SECOND FIVE-YEAR REVIEW REPORT FOR
JASPER CREOSOTING COMPANY, INC. SUPERFUND SITE
JASPER COUNTY, TEXAS
SEPTEMBER 2018
The photos above show excavation of contaminated soil during the Site's 2006 removal action (left) and the
cap of the Site's Resource Conservation and Recovery Act (RCRA) containment cell (RCC) in 2017 (right).
Prepared by
U.S. Environmental Protection Agency
Region 6
Dallas, Texas
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SECOND FIVE-YEAR REVIEW REPORT
JASPER CREOSOTING COMPANY, INC. SIJPKRFIJND SITE
EPA ID#; TXD008096240
JASPER COUNTY, TEXAS
This memorandum documents the U.S. Environmental Protection Agency's performance, determinations and
approval of the Jasper Creosoting Company, Inc. Superfund site (Site) second five-year review (FYR) under
Section 121 (c) of the Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.
Code Section 9621 (c), as provided in the attached Second FYR Report.
Summary of the Second Five-Year Review Report
Between 1946 and 1986, wood-treating operations at the Site contaminated soil, sediment, groundwater and
surface water. Three EPA removal actions between 1996 and 2006 addressed immediate threats. EPA selected
the Site's long-term remedy in the Site's 2006 Record of Decision (ROD). The remedy included excavation
of contaminated soil and sediment from the former process area, drainage ditch and waste cell; removal of
contaminated surface water and sediment from the forested wetland; construction of a Resource Conservation
and Recovery Act (RCRA) containment cell (RCC); and consolidation of contaminated site media in the
RCC. It also included construction and operation of a dense non-aqueous phase liquid (DNAPL) recovery
system and a hydraulic containment system; establishment of a Technical Impracticability Zone (TIZ) that
identifies'the area where restoration of groundwater quality to drinking water standards has been determined
to be impracticable; and establishment of a designated Plume Management Zone (PMZ). The remedy also
includes long-term monitoring and institutional controls to prevent exposure to contaminated soil and
groundwater and to maintain the integrity of the remedy.
EPA documented the completion of remedy construction in the Site's Preliminary Close-Out Report in
September 2008. The Site is not in use and there are no complete exposure pathways at the Site. EPA is -
currently evaluating options to optimize the Site's groundwater remedy. For the remedy to be protective over
the long term, the issues identified in this FYR need to be addressed.
Environmental Indicators
Human Exposure Status; Current human exposures at the Site are under control.
Contaminated Groundwater Status: Groundwater migration is under control. .
Site-Wide Ready for Reuse: Yes
Actions Needed
The following actions must be taken for the remedy to be protective over the long term:
1) Continue ongoing evaluation of remedy optimization options to address remedial performance issues
identified in this FYR and implement the selected optimization strategy. .
2) Evaluate groundwater preliminary remedial goals (PRGs) for naphthalene and 2-methylnaphthalene to
determine if they remain valid and protective of human health and consider whether the TIZ should be
expanded.
3) Evaluate surface water PRGs for benzo(a)anthracene, benzo(b)fluoranthene, dibenz(a,h)anthracene,
indeno(l,2,3-cd)pyrene, benzene and pentachlorophenol (PCP) to determine if they remain valid and
protective of human health and ecological receptors.
4) Continue to routinely monitor surface water in the forested wetland. If surface water contaminant of
concern (COC) concentrations continue to exceed PRGs, take actions as needed to prevent human exposure to
forested wetland surface water and to prevent the discharge of surface water to Sandy Creek at concentrations
above surface water PRGs.
5) Ensure that laboratory reporting limits are low enough to assess the achievement of groundwater and
surface water PRG concentrations.
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Ik-termination
I have determined that the remedy for the Jasper Creosoting Company, Inc. Superfimd site is currently
protective of human health and the environment. This Five-Year Review Report specifies the actions that
need to be taken for the remedy to remain protective over the long term.
Carl E. Edlund, P.E. Date
Director, Superfund Division
U.S. Environmental Protection Agency, Region 6
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CONCURRENCES
SECOND FIVE-YEAR REVIEW REPORT
JASPER CREOSOTING COMPANY, INC, SUPERFUND SITE
EPA ID#: TXD008096240
JASPER COUNTY, TEXAS
' La " ' ( c->
Robert SullivadS^^ Date
Remedial Project Manager
> /( -..i ¦ ./¦ t. _ ^ /S'l/iJi
ni
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ISSUES/RECOMMENDATIONS
SECOND FIVE-YEAR REVIEW REPORT '
JASPER CREOSOTING COMPANY, INC. SUPERFUND SITE
EPA ID#: TXD008096240
JASPER COUNTY, TEXAS
OU(s): 1
Issue Category: Remedy Performance
Issue: To achieve groundwater remedial action objectives (RAOs) established in
the Site's Record of Decision (ROD), non-aqueous phase liquid (NAPL) recovery
efforts may need to be expanded. In addition, the treatment system is no longer
recovering dense non-aqueous phase liquid (DNAPL).
Recommendation: Continue ongoing evaluation of remedy optimization options
to address remedial performance issues identified in this FYR and implement the
selected optimization strategy.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party/Support
Agency
Milestone Date
No
Yes
EPA
EPA
9/6/2020
OU(s): 1
Issue Category: Monitoring
Issue: Based On current toxicity values, the risk-based groundwater preliminary
remedial goal (PRG) established by the ROD for naphthalene falls outside of
EPA's acceptable risk management range of 1 x 10~6 to 1 x 10"4, Risk-based
groundwater PRGs for naphthalene and 2-methylnaphthalene also result in hazard
quotients (HQs) that exceed EPA's benchmark of 1 for noncarcinogens.
Recommendation: Evaluate groundwater PRGs for naphthalene and 2-
inethylnaphthalene to determine if they remain valid and protective of human
health and consider whether the Technical Impracticability Zone (TIZ) should be
expanded.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party/Support
Agency
Milestone Date
No
Yes
EPA
EPA
9/6/2020
OU(s): 1
Issue Category: Monitoring
Issue: Current surface water standards for benzo(a)anthracene,
benzo(b)fluonmthene, dibenz(a,h)anthracene, indeno( 1,2,3-cd)pyrene, benzene
and PCP are more stringent now than at the time of the ROD'S issuance. Surface
water PRGs for those constituents may no longer be valid.
Recommendation: Evaluate surface water PRGs for benzo(a)anthracene,
benzo(b)fluoranthene, d i ben z(a,h) a nth ra ccne, indeno( 1,2,3-cd)pyrene, benzene
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and pentachlorophenol (PCP) to determine if they remain valid and protective of
human health and ecological receptors.
Affect Current
Proteetiveness
Affect Future
Proteetiveness
Party
Responsible
Oversight
Party/Support
Agency
Milestone Date
No
Yes
EPA
EPA
9/6/2020
OU(s): 1
Issue Category: Monitoring
Issue: In January 2017, benzo(b)fluoranthene, benzo(k)fluoranthene and
indeno(l,2,3-cd)pyrene were detected in a forested wetland surface water sample
at concentrations slightly above surface water PRGs,
Recommendation: Continue to routinely monitor surface water in the forested
wetland. If surface water contaminant of concern (COC) concentrations continue
to exceed PRGs, take actions as needed to prevent human exposure to forested
wetland surface water and to prevent the discharge of surface water to Sandy
Creek at concentrations above surface water PRGs.
Affect Current
Proteetiveness
Affect Future
Proteetiveness
Party
Responsible
Oversight
Party/Support
Agency
Milestone Date
No
Yes
EPA
EPA
9/6/2019
OU(s): 1
Issue Category: Monitoring
Issue: Laboratory reporting limits used for some groundwater and surface water
constituents are higher than PRGs established for those constituents.
Recommendation: Ensure that laboratory reporting limits are low enough to
assess the achievement of groundwater and surface water PRG concentrations.
Affect Current
Proteetiveness
Affect Future
Proteetiveness
Party
Responsible
Oversight
Party/Support
Agency
Milestone Date
No
Yes
EPA
EPA
9/6/2019
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Table of Contents
LIST OF ABBREVIATIONS AND ACRONYMS 3
I, INTRODUCTION ................. 4
Site Background 4
FIVE-YEAR REVIEW SUMMARY FORM.,..,,.,.,,,,,., ............. 5
II, RESPONSE ACTION SUMMARY 7
Basis for Taking Action 7
Response Actions 7
Status of Implementation 9
Systems Operations/O&M 15
III, PROGRESS SINCE THE PREVIOUS REVIEW 16
IV, FIVE-YEAR REVIEW PROCESS 20
Community Notification, Community Involvement and Site Interviews... 20
Data Review 20
Site Inspection 26
V, TECIINICAL ASSESSMENT 26
QUESTION A: Is the remedy functioning as intended by the decision documents? 26
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the
remedy selection still valid? 27
QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy? - 28
VI, ISSUES/RECOMMENDATIONS 29
OTHER FINDINGS 30
VII, PROTECTIVENESS STATEMENT..,.....,. 31
VIII, NEXT REVIEW. 31
APPENDIX A - REFERENCE LIST A-l
APPENDIX B - SITE CHRONOLOGY ........................... B-l
APPENDIX C - INSTITUTIONAL CONTROLS C-l
APPENDIX D - PRESS NOTICE D-l
APPENDIX E - INTERVIEW FORMS E-l
APPENDIX F - ADDITIONAL FIGURES AND 2016 MONITORING RESULTS 11
APPENDIX G - SITE INSPECTION CHECKLIST .G-l
APPENDIX H - REMEDIAL ACTION AND SITE INSPECTION PHOTOS ! H-l
APPENDIX I - ARARS REVIEW .................................1-1
APPENDIX J - TOXICITY REVIEW .J-l
Table 1: COCs and PRGs for Contaminated Site Media 8
Table 2; Summary of Institutional Controls (ICs) 13
Table 3: Annual TCEQ O&M Costs, 2013 to 2017 15
Table 4: Annual LTRA Costs, 2013 to 2016 16
Table 5: Protectiveness Determination/Statement from the 2013 FYR Report 17
Tabic 6: Status of Recommendations from the 2013 FYR Report 18
Tabic 7: 2016 Exceedances of Groimdwater-to-Surface Water PRGs for Well MW-18-2 22
Table B-l: Site Chronology B-l
Table F-l: TPAH Concentrations in Groundwater, 2008 to 2016 12
Table F-2: VOC and SVOC Concentration in Groundwater, 2016 14
Table F-3: Surface Water Monitoring Results, 2016 13
Table 1-1: Groundwater ARAR Comparison 1-1
Table 1-2: Surface Water ARAR and Cleanup Goal Review 1-2
Table J-l: Review of Surface Soil PRGs - Human Health Direct Contact J-l
1
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Table J-2: Review of Groundwater PRCs j_2
Figures
Figure 1: Site Vicinity Map 6
Figure 2: Site Layout and Key Remedial Features 11
Figure 3: Institutional Control Map 14
Figure 4: Groundwater Monitoring Well Network 24
Figure 5: Groundwater Monitoring Well Network and 2006 Naphthalene Plume Boundary 25
Figure C-l: PMZ Registration Letter C-l
Figure C-2: PMZ Survey and Legal Description, Q.3
Figure C-3: Jasper Code of Ordinances: Water Wells C-6
Figure C-4: Jasper Code of Ordinances: Contaminated Wells C-7
Figure C-5: 2014 TRRP Deed Notice for the Main Site Property C-10
Figure C-6: Excerpts From a 2014 TRRP Restrictive Covenant for an Off-Site Property C-27
Figure F-1: Surface Water Monitoring Locations 11
2
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list of abbreviations and acronyms
ARAB. Applicable or Relevant and Appropriate Requirement
BNSF Burlington Northern Santa Fe
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CM T Continuous Multichannel Tube
COC Contaminant of Concern
DNAPL Dense Non-Aqueous Phase Liquid
EPA United States Environmental Protection Agency
FYR Five-Year Review
HQ Hazard Quotient
IXS Leachate Collection System
LDS Leachate Detection System
LNAPL Light Non-Aqueous Phase Liquid
LIRA Long- Term Response Action
MCL Maximum Contaminant Level
Hg/L Micrograms per Liter
mg/kg Milligrams per Kilogram
MNA Monitored Natural Attenuation
MW Monitoring Well
NA Not Applicable
NAPL Non-Aqueous Phase Liquid
NCP National Contingency Plan
NPL National Priorities List
O&M Operation and Maintenance
OLf Operable Unit
PAH Polycyclic Aromatic Hydrocarbon
PCP Pentachlorophenol
PMZ Plume Management Zone
POTW Publicly-Owned Treatment Works
PRG Preliminary Remedial Goal
RAO Remedial Action Objective
RCC RCRA Containment Cell
RCRA Resource Conservation and Recovery Act
RI Remedial Investigation
Rl/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
RPM Remedial Project Manager
RSL Regional Screening Level
SVOC Semi-Volatile Organic Compound
TarGOST Tar-Specific Green Optical Screening Tool
TCEQ Texas Commission on Environmental Quality
TDLR Texas Department of Licensing and Regulation
TEQ Toxic Equivalency
TI Technical Impracticability
TIZ Technical Impracticability Zone
TPAH Total PAH
TRRP Texas Risk Reduction Program
UU/UE Unlimited Use and Unrestricted Exposure
VOC Volatile Organic Compound
3
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I. INTRODUCTION
The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to
determine if the remedy is and will continue to be protective of human health and the environment. The methods,
findings and conclusions of reviews are documented in FYR reports such as this one. In addition, FYR reports
identify issues found during the review, if any, and document recommendations to address them.
