site work and the inflexibility of the regulatory project manager on how to appropriately deal with this under-funded facility. Regulatory inflexibility, lead
to limited cooperation between the parties and little progress was made after the initial Interim Measures were completed. During the past year, the
regulatory project manager changed and the facility is now participating in the Region 6 Corrective Action Strategy (CAS) process which focuses on
risk-based / performance-based corrective action objectives for the site. The facility ceased operations in 2008 due to a downturn in the economy and
loss of contracts. Investigation and cleanup activities at the facility were completed in 2009. In September 2010, LDEQ and EPA issued a Ready for
Reuse determination for a portion of the site, which was sold to the adjacent grain elevator operations in 2011. In 2012, EPA made a final remedy
determination for the site and completed documentation for the CA550 construction complete. In 2013, EPA will close out its Order and post closure
care will be conducted under a new LDEQ post closure order or permit.
The Micro Chemical Facility is located in Winnsboro, Louisiana 45 minutes south of Monroe on Hwy 15. It is located on 4.75 acres and has been
formulating, blending and packaging agri-chemicals (pesticides and herbicides) for local use since 1954. The facility closed in 2008 due to a shrinking
competitive market. The owner of the facility has since retired (approximately 80 years of age) but is willing to use remaining limited resources to
complete site investigation and cleanup activities. After the cleanup of the property is complete, EPA and the State will provide a Region 6 Ready for
Reuse comfort letter to aid in the sale of the property to the adjacent feed mill operation. The proceeds from the sale will be used as financial
assurance for long term monitoring and post closure case.
In 1994 Micro Chemical Company entered into an Administrative Order on Consent with EPA to identify, investigate and prevent the further release
and/or migration of hazardous constituents to the environment and to perform corrective actions necessary to protect human health and the
environment.
In 1996 interim measures were performed which consisted of:
• 14,000 cu/yards of contaminated soils being consolidated, stabilized and capped onsite
• 13 nested pairs of groundwater wells were installed and semi-annual groundwater monitoring was initiated
• Sediments in a near-by abandoned oxbow were sampled and tested
In 1997 a draft RFI work plan was submitted but the final was never approved
In 1999 a draft RFI report was submitted but was never approved
~ 38 ~
-------
No additional site investigation or cleanup activities took place until 2008
In 2008 the Facility, under new regulatory project management initiated corrective action streamlining activities using the Region 6 Corrective Action
Strategy
Since that time the following has been accomplished:
• conducted 4 separate rounds of groundwater delineation step-out sampling the define the extent of the plume
• conducted soil sampling in the MSMA process and tank storage area
• conducted soil sampling along the abandoned Toxaphene delivery line and tank storage area
• conducted additional sediment sampling in the Turkey Creek oxbow
• Excavated, stabilized and consolidated an additional 1,500 cu/yards of contaminated soils (all surface soils were excavated to a minimum of 2
feet and replaced with clean top soil)
• Installed 4 new wells to groundwater monitoring well network
• Financial assurance will be provided by the facility via the sale of the property for long term monitoring and maintenance.
• CA550 documentation was completed in 2012, where Interim Measures serve as the final remedy at the facility.
~ 39 ~
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ADDENDUM 3
Rogers Delinted Cottonseed Co. Site, Robstown, TX
This former cottonseed delinting facility in South Texas was recently purchased by the Robstown Industrial Development Corporation (RIDC) from
Nueces County. The County had originally obtained the property on back taxes from the deceased property owner, Koshiro Yazaki (Yazaki USA
Corporation). The RIDC would like to complete whatever cleanup is required at the facility and promote the property for use that would complement
the new Nueces County Fairground and Convention Center that is located across the highway from the RDCC facility. A new retail outlet mall is also
proposed for development this year next to the fairgrounds. During the summer of 2011, EPA Region 6 Superfund performed some removal actions at
the facility which included cleaning out a collapsed aboveground storage tank, cleaning up/removing the pesticide application room, removing
containers of pesticides left at the facility, sweeping and pressure washing the facility buildings to remove pesticide residues, and performing lead-
based paint and asbestos inspections in the facility buildings. EPA Region 6 RCRA has used REPA contract funds to install groundwater monitoring
wells at the facility, perform groundwater monitoring, and perform soil sampling. EPA Region 6 RCRA will work with the TCEQ to determine what
further corrective actions are required at the facility based on its potential future reuse. The facility has achieved the CA725 human exposure under
control goal. The EPA will determine the status of meeting CA750, CA400, and CA550 milestones after discussions and resolutions with the TCEQ.
The former Rogers Delinted Cottonseed Co. facility is located just northeast of Robstown, TX, in Nueces County, on the east side of U.S. Hwy 77
(Business). It produced cottonseed for sale by using a wet acid cottonseed delinting process, in which highly concentrated sulfuric acid was used on
cottonseeds to remove cotton fibers from the seed. The spent sulfuric acid and rinsewaters were discharged from a sump into a series of evaporation
ponds. The seed was then dried and treated with fungicides and insecticides. The plant operated from about 1962 to 1983 and has been abandoned
since 1984.
