PETRO-CHEMICAL
SYSTEMS, INC.
(TURTLE BAYOU)
TEXAS
EPA ID# TXD980873350
Site ID: 0602957
EPA REGION 6
CONGRESSIONAL DISTRICT 36
Liberty County
Other Names:
Turtle Bayou
Raji Josiam, (214) 665-8529
Updated: August 2014
Background 	
The Retro-Chemical Systems, Inc. Superfund Site (Site) is located on County Road 126 or CR 126
(previously known as Frontier Park Road or FPR), south of Liberty (east of Houston and FM 563; 7 miles
north of 1-10), Liberty County, Texas. CR 126 traverses the site. Site operations commenced prior to
1970 and continued until the late 1970s. Waste oils were dumped on CR 126 and into unlined waste pits
along road. A conditional commercial permit was issued in 1971 but was revoked due to legal action and
withdrawn in 1974. After 1974, the land was developed and subdivided into residential properties. In
1986, EPA installed a fence and conducted site sampling. In 1988, CR 126 was excavated, back-filled,
and re-built; residents were relocated during this period.
Resurfaced Road
Remedial Action, Current Status, and Issues	
•	With the cleanup actions described above, the EPA has greatly reduced the potential for accidental
contact or exposure to contaminated soil and dust along CR 126 while cleanup actions are being
designed.
•	What is the status of remedial action at Petro-Chemical Systems, Inc. site?
•	The areas where remedial actions have taken place or are required are as follows: County Road
(CR) 126 (previously FPR), the CR 126 West Area, the West Road Area, the Main Waste Area,
the Office Trailer Area, the Easement Area, the Bayou Disposal Area, and the MW-109 area.
•	The Remedial Investigations and Feasibility Studies (RI/FS) for both FPR and Source Control
phases (operable units) were initiated in April 1988. The remedy for CR 126 road was completed
in 1988. The remedy included excavation of the road's most contaminated soils, placement of
these soils in a temporary on-site RCRA storage facility, and paving the road to prevent direct
contact with less contaminated soils. The remedial action cost for the road was approximately $2
million.
Monitoring Wells installed in MW-109 Area
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•	The remedy for the site's West Road Area, Main Waste Area, Office Trailer Area, and Easement
Area has been implemented by Lyondell Chemical Company and Atlantic Richfield pursuant to a
Consent Decree. The remedy included the application of various soil and ground water remedial
technologies (e.g., soil vapor extraction, in-situ bioremediation). Based on 7+ years of active
remediation, attainment of the site's cleanup goals has been determined to be technically
impracticable. These affected areas have been purchased by Lyondell to preclude access and
residential exposure. Long-term ground water monitoring is taking place to ensure contaminant
migration outside these areas does not occur. Approximately $30 million was spent for remedial
activities in these areas.
•	For the Bayou Disposal Area no removal of the affected soil was required since the soil already
met the Amended ROD soil cleanup criteria for non-residential use and institutional controls are in
place.
•	The remedial action for the CR 126 West Area is complete and included mechanical auger mixing
and in-situ chemical oxidation of contaminated soils and groundwater for a cost of approximately
$9 million. EPEC Polymers Inc. conducted these activities pursuant to a Consent Decree that
was entered on August 21, 2007. Remedial Action construction work in the CR 126 West area
was completed in September 2008 and confirmatory samples were taken in October 2008.
Confirmatory sampling results confirm that the cleanup goals have been met. Quarterly
groundwater monitoring is being implemented. An Interim Remedial Action Report was submitted
to the EPA and TCEQ in August 2009.
•	Community Involvement: A Community Open House was held on March 24, 2010 at the First
National Bank in Liberty to share information on the MW-109 Area remedial action, the CR-126
road resurfacing, and the TBB outfall flow optimization. EPA continues to work with Liberty
County and the residents to ensure protection.