The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National
Contingency Plan (NCP) (40 CFR Section 300.430(f)(4)(ii)), and considering EPA policy.
This is the second FYR for the Jasper Creosoting Company, Inc. Supeifund site (the Site). The triggering action
for this statutory review is the completion date of the previous FYR. The FYR has been prepared because
hazardous substances, pollutants or contaminants remain at the Site above levels that allow for unlimited use and
unrestricted exposure (UU/UE).
The Site consists of one operable unit (OU), which is addressed by this FYR. The OU addresses contaminated
soil, sediment, surface water and groundwater.
EPA remedial project manager (RPM) Robert Sullivan led the FYR. Participants included Texas Commission on
Environmental Quality (TCEQ) project manager Andy Bajwa, Terry Andrews and Xiaoxia Lu from TCEQ,
Darren Davis from EPA remedial contractor CH2M HILL, and Melissa Oakley and Brice Robertson from EPA
FYR support contractor Skeo. The review began on 11/1/2017.
Site Background
The 11,3-acre area is a former wood-treating facility located at 601 North McQueen Street in Jasper, Texas
(Figure 1). Wood-treating processes took place at the Site between 1946 and' 1986. Coal tar creosote and
pentachlorophenol (PCP) dissolved in diesel were used to treat railroad ties and utility poles. Site operations
included drying freshly-treated wood over a drip pad, storage of wood-treating chemicals and treated wood, and
discharge of process wastewater into a drainage ditch along the eastern edge of the Site (Figure 1). Improper
waste management and disposal practices resulted in the release of creosote, a listed hazardous waste, into soil,
groundwater, surface water and sediment at and downgradient of the Site.
The Site is not currently in use. Current site features include a fenced Resource Conservation and Recovery Act
(RCR A) containment cell (RCC), a fenced groundwater treatment plant and associated remedial infrastructure.
McQueen Street borders the Site to the west. Burlington Northern Santa Fe (BNSF) railroad tracks and a forested
wetland border the Site to the east. State highway FM 776 borders the Site to the south. An inactive industrial
property borders the Site to the north. Surrounding land uses include industrial, commercial and residential areas
(Figure 1)., The forested wetland area is the discharge point for surface water treated by the Site's water treatment
plant. Surface'water from the forested wetland area discharges to Sandy Creek,
The Site is underlain by alluvium extending to a depth of 150 feet. The alluvium consists of three primary zones:
Permeable Zone P-l (ground surface to 32 feet below ground surface), Low Permeable Zone 1-2 (32 to 38 feet
below ground surface), and Permeable Zone P-3 (38 to 150 feet below ground surface). Zone 1-2 is discontinuous
along the southeast portion of the former process area, facilitating contaminant transfer from Zone P-l to P-3.
Groundwater is present in Zones P-l and P-3. Zone P-3 is the primary zone for groundwater flow and
contaminant transport. Groundwater at the Site generally flows to the southeast. The nearest active water supply
well is Jasper municipal well #6 (CWA-6), located 0,7-mile southeast (downgradient) of the Site,1 This well
draws water from between 416 and 767 feet below ground surface. Multiple clay units between Zone P-3 and the
uppermost screened section of CWA-6 serve as barriers to vertical contaminant migration from the Site.
1 On March 30, 2006, TCEQ performed a door-to-door survey of a 200-acre area southeast of the Site. It confirmed that there
was no residential use of groundwater between the Site and CWA-6 at that time.
4
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Sandy Creek is the nearest surface water feature; it is located about 1,200 feet southeast and downgradient of the
former process area (Figure 1), A significant upward vertical gradient present at the creek near the intersection of
Sandy Creek and FM 776 promotes upward groundwater flow and contaminant transport from Zone P-3 into
Sandy Creek. Appendix A includes a list of documents reviewed during this FYR. Appendix B provides a
chronology of site events.
FIVE-YEAR REVIEW SUMMARY FORM
5
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Figure 1: Site Vicinity Map
Disclaimer; This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational
purposes only regarding CPA's response actions at the Site.
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6
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II. RESPONSE ACTION SUMMARY
Basis for Taking Action
A 1981 investigation linked facility operations to a fish kill in Sandy Creek. In March 1982, the Texas
Department of Water Resources ordered Jasper Creosoting Company to stop discharging to the drainage ditch. In
1983, the same agency detected elevated concentrations of PCP and wood-treating chemicals in surface water
samples collected from the drainage ditch and Sandy Creek. The company shut down its wood-treating operations
and abandoned the facility in 1992.
In August 1995, a removal assessment by EPA's Technical Assessment Team addressed on -site contaminant
sources associated with the process area and surface impoundment. EPA identified the potential for rupture or
spills of liquid creosote or PCP into the drainage ditch, wetland and Sandy Creek from aboveground storage tanks
as an immediate threat. EPA placed the Site on the Superfund program's National Priorities List (NPL) hi July
1998.
EPA performed a risk assessment as part of the Site's 2004 remedial investigation/feasibility study (Rl/FS) and
updated it with data collected during the 2006 supplemental RI. The risk assessment determined that the principal
threats posed by hazardous substances at the Site included direct contact with contaminated soil and sediment,
ingestion of contaminated groundwater by future residents and ecological receptor exposure to contaminated
groundwater that discharges to Sandy Creek. Primary contaminants of concern (COCs) identified by the risk
assessment include polycyclic aromatic hydrocarbons (PAHs), PCP, benzene and dioxins.
Response Actions
Between 1996 and 2006, EPA conducted three removal actions at the Site. The 1996 removal action included
removal and off-site disposal of site structures, equipment and heavily-contaminated soil. EPA excavated and
expanded an area encompassing the footprint of a former impoundment for use as a temporary on-site waste cell
and installed a fence around it. Between November 1999 and January 2000, EPA conducted the second removal
action, which included stabilization of the waste cell, removal of creosote-soaked lumber and installation of
surface water diversions along the Site's southeast edge. The third removal action took place between July 2005
and March 2006. It addressed imminent threats posed by creosote-contaminated soil and sediment identified
during the Site's 2004 Rl/FS. The removal action implemented components of the remedy for contaminated soil
and sediment later selected in the Site's 2006 Record of Decision (ROD). Implementation of those remedial
components is discussed in the Status of Implementation section. The Site's first FYR Report provides detailed
information about the removal actions.
EPA selected a remedy to address soil, sediment, surface water and groundwater contamination in the Site's 2006
ROD. The ROD identified the following remedial action objectives (RAOs):
• Prevent direct human (industrial site workers) contact with surface soil containing COCs at
concentrations above surface soil preliminary remedial goals (PRCs).
• Prevent COCs from leaching into groundwater from the surface and subsurface soils that contain COCs at
concentrations above the respective PRGs. Prevent the increase in COC concentrations within the existing
groundwater plume that would result from such leaching.
• Prevent exposure to groundwater containing concentrations of COCs above groundwater PRGs and
reduce the quantity of non-aqueous phase liquid (NAPL) in the saturated zone to the extent practicable.
• Prevent plume expansion and prevent migration of COCs from groundwater into Sandy Creek surface
water, which could result in surface water COC concentrations above surface water PRGs.
• Prevent direct contact of adolescent recreational users with the wetland surface water and prevent
discharge of water containing COCs at concentrations above surface water PRGs into Sandy Creek.
The selected remedy included the following primary components;
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• Construction of the RCC in the process area south of the waste cell to contain the soil and sediment
excavated from the Site,
• Excavation of contaminated soil containing COCs exceeding human health PRGs in the waste cell,
former process area, drainage ditch and creosote-contaminated sediment in the wetland water inlet area,
and disposal of the excavated media in the RCC.
• Backfilling of excavations with clean soil or soil below PRGs and revegetation of the backfilled areas.
• Monitored natural attenuation (MNA) for remaining ecological PRG exceedanees in wetland area
sediment.
• Removal of contaminated surface water in the wetland area and treatment with granular activated carbon
prior to discharge into Sandy Creek.
• Monitoring of the RCC cover.
• Implementation of institutional controls to protect the integrity of the RCC and to maintain a future
industrial or commercial land use scenario for on-site and off-site properties affected by site-related
contamination.
• Construction and operation of a dense non-aqueous phase liquid (DNAPL) recovery system to remove
free-phase and mobilized DNAPL from Zones P-1 and 1-2 to the extent practicable.
• Construction and operation of a hydraulic containment system to prevent expansion of the dissolved-
phase plume and contaminated groundwater entry to Sandy Creek.
• Application of a Technical Impracticability (TI) waiver to waive the maximum contaminant levels
(MCLs) and/or groundwater PRGs and establishment of a TI Zone (TIZ) that identifies the area where
restoration of groundwater quality to drinking water standards has been determined to be impractical.
• Establishment of a designated Plume Management Zone (PMZ) to restrict groundwater use within and
adjacent to the TIZ.
• Implementation of institutional controls to restrict future groundwater use within the TIZ and PMZ.
• Long-term groundwater monitoring to evaluate remedy effectiveness, quantify the natural attenuation rate
and verily management of contaminated groundwater within the PMZ.
Table 1 lists the COCs and PRGs for contaminated media at the Site identified in the 2006 ROD.
Table 1: COCs aiid PRGs for Contaminated Site Media
CO< 1
Surface Soil
PRG" (mg/kg)
Subsurface
Soil-to- Groundwater
Groundwater I'RG'1 (jig/L)
PRGC (mg/kg)
Grouudvvater-
to-Surfacc
Water
Protection
PRGc(ug/L)
Surface Water
PRC (fig/L)f
Metals
Arsenic
NA
NA
10*
NA
NA
Iron-
NA
NA
4,240
NA
NA
Thallium
NA
NA
2*
NA
NA
Vanadium
NA
NA
14
NA
NA
PA lis
Acenaphthene
34
34
130
153
23
Benzo(a)anthracene
21
34
0.085
5.4
0.81
Benzo(a)pyrene
2.1
92
0.2*
0.093
0.014
Benzo(b)fluoranthene
21
115
0.05
0.093
0.014
Benzo(k)fluoranthene
210
295
12
0.093
0.014
Chrysene
52
52
8.5
46.7
7
Dibenz(a,h)anthracene
2.1
183
0.12
1.2
0.18
Indeno( 1,2,3-c,d)pyrene
21
333
0.05
0.093
0.014
Naphthalene
240
240
100
1,667
250
Phenanthrene
82
82
290
200
30
Others
2,4-DimethylphenoI | 4.2
4.2
250
700
105
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2-Methylnaphthalene
76
76
57
420
63
Benzene
0.21
0.21
5*
707
106
Carbazole
21
21
43
379
56.8
Cresols, M- & P-
3.6
3.6
710
1,813
272
Dibenzofuran
47
47
4.3
493
74
Pentachlorophenol
6.2
6.2
1*
34.9
5.23 ¦
Xylene, U- & P-
61
61
10,000*
8,933
1,340
2,3,7,8-TCDD (TEQ)
0.00052
NA
NA
. NA
NA
Notes:
a. COCs as established in the 2006 ROD. The 2006 ROD adopted the PRGs listed in its RAOs and remedial goals
section as the final remedial goals. The ROD refers to the values as PRGs throughout the document. Therefore, the
final remedial goals for site media are presented as PRGs in this table and throughout this FYR Report.
b. The ROD established risk-based soil PRGs based on a future industrial land use scenario. Surface soil PRGs were
determined by selecting the lower values of direct contact PRGs and soil-to-groundwater protection PRGs.
c. The ROD developed soil-to-groundwater protection PRGs to ensure that the leaching of COCs from contaminated
soil into groundwater does not result in an increase of COC concentrations in the existing groundwater plume. Soil-
to-groundwater protection PRGs were selected as subsurface soil PRGs because soil to groundwater is the only
exposure pathway of concern for subsurface soil.
d. Since groundwater is a potential future drinking water source, the ROD developed groundwater PRGs, which
include both MCLs and risk-based values, based on a drinking water scenario.
e. The ROD developed groundwater-to-surface-water PRGs to ensure that the migration of COCs from groundwater to
surface water will not result in surface water PRO exceedances.
f. Surface water PRGs are the lower of two surface water screening values (human health and ecological health).