The facility is on EPA's GPRA baseline list for corrective action, and as such must meet El determinations and corrective action completion.
August 2003 groundwater sampling by TCEQ found arsenic, benzene and organochlorine pesticides above MCLs. EPA conducted a site
reconnaissance trip on August 4, 2004, and found that part of the site was actively being used for playing paintball games, as noted by paintball
equipment left on site, paintball debris, and paintball splatters on wooden pallets in the warehouse building.
In March 2005, EPA returned to the site to conduct sampling and to post signs to warn trespassers that the site was under investigation. Sampling
results indicated that the fungicide and pesticides wastes left on site in the process building had elevated
levels of lead, chromium and thiram. This waste was bagged. Floor sweep samples from the warehouse building indicated elevated levels of arsenic,
lead and chromium. Surface soil samples indicated elevated levels of lead.
EPA returned to the site in July 2005 and conducted the following interim measures:
• the bagged waste in the process building was drummed and removed from the site,
• the warehouse building was swept and wastes were drummed and removed,
/| Q JN/
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• surface soils outside the warehouse that had elevated levels of lead were covered with a clay-gravel mixture to prevent exposure to surface
soils,
• All openings to the process building were fenced off and marked with KEEP OUT signs.
The property owner passed away in 1997 with a significant accumulated property tax levy. The City of Robstown had an interest in securing the
property through tax resale. Therefore, the EPA collaborated with the City of Robstown to move the site forward. The fencing and most of the warning
signs that EPA installed in 2005 had been removed by trespassers. The City of Robstown initiated a trash cleanup day at the site to remove the tires
and wood pallets that trespassers had been using to build paintball courses. The City of Robstown also cleared brush so that EPA could access the
site for an investigation. In June 2010, EPA contractors installed groundwater monitoring wells at the site and groundwater was sampled. Soil borings
were installed within the unclosed ponds and subsurface soil samples were collected. Surface soil samples were also collected throughout the site.
EPA Region 6 RCRA Multimedia Planning and Permitting Division (PD) requested assistance from Region 6 Superfund Division to perform some
waste removal work at the site. During the summer of 2011, EPA Superfund performed removal activities (interim measures) at the facility which
consisted of cleaning out a collapsed sulfuric acid tank, testing and disposal of abandoned drums, cleaning the process building, performing an
asbestos and lead based paint survey, and removing the pesticide application equipment. Also during the summer of 2011, EPA contractors
performed another round of groundwater monitoring at the site as well as a water well survey and well yield test.
In March 2012, the Robstown Improvement Development Corporation (RIDC) purchased the property as a tax resale.
In July 2013, EPA contractors performed groundwater sampling, installed 2 soil borings into Pond 1, and collected over 100 surface soil samples for
pH analysis. The surface soil sampling revealed that the non-vegetated areas of the site are of low pH and may require pH adjustment or soil cover
before the property is put into reuse.
EPA intends to work with the RIDC and the TCEQ to achieve CA750, CA400 and CA550; and encourage the beneficial reuse of the property by
recycling onsite materials including metal equipment and building components.
-------
ADDENDUM 4
The Region 6 RCRA Hazardous Waste Program En vironmenta! Justice Strategy
Introduction
The Agency has made "Expanding the Conversation on Environmentaiism and Working for Environmental Justice" a priority. To implement this priority,
EPA launched Plan EJ 2014 as the Agency's strategy for integrating environmental justice (EJ) in its programs, policies and activities. This four-year
plan will help EPA move forward to develop a stronger relationship with communities and increase the Agency's effort to improve the environmental
conditions and public health in overburdened communities. The plan seeks to protect the environment and health in overburdened communities;
empower communities to take action to improve their health and environment and establish partnerships with local, state, tribal and federal
governments and organizations to achieve healthy and sustainable communities.
The Region 6 EJ office has identified five areas of concern for EJ consideration. A map showing the locations is shown in Appendix A. These areas will
be used as initial assessment areas by the RCRA program to focus our efforts.
The Region 6 RCRA Hazardous Waste Program evaluated three EJ assessment tools. These were available for use to prioritize sensitive areas for
consideration. See Appendix B for a comparison table of the three tools. EPA Region 6 uses the Potential EJ Index (PEJI) ranking tool which has high
resolution because it is based on the Census block level, but there are a low number of social demographic indicators used in the ranking. (Social
demographic indicators include: percent minority, per capita income, population density and others.) The Social Vulnerability Index (SVI) ranking tool
utilized by Region 9 makes assessments at the Census block group level, which is a lower resolution than the PEJI, but considers a higher number of
social demographic indicators, including: percent minority, per capita income, percent population over 18, percent population over 64, percent
population without high school diploma, and percent households with limited English proficiency. OECA's Environmental Justice Strategic Enforcement
Assessment Tool (EJSEAT) assesses at a Census tract level, the highest resolution of the three indices. EJSEAT evaluates the same social
demographic indicators as the SVI, but also includes various environmental, human health, and compliance indicators. In order to eliminate the diverse
assessment of tools, the EPA Headquarters is working to create a national EJ ranking tool, anticipated to be released in 2014. For the purposes of this
strategy, the RCRA Hazardous Waste oversight program will evaluate factors from the various rankings until the national tool is available, and will
designate identified areas as areas of concern.