•	The MW-109 area has been characterized for the extent of contamination. The extent of
contamination in this identified area is localized since previous ground water sampling has shown
elevated benzene concentrations in MW-109 but not in the surrounding wells. EPA had an
Interagency Agreement in place with the US Army Corp of Engineers (USACE) to conduct the
Remedial Design and Remedial Action for the MW-109 area. EPA issued an ESD for the MW-
109 Area on September 23, 2010. An Administrative Record for the ESD was established in
early November at the Liberty County Library and at the TCEQ office in Austin. A Notice
announcing the availability of the ESD was published in the Liberty Vindicator in early November,
2010.
•	In-Situ Chemical Oxidation (ISCO) was implemented in the MW-109 area. With two full rounds of
chemical injections in the entire MW-109 area and several rounds of injections in the western
quadrant of the MW-109 area, the soil remediation goals have not been able to be met. An
alternative remedy identified in the 1998 ROD Amendment, soil excavation with ex-situ
biotreatment, has been completed and the soil meets the residential and industrial right-of-way
cleanup goals. ISCO and ex-situ biotreatment was conducted at a cost of approximately $1.5
million. USACE and their contractor completed confirmatory sampling in the MW-109 area. Three
additional ground water monitoring wells have been installed in the area and eight rounds of
quarterly sampling have been completed at the MW-109 Area and the results are being evaluated
for additional investigation to be conducted in the area.
•	EPA had an Interagency Agreement with the USACE to re-surface CR-126 to meet County Road
Specifications for County acceptance and maintenance for an estimated cost of approximately
$1.7 million. Soil borings were taken along the CR-126 roadway and the soil boring data was
evaluated for design recommendations. The design for the CR-126 road resurfacing was
completed and approved by the Liberty County Commissioner's Court on June 29, 2010. The
CR-126 road resurfacing has been completed on September 28, 2010. A meeting and site walk
through/inspection was held at the site between EPA, USACE, TCEQ, the Liberty County
Commissioner, and the USACE Contractors on November 12, 2009. Another site visit/walk
through with the contractors was conducted on December 9, 2009 and discussions were also
held with the residents of the area.
•	The Liberty County Commissioner's Court met on October 26, 2010 and has accepted the road
as a County Road and will assume responsibility for operations and maintenance of the road
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once the signed easements are transferred over to the County. A Memorandum of Agreement
between the EPA and Liberty County has been signed on January 21, 2011 for the County to
operate and maintain the road. USACE has obtained signatures from all the property owners
adjacent to CR-126 on the Easement Agreement and has submitted those to the County in
August 2013 for their continued maintenance, improvement, and upkeep of the road in
accordance with the MOA.
•	In addition the outfall under the Turtle Bayou Bridge (TBB) was evaluated by USACE contractors
for the need to widen/clear in order to maintain an optimal flow under the bridge for a total
estimated cost of under $200,000. Sediment samples have been taken at the TBB outfall area
and the results were evaluated. Hydraulic analyses of the channel recommend no sediment
removal.
•	Lyondell's bankruptcy filing was finalized in 2010. EPA and TCEQ met with the Lyondell
Custodial Trust Trustee and their contractor on April 14, 2010 at TCEQ to discuss a plan of action
on the former Lyondell areas.
•	EPA issued the Preliminary Close-Out Report for construction completion at the site on
September 30, 2010. A notice announcing the Construction Completion at the Site was
published in the Liberty Vindicator at the end of November, 2010.
•	The final Interim Remedial Action Report for the MW-109 Area has been submitted to EPA and
TCEQ for the MW-109 Area and has been approved March 9, 2011.
•	EPA has an interagency agreement with USACE to perform the third Five Year Review at the
site. USACE's contractor conducted the site inspections along with EPA and TCEQ during the
first week of May. The initial draft Five Year Review Report has been submitted to the EPA and
TCEQ for review. The Third Five Year Review Report was approved and signed by the EPA on
September 16, 2011.
•	The Remedial Action Report for the Lyondell Trust's properties was finalized and was approved
on September 15, 2011.