Human health values were selected with the following hierarchy - Texas Surface Water Quality Standards (30 TAC
§307) and then National Recommended Ambient Water Quality Criteria - and calculated according to the TCEQ
guidance document Determining Protective Concentration Levels for Surface Water and Sediment. Ecological
screening values come from the TCEQ guidance document Guidance for Conducting Ecological Risk Assessments
at Remediation Sites in Texas (2006 revision) or were developed according to the method provided in the guidance.
* The PRG is the MCL. Groundwater PRGs without asterisks were calculated based on risk.
NA = not applicable
mg/kg = milligrams per kilogram
|ig/L = micrograms per liter
TEQ = toxic equivalency
Status of Implementation
The 2005-2006 removal action implemented components of the selected remedy for contaminated soil and
sediment, as described in the 2006 ROD. EPA excavated contaminated soil and sediment from the former process
area, drainage ditch and waste cell. Cleanup also included removal of contaminated surface water and sediment
from the wetland water inlet area in the southwest part of the forested wetland. EPA disposed of 61,000 cubic
yards of contaminated media in the on-site RCC. The RCC's construction included subgrade preparation, liner
system construction, primary and secondary leachate collection systems, and a final cover system. Following the
removal action, residual COCs in wetland sediment no longer posed unacceptable risks to human health or
ecological receptors. Therefore, according to the ROD, the wetland cleanup resulted in the removal of the MNA
requirement for wetland sediment. EPA's 2010 Interim Groundwater Remedial Action Completion Report
documented that: the removal actions eliminated the immediate threat at the Site posed by soil, sediment and
surface water contamination.
In September 2007, EPA approved the Site's final remedial design and remedial action work plan. EPA remedial
contractor CH2M HILL started remedial action in January 2008. Construction of the DNAPL recovery system
and hydraulic containment system included installation of new extraction and recovery wells, construction of a
water treatment system and building, and installation of infiltration trenches and a surface water discharge pipe to
allow overflow from the infiltration trenches to a nearby surface water discharge ditch.
In August 2008, EPA performed start-up testing of the groundwater extraction and treatment system. The goal of
the treatment system is to remove contaminants from groundwater so that remaining concentrations are less than
9
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the groundwater and surface water PRGs. The system was also designed to remove free-phase and residual
DNAPL beneath the former facility process area by periodically pumping total fluids (groundwater and DNAPL)
from a recovery trench at the base of Zone P-l, EPA completed construction of the groundwater remedy in
September 2008. Full-scale system operations began in December 2009 and are ongoing. Figure 2 shows the
Site's current layout and key remedial features, including the groundwater treatment plant.
Due to the presence of free-phase and residual DNAPL in permeable and less permeable zones, the ROD
determined that restoring groundwater quality to drinking water standards within a reasonable period was
technically impracticable. As required by the ROD, EPA defined a TIZ that identifies the area where restoration
of groundwater quality to drinking water standards has been determined to be impracticable. Therefore,
restoration of groundwater quality to drinking water standards within the TIZ is not required by the ROD. Figures
2 and 3 show the horizontal extent of the TIZ. The TIZ is vertically defined as the groundwater present in Zones
P-l and P-3 from ground surface to depths of about 150 feet (on site) and 130 feet (off site) below ground surface.
As required by the ROD, EPA also established a PMZ, which encompasses the TIZ, to ensure that future
groundwater pumping does not mobilize contaminants beyond the TIZ (Figure 2). The PMZ encompasses an area
of about 25 acres. The Institutional Control Review section provides more information regarding the PMZ. EPA's
long-term groundwater monitoring program evaluates the effectiveness of the remedy and verifies that
groundwater contaminated with COC concentrations greater than remedial goals is hydraulieally contained within
the PMZ.
In August 2008, EPA and TCEQ conducted a final site inspection. EPA documented the completion of remedy
construction in the Site's Preliminary Close-Out Report in September 2008.
There is uncertainty concerning the effectiveness of the hydraulic plume containment system. In particular,
emulsified oil and light non-aqueous phase liquid (LNAPL), not originally identified during the RI, are
complicating remedial efforts. The treatment system is not currently configured to separate oil and water. As of
January 2018, the treatment plant treats dissolved-phase contaminated groundwater and recovered LNAPL. The
system is no longer recovering DNAPL because the extraction wells can no longer reach the DNAPL. EPA is
considering different options to optimize these components of the groundwater remedy. The Systems
Operations/Operation and Maintenance (O&M) section provides additional information.
10
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Figure 2: Site Layout and Key Remedial Features
0 125 250
500
I Feet
Sources; Esri, DigitalGlobe,
GeoEye, Earthstar Geographies,
CNES/Airbus DS, USDA, USGS,
AeroGRID, IGN, the GIS User
Community and CH2M HILL.
Legend
Former Jasper Creosoting
Company Facility Boundary
Technical Impracticability
L...J zone
Plume Management Zone
RCRA Containment Cell
=¦=* Stormwater Ditch
^ Groundwater Treatment
* Plant
^ Skeo
Jasper Creosoting Company, Inc. Superfund Site
City of Jasper, Jasper County, Texas
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational
purposes only regarding F.PA's response actions at the Site.
11
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Institutional Control (IC) Review
The ROD requires institutional controls for the PMZ, including enforceable deed notices or restrictive covenants,
to eliminate the potential groundwater exposure pathway by preventing construction of water supply wells in the
PMZ. It also requires institutional controls to maintain the integrity of the RCC and to restrict future land uses at
the Site and at contaminant-impacted off-site properties to commercial and industrial uses. Except for the railroad
right of way, all contaminated soil is contained on site, within the former facility boundary; therefore, land use
restrictions are not needed for off-site properties affected only by groundwater contamination. In July 2012, EPA
submitted a PMZ/TIZ registration letter to the City of Jasper, the Texas Department of Licensing and Regulation
(TDLR), and the Southeast Texas Ground Water Conservation District (Appendix C, Figure C-l). As part of the
letter, EPA included a surveyed map and legal description of the PMZ (Figure C-2). The ROD states that, prior to
drilling new water wells within the PMZ, drillers must get a drilling permit from TDLR's Water Well
Driller/Pump Installer Section. The Jasper Code of Ordinances, Chapter 26, Subsection 31 states that it is
unlawful for any person to drill a well without a city-issued permit (Figure C-3), The Jasper Code of Ordinances,
Chapter 26, Subsection 51 also requires the plugging or sealing of contaminated wells, as appropriate, inside or
within a mile of the city, to protect the public water supply (Figure C-4),
In May 2014, the TCEQ received signed Texas Risk Reduction Program ( I'RRP) restrictive covenants from all
affected property owners and recorded the documents with the Jasper County Clerk's Office. For off-site
properties in the TIZ and PMZ, the restrictive covenants inform property owners of site-related groundwater
contamination affecting their properties, inform them of site-related maintenance and monitoring requirements,
and prohibit groundwater use. The restrictive covenants also state that they run with the land and that their
removal or modification is prohibited without TCEQ approval. Based on the groundwater data review performed
as part of this FYR, the groundwater use restrictions implemented by the 2014 deed notice (discussed below) and
restrictive covenants, the PMZ/TIZ registration letter, and the two city ordinances cover all areas impacted by
site-related groundwater contamination and meet the ROD's groundwater institutional control requirements.
In May 2014, TCEQ filed a TRRP deed notice with Jasper County for the main site property, which includes the
RCC. The deed notice informs the property owner of site-related contamination on the property and site-related
maintenance and monitoring requirements, and prohibits groundwater use and residential land use. The
maintenance and monitoring requirements ensure the ongoing integrity of the RCC. One of the restrictive
covenants and the deed notice are included in Appendix C (Figures C-5 and C-6), Table 2 summarizes the Site's
institutional controls. Figure 3 shows the properties subject to the 2014 deed notice and restrictive covenants.
The former drainage ditch was previously located within the railroad right of way of an active rail line. The soil
cleanup in the former drainage ditch area left contamination in place that does not allow for UU/UE. Land use
restrictions are not in place for the railroad right of way to prohibit residential use. However, future land use is
expected to remain as a railroad right of way; the area is not appropriate for any type of non-industrial use. If land
use within the railroad right of way changes in the future, the need for land use restrictions for that area will be
reevaluated at that time.
12
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Table 2: Summary of Institutional Controls (ICs)
Media, Engineered
Controls, and Areas
That Do Not
/'¦'¦ICr V/:
ICs Called
for in the
Impacted Areas2
IC
Title of IC Instrument Implemented and Date
Support UUXT
Based on Current
Conditions
Needed
Decision
Documents
Objective
Soil
Yes
Yes
Former Jasper Creosoting
Company facility property, which
includes the RCC and remedial
infrastructure
IC Tract 1 (11.153 acres)
Maintain the integrity of the
RCC and restrict future land
uses at the Site and at
impacted off-site properties
to commercial and industrial
uses.3
TRRP Deed Notice, recorded May 20, 2014
Instrument Number: 256415
(IC Tract I)
Former Jasper Creosoting
Company facility property, IC
Tract 1 and off-site properties
within the TIZ and PMZ:
July 2012 PMZ/TIZ registration letter
Groundwater
Yes
Yes
IC Tract 3 (48.977 acres)
IC Tract 4 (44.810 acres)
IC Tract 5(33.137 acres)
IC Tract 6 (41.662 acres)
IC Tract 7 (1.357 acres)
IC Tract 8 (1.004 acres)
IC Tract 9 (3.07 acres)
Prevent construction of
water supply wells within
the PMZ.
Jasper Code of Ordinances, Chapter 26,
Subsection 31
Jasper Code of Ordinances, Chapter 26,
Subsection 51
Former Jasper Creosoting
Company facility property, IC
Tract 1
Prohibit groundwater use.
TRRP Deed Notice, recorded May 20, 2014
Instrument Number: 256415 (IC Tract 1)
Off-site properties within the TIZ
and PMZ:
IC Tracts 3,4, 5, 6, 7, 8 and 9
Prohibit groundwater use.
TRRP Restrictive Covenants for Environmental
Conditions, recorded May 20,2014
Instrument Numbers:
256418 (IC Tract 3), 256417 (IC Tract 4),
256422 (IC Tract 5), 256419 (IC Tract 6),
256421 (IC Tract 7), 256416 (IC Tract 8) and
256420 (IC Tract 9)
2 There is no IC Tract 2. The Site's TRRP institutional controls are numbered as IC Tracts 1, 3,4, 5, 6, 7, 8 and 9.
3 The ROD requires institutional controls to restrict future land uses at contaminant-impacted off-site properties to commercial and industrial uses. However, with the
exception of the railroad right of way, all contaminated soil is contained on site, within the former facility boundary; therefore, land use restrictions are not needed for off-
site properties affected by groundwater contamination only.
13
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Figure 3: Institutional Control Map
375 750
1,500
Feet
Sources: Esri, DigitalGlobe, GeoEye,
Earthstar Geographies, CNES/Airbus DS,
USDA, USGS, AeroGRID, IGN, the GIS
User Community, CH2M HILL and the
Site's 2014 TRRP Deed Notice and
Restrictive Covenants.
Legend
Property subject to land
I | and groundwater use
restrictions
Properties subject to
XM groundwater use
restrictions
Plume Management Zone
Technical Impracticability
1 1 Zone
'//A RCRA Containment Cell
^ Skeo
Jasper Creosoting Company, Inc. Superfund Site
City of Jasper, Jasper County, Texas
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational
purposes only regarding EPA's response actions at the Site.