The Region 6 RCRA Hazardous Waste Program strategy describes the goals and methods for incorporating EJ into the day to day operations of our
program. This strategy defines three focus areas for the RCRA Hazardous Waste State Program oversight process:
1. Program oversight review of state-issued permits and GPRA corrective action reviews
2. Program oversight review of state public participation activities associated with permit renewals and RCRA corrective action, and
3. In other program areas, we will consider areas of concern in our decision-making process for EPA assistance to the states. This would involve
RCRA underfunded/near bankrupt sites and the various state voluntary cleanup programs.
-------
Focus Area 1; Oversight Review of Permits and GPRA Corrective Action
There are several areas in our oversight of state- implemented RCRA hazardous waste programs where we can more effectively protect human health
and the environment for disproportionately burdened populations by incorporating EJ considerations into our reviews.
• Complete an initial review of the five areas of concern identified by the Region 6 EJ office. Using GIS layer treatment storage and disposal
(TSD) and permit data along with GPRA 2020 data for corrective action sites within a 5 mile radius of the areas of concern.
• Expand the list of facilities by incorporating information on voluntary cleanup program (VCP) sites. For Texas this will include facilities located in
municipal settings designated (MSD) areas.
• Prioritize the facilities within an area of concern by narrowing the focus to facilities with an identified off-site release. In addition to the above we
will prioritize our reviews and oversight based upon the ORCR Corrective Action EJ Analysis. This analysis places GPRA 2020 corrective
action sites into one of three categories.
• Expand the number of areas of concern by using other screening tools to look at areas that may be disproportionately burdened by RCRA
facilities. There are numerous pockets of that have large numbers of 2020 Corrective Action sites. See Appendix C.
• To further prioritize the identified areas of concern, the concentration of RCRA facilities within an area will be used for screening.
• Prioritize our annual permit and corrective action reviews for each state by ensuring that facilities located in the areas of concern are given
priority.
• Prioritize GPRA corrective action status updates (via monthly conference calls) based on areas of concern or sensitive areas.
• Based on facility-specific information on corrective action progress and agreement with state partners, referrals to the Hazardous Waste
Enforcement Branch of the Region 6 Compliance Assurance and Enforcement Division may be appropriate.
-------
Focus Area 2: Oversight Review of State Public Participation
In February 1996, EPA finalized the RCRA Expanded Public Participation Rule (EPA530-F-95-030) to empower communities to become involved
earlier and more often in the process of permitting hazardous waste management facilities. The Rule supports 1) involving the public earlier in the
permitting process, 2) providing more opportunities for public involvement, 3) expands access to public information, and 4) provides guidance on how
facilities can improve public participation.
• During our RCRA Permit Program and Corrective Action Program reviews for a state, EJ considerations will be incorporated into the review.
This includes documenting how each state supports the RCRA Expanded Public Participation Rule into their permitting and corrective action
processes. For example see Appendix D, Summary of Region 6 States RCRA Public Participation.
Focus Area 3: EPA Assistance to the States
Facilities that are identified within areas of concern through the use of the various EJ prioritization tools will be prioritized for EPA assistance which
may include:
• Use of contract dollars for additional sampling at facilities located in areas of concern.
• Coordination with each of our states to ensure that appropriate actions are taken for all sites and that disproportionately burdened populations
are included to the extent practicable in the decision making process.
• Referrals to enforcement or requests for additional support will be prioritized based impact to the areas of concern.
• Special consideration for sites in the VCP with potential Indoor Air Exposures.
Pati Forward
The RCRA Hazardous Waste Program will concentrate on the five areas of concern to perform an initial screen of RCRA sites and 2020 GPRA
corrective action sites. The Grants Mining District in New Mexico does not have any RCRA sites or 2020 GPRA corrective action sites within the 5 mile
radius we are using for the screen. The initial mapping effort for Manchester and Port Arthur, Texas along with Mossville, Louisiana will be completed
by the end of September 2011. The Corpus Christi, Texas area is dependent upon receiving parcel boundary data, but should be completed by
December 2011.
In addition to mapping the 2020 GPRA corrective action sites located within the areas of concern, we will prioritize them to prepare for discussions with
the states. This should be completed by December 2011. See Appendix E for a list.
We will use the screening information to prioritize our permit and corrective action reviews for FY 2012.
We currently host monthly calls with Louisiana to discuss issues with corrective action sites. If the need arises we will implement a similar strategy in
other states.
/| /| JN/
-------
The Region 6 RCRA program will incorporate an Environmental Justice element into the RCRA state grant program for each of the five states. This
would occur during the negotiations for the 2013 fiscal grant year for each state and would require the consideration of EJ facility rankings as a factor
in the setting of priorities for review of state lead corrective action activities.