•	The Tl Zone document for the EPEC's Far West Road Area was finalized and the ESD has been
signed in August 2012.
•	The Tl Zone document for Lyondell Trust's properties was finalized and the ESD has been signed
in August 2012.
•	EPA and TCEQ visited the Site in September 6, 2012 and met with EPEC's contractor - URS and
with Lyondell Trustee's Contractors - ENVIRON. No significant issues were identified. New
signs were posted in the Lyondell Trustee properties. Plans for the waste disposal in the different
Lyondell Trustee areas and sump water in the Main Waste Area were discussed.
•	One newly installed well nest (EMW-044 and EMW-045) in the Office Trailer Area outside the Tl
Boundary had 1,2-dichloroethane (1,2-DCA) and tert-butyl alcohol (TBA) above their cleanup
standards in the 2012 4th quarter sampling. Further investigation is being conducted in this area
by Lyondell Trustee's Contractors.
•	EPEC and Lyondell Trustee's Contractors continue with the ground water monitoring as per the
long term monitoring plan. EPA, TCEQ, and the Trustees's Contractors are discussing changes
to the long term monitoring plan based on data available to date.
•	The Trustees's Contractors are working on a plan for dismantling/decommissioning the
Temporary RCRA Storage Facility.
Benefits 	
•	Local residents and businesses in the site area are now safe from direct contact and dust inhalation
of CR 126 wastes.
•	Remedial activities are cleaning the site to be fully protective for those living on the site now or in the
future.
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National Priorities Listing (NPL) History
NPL LISTING HISTORY
Site HRS Score: 29.94
Proposed Date: 10/15/84
Final Date: 5/20/86
NPL Update: No. 2
•There are residences and drinking water wells within a one-mile radius of the site along
FM 563 and CR 126.
•Of the 500+acre tract, 6 disposal areas have been identified.
•	Contaminated waste oils were used as dust control along CR 126.
•	In addition to CR 126, areas identified on the site include the CR 126 West Area, West
Road Area, Main Waste Area, Office Trailer Area, Easement Area, and the Bayou
Disposal Area. An additional area, the MW-109 area, is currently being evaluated for
extent of contamination
•The site is characterized by recent alluvial deposits, which overlay Texas Coastal Plain
deposits.
•The water table is at 18 to 25 feet below the surface of the site.
•The east end of the site falls within the 100-year flood plain along the Turtle Bayou
tributary.
Site Map and Diagram	
LOCATION MAP
liberty!
PETRO-C HEMIC AL
SYSTEMS SITE "—I
Population:
Setting:
Hydrology:
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Retro-Chemical Systems Inc. Superfund Site Location
CR-126 Frontier Park Road (OlM)
MW-109
AREA
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approximately 180 feet or more.
Enforcement	
•	During the course of the original RI/FS, a supplemental RI/FS was conducted by ARCO under an
Administrative Order on Consent signed 3/6/91.
•	In May 1993, Special Notice Letters were sent to eight parties to conduct the RI/FS.
•	After a failed attempt to negotiate a Consent Decree with site PRPs, a Unilateral Administrative Order
(UAO) was issued to Potentially Responsible Parties (PRPs) in December 1993. ARCO Chemical
Company and Atlantic Richfield Company are the only PRPs currently implementing work required by
UAO.
•	A Consent Decree between EPA, Lyondell (formerly ARCO Chemical), and Atlantic Richfield has
been entered with the Eastern District Court of Texas by the Department of Justice. The Consent
Decree was lodged by the court on December 8, 1998.
•	A Consent Decree between EPA and EPEC Polymer Inc. was lodged in the Eastern District Court of
Texas court on March 20, 2007 by the Department of Justice. The Consent Decree was entered by
the court on August 21, 2007.
•	Pursuant to the Lyondell Bankruptcy, the Consent Decree between EPA, Lyondell (formerly ARCO
Chemical), and Atlantic Richfield was amended and entered by the court on June 13, 2012 in which
the Lyondell Environmental Custodial Trust is substituted for Lyondell Chemical Company as a party
under the 1998 Consent Decree.