ICxTract-3>
xZW \ /\
IC\Tract:4„
IG Tracts
' s\
•IC Tract9
3.07 acres
'IC Tract 7
1.357 acres
IG Tract 8
1.004 acres
^X>IC,Tract Q(
% yAl<662-acres"
Note: There Is no IC Tract 2. The Site's TRRP Institutional controls are numbered as IC Tracts 1, 3, 4, 5, 6, 7, 8 and 9.
14
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Systems Operations/O&M
TCEQ performs O&M activities associated with the RCC. EPA performs activities associated with long-term
response actions (LTRAs). O&M responsibility for the RCC transferred to TCEQ in 2007, TCEQ contracts with
AECOM to perform RCC-related O&M activities at the Site. Current O&M responsibilities include RCC cap
inspection, cap maintenance, leachate collection system (LCS) and leachate detection system (LDS) inspections,
and leachate sampling and disposal. TCEQ's O&M contractor performs O&M activities in accordance with the
Site's 2009 Operations and Maintenance Manual and documents O&M inspections in Annual Reports of Field
Activities. Between 2014 and 2017, no significant O&M issues were noted. O&M inspections since the previous
FYR indicate that the RCC cap is in good condition and covered with healthy, well-established vegetation, with
no cracking or seepage observed. Minor areas of erosion are addressed promptly.
In accordance with the Site's Leachate Removal Work Plan, TCEQ's O&M contractor removes leachate from the
LCS and LDS, analyzes the liquid in the tanks, and then transports the liquid to the Site's treatment system. The
last leachate removal event took place in 2013. It included removal of 20,000 gallons of leachate from the LCS
and 1,200 gallons of leachate from the LDS. TCEQ anticipates performing the next leachate removal event in
2018.
The 2006 ROD estimated total O&M costs of $390,000 for the soil remedy over 30 years, resulting in estimated
annual O&M costs of $13,000. Table 3 shows annual O&M costs incurred by TCEQ since 2013. The high O&M
cost incurred in 2013 can be attributed to the leachate removal event and performance of an institutional control
land survey. The elevated O&M costs in 2014 were associated with the filing of institutional controls and repair
of erosion for the southeast corner of the RCC. Actual O&M costs in 2015,2016 and 2017 were consistent, and
slightly lower than the annual cost estimated by the ROD.
Table 3: Annual TCEQ O&M Costs, 2013 to 2017
Year
Total Cost"
2013
$168,000
2014
$21,000
2015
$11,000
2016
$11,000
2017
$12,000
a Annual O&M totals are rounded to the nearest thousand.
EPA contractor CH2M HILL performs LTRA activities in accordance with the Site's 2009 Operations and
Maintenance Manual. Those activities include operation of the Site's DNAPL recovery and hydraulic
containment systems, and associated monitoring. CH2M HILL documents O&M activities in annual O&M
reports. The information in this section comes from the Site's 2013-2016 annual O&M reports.
System performance monitoring indicates that groundwater extraction wells continue to draw contaminant mass
from the subsurface. Operation of the groundwater extraction system between September 2008 and December
2016 withdrew about 2,409 gallons of DNAPL and 87.5 million gallons of contaminated groundwater. However,
total PAH (TPAH) concentrations in Zone P-3 have not decreased. The recovery of DNAPL from Zone P-l has
not significantly reduced PAH concentrations in Zone P-3 groundwater, indicating that the NAPL source area
spans both zones P-l and P-3. NAPL production from the recovery trench, recovery well R-l, R-2 and R-l 1 has
remained fairly low, with only 42 gallons recovered in 2016. Continuous groundwater pumping from wells R-l,
R-2, R-10 and R-l 1 is limited because of the 1,800-gallon capacity available in the NAPL separation-storage
storage tank. To address this issue, EPA installed a temporary NAPL management system outside the treatment
plant in 2017; it increased overall NAPL/groundwater storage capacity by 10 times. EPA will evaluate the
operation of this temporary system; if the treatment process is effective, a more permanent system will be
15
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designed. Throughout this FYR period, EPA has also performed pilot and treatability tests to explore other
options to address the issue of the emulsified oil and LNAPL in groundwater.
According to the Site's 2016 O&M Report, to achieve groundwater RAOs established in the ROD, NAPL
recovery efforts may need to be expanded to include well R-l 1 and continuous (versus pulsed) pumping from the
Zone P-l trench. However, the report goes on to state that for these systems to operate effectively and efficiently,
the treatment system would need to be modified to allow for inline oil and water separation. In 2016, the average
well field pumping rate was about 48 percent of the design rate arid similar to the average 2014 and 2015 pumping
rates. Recovery well pumping rates at three of the seven recovery wells (R-l, R-2 and R-3) were maintained
intentionally below design levels in 2016 to prevent NAPL entrainment in the treatment system influent stream.
Well R-l remained off from September to December 2016 due to the presence of NAPL. Pumping rates at wells
R-l to R-3 will be maintained at the reduced rates until the Site's NAPL recovery efforts are expanded.
Treated water discharged to the RCC stormwater ditch infiltrates Zone P-l upgradient of the BNSF railroad
tracks. Treated water from the water treatment plant has not yet been discharged to Jasper's publicly-owned
treatment works (POTW) because the RCC stormwater ditch has been able to infiltrate all treated water
discharged from the treatment system. EPA's contractor samples treatment system effluent monthly and compares
effluent COC concentrations to groundwater and surface water PRGs. Between 2013 and 2016, treatment system
effluent exceeded PRGs on a few occasions. However, because the system reinjects all treated water to Zone P-l
upgradient of the extraction well capture zone, the concentrations of these COCs in the treated water did not
adversely affect the protectiveness of the remedy.
Biofouling has been a recurring problem in the treatment system and at well R-5. Even though a biocide and iron
sequestering agent are injected upstream of the equalization tank, biofouling of the cartridge filters still occurs
regularly. The proximity of well R-5 to Sandy Creek places it near the groundwater-surface water interface. Under
pumping conditions, downgradient flowlines draw surface water into the well. The surface water is rich in
dissolved oxygen and microorganisms. Groundwater pumping rates at well R-5 were lowered in 2013 to reduce
surface water intrusion. The lowered pumping rate decreases plume capture. EPA addresses the biofouling of well
pumps by manually cleaning them or replacing them, as needed.
The 2006 ROD estimated that annual LTRA costs of $532,843 ($144,000 for O&M of the groundwater
containment system and $388,843 for O&M of the remainder of the selected groundwater remedy). The Site will
be in LTRA until August 2020. After LTRA is complete, the ROD estimated that annual O&M costs of $237,989 .
($144,000 for groundwater containment system O&M and $93,989 for O&M for the remainder of the selected
groundwater remedy). Table 4 lists actual LTRA costs between 2013 and 2016.
Table 4: Annual LTRA Costs, 2013 to 2016
Year
Total Cost"
2013
$536,000
2014
$682,000
2015
$762,000
2016
$659,000
a Annual O&M totals are rounded to the nearest thousand.
III. PROGRESS SINCE THE PREVIOUS REVIEW
This section includes the protectiveness determination and statement from the previous FYR as well as the
recommendations from the previous FYR and the status of those recommendations.
16
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Table 5: Protectiveoess Determination/Statement from the 2013 FYR Report
Proteetiveness
Determination
IVolecfiveness Statement
i
Short-term Protective
The remedy for the Site currently protects human health and the
environment in the short term. Current exposure to contaminated
media has been addressed through surface water, soil and sediment
cleanup actions and is being addressed through operation of a
groundwater extraction and treatment system arid restrictions on
drilling drinking water wells in the PMZ. For the remedy to be
protective in the long term, the following actions need to be taken:
• Perforin annual monitoring of surface water in Sandy Creek
to ensure that surface water is not negatively affected by
groundwater discharge.
• Implement enforceable restrictions to prevent potential
exposure to contaminated material in the RCC and to restrict
future land uses both on site and at off-site contaminant-
impacted properties to commercial and industrial activities.
* Determine if the potential exists for a future vapor intrusion
exposure pathway. If so, determine whether it results in an
unacceptable risk.
* Consider whether the Site's cleanup goals are still valid, in
light of revised toxicity values.
17
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Table 6: Status of Recommendations from the 2013 FYR Report
OtT
Issue
Recommendation '"status* Current Implementation Status Description
Completion
Date
1
Institutional controls not in
place to prevent exposure to
contaminated material in the
RCC or to restrict future land
uses on site and at
contaminant-impacted off-site
properties to commercial and
industrial activities.
Implement enforceable restrictions to
prevent exposure to contaminated
material in the RCC and to restrict
future land uses at the Site to
commercial and industrial activities.
Evaluate the need for land use
restrictions for contaminant-impacted
off-site properties, document the basis
of evaluation findings and implement
restrictions as necessary.
Completed
The TRRP deed notice filed by TCEQ in May 2014 for the main site
property (which includes the RCC) informs the property owner of
site-related contamination and site-related maintenance and
monitoring requirements, and prohibits groundwater use and
residential land use. The maintenance and monitoring requirements
ensure the ongoing integrity of the RCC.
For off-site properties within the TIZ and PMZ, the 2014 TRRP
restrictive covenants inform property owners of site-related
groundwater contamination affecting their properties, inform them
of site-related maintenance and monitoring requirements, and
prohibit groundwater use. With the exception of the railroad right of
way, all contaminated soil is contained on site, within the former
facility boundary; therefore, land use restrictions are not needed for
off-site properties affected by groundwater contamination only.
Land use restrictions are not in place for the railroad right of way to
prohibit residential use. However, future land use is expected to
remain as a railroad right of way; the area is not appropriate for any
type of non-industrial use. If land use within the railroad right of
way changes in the future, the need for land use restrictions for that
area will be reevaluated at that time.
5/20/2014
1
Routine surface water
monitoring of Sandy Creek is
not performed. Therefore, it
will be unclear in the future if
groundwater contaminants are
entering surface water in
Sandy Creek at concentrations
above groundwater-to-surface
water PRGs.
Perform yearly surface water
monitoring of Sandy Creek as part of
annual O&M.
Completed
Surface water samples are collected from Sandy Creek near
monitoring well MW-18 to evaluate potential water quality effects
from groundwater discharge. Surface water sampling in November
2015 and May 2016 did not detect COCs at concentrations above
surface water PRGs in Sandy Creek.
5/25/2016
1
It is unclear if vapor intrusion
would pose a human health
threat if structures were
located over the plume.
Review available data and collect
new data to determine if the potential
exists for a future vapor intrusion
exposure pathway, especially since
inhalation toxicity values for many of
the COCs have changed. If so,
determine whether it results in an
unacceptable risk.
Completed
Using multiple lines of evidence, CH2M HILL performed a vapor
intrusion evaluation and documented the findings in a January 2017
Technical Memorandum. The evaluation assessed potential vapor
intrusion exposure pathways of groundwater and soil to indoor air
. under current and future land use scenarios. It did not identify any
complete vapor intrusion exposure pathways at the Site under the
. current land use scenario. If the groundwater plume were to expand
toward the off-site residential area (along state highway FM 776) in
the future, additional evaluation of the exposure pathway would be
1/3/2017
18
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warranted at that time. The Technical Assessment section provides
additional information.
1
Fourteen COCs have toxicity
values more stringent now than
at the time of the 2006 RI/FS.
Consider whether the Site's cleanup
goals are still valid, in light of these
revised toxicity values.
Completed
¦ This FYR includes a review of soil and groundwater cleanup goals
to determine if they remain valid given changing toxicity values.
The Technical Assessment section provides more information.
1/30/2018
19
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IV. FIVE-YEAR REVIEW PROCESS
Community Notification, Community Involvement and Site Interviews
A public notice was made available by newspaper posting in the Jasper Newsboy on ] 1/29/2017 (Appendix D). It
stated that the FYR was underway and invited the public to submit any comments to the EPA. The results of the
review and the report will be made available at the Site's information repository, the Jasper Public Library,
located at 175 East Water Street in Jasper, Texas.
During the FYR process, interviews were conducted to document any perceived problems or successes with the
remedy implemented to date. Completed interview forms are included in Appendix E. The interviews are
summarized below.