Once the initial review of potential oversight areas is complete we will continue to screen additional facilities in these areas of concern, such as
voluntary cleanups to ensure that our oversight program is adequate. This task would start in FY 2013. Additional areas of concern could be identified
based upon screening criteria the Region decides to implement in the interim until an Agency wide screening tool is developed hopefully in FY 2014.
-------
APPENDIX A
luquerque
Oklahoma--
__ Cily"
" i
OKLAHOMA
ARKANSAS
5hsvena!t_ga
¦*
Louisiana
TEXAS
Mossville, LA
Beaumoi
^ _jiouston.<-i
Manchester, TX
Port Arthur, TX
Laredo
Corpus
'Christl
Region 6 Environmental Justice
Areas of Concern
Location of 5 Areas of Concern
Abilene
Corpus Christi, TX
Grants Mining District, NM
9 NEW
\ MEXICO
0Amarillo
- _o —
Lubbock
o
-------
APPENDIX B
OECA - Environmental Justice Strategic Region 9 - Social Vulnerability Index Region 6 - Potential Environmental Justice Index
Enforcement Assessment Tool (EJSEAT) (SVI) (PEJI)
~ Assessed at Census Tract Level (multiple tracts make
up a county)
~ Designed for enforcement/compliance programs to
rank census tracts and regulated facilities
~ Project started in 2005 - draft tool still in development
~ Score: 1 (Highest Potential EJ Concern) - 10 (Lowest
Potential EJ Concern)
Tool pulls data for 4 indicator categories from 18 select
federally-recognized or managed databases:
~ Assessed at Census Block Group Level
(multiple block groups make up a tract)
~ Designed for ranking both census block
groups and Corrective Action sites
~ Developed by Region 9's Environmental
Justice Program
~ Score: 0 (Least Socially Vulnerable) -18
(Most Socially Vulnerable)
Tool pulls data for 1 indicator category from 6
select federally-recognized or managed
databases:
~ Assessed at Census Block Level (multiple blocks make up a
block group)
~ Designed for all Region 6 programs to identify potential EJ
areas of concern
~ Methodology derived in the mid- 1990s (from Human Health
Risk Index)
~ Score: 0 (Low EJ Sensitivity) -100 (High EJ Sensitivity)
Tool pulls data for 1 indicator category from 3 select federally-
recognized or managed databases:
> Social Demoaraohic Indicators
(2000 Census Data)
o Percent minority
o Percent in poverty
o Percent population under 5
o Percent population over 64
o Percent population without high school diploma
o Percent households with limited English
proficiency
> Social Demoaraohic Indicators
(2000 Census Data)
o Percent minority
o Per capita income
o Percent population under 18
o Percent population over 64
o Percent population without high school
diploma
o Percent households with limited English
proficiency
> Social Demoaraohic Indicators
(2000 Census Data)
o Percent minority
o Percent in poverty/economically stressed (percent of
households with income under $20,000 - adjusted to
present day)
o Population density (pop. per sq mi)
> Environmental Indicators
o NA TA cancer and non-cancer risk from air
emissions
o Toxic chemical emissions and transfers from
industrial facilities-TRI
o Population weighted ozone and PM 2.5
monitoring data
> Human Health Indicators
o Percent infant mortality
o Percent low birth weight
> Compliance Indicators
o Inspections, violations, and formal actions at
major facilities
o Facility density (no. of permitted facilities per q
mi)
-------
OECA - Environmental Justice Strategic
Enforcement Assessment Tool (EJSEAT)
Region 9 - Social Vulnerability Index (SVI)
Region 6 - Potential Environmental Justice
Index (PEJI)
How community vulnerability is scored:
• Each indicator is scaled from 0-100 within each state
by Census tract
• The scaled indicator values are averaged within
each category (e.g., demographic, health)
• The four category values are averaged into an
overall value
• This value is again rescaled from 0-100 within each
state, and the final summary value is represented as
a decile (1-10) for the Census tract
How community vulnerability is scored:
Each dataset for each block group is assigned an index
score of 0-3, based on whether the value in that dataset
falls in the top quartile (score=3), second quartile (score=2),
third quartile (score=1), or bottom quartile (score=0)
• Top quartile represents most vulnerable (i.e., block
group with the highest percent minority)
• The datasets are then all added together to assign a
comprehensive score to each block group (0-18)
How community vulnerability is scored:
• Population density (population per 1 square mile) is
scaled 0-4 (0 = 0, 4 = >5,000)
• Economically stressed and percent minority are
scaled 1-5 (based on comparison to State Avg.)