Record of Decision 	
Signed: March 27. 1987 (FPR)
Signed: September 6. 1991
(Source)
ROD Amendment: April 30. 1998
(Source & Ground Water)
ROD Amendment: September 22.2006
(Source & Ground Water)
ESD MW-109 Area: September 23. 2010
(Source)
ESD CR 126 West Area: August 17. 2012
(Groundwater)
ESD Lyondell Properties: August 22. 2012
(Groundwater)
Frontier Park Road (CR 126):
•	The Record of Decision (ROD) for FPR called for excavation of soil on and around the road followed
by placement of the contaminated soil within a temporary on-site RCRA storage facility with
temporary relocation of residents.
•	This remedy includes mowing of the temporary RCRA storage facility and road area, visual
inspections, and disposal of leachate.
Source Control:
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• The Source Control ROD selected soil vapor extraction and catalytic oxidation of organic
contamination and includes cap and slurry walls around waste disposal areas. To address ground
water contamination, soil sparging with extraction and treatment of contaminated vapors was
identified. As a result of extensive field pilot study activities conducted during the remedial design,
additional soil and ground water remedy enhancements have been identified. These include in-situ
bioremediation of contaminated ground water. To more effectively address soil contamination, the
following remedial enhancements were identified: thermal desorption, bioventing, excavation and
treatment and/or offsite disposal of site 'hot spots', etc. In 1998, the EPA amended the 1991 ROD to
include these and other remedial approaches.
Other Remedies Considered
1.	"No Action"
2.	Onsite storage with
temporary detours
3.	Off-site disposal with
relocation of residents
4.	Off-site disposal with
temporary detours
5.	Alternative access,
Fence contaminated areas
6.	Removal to background levels,
temporary detours
7.	Surface barrier,
temporary detours
Reason Not Chosen
-FPR-
Road needs action, too great a threat
More costly than relocation
Not cost-effective; transportation risks
Not cost-effective; transportation risks
Does not eliminate threat from road
Not cost-effective
Does not alleviate threat from road
1.	"No Action"
2.	Cap and Slurry Wall
3.	Biological treatment
4.	Solvent extraction
5.	Thermal destruction
6.	Thermal stripping
7.	On-site landfill disposal
8.	Offsite landfill disposal
9.	Soil vapor extraction and
catalytic oxidation
10.	Ground water extraction (wells),
carbon adsorption or direct disposal
11.	Ground water extraction by recovery
trenches; carbon adsorption or direct
disposal.
12.	Combination of treatment technologies
to address various areas of site.
-Source Control-
Not protective of human health and the
environment
Part of selected remedy
Short Term Impacts
Short Term Impacts
Not cost-effective
Short Term Impacts
Short Term Impacts
Short Term Impacts
Part of selected remedy
May be used, based on pilot study results
May be used, based on pilot study results
May be used, based on pilot study results
• An Inter-agency agreement was signed with Federal Emergency Management Agency to relocate
residents during work on FPR.
ROD Amendments and Explanation of Significant Differences:
The 1998 ROD Amendment addressed a modification to the soil cleanup criteria for benzene identified in
the September 6, 1991 ROD. The 1991 ROD"s benzene soil cleanup criteria was based on numerical
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model predictions of the allowable benzene concentrations in soils that, when attained, would not result in
exceeding the federal drinking water standards in the underlying shallow aquifer via leaching. The
benzene soil cleanup criteria modification is based on the following:
X rerunning the numerical model using site specific data (e.g., soil moisture profiles, field
permeability test results) collected during the field pilot study activities; and
X consideration of the Texas Natural Resource Conservation Commission"s residential exposure
standard for benzene in soil from zero to two feet below ground surface.
All other 1991 ROD performance standards, including the benzene ground water cleanup criteria,
remained unchanged.