The two Jasper City officials interviewed indicated that they feel well-informed regarding site-related activities
and remedial progress. They stated that EPA keeps involved parties and surrounding neighbors informed of
activities at the Site and that they are not aware of any changes to state laws or local regulations that might affect
the protectiveness of the Site's remedy. The officials indicated that EPA and TCEQ are doing a good job at the
Site and that they currently have no concerns regarding the Site.
The site's TCEQ Project Manager, Andy Bajwa, noted that even though the groundwater containment and
DNAPL recoveiy aspects of the remedy are not operating as intended, the remedy is currently protective of
human health and the environment. O&M activities associated with the RCC are performed routinely as required
and plans are underway to modify the access area for the LCS and LDS so that leachate measurement can be
performed without entering a confined space. Mr. Bajwa indicated that TCEQ is comfortable with the status of the
site's institutional controls and that the agency is not aware of any changes to state laws that might affect the
protectiveness of the Site's remedy. Mr. Bajwa also stated that TCEQ would like to request that the I.TRA period
be extended.
TCEQ's O&M contractor, Chuck Neeley, expressed that O&M activities associated with the RCC are effective
and being performed as required. He indicated that there have been no unexpected O&M difficulties or costs
associated with RCC O&M activities over the last five years and recommended that leachate removal be
performed in the near future.
EPA's LTRA contractor, Darren Davis of CI 12M HILL, noted the current issues related to the presence and
management of LNAPL in groundwater at the site, and concerns regarding the ability of recoveiy well R-4 to
effectively prevent plume migration toward recovery well R-5. However, he also indicated that in general, most
remedial components are operating as intended. Mr. Davis summarized several LTRA-related optimization efforts
that are resulting in significant savings and improved remedial performance, including the modification of the
groundwater sampling schedule from semiannual to annual and the use of a new cartridge filter vendor.
Data Review
This data review section provides an overview of current groundwater and surface water quality at the Site, as
summarized in the 2016 O&M Report. It also includes discussion of monitoring data from the 2013, 2014 and
2015 annual O&M reports. Historical context for the results is provided as appropriate to document trends at the
Site. Figure 4 shows the groundwater monitoring well network. Appendix F includes 2016 groundwater and
surface monitoring results. The 2006 ROD did not require soil or sediment monitoring.
Groundwater
Primary groundwater COCs identified in the ROD include PAHs, PCP and benzene. Sixteen different PAH
compounds are typically associated with creosote wood-treating sites. This review discusses a few individual
PAH compounds, but also discusses TP AH concentrations as calculated and presented in the annual monitoring
20
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that, as of 2016, COC concentrations above PRGs remain confined within the PMZ. Continued monitoring is
required to ensure that the plume does not extend beyond the PMZ boundary.
In 2016, in some cases, laboratory reporting limits for PCP, chrysene and dibenzofuran in groundwater were
higher than the respective groundwater PRGs for those constituents. In 2016, the laboratory reporting limits for
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, dibezo(a,h)anthracene and
indeno(l,2,3-cd)pyrene sometimes exceeded both groundwater and groundwater-to-surface water PRGs.
Laboratory reporting limits must be low enough to achieve PRGs.
Surface Water Quality
Routine monitoring includes the collection of groundwater samples from well MW-18, located near the west bank
of Sandy Creek, and comparison of analytical results to the groundwater-to-surface water protection PRGs.
Surface water samples are also collected from Sandy Creek and the forested wetland for comparison to surface
water PRGs.
Groundwater-to-Surface Water Protection
Comparison of the 2016 groundwater monitoring results for well MW-18 to the groundwater-to-surface water
protection PRGs shows that several groundwater COCs exceeded their respective groundwater-to-surface water
protection PRGs at MW-18-2 (Table 7). Well MW-18-2 is screened in the uppermost portion of Zone P-3. No
PRG exceedances were observed at any of the other MW-18 ports in 2016.
Table 7: 2016 Exceedances of Groimdwater-to-Surface Water PRGs for Well MW-18-2
Groundwater-
to-Surface
Water PRG
(pg/L)
MW-18-2 '
Average All CMT Sample Ports
Sampling Event
Sampling Event
COC
. May 2016
November 2016
- May 2016 ,
November
2016
Result units in jrg/L
Result units in pg/L .
Acenaphthene
167
97.5
167
28 •
33 LI
Naphthalene
1,667
3,570
5,750
531 J
865
2,4-Dimetlrylphenol
700
457
1,260
' 68
182
2-Methylnaphthalene
420
237
436
36
66 LI
Carbazole
.379 '
261 J
379 J ¦
59 J
77 LI
PCP
34.9
¦ 748
993 J
109
144 J
J = the analyte was detected, but the result is estimated.
LI - the identification of the analyte is acceptable; however, the reported value is an estimate and biased low.
Bold = value indicates PRG exceedance.
In addition to presenting port-specific results, the annual O&M reports also present average concentrations of
COCs from across the entire MW-18 monitoring interval (the seven sampling ports). Those average
concentrations are expected to be more representative of groundwater quality entering Sandy Creek. Between
2010 and 2016, PCP (averaged concentrations across all ports) has been the only COC to routinely exceed its
groundwater-to-surface water PRG at MW-18. Since 2012, the averaged PCP concentrations at MW-18 have
consistently increased from 20,8 pg/L in 2012 to 144 pg/L (estimated result) in November 2016; PCP's
groundwater-to-surface water PRG is 34.9 pg/L.
Surface Water Sampling
Between 2013 and 2016, annual surface water sampling included the collection of four samples from Sandy Creek
(Appendix F, Figure F-l). Between 2013 and 2016, no contaminants were detected at levels above their respective
surface water PRGs (see Appendix F, Table F-3 for 2016 sampling results). These results indicate that while some
COC concentrations in groundwater at well MW-18 exceeded groundwater-to-surface water PRGs in 2016,
surface water PRGs for those constituents are being met in Sandy Creek.
In January 2017, EPA's contractor sampled surface water from a culvert that runs from the forested wetland area,
beneath FM 776 and toward Sandy Creek (see Figure F-3) for the first time. Three PAH constituents -
22
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reports.4 The TP AH concentration provides an indicator of sitewide contaminant distribution and is used to -
determine if the plume boundary is changing within the PMZ. As recommended in the 2015 annual operations
report, EPA approved the modification of the groundwater monitoring frequency from semiannual to annual in
2016 due to the slow rate of PAH concentration reductions. With the exception of well MW-18, which is
monitored semiannually, all wells are now sampled annually in the spring.
The Site's current monitoring well network includes 26 single and multi-completion wells (Figure 4). Three of the
wells (MW-10, MW-11 and MW-12) are screened in Zone P-l (perched aquifer). Remaining wells are screened in
the deeper Zone P-3 aquifer. In May 2016, the groundwater monitoring program included sampling of one Zone
P-l well and 17 Zone P-3 wells. Additionally, monitoring well MW-18 was sampled in November 2016 to assess
the effectiveness of the change in pump depth setting. This change in pumping depth was done to intercept higher
PAH and PCP concentration groundwater present at the depth corresponding to well MW-18-2 screen interval
Well MW-18 is one of the Site's five continuous multichannel tube (CMT) wells, which allow for detailed
vertical contaminant profiling.
TPAH
The highest observed TP All concentrations occur in the plume's core region, which is the area beneath the BNSF
railroad tracks and next to recovery well R-l and the Site's Zone P-l NAPL source (Figure 4). TPAH.
concentrations in the 2016 groundwater samples collected from monitoring wells in this area ranged from 18
micrograms per liter (pg/L) at M-2TD to 8,270 pg/L at M-2S. Well M-2S has had consistently high TPAH
concentrations since implementation of routine groundwater monitoring in 2008. Well MW-2S is located next to
recovery well R-l, and the high TPAH concentrations observed there are attributed to presence of NAPL near- the
well. Elevated TPAH concentrations at that location are acceptable based on the Well's central location within the
PMZ.
In 2016, TPAH groundwater concentrations in Zones P-1 and P-3 monitoring wells were similar to previous
years. This finding indicates that, despite NAPL recovery operations from the Zone P-l trench and Zone P-3 well
R-l 1, a significant NAPL mass is still present. According to the Site's 2016 O&M Report, aggressive NAPL
recovery from well R-l 1 is needed before measurable PAH concentration reductions occur.
Leading Edge of the Plume
To reduce groundwater contaminant flux to Sandy Creek, hydraulic containment pumping is ongoing at recovery
well R-5 (Figure 4). Groundwater sampling at well MW-18 monitors COC concentrations between R 5 and Sandy
Creek. Groundwater sampling at the Site's farthest downgradient monitoring wells (MW-16 and MW-17) ensures
that the plume is not advancing past Sandy Creek.
In 2016, TPAH concentrations present at MW-18-1 to MW-18-7 suggest that the leading edge of the PAH plume
is in close proximity to Sandy Creek. Naphthalene concentrations were above the groundwater PRG of 100 pg/L
at MW-18-2 and MW-18-3 in 2016. In May 2016, naphthalene concentrations ranged from less than the detection
limit (2.1 ng/L) at port MW-18-3 to 3,570 pg/L at port MW-18-2. Naphthalene concentrations in November 2016
ranged from 11 jig/L at MW-18-4 to 5,750 pg/L at MW-18-2. This indicates that a small portion of the plume, in
the uppermost portion of Zone P-3, is not being captured by well R-5 pumping.
Groundwater contamination at concentrations above PRGs remains confined to the west side of Sandy Creek.
During the May 2016 sampling event, with the exception of naphthalene, no COC was detected at downgradient
wells MW-16 or MW-17 (Figure 4, Table F-2). Naphthalene has been detected at concentrations below 1 pg/L at
wells MW-16 and MW-17 since monitoring began in 2008. Well M-5 is located outside the southwestern edge of
the PMZ, west of Sandy Creek. In May 2016, with the exception of naphthalene, which was detected at an
estimated concentration of less than 1 pg/L, no other COCs were detected at that location. This finding confirms
A PAH compounds that were not detected are included in the TPAH value at a concentration equal to one-half of the
laboratory reporting limit; consequently, in samples with low or non-detect PAH constituent concentrations, the reporting
limit can have a significant influence on the TPAH concentration
21
-------
benzo(b)fluoranthene (0.03 jig/L), benzo(k)fluoranthene (0.018 ng/L), and inclcno( 1,2,3-cd)pyrene (0.028 jig/l.)
were detected at estimated concentrations slightly above their 0.014 ng/L surface water PRG. However, the
laboratory reporting limit for those three surface water constituents of 0.1 Hg/L is higher than their surface-water
PRG of 0.014 (.ig/L. Laboratory reporting limits must be lower than PRGs in order to assess whether PRGs have
been achieved. In 2016, the laboratory reporting limit of 0.1 fxg/L used to analyze benzo(a)pyrene in surface water
was also higher than the surface water PRG of 0.014 ^ig/L for that constituent.
Continued monitoring of surface water in the culvert, when present, will determine if the detection of those COCs
above their respective surface water PRGs was an isolated incident or the result of laboratory reporting issues.
23
-------
(MWM2.
MW-05
MW-1,1k j I
• MW-08
' MW-20.
MW-21
Water
Treatment
Plant
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C>:-%
LEGEND
® Single Completion Monitor Well
¦ CMTWell
© Zone P-3 Recovery Well
# Zone P-l Recovery Well
4 '
I z9B2
¦
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N ' i
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- k- i ^ Ja
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Creek or Ditch
Rail road
Ponded Wetland
Seasonal Wetland
- - ¦ Former JCC Property
Boundary
—— DNAPL Recovery Trench
Infiltration Trench
11 Hydrogeologic
Cross-Section
PMZ Boundary
TIZ Boundary
-¦ Estimated Boundary of
NAPL - Source Area
1 Suspected Zone P-l Mobile
NAPL Source Zone
BNSF = Burlington Northern Santa Fe
CMT ¦ Contiuous Multi-channel Tubing
DNAPL = Dense Nonaqueous Phase Liquid
JCC «Jasper Creosoting Company
NAPL = nonaqueous phase liquid
PMZ = plume management 2one
RCC = RCRA Containment Cell
RCRA ~ Resource Conservation and
Recovery Act
TI2 "Technical Impracticability Zone
Figure 1-2.
Site Map
Jasper Creosoting Company
Superfund Site
Jasper, Texas
ck2An
Figure 4: Groundwater Monitoring Well Network
24
-------
•xs 1 rAivits
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on
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NS
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Figure 5: Groundwater Monitoring Well Network and 2006 Naphthalene Plume Boundary
Note: The Figure above is Figure 3-4 from the Site's 2016 Annual O&M Report. The naphthalene plume boundaries shown in the figure are from 2006 and
not illustrate the current plume location.