• Population density and percent minority are
calculated at the block level; economically stressed
calculated at the block group level, and then applied
to the block level
• The 3 factors are multiplied together to assign a
comprehensive EJ score to each block (0-100)
How facility ranking is scored:
• Facilities are ranked based on their proximity
(currently, considered within 2/3 mile) to Census
tracts with high EJSEAT scores
How site ranking is scored:
• A one-mile radius is drawn around each site
• If a site's radius falls within one block group, then the
SVI score for that block group is assigned
• If a site's radius covers multiple block groups, then the
percentage of each block group that falls within the
radius is calculated, and then multiplied by the total
population within each block group
• Each value is then multiplied by that block group's SVI
score, and then summed
• This value is then divided by the total population that
falls within the one-mile radius to come up with a
weighted SVI score for the site
How site ranking is scored:
• N/A - there is no site ranking component to this
methodology
Advantages:
• Considers multiple indicators and datasets
• Calculates a score not just for a demographic area,
but also for a regulated facility
Advantages:
• Flexible: easy to customize output
• Block group scale can pick up more EJ communities
than Census tract
• Calculates a score not just for a demographic area
(i.e., block group), but also for a site location
Advantages:
• Flexible: easy to customize output
• Block scale can pick up more EJ communities than
Census tract or block group
Disadvantages:
• Static: limited ability to customize output
• Census tract scale is not detailed enough to pick up
all EJ communities
• Environmental indicators are focused on outdoor air
risk and toxics; do not take into account indoor air
quality, drinking water, groundwater, pesticide, and
other concerns
Not all indicators have data available at the Census tract
level (e.g., health indicators are at the County level)
Disadvantages:
Doesn't consider multiple indicators (e.g., environmental,
human health)
Disadvantages:
• Doesn't consider multiple indicators (e.g.,
environmental, human health)
Current methodology doesn't take into account calculating
a score for a regulated facility or Corrective Action site
/-N^ ^ /V/
-------
APPENDIX C
Tulsa,
Albuquerque ^
/ NEW
/MEXICO
OKLAHOMA
Little""!
Rock <3^*
Lubbock
•o
_ Fort L _
Wbith/* ll**~
— - -A- Dallas
Abilene ^ • «
Waco \
El Paso
/• LOU I
i *
Beaumont
fNew |
Orleans
San Antonio,
Region 6 RCRA Corrective Action
Baseline
s Location of CA2020 site
Q /V/
-------
APPENDIX D
Summary of Region 6 States RCRA Public Participation
All of the states in Region 6 are authorized to implement the RCRA permitting corrective action programs. As such EPA does not
issue RCRA permits in Region 6. We rely on the state programs to follow at minimum EPA guidelines for public participation. As our
role of oversight has expanded we continue to look all parts of the RCRA permitting and corrective action programs, including public
participation.
In general the states follow the RCRA public participation requirements with some enhancements that are unique for each state.
Several of the states provide the public access to draft permits on-line. States also have documents related to corrective action
activities on-line. This allows the public easy access to documents for review and in some cases to leave comments. Included is a
brief description of each states program and how environmental justice factors into decisions.
Arkansas
The Arkansas Department of Environmental Quality (ADEQ) follows the basic required steps for public notices/participation during
the permitting process for all Class 1/2/3 Permit Modifications as well as Permits (both initial and renewals). This involves both
administrative completeness as well as technical completeness. For Commercial facilities, they always hold a public meeting/hearing
for all Class 3 modifications/renewals. For Non-Commercial facilities a public notice of the decisions is made and they await final
decisions after the close of the public comment period, etc. Public meetings/hearings are not required to be held for Non-Commercial
facilities, but there have been an occasion in which ADEQ has felt it was prudent based upon public concerns, etc. In all public
notices, ADEQ offers the public the opportunity to request a public hearing (if not originally required or scheduled).
All comments (both verbal and written) are addressed in a Responsiveness Summary and are sent to all parties that are on the
mailing list for the respective facility or to those that provided comments. This Responsiveness Summary becomes part of the final
approval/notice of issuance. All final decisions are discussed in Responsiveness Summary and Fact Sheet on each respective
decision.
The current State Administrative Regulation (APC&EC Reg. No. 8) allows for any party to request a hearing/meeting if one is not
initially offered. Based upon discussions with program managers they could not recall a time in which someone requested a
meeting/hearing that the Director did not grant such request.
The point where the local community has input into the process is from the point the facility submits a request to ADEQ for a Permit
Modification or a Renewal (or initial issuance) since (1) the facilities are required regulatory to do a public notice when applications
~ 50 ~
-------
are submitted to ADEQ for consideration and (2) ADEQ issues notices of intent to either deny or grant. This later notice has a 30 to
45 day public comment period built into the process. Administrative Repositories are established for all Permitting decisions and the
locations of these are placed in the initial public notice Fact Sheets.
There is also a public participation process in RCRA corrective action. A RCRA final remedy for a site is described in a Remedial
Action Decision document (RADD), which has a 45-day (or 30-day) public comment period. Once public comments are collected,
the authorized agency writes a Response to Comments/Final Decision document.
Louisiana
The Louisiana Department of Environmental Quality (LDEQ) follows the required steps for public notices/participation during the
permitting process. LDEQ also has a Public Participation Group that is part of the Permit Support Services Division. They are
responsible for issuing public notices and conducting public hearing and meetings associated with permitting activities.