The 1998 ROD Amendment addressed the remedy for the site's contaminated soils and
contaminated ground water. The remedy for the soil contamination addresses the principal threats (i.e.,
areas of the site where soil is known or suspected to contain high concentrations of dissolved and/or free
non-aqueous phase liquid) as well as low level threats at the site by minimizing potential exposure by way
of ingestion, inhalation or direct contact with contaminants and by reducing the potential for the
contaminated soil to act as a continued source for ground water contamination. The remedy for the
ground water contamination addresses the principal risk at the site by minimizing potential exposure by
way of direct contact and ingestion with contaminants and by eliminating the potential for migration of
contaminants to deeper ground water zones.
The 1998 ROD Amendment enhanced the site's remedy by identifying additional soil and ground
water remedy components, which can be used in combination with 1991 ROD, remedy components to
achieve the site's performance standards in compliance with all Federal, state and local applicable or
appropriate requirements. The identification of the additional remedy components used to achieve the
site performance standards is based upon further site characterization, results of field pilot studies, and
the ongoing operation of the pilot systems. The additional soil and ground water remedy components
include:
X in-situ aquifer bioremediation;
X bioventing;
X aqueous phase soil bioremediation;
X soil excavation and off-site treatment and/or disposal;
X soil excavation and biotreatment;
X thermal desorption;
X soil washing;
X containment (e.g., living cap);
X monitored natural attenuation; and
X institutional controls.
Remedy components identified in the 1991 ROD include:
X soil vapor extraction;
X containment (e.g., traditional synthetic liner cap);
X selected directional containment (e.g., slurry wall);
X installation of storm water management controls;
X monitoring ground water; and
X the restoration of the site surface upon completion of the remedial action.
The primary remedy treatment components addressing site contamination are soil vapor extraction and
in-situ aquifer bioremediation. The field pilot studies have shown that a flexible approach is an effective
means of addressing the varying geologic conditions at the site and area specific problems. It is
anticipated that to attain the performance standards, the use of the various remedy components in
succession will be required. The use of multiple remedy components maximizes the efficiency of
remedial operations: overtime, treatment technologies such as soil vapor extraction become less
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effective in removing contamination, at which point it is more efficient to change to another, more passive,
technology (e.g., bioventing). The transition from one remedy component (e.g., soil vapor extraction) to a
subsequent remedy component (e.g., bioventing) will generally be determined by progress sampling. In
general, benzene will be the main chemical of concern; the levels of benzene will be measured overtime;
a significant decrease in the time rate removal of benzene will indicate a remedy component change.
The ROD Amendment describes in more detail the use of various technologies in different areas of the
site.
The September 2006 ROD Amendment addresses the following modifications to the previous 1991 ROD
and the 1998 ROD Amendment:
1.	Documenting that a Technical Impracticability (Tl) determination for restoration of portions of
the shallow ground water at the site (the S1 sand and the deeper S2 sand) has been made for
the site.
2.	Expanding the scope of the remediation to include an additional contaminant source area
designated as the County Road (CR) 126 West Area (a.k.a. Far West Road Area).
3.	Identifying the remedy for the CR 126 West Area.
4.	Identifying factors which support granting a Tl waiver for the Main Waste Area, the West Road
Area, the Office Trailer Area, the Easement Area, and the CR 126 West Area.
5.	Presenting MW-109 Area information, although no remedial decisions for this area are being
made at this time because further investigations should be conducted.
6.	Amending the site's ground water cleanup levels.
7.	Amending the site's soil cleanup criteria.
8.	Amending the remedy for the Bayou Disposal Area.
9.	Amending the remedy for the Main Waste Area's on-site soils vault.
10.	Designating that the exact boundaries of the Tl Zones will be established after a two-year
transitional monitoring period. The two-year monitoring period will also be used to determine
whether the selected remedy is effective to prevent contaminants with concentrations
exceeding the groundwater protection standards from migrating beyond the S1 and S2 Tl zone
boundaries
11.	Identifying contingency remedies for the site in the event that future groundwater monitoring
demonstrates that the plumes of contaminated ground water are expanding in either the S1 or
S2 sand. These contingency remedies could be implemented, if necessary, at any of the
impacted areas throughout the site.