\\houtsp02\ProJ -T:\JS\Pfof\Hart_i3jper\v/Ip\rnxd\f4SDer_2016_NAP_All0«3thi.rn*d gtwfgg c/SC/2017 235:22 PM
NOTES:
1. NS = not sampled
2. J - estimated result
3. U - not detected
4. Only weds sampled as part of the current
monitoring program shown
5. Bold values exceed the PRG or 100 pg/l
CMT <= continuous multi-channel tubing
PMZ» Plume Management Zone
RCC = RCRA Containment Cell
RCRA= Resource Conservation and
Recovery Act
pg/L ¦ microgram per liter
Figure 3-4.
Naphthalene Distribution in
Groundwater
jasper Creosoting Company
Superfund Site
Jasper, Texas
chzm
9 Zone P-B Recovery Well
# Zone P-l Recovery Well
Creek or Ditch
Railroad
Ponded Wetland
Seasonal Wetland
¦ ¦ ¦ Site Boundary
Estimated Boundary
of Naphthalene Plume
at 100 ng/L Remedial Goal
PMZ Boundary
LEGEND
0 Zone P-3 Single
Completion Monitor Well
~ Zone P-l Single
Completion Monitor Well
¦ CMT Well
2010 and do
25
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Site Inspection
The site inspection took place on 12/7/2017, Participants included EPA RPM Bob Sullivan, Andy Bajwa, Terry
Andrews and Xiaoxia Lu from TCEQ, Darren Davis from CH2M HILL, and Eric Marsh and Brice Robertson
from Skeo. The purpose of the inspection was to assess the protect iveness of the remedy. The site inspection
checklist is included in Appendix G. Site inspection photographs are included in Appendix H,
Participants met at the entrance to the Site and Mr. Sullivan pointed out the Site's surroundings. Participants noted
that the entrance gate was locked and the Site was clearly marked with signs. Plant operator Trey Pumphrey
assisted with the inspection. Participants began the inspection by touring the groundwater extraction and treatment
plant building. Site inspection participants observed the temporary NAPL management system tanks outside the
treatment plant. Mr. Sullivan pointed out that the system is no longer recovering DNAPL because the extraction
wells cannot currently reach it. The treatment plant appeared to be in good condition and was operational at the
time of the inspection. All treatment system tanks were clearly marked. The plant control room contains all
system breakers, an automated system that monitors and controls plant operations and all site-related health and
safety plans, O&M plans and regulatory documentation.
Participants walked to the railroad tracks and inspected monitoring and extraction wells. Wells were clearly
marked and locked. Participants viewed Sandy Creek and well MW-16, located east of Sandy Creek. Participants
then inspected the RCC area. RCC cap vegetation was well-established and in good condition. The fence that
surrounds the RCC was clearly marked with signage and appeared to be in good condition. Participants viewed
the LCS and RCC stormwater management features; both appeared to be in good condition.
During the site inspection, Skeo staff visited the Site's local information repository, located at the Jasper Public
Library. The repository contained site-related documents, including the 2006 ROD. The 2013 FYR Report was
not available. Skeo staff also visited the Jasper County Tax Appraisal District Office, located at 137 North Main
Street in Jasper, and collected parcel boundary information for parcels on and near the Site.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary;
Yes. With the exception of some performance issues related to the groundwater extraction and treatment system,
the remedy is generally functioning as intended by site decision documents. There are no complete exposure
pathways at the Site. Placement of contaminated sediment and soil within the RCC prevents direct contact with
those media and prevents soil and sediment COCs from leaching into groundwater. With the exception of the
railroad right of way, the Site's institutional controls are in place to prevent exposure to contaminated soil and
groundwater. Despite the operational issues associated with the effectiveness of the groundwater treatment
system, hydraulic containment pumping helps prevent plume expansion and migration of COCs from
groundwater into Sandy Creek surface water.
System performance monitoring indicates that the groundwater extraction wells continue to draw contaminant
mass from the subsurface. However, there is uncertainty concerning the effectiveness of the hydraulic plume
containment system. Emulsified oil and LNAPL are complicating remedial efforts. In 2016, TP AH groundwater
concentrations in Zones P-l and P-3 monitoring wells were similar to previous years. This finding indicates that,
despite NAPL recovery operations from the Zone P-l trench and Zone P-3 well R-l 1, a significant NAPL mass is
still present. According to the Site's 2016 O&M Report, NAPL recovery efforts may need to be expanded to
include well R-l 1 and continuous pumping from the Zone P-l trench to achieve groundwater RAOs established in
the ROD. The report also states that, for these systems to operate effectively and efficiently, the treatment system
should be modified to allow for inline oil and water separation. In addition, the system is no longer recovering
DNAPL. EPA is currently evaluating options to optimize the remedy.
26
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The Site's long-term groundwater monitoring program evaluates the effectiveness of the RCC and groundwater
remedies. A review of 2016 groundwater data from wells outside of the TIZ along its farthest downgradient
boundary (wells MW-15s, MW-16, MW-17 and M-5s) confirms that groundwater contamination at
concentrations above groundwater PRGs remains confined within the PMZ. To reduce groundwater contaminant
flux to Sandy Creek, hydraulic containment pumping is ongoing at recovery well R-5. In 2016, TPAH
concentrations present at MW-18-1 to MW-18-7 suggest the leading edge of the PAH plume is in close proximity
to Sandy Creek. However, while PCP and naphthalene concentrations in groundwater at well MW-18 exceeded
groundwater-to-surface water PRGs in 2016, surface water PRGs for those constituents are still being met.
The 2014 institution controls prevent unacceptable exposures to contaminated soil and groundwater and ensure
that the integrity of the remedy is maintained. Local ordinances also prevent exposure to site-related groundwater
contamination. Land use restrictions are not in place for the railroad right of way to prohibit residential use.
However, future land use is expected to remain as a railroad right of way; the area is not appropriate for any type
of non-industrial use. If land use within the railroad right of way changes in the future, the need for land use
restrictions for that area will be reevaluated at that time. Based on the groundwater data review performed as part
of this FYR, the Site's groundwater institutional controls cover all areas affected by site-related groundwater
contamination and all properties located within the PMZ.
The RAO for contaminated surface water in the forested wetland is to prevent direct human contact (adolescent
recreators) with wetland surface water and prevent discharge of water containing COCs at concentrations
exceeding surface water PRGs into Sandy Creek. In January 2017, EPA's O&M contractor sampled surface water
from a culvert that runs from the forested wetland area, beneath FM 776 and toward Sandy Creek, for the first
time. January 2017 surface water sampling detected three PAHs at estimated concentrations slightly above their
PRGs but below laboratory reporting limits. While surface water is sometimes present in the forested wetland, the
area is densely wooded and not accessed by people. It is also unlikely that a person would come in contact with
surface water (when present) in the culvert that passes beneath FM 776. Continued monitoring of surface water in
the culvert, when present, will determine if the detection of those COCs above their respective surface water
PRGs was an isolated incident or related to issues with laboratory reporting limits.
In 2016, in several cases, the laboratory reporting limits used for groundwater and surface water COCs were
higher than the surface water, groundwater and groundwater-to-surface water PRGs for those constituents.
Laboratory reporting limits must be lower than PRGs in order to assess whether PRGs have been achieved.
Based on a review of annual O&M reports and observations made during the site inspection, site O&M activities
are adequate. O&M inspections since the previous FYR indicate that the RCC cap is in good condition and
covered with healthy, well-established vegetation, with no erosion, cracking or seepage observed. Treatment plant
operational challenges regarding emulsified oil and LNAPL in the influent have been identified and are being
addressed. Biofouling of the treatment system and recovery wells is an ongoing problem. EPA addresses the issue
by adding biocide and iron sequestering upstream of the equalization tank, by regularly changing media filters,
and by manually cleaning well pumps, EPA continues to look for remedy optimization opportunities.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the
remedy selection still valid?
Question B Summary:
No. Although, the exposure assumptions and RAOs used at the time of the remedy selection remain valid,
changes to toxicity data have occurred since remedy selection, and some groundwater and surface water PRGs
may no longer be valid. However, those changes do not affect the current protectiveness of the remedy.
This FYR evaluated the chemical-specific Applicable or Relevant and Appropriate Requirements (ARARs)
identified in the ROD to determine if changes in chemical-specific standards affect the protectiveness of the Site's
remedy. The Site's l'I waiver waives Safe Drinking Water Act ARARs for the area within the TIZ. The ROD
established the TIZ as the area where the TI waiver will be applied; therefore, groundwater beyond the TIZ would
27
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be subject to groundwater ARARs and must meet MCLs. This FYR compares groundwater ARARs identified in
the ROD to current federal standards to determine if any changes have occurred (Appendix I, Table I-i), There
have been no changes to MCLs since EPA issued the ROD.
Some soil ARARs specified in the 2006 ROD were relevant during the remedy's construction but may not be
relevant to its continued protectiveness. The ROD established Texas Surface Water Quality Standards (30 TAG
§307) as an ARAR applicable to the discharge of groundwater co-extracted with NAPL, if discharge of '
groundwater to surface water is necessary. Effluent from the treatment system is compared to groundwater and
surface water PRGs. While not required by the ROD, routine monitoring now includes sampling of surface water
in the forested wetland area and in Sandy Creek. Therefore, this FYR compared surface water PRGs from the
2006 ROD to current surface water standards for protection of human health and ecological receptors (Appendix
I, Table 1-2). Current standards for benzo(a)anthraeene, benzo(b)fluoranthene, dibenz(a,h)anthracene,
indeno( 1,2,3-cd)pyrene, benzene and PCP are more stringent than they were at the time of the ROD. Based on
this review, surface water PRGs for those constituents may no longer be valid. Additional evaluation is
recommended to determine whether surface water PRGs need to be revised to protect human health and
ecological receptors.
The 2006 ROD selected surface soil cleanup goals based on an anticipated industrial land use. This FYR
evaluated the current validity of those cleanup goals using EPA's RSLs. The evaluation found that all surface soil
PRGs remain valid for commercial/industrial use; the concentrations are within EPA's risk management range of
1 x 10"6 to 1 x 104 and are below EPA's hazard quotient (HQ) benchmark of 1 for noncarcinogens (see Appendix
J, Table J-1).
As required by the ROD, EPA defined a TIZ that identifies the area where restoration of groundwater quality to
drinking water standards has been determined to be impracticable. Site-related groundwater beyond the TIZ needs
to meet groundwater PRGs. The ROD selected MCLs as PRGs for groundwater. In the absence of MCLs, the
ROD selected risk-based concentrations as the PRGs. To determine if the risk-based PRGs for groundwater
remain protective, this FYR compared the values to EPA's current tapwater RSLs (Appendix J, Table J-2). Based
on the evaluation, the PRG for naphthalene falls outside of EPA's acceptable risk management range of 1 x 10"^ to
1 x 10"4. PRGs for naphthalene and 2-methylnaphthalenc result in HQs that exceed EPA's benchmark of 1 for
noncarcinogens. However, these changes do not affect current protectiveness because no one uses groundwater.
While naphthalene is detected at wells outside of the TIZ, detections at most of those locations are routinely
below 1 (ig/L. Such low concentrations correspond to risk levels that fall well within EPA's acceptable risk-
management range and result in HQs of less than 1. Based on the current extent of the TIZ, those groundwater
PRGs may warrant reevaluation to determine if they remain protective of human health over the long term.
Groundwater COCs for the Site include volatile organic compounds (VOCs) and semi-volatile organic
compounds (SVOCs). The 2006 ROD did not identify vapor intrusion as a site risk. In response to a previous
FYR issue and recommendation regarding the need to evaluate the vapor intrusion exposure pathway at the Site,
CH2M HILL performed a vapor intrusion evaluation using multiple lines of evidence and documented the
findings in a January 2017 Technical Memorandum, The evaluation assessed the potential vapor intrusion
exposure pathways of groundwater and soil to indoor air. It did not identify any complete vapor intrusion
exposure pathways at the Site under the current land use scenario. If the groundwater plume were to expand
toward the off-site residential area (along state highway FM 776) in the future, additional evaluation of the
exposure pathway would be warranted at that time. The evaluation identified a potentially-complete vapor
intrusion pathway in the area underlying the railroad tracks where shallow NAPL impact (less than 15 feet) was
identified under the future exposure scenario. However, the evaluation concluded that as long as this area remains
a railroad right of way, a complete future vapor intrusion exposure pathway is unlikely; the area is not suitable for
building construction.