One additional enhancement is noted in the requirements to hold an evidentiary hearing in LAC 33:V.709, Evidentiary Hearings on
Operating Permit Applications for Commercial Hazardous Waste Treatment, Storage, Disposal, or Recycling Facilities. This applies
to a company applying for a RCRA permit as a commercial TSD. The department must hold an evidentiary hearing after the technical
review of the permit. There is a public notice and hearing at which extra information regarding the application can be submitted by
the public to the LDEQ. LDEQ can't issue the draft permit until it has received and reviewed the record of the evidentiary hearing.
The state maintains an on-line method for the public to access permits (both draft and final), correspondence, public notices and
applications.
There is also a public participation process in RCRA corrective action. A RCRA final remedy for a site is described in a Basis of
Decision document which has a 45-day (or 30-day) public comment period. Once public comments are collected, the authorized
agency writes a Response to Comments/Final Decision document.
Oklahoma
The Oklahoma Department of Environmental Quality (ODEQ) follows the required steps for public notices/participation during the
permitting process. ODEQ has a Customer Assistance Program which provides a point of access for agency information. Among
other things they provide risk communication and citizen assistance. This allows citizens and public interest groups to obtain copies
of permits and other documents.
~ 51 ~
-------
Another enhancement over and above the basic public participation requirement is how they post all draft permits on the ODEQ web
site. The permits can be viewed and comments can be provided on-line by interested parties. ODEQ plans to have all active permits
available on line for viewing.
There is also a public participation process in RCRA corrective action. A RCRA final remedy for a site is described in a Statement of
Basis which has a 45-day (or 30-day) public comment period. Once public comments are collected, the authorized agency writes a
Response to Comments/Final Decision document.
Mem Mexico
The New Mexico Environment Department (NMED) follows the required steps for public notices/public participation during the
permitting process. The New Mexico Hazardous Waste Management Regulations, 20.4.1 NMAC provides for a robust public
participation process. Through involvement of the public in the permitting process the hazardous waste permits in New Mexico are
improved.
Through negotiations with the applicants and the public, comments received during the comment period the final permits are greatly
enhanced to provide the public with more awareness, such as e-mail notifications of various activities that occur at the facility through
the term of the permit. NMED will also extend the public comment period on some of the more complex permits.
The New Mexico Hazardous Waste Management Regulations, at 20.4.1.901.A(4) NMAC, states: "If the Secretary issues a Draft
Permit, and a timely written notice of opposition to the Draft Permit and a request for a public hearing is received, the Department,
acting in conjunction with the applicant, will respond to the request in an attempt to resolve the issues giving rise to the opposition. If
such issues are resolved to the satisfaction of the opponent, the opponent may withdraw the request for a public hearing." NMED has
interpreted this rule to allow face-to-face discussions with commenter's and the applicant. NMED has successfully conducted such
meetings, which have led to withdrawal of hearing requests. While avoiding a hearing can save months of time and considerable
resources preparing for an administrative hearing, conducting multiple meetings can also add to the delay in issuing permits.
Commenter's that did not request a hearing are not invited to the meetings with NMED and the applicant. The intent is to resolve as
many issues as possible during these meetings. The meetings provide a beneficial interaction and understanding of each party
position and in many instances, through detailed discussion of the specific issue, ends in a mutual resolution or compromise.
Concerns being discussed may include environmental justice issues. The resolution or compromise must be consistent with and not
conflict with the regulations and statute.
At the end of these meetings there are several procedures that may occur. If the withdrawal of hearing requests is made then NMED
could issue a final permit. If hearing requests are not withdrawn NMED could then reissue the draft permit for public comment if
~ 52 ~
-------
significant changes have been made. NMED could schedule a public hearing which would be limited to those issues that were not
resolved during the meetings. Other iterations could be considered in the process.
NMED has employed all of these strategies at various times, depending on the circumstances peculiar to each permitting action.
In addition LANL and WIPP have e-mail notification when certain actions occur. These are required in their respective hazardous
waste permits. Also, WIPP held pre-submittal meetings when they applied for their permit renewal and they also hold them for Class
2 and Class 3 permit modification proposals. LANL has held pre-submittal meetings on permit modifications, and recently, a new unit
they are proposing to add to the current permit. NMED has and continues to encourage the facilities to hold pre-submittal meetings
on major modifications and renewal applications. New Mexico public notices permit applications as required by 40 CFR 124.32.
Many of our federal facilities also have established physical information repositories. LANL has recently employed an electronic
repository in addition to a physical repository as was negotiated during the permit process and required under the current permit.
WIPP also has an electronic repository and a physical repository. In addition, many of our facilities are required to put in place a
community relations plan (CRP) that engages the public, and in some instance tribes, on how to inform the communities and
interested public of permit and corrective action related activities. The CRPs are required to be updated annually with input from
communities, tribes and interested persons.
NMED has established a Border Liaison and a Tribal Liaison to work on EJ concerns and issues. The liaisons were established in
response to a public participation process to ascertain the extent and nature of unique and differing EJ issues and concerns in
NMED's five state-wide districts. The goal of the liaisons is to be the main point of contact for border or tribal EJ issues focusing on
reducing air pollution, providing safe drinking water, reducing the risk of exposure to hazardous waste, training and outreach.