The 2006 ROD Amendment identified the need for further evaluation of the area surrounding monitoring
well (MW) 109 (the MW-109 Area) and the possible need to conduct remedial action in this area.
Groundwater sampling of MW-109 conducted during the period of August 2000 through May 2005 found
elevated contaminant concentrations of benzene which was previously undetected. Further evaluation in
2007 indicated an estimated volume of impacted soil of 2,388 cubic yards in the MW-109 Area. Due to
this increase in contaminated soil volume and the additional costs involved to remediate the MW-109
Area, compared to what was identified in the 2006 ROD Amendment, EPA issued an Explanation of
Significant Different (ESD) in September 2010 to document this significant change related to the remedy
for the Site. The ESD documents the decision to conduct remedial action of the contaminated soil at the
MW-109 Area of the Site using In-Situ Chemical Oxidation (ISCO), which was the remedy selected in the
2006 ROD Amendment, followed by excavation with bio-treatment, which was selected as a remedy for
Site contamination in the 1998 ROD Amendment, and to install three new monitoring wells in the MW-109
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Area as part of the existing Site groundwater remedy.
The Tl Zone document for the EPEC's Far West Road Area was finalized after a two year transitional
monitoring period and the ESD was signed in August 2012. A separate ESD for the Lyondell Trust's
properties to document the Tl Zone was also signed in August 2012.
Community Involvement 	
•	Community Involvement Plan: Developed 8/85, revised 11/89
•	Open houses and workshops: 12/84, 11/85, 3/89, 4/91, 6/91, 2/96, 7/00, 11/00
•	Proposed Plan Fact Sheet and Public Meeting: 11/86 (FPR), 6/91 (Source)
•	ROD Fact Sheet: 3/87 (FPR), 9/91 (Source), 5/06 (Source and Groundwater)
•	Milestone Fact Sheets: 10/86, 7/87, 12/87, 7/88, 1/89, 11/90 (TWC), 05/91, 08/95, 09/99
•	Proposed ROD Amendment fact sheet (10/97) and public meeting (11/97), 4/06, 9/07
•	Public Open House: (3/24/10) (for MW-109 area remediation, CR-126 Road resurfacing, and Turtle
Bayou Bridge Channel Optimization Evaluation)
•	Constituency Interest: Site-area residents are concerned about site contamination, property values,
and maintenance of CR 126.
•	Site Repository: Liberty Municipal Library, 1710 Sam Houston Avenue, Liberty, TX 77575
Technical Assistance Grant 	
•	Letters of Intent Received: None
•	Grant Award: N/A
•	Current Status: No apparent citizen interest in applying for the grant.
Contacts
Remedial Project Manager:
EPA Regional Public Liaison:
Community Involvement Coordinator:
State Contact: (TCEQ)
Attorney:
Prime Contractors:
Raji Josiam, (214) 665-8529, Mail Code: 6SF-RA
Donn R. Walters, (214) 665-6483
Stephen Harper (214) 665-2727
Audrey Smith, (713) 767-3721
Anne Foster, (214) 665-2169
EA Engineering, Science, and Technology Inc.
EPA Toll Free Telephone No. 1-800-533-3508
Information Repository
Liberty Municipal Library
1710 Sam Houston Ave.
Liberty, Texas 77575
Phone Number: (936) 336-8901
M-TH: 10:00 am - 6:00 pm;
Fr: 1:00 pm - 5:00 pm
Sa: 10:00 am - 4:00 pm
Texas Commission on Environmental Quality
Records Management Center
Building E, Records Management First Floor
12100 Park 35 Circle
Austin, Texas 78753
Phone number 1-800-633-9363 or 512-239-2920
M - Fr: 8:00 am - 5:00 pm
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