Implementation of the remedy has met most of the RAOs established by the ROD. Optimization of the Site's
groundwater remedy is expected to reduce the quantity of NAPL in the saturated zone to the extent practicable.
QUESTION C ; Has any other information come to light that could call into question the protectiveness of the ¦
28
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remedy?
No other information has come to light that could call into question the protectiveness of the remedy.
VI. ISSUES/RECOMMENDATIONS
Issues/Recommendations
()U(s) without Issues/Recommendations Identified in the FYR;
None
Issues and Recommendations Identified in the FYR:
GU(s); 1
Issue Category: Remedy Performance
Issue: To achieve groundwater RAOs established by the ROD, NAPL recovery
efforts may need to be expanded. In addition, the treatment system is no longer
recovering DNAPL.
Recommendation: Continue ongoing evaluation of remedy optimization options
to address remedial performance issues identified by this FYR and implement the
selected optimization strategy.
Affeet Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party/Support
Agency
Milestone Date
No
Yes
EPA ¦
EPA
9/6/2020
OU(s): 1
Issue Category: Monitoring
Issue: Based on current toxicity values, the risk-based groundwater PRO
established by the ROD for naphthalene falls outside of EPA's acceptable risk
management range of 1 x 10"6 to 1 x 10"4, Risk-based groundwater PRGs for
naphthalene and 2-methylnaphthalene also result in HQs that exceed EPA's
benchmark of 1 for noncarcinogens.
Recommendation: Evaluate groundwater PRGs for naphthalene and 2-
methylnaphthalene to determine if they remain valid and protective of human
health and consider whether the TIZ should be expanded.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party/Support
Agency
Milestone Date
No
Yes
EPA
EPA
9/6/2020
OU(s): 1
Issue Category: Monitoring
Issue: Current surface water standards for ben/.o(a)anthracene,
benzo(b)fluoranthene, dibenz(a,h)anthracene, indeno( 1,2,3 -cd)pyrene, benzene
and PCP are more stringent than they were at the time of the ROD. Surface water
PRGs for those constituents may no longer be valid.
29
-------
Recommendation: Evaluate surface water PRGs for benzo(a)anthracene,
benzo(b)fluoranthene, dibenz(a,h)anthracene, indeno(l ,2,3 -ed)pyrene, benzene
and PCP to determine if they remain valid and protective of human health and
ecological receptors.
Affect Current
Protectiveness
Affect Future
Protectiveness
Parly
Responsible
Oversight
Party/Support
Agency
Milestone Date
No
Yes
EPA
EPA
9/6/2020
OU(s): 1
Issue Category: Monitoring
Issue: In January 2017, ben/o(b)fluoranthcne, benzo(k)fluoranthene and
indeno( i ,2,3-cd)pyrene were detected in the forested wetland surface water
sample at concentrations slightly above surface water PRGs.
Recommendation: Continue to routinely monitor surface water in the forested
wetland. If surface water COC concentrations continue to exceed PRGs, take
actions as needed to prevent human exposure to forested wetland surface water
and to prevent the discharge of surface water to Sandy Creek at concentrations
above surface water PRGs.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party/Support
Agency
Milestone Date
No
Yes
EPA
EPA
9/6/2019
OlJ(s): 1.
Issue Category: Monitoring
Issue: Laboratory reporting limits used for some groundwater and surface water
constituents are higher than PRGs established for those constituents.
Recommendation: Ensure that laboratory reporting limits are low enough to
assess the achievement of groundwater and surface water PRO concentrations.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight
Party/Support
Agency
Milestone Date
No
Yes
EPA
EPA
9/6/2019
OTHER FINDINGS
Additional recommendations were identified during the FYR. These recommendations do not affect current
and/or future protectiveness.
• Annual O&M reports do not show the TIZ and naphthalene or TP All plumes on the same figure. In the
future, inclusion of the TIZ and plume boundaries on the same figure is recommended to make it easy to
determine the location of the plume in relation to the TIZ, Also, figures in annual O&M reports should
include current plume boundaries.
• Update the Site's information repository with the most recent FYR Report and other site documents.
30
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VII. PROTECTIVENESS STATEMENT
Sitewide Protectiveness Statement
Protectiveness Determination:
Short-term Protective
Protectiveness Statement:
The remedy at the Site currently protects human health and the environment because there are no
complete exposure pathways to contaminated site media. Placement of contaminated soil and sediment
in the RCC prevents unacceptable exposures to human and ecological receptors through direct contact,
the Site's hydraulic containment system prevents contaminated groundwater from entering surface
water at concentrations above surface water PRGs, institutional controls are in place to prevent
unacceptable exposures to contaminated soil and groundwater, and groundwater remediation and
monitoring are ongoing. However, in order for the remedy to be protective over the long term, the
following actions are needed to ensure protectiveness:
1) Continue ongoing evaluation of remedy optimization options to address remedial performance
issues identified by this FYR and implement the selected optimization strategy.
2) Evaluate groundwater PRGs for naphthalene and 2-methylnaphthalene to determine if they remain
valid and protective of human health and consider whether the TIZ should be expanded.
3) Evaluate surface water PRGs for benzo(a)anthracene, benzo(b)fluoranthene, dibcnz(a,h)anthracene,
indeno(l,2,3-cd)pyrene, benzene and PCP to determine if they remain valid and protective of human
health and ecological receptors.
4) Continue to routinely monitor surface water in the forested wetland. If surface water COC
concentrations continue to exceed PRGs, take actions as needed to prevent human exposure to forested
wetland surface water and to prevent the discharge of surface water to Sandy Creek at concentrations
above surface water PRGs.
5) Ensure that laboratory reporting limits are low enough to assess the achievement of groundwater
and surface water PRG concentrations.
VIII. NEXT REVIEW
The next FYR Report for the Jasper Creosoting Company, Inc. Superfund site is required five years from the
completion date of this review.
31
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APPENDIX A - REFERENCE LIST
2014 Final Annual O&M Report, Jasper Creosoting Company. Prepared for TCEQ by IMS Corporation. August
2014.
2015 Final Annual Report of Field Activities, Jasper Creosoting Company. Prepared for TCEQ by AECOM,
August 2015.
2016 Final Annual Report of Field Activities, Jasper Creosoting Company. Prepared for TCEQ by AECOM.
August 2016.
2017 Final Annual Report of Field Activities, Jasper Creosoting Company. Prepared for TCEQ by AECOM.
August 2017.
Final Leachate Removal Work Plan, Hart Creosoting Federal Superfund Site and Jasper Creosoting Federal
Superfund Site, Jasper, Texas, Prepared for TCEQ by AECOM. March 2017.
Interim Groundwater Remedial Action Completion Report, Jasper Creosoting Company Superfund Site. Prepared
for EPA Region 6 by CH2M HILL. July 2010.
Jasper Creosoting Company Superfimd Site Evaluation of Potential Vapor Intrusion Pathway. Prepared for EPA
Region 6 by CH2M HILL. November 2017.
Jasper Creosoting Company Superfund Site - NAPL Management System Modification. Prepared for EPA
Region 6 by CH2M HILL. May 2017.
Jasper Creosoting Company Superfund Site - Nonaqueous Phase Liquid Source Area TarGOST Investigation
Approach. Prepared for EPA Region 6 by CH2M HELL. October 2017.
First Five-Year Review Report for Jasper Creosoting Company, Inc. Superfund Site. Jasper County, Texas. EPA
Region 6. September 2013.
Jasper Creosoting Company Superfund Site Evaluation of Potential Vapor Intrusion Pathway Technical
Memorandum. Prepared by CH2M HILL for EPA Region 6. November 2017.
Leachate Removal Field Activity Report, Jasper Creosoting Federal Superfund Site, Jasper, Jasper County, Texas.
Prepared for TCEQ by 11RS Corporation. August 2013.
Preliminary Close Out Report, Jasper Creosoting Company, Inc. Superfund Site, Jasper, Jasper County, Texas.
United States Environmental Protection Agency Region 6. September 2008.
Record of Decision, Jasper Creosoting Company, Inc. Superfund Site, Jasper, Jasper County, Texas. United States
Environmental Protection Agency Region 6. September 2006.
Remedial Investigation and Feasibility Study Report, Jasper Creosoting Company, Volume 1. Prepared for EPA
Region 6 by CH2M HILL. September 2006.
Removal Report for Jasper Creosoting Company, Jasper, Jasper County, Texas. Prepared for EPA by Weston
Solutions, Inc. April 2006.
Year 2013 Annual Operations Report, Version No. 1.0, Jasper Creosoting Company Superfund Site. Prepared for
EPA Region 6 by CH2M HILL. April 2014.
A-l
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Year 2014 Annual Operations Report, Version No, 1.0, Jasper Creosoting Company Superfund Site. Prepared for
EPA Region 6 by CH2M HILL. July 2015.
Year 2015 Annual Operation and Maintenance Report, Version No. 1.0, Jasper Creosoting Company Superfund
Site. Prepared for EPA Region 6 by C1I2M HILL. September 2016.
Year 2016 Annual Operation and Maintenance Report, Version No. 1.0, Jasper Creosoting Company Superfund
Site. Prepared for EPA Region 6 by CH2M HILL. July 2017.
A-2
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APPENDIX B - SITE CHRONOLOGY
Table B-l: Site Chronology
Event
Wood-treating operations were active on site
1946-1986
An investigation linked Jasper Creosoting Company's operations to a fish
kill in Sandy Creek
August 17, 1981
Texas Department of Water Resources sampling of on-site drainage ditch
discovered high levels of PCP contamination
February 1983
Texas Department of Water Resources sampling of surface water in Sandy
Creek discovered detectable levels of wood-treating chemicals
March 29, 1983
State of Texas issued an Agreed Order granting temporary injunction
ordering Jasper Creosoting Company to submit a groundwater assessment
plan
August 19, 1988
Company ceased wood-treating operations and abandoned the facility
1992
State of Texas entered Final Judgment against Jasper Creosoting Company
concerning site cleanup responsibilities
January 1, 1993
EPA performed expanded site inspection
March 11, 1994
EPA's Technical Assessment Team performed removal assessment
August 1995
EPA initiated first time-critical removal action to address existing
buildings/structures, aboveground storage tanks and other facility
equipment The removal action also included off-site disposal of scrap
creosote-treated wood, heavily contaminated on-site soil, and liquid wastes
from tanks and containers.
April 8, 1996
EPA completed first time-critical removal action
June 22, 1996
Texas Natural Resource Conservation Commission, Emergency Response
and Assessment Section completed Human Risk Study
November 1997
EPA listed the Site on the NPL
July 28, 1998
EPA initiated second removal action, which included stabilization of the
waste cell, removal of creosote-soaked lumber, and removal and off-site
disposal of liquid from an exposed pipe leading out of the waste cell.
November 1999
EPA completed second removal action
January 2000
First remedial design initiated by EPA
September 26, 2002
EPA completed first remedial design
August 22,2003
EPA initiated third removal action to address immediate threats to human
health and the environment identified during the Site's 2006 RI/FS
July 7, 2005
EPA completed remedial RI/FS
August 2005
EPA completed third removal action
March 2006
EPA completed Supplemental RI
July 2006
EPA issued the Site's ROD
September 20, 2006
EPA initiated second remedial design
March 13, 2007
EPA completed second remedial design
September 9,2007
EPA approved remedial action
September 20, 2007
EPA started remedial action on-site construction
January 30,2008
EPA issued Preliminary Close-Out Report documenting completion of
remedy construction activities
September 12, 2008
EPA completed remedial action
August 4, 2010
EPA completed Site's first FYR
September 6, 2013
TCEQ filed TRRP deed notice and restrictive covenants with the Jasper
County Clerk's Office for the main site property and off-site properties
within the TIZ and PMZ
May 20,2014
B-l
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APPENDIX € - INSTITUTIONAL CONTROLS
Figure C-l: PMZ Registration Letter
#e08%
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONS
1445 ROSS AVENUE, SUITE 1200
DALLAS TX 7S202-2733
JUL 2 3 2BI2
Lee I'arham/ Manager
Texas Department of Licensing and Regulation
Wafer Well Driller/Pump Installer Section r
Compliance Division
P.O. Box 1215?