Other enhancements that allow easy access to documents include the NMED website which has all of the current RCRA permits on-
line for viewing or download. The site also includes public notices.
There is also a public participation process in RCRA corrective action. A RCRA final remedy for a site is described in a Statement of
Basis which has a 45-day (or 30-day) public comment period. Once public comments are collected, the authorized agency writes a
Response to Comments/Final Decision document
Texas
The Texas Commission on Environmental Quality (TCEQ) follows the required steps for public notices/public participation during the
permitting process. Enhancements include publishing notices in an alternate language. After a preliminary decision is reached (Final
Draft Permit is sent the Office of Chief Clerk (OCC)): a) OCC sends notice of preliminary decision to all persons listed in 30 TAC
39.413; b) Applicant publishes notice in English in local newspaper (in some areas also in an alternate language...i.e. Spanish); c) for
new, renewal, and major amendments (not Class 3 modifications) the company will also do a radio broadcast.
~ 53 ~
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Comments and hearing requests will be accepted and considered from the first notice through the final comment period. Also, for
major permitting actions and new facilities, the Commission may hold a public meeting as per 30 TAC 39 if public interest is shown.
TCEQ provides easy to find public participation information on-line. In addition the state maintains an Environmental Equity office to
address EJ issues. Some of the goals of the program are to help citizens and neighborhood groups participate in regulatory
processes; serve as the agency contact to address allegations of environmental injustice; serve as a link for communications
between the community, industries, and the government; and to thoroughly consider all citizens' concerns and handle them fairly.
There is also a public participation process in RCRA corrective action. A RCRA final remedy for a site is described in a Statement of
Basis which has a 45-day (or 30-day) public comment period. Once public comments are collected, the authorized agency writes a
Response to Comments/Final Decision document.
-------
APPENDIX E
2020 CPRA Corrective Action Sites within 5 Miies of Communities of Concern
EPA ID NO.
FACILITY
PARCEL
OWNER
LEAD
AGENCY
RANK
CA075
HUMAN
HEALTH
CA725
GROUNDWATER
CONTROLLED
CA750
REMEDY
SELECTED
CA400
REMEDY
CONSTRUCTED
CA550
PROJECTED
REMEDY
CONSTRUCTED
CA 550
EJ SEAT
RANKING
Manchester, Texas
TXD000802959
Ak Steel
Corporation
Armco Inc
EPA
TX47
ME
YE 10/09
OK
OK
OK
2017
1
TXD008089021
Koppers Company
Inc
Magellan
Terminal
Holdings
STATE
HI
YE 07/04
YE 07/04
08/06
2011
1
TXD008098725
Chevron Phillips
Chemical
Company Lp
Chevron Phillips
Chemical
STATE
HI
YE 02/09
YE 02/09
02/09
NR 02/09
1
TXD008099079
Rhodia Inc
Rhodia / Texas
Ultra Pure (joint
parcel
ownership)
EPA
TX47
ME
YE 03/07
OK
OK
OK
2018
1
TXD008105959
Parkans
International Lie
Seafood
Internationale
LLC
EPA
TX47
LO
YE 10/09
OK
OK
OK
2018
2
TXD026481523
Kinder Morgan
Liquids Terminals
LP
GATX Terminals
Corp
STATE
HI
YE 12/04
YE 12/04
08/08
RC 08/08
TXD053624193
Valero
Valero Refining
Co Texas
STATE
LO
YE
11/10
YE 11/10
10/10
10/10
1
TXD055135388
Set Environmental
Inc
Set
Environmental
Inc
EPA
TX47
LO
YE
9/10
OK
OK
OK
1
TXD082684002
Exxon Chemical
Americas
Baytown Chemical
Exxon Corp
EPA6PD
CASE
HI
YE
8/07
IN 8/07
2016
TXD082688979
Lyondell Citgo
Refining Lp
Houston
Refining
STATE
HI
YE 08/02
YE 08/02
07/06
RC 08/07
5
TXD084972777
Bayer Corp
John E Frantz
STATE
HI
YE 10/01
YE 08/02
02/08
NR 02/08
1
~ 55 ~
-------
EPA ID NO.
FACILITY
PARCEL
OWNER
LEAD
AGENCY
RANK
CA075
HUMAN
HEALTH
CA725
GROUNDWATER
CONTROLLED
CA750
REMEDY
SELECTED
CA400
REMEDY
CONSTRUCTED
CA550
PROJECTED
REMEDY
CONSTRUCTED
CA 550
EJ SEAT
RANKING
TXD982560294
Nuclear Sources
And Services Inc
Robert D
Gallagher
STATE
HI
YE 10/00
YE 10/00
02/06
NR 02/06
1
TXD990757486
Air Products Lp
Air Products
Incorporated
STATE
ME
IN 07/97
IN 07/97
01/09
RC 01/09
1
Corpus Christi, Texas
TXD008117186
Encycle Texas Inc
Still waiting on
data
EPA6PD
CASE
HI
YE 12/04
YE 04/04
11/10
2013
3
TXD008132268
Valero Energy
Corp
Still waiting on
data
STATE
ME
YE 01/09
YE 01/09
2012
1
TXD051161990
Citgo Petroleum
Corporation
Still waiting on
data
STATE
LO
YE 01/09
YE 01/09
2012
1
TXD066447376
Flint Hills
Resources Lp
Still waiting on
data
STATE
HI
YE 02/00
YE 12/03
08/07
RC 08/07
1
TXD981153711
Citgo Refining And
Chemicals
Company Lp
Still waiting on
data
STATE
ME
YE 09/09
YE 06/09
02/09
NR 02/09
3
TXD981157530
Citgo Refining And
Chemicals Inc
Still waiting on
data
STATE
LO
IN 03/07
IN 03/07
3/11
3/11
Port Arthur, Texas
TXD000820928
Huntsman
Petrochemical
Corporation
Huntsman
Petrochemical
Corp
STATE
LO
YE 03/05
YE 03/05
02/06
RC 02/06
3
TXD008076846
Huntsman
Petrochemical
Corporation
Huntsman
Petrochemical
Corp
STATE
ME
YE 09/09
YE 09/09
09/09
NR 09/09
2
TXD008090409
The Premcor
Refining Group Inc
Golden Triangle
Properties LLC
STATE
HI
YE 02/03
YE 02/03
2012
4
TXD008097529
Motiva Enterprises
Lie
Motiva Refinery
STATE
HI
YE 04/04
YE 04/04
02/09
2015
3
TXD980626022
Motiva Enterprises
Lie
Motiva Refinery
EPA6PD
CASE
HI
YE 12/04
YE 12/04
2019
2
Mossville, Louisiana
LAD000618256
Cecos Intl, Inc.
Calcasieu Facility
Cecos
International Inc
STATE
HI
YE 05/03
YE 05/03
06/08
2/11
9
~ 56 ~
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PARCEL
OWNER
LEAD
AGENCY
RANK
CA075
HUMAN
GROUNDWATER
REMEDY
REMEDY
PROJECTED
REMEDY
CONSTRUCTED
CA 550
EJ SEAT
RANKING
EPA ID NO.
FACILITY
HEALTH
CA725
CONTROLLED
CA750
SELECTED
CA400
CONSTRUCTED
CA550
LAD008080350
Citgo Petroleum
Corporation
Citgo Petroleum
Corporation
STATE
HI
YE 04/05
IN 08/99
2018
3
LAD008080681
Olin Corporation,
Lake Charles
Olin Corporation
STATE
HI
YE 06/03
YE 06/03
2014
3
LAD008086506
PPG Industries Inc
PPG Industries
Inc
STATE
HI
YE 06/04
YE 06/04
6/10
2012
3
LAD086478047
Georgia Gulf Lake
Charles, Lie
Georgia Gulf
Lake Charles
LLC
STATE
HI
YE 03/03
YE 03/03
02/10
NR 02/10
3
LAD981514441
Ppg Industries No
5 Incinerator
PPG Industries
Inc
STATE
HI
YE 06/00
YE 06/00
12/05
12/05
LAD990683716
ConocoPhillips
Company
Conoco Inc
STATE
HI
YE 10/05
YE 10/05
2020
3
LAR000018333
Lyondell Chemical
Company
Lyondell
Chemical
Company
STATE
LO
6/10
2014
3
LAR000041087
Sasol North
America Inc.
Sasol North
America Inc
STATE
LO
2014
3
Grants, New Mexico - no RCRA 2020 sites within 40 miles
~ 57 ~
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Table of Contents
Page
Original Corrective Action Strategy to Meet GPRA 2020 Goals 1
Updated Regional Corrective Action Strategy 3
Chart 1: Projected Progress to CA550 11
Table : \ Projected % Facilities Reaching GPRA Goals 12
Table 1B Actual % Facilities Reaching GPRA Goals 13
Table 2: Projected and Actual % Facilities in Total Universe Reaching GPRA Goals 14
Chart 2: Projected versus Actual Progress to CA550 15
Table 3: Facilities of Concern 17
Table 4: Categorization of Difficult Baseline Facilities 25
Addendum 1: Huffman Wood Preserving and Oklahoma Pole and Lumber Facilities 29
Addendum 2: MicroChemical Company 31
Addendum 3: Rogers Delinted Cottonseed Company 33
Addendum 4: Region $ RChazardous Waste Program Environmental Justice Strategy 35
Appendix A: Map EJ Areas of Concern 39
Appenc fironmental Justice Strategic Enforcement Assessment Tool 40
Appenc Map Region 6 Corrective Action Baseline Facilities Location 43
Appendix D: Summary of Region 6 States RCRA Public Participation 45
Appendix E: 2020 GPRA CA Sites within Five Miles of Communities of Concern 51
~ 58 ~
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