Austin, Texas 78711
Subject: Ground Water Contamination and Restricted Water Well Drilling Area at the
Jasper Creosoting Superftrad Site, Jasper, Jasper County, Texas
Dear Mr. Parham;
The United States Environmental Protection Agency (EPA) Region 6 is providing this letter to
the Texas Department of Licensing and Regulation (TDLR) as notification of the presence of -
ground water contamination associated with the Jasper Creosoting Superfund Site located in
Jasper, Jasper County, Texas. BP A has conducted ground water sampling and analysis in the
affected area (as indicated on the attached map), which detected elevated concentrations of
constituents from historical wood preserving operations. The following is the list of ground water
contaminants of concern (COCs) provided in the Record of Decision (ROD) for the Jasper
Creosoting .Superfund Site.
Arsenic Indeno( 1,2,3-c,d)pyrene
Iron Naphthalene
Thallium Phenanthreiie
Vanadium 2,4-D imethylpheno 1
Acenaphthene 2-Motbylnaphthalene
Bcti7.o(a)anthraeene Benzene
Bcnzo(a)pyrcne Carbazolo
Benzo(b)fluoranthene PentachlorophenoJ
Benzo(k)tluoranUiene Xylene, M- & P-
Chrysene 2,3,7, R-TCDD(TKQ)
Dibenz(a,h)anthraccne
Hie known ground water contaminant plume and restricted drilling area are located within the
southwestern portion of Grid 62-01-4 of the Texas Water Well Numbering System. Due to
known levels of contaminants in the pound water, the ROD established a Plume Management
Zone (PMZ) where the installation of new water supply wells is restricted. Abandonment and
plugging of existing water wells may also be required in this area for ground water protection.
The attached map shows the boundary of the PMZ and legal description as defined by Mark
Birdwell Surveying on December 21,2010 (enclosed),
internet Address 0J8L) «
Racyctad/Recy dabte • ptfnled with Vegetable ok Baaed ?nks on 100% Recycled Pap*r, Pmcest CNorir* Froa
C-l
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j If you have any questions or require additional information concerning this notification, please
contact Robert Sullivan, EPA Remedial Project Manager, at (214) 665-2223.
Sincerely,
vRoDMSfilUyail:
Remedial Project Manager
EPA Region 6
Enclosures
Co: Alan (Buddy) Henderson
TCEQ
AitdyBajwa
TCEQ
John Martin, General Manager
SETGCD
Tommy Boykin, City Manager
City of Jasper
Honorable Mark W. Allen
Jasper County Judge
.
i
C-2
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Figure C-2: PMZ Survey and Legal Description
Mark Birdwell Surveying
TO Box 1142
12 J Market Street
Hemphill, TX. 75B48
Phone <4i») 7A7-2722
Fux (409) 7S7-9986
Stale of Texas
County of J jsptfi*
Legal Dist iipiiiMi
To a
38.768 Tract
(Plume Management Zone}
Being a legal description to a 38.768 acre irncl {Plume Miiwgs!in«l)1 Zone),
i 'K.i'nl ill Jnspcr County, Trao.i ami is further described by metes and bounds as
fclluwa ta-wit;
BEGINNING! At n point with » cwrtlinatc value of l«,j«H,111.23(1 N
4.286,fi20.D21 E (Texas Slate PhiieCounltiiittes);
I HLSCli: Along the boundary of a 38.76$ a«ft trad as follows:
1. S E 587.14' to a point:
2. S ?.7°4tj'3S" B 1240,58'to a point;
3. 3 0"MMy W 345M' to a point,
8. N S<)"00,21" 8 987, IS' to (he pninS uf beginning ecmtaiistiij: 38.768 aem of
liuul;
~*NOTE*~
1. I, Win Mark Birdwell Ul'L.S #5148, did net perform u Sttrvvy oil tiii*
ground,
2. Surveyor ilitl mil Abstract for title iitHi did not locate any utilities,
C-3
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% AH licuting, lifstanvcs, jiihI coord.nates her.in recited arc J nam infonniiuu:i
provided b> L & L Enjjiruurs jiriU Pl-innci*, luo,
4. AN Dwd infumotion Iwrww wwi |ifoviilc«l ty I & I. Fnglncenc m!
Planners, Irtc.
5. Above rxroojic calculated from inlotmiilunproMilei) by L & ( f'nghuvtx
sitt'.l iNsumi'is, Iisc.
ft, SurvcNor iloi'n ni»l ^unraiilt'O iicfc«n rtvUiMey i>{'iftis lc£;tl dreumerX
7 AIxhy di"*'m^ ami aiv meant fur dcwiiptivv
pmpuavri only.
fftlifc document Is i»! signed and sealed In red* il Is deemed void by llie above sdjpicd
Surveyed hyi
Wm. Musk Birdwdt
ilp.l.5. mm
December 21. 2010
hb ummm m%m$ #plume
C-4
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\
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PLUWr MANAG'IMlNf ZONh \
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C-5
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Fi»iiiT C-3: Jasper Code of Ordinances: Water Wells
Jasper, Texas, Code of Ordinances » PART II - CODE OF ORDINANCES » Chapter 2G - WELLS »
ARTICLE II, - WATER WELLS » DIVISION 2, - PERMIT »
DIVISION 2. - PERMIT
Sec, 26-31 - Permit .recoiled.
See 26-3? - Application
See - Issuance.
Ss.i_a 34. ^Eeas.
3ea^28r35,..-..Executing in duplicate.
Sees 28-36 .?6-S0. - Reserved,
Sec. 26-31. - Permit required.
It shall be unlawful for any person to drill or otherwise construct, repair, correct, abandon or
plug a well without a permit issued by the city,
(Orel. No. 11-00.2, 11 4 00)
Sec, 26-32. Application.
An application for a permit for the construction, repair and correction, abandonment or
plugging of a well shall be filed with the city manager and shall state:
(1) The name and address of the owner of the well;
(2) The purpose for which the permit is desired;
(3) The location of the well or proposed wall;
(4) Its approximate depth;
(5) if the application is for a permit for the drilling or construction or repair and correction
of a water well, the estimated amount of water to be, or which is, pumped daily,
monthly or annually, and the uses for which the water will be or is required;
(6) If the application is for a permit for the drilling or construction or for the repair and
correction of a wall, the proposed method of drilling or construction, or the proposed
method of repair and correction, and the kind of equipment to be used;
(7) The name of the contractor when the owner desires to drill or construct, repair and
correct, or do the work pursuant to an abandonment of a well in compliance with this
article through a contractor.
(Ord, No. 11-96.2, 11 >i-m;
See, 26-33. -• Issuance,
A permit to drill or otherwise construct, repair, correct, abandon or plug a well shall be
granted by the city manager, with the approval of the city council, to any person who files with the
city manager the required application and pays the required fea and complies with all other
provisions of this article.
C-6
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Figure C-4: Jasper Code of Ordinances: Contaminated'Wells
Municode
Page I of3
Jasper, Itxas, Code of Ordinances » PART II - CODE OF ORDINANCES » »
DIVISION 3. - CONTAMINATED WELLS
Ssa^SJ-^as&^Brtaa^
See. 26-S-2. - Plugging «noounteffi&
S#e. 20-53. - PrfltMiunt wtiew w*i» greatertlM».»eiall»fftldemajaptariiinaterf.
"'..'A ^rrfc-^n aMt'K'.
-s..,.. . rc:a.g:,k.ia-Ltlti:il,
il
Sec. 26-51. ¦ Scope: compliance.
7>e provisions of]this division shall apply la ali wells, whether trside or within one (I) mite or
the city, heretofore drifed or which may have been abandoned, and upor p-oper notice as called
for be n; giver to toe owner, agent of the owne' or lessee of tne property on which any such wel- is
situated such well shall be plugged or sealed as called for herein.
i 3'- '*,% ;
Sec. 26-52. - Plugging required when contaminated water encountered,
if a stratum of contaminated water or water having a high minora' cortent is encountered in
the test hole be'icw the aater bearing strata from which the water suppV of the city is taken or
crawn, such contaminated or highly mineralized stratum sha! he plugged or closed off from the
remainder of tie wet;. This shall be accomplished by pumping through a pipe extending to r e
bottom of the test hole a plastic or aqueous mixture of qulck-setfng cement of sufficient quant.ty to
completely plug or extend entirely through the contaminated or mmeraVzed stratum and well up into
the first impervious or nof.water bearing stratum above. The test hole s*al then :>e allowed to
regain undisturbed for a period of at least seventy-two {72) hours in order that the cement p.ug
Decorne thoroughly set or hardened.
, 0-c ,V^ 1i
Sec. 26-53. - Procedure when well greater than eighty feet deep is contaminated.
in order to prevent contaminated, polluted, highly minerafcec o- otherwise ob;ectiona»le
water encountered 'n any stratum above those from which the water supply of the city is taken or
drawn, from entering or mixing with the water bearing strata from which the city supply is taken cr
drawn; and to prevent the entrance of surface water to such water oearir-g st-a'.a in each case of a
well dri.lec over eighty (801 feet and in penetrating the water bearing strata from wh ch the city
supply is taken or drawn. Ire following procedure sha'l be followed;
(1)
llftpI//li^JralT.olt»icoie.c^lalfp^iflt.asJJX?ll=^cSeatl>=117S4&:^^Il•IReaBcsH^ttl»%3a%2f,/#... 6/5/2012
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The test hole shall be reamed out to the desired oiamety of trie finished we;! down to
tne first impervious or nonwater bearing stratum aocve the strata from which the water
supply of the city is taken or drawn.
(2) Tne easing shall then be set down to the aforesaid point or depth and upon a
nonwater bearing or impervious stratum,
(3} The annular space between the outside of the casing and the bare hole or natural
formations shall then be completely filled with a plastic or aqueous mixture of quick-
setting cement which shall be pumped into t-e well under pressure through a pipe or
conduit extending to me bottom of the casing as set, such cement entering the
annular space between the outside of trie casing and the bore hole at the bottom of
such casing, arid filling such annular space by flowing upward to the top of the well or
surface of the ground. Evidence cf such annular space being completely filled shau be
by the plastic or aqueous cement mixture returning to and flowing from the anrufa-
space at the surface of the ground.
Sec, 26-64, - Defective wells declared nuisance; correction of defect,
(a) Every well which for any reason does not completely prevent tne mixing of water or other
liquid from above ard below the source of the city's water supply wri* the water ir the source
of the city's water supply, or which for any reason woidd tend to pollute o-contaminate the
water in the course of tne city's water supply shall be considered a defective well. Defective
we'ls are hereby declared to constitute a nuisance, arc the city1 manager on Hs own initiative
or upon information or complaint from any source shall make an examination of any well
suspected of be ng defective, and sha-l issue written instructions to the owner or his agent in
cha-ge of such well or the property upon which it is situatee, for correcting tie defects and
complying with provisions of this article The city marager shall preserve a tme which, in his
judgment, under all the circumstarces, is reasonable arxi w.thin which the instructions shail
be complied with, it shail be unlawful for the owners or operators cf a defective we'l to fail to
eompV with the city managers instructions and abate re wtsarce with!/* the time jimit
prescribed, if the instructions are not complied with, the nu.sance may be abatsc ay the city
as provided in this section.
0) If tne owner, agent of owner or lessee fails to comply w'tH the city manager's instructors, the
city manager may apply to the city council for permission to plug, seal or case the defective
well and thereby abate the nuisance, and place a lien on fe property and a personal charge
against the owner to cover the costs of sealing the defective well. The manager shal set
forth in his application the location cf the well, the name of the record owrers of the property
and the manner in which the well Is defective. Not-ce of the fling of such appiicat on to plug,
case or seal the well and place a iter on the property and pe~sor,al:y charge i~a owner to
cover the costs [of], sealing the defective *el . shall be published once in the offclal
newspaper of the city not more (nan fve <5} days p-'or to ary regular msetlrg of the city
council.
<>c) The city council may hear the application, and if it determines by resolution that the well is
defective and thereby constitutes a nuisance, it shall be resolutiar crcer *he Crty manager to
proceed with the plugging, casing or sealing of the well and to file upon completion of the
wort;, with the c'ty secretary, a sworn, statement sett'ng foh;h the expenses incurred In
plugging, sealing or casing the wel Upon filing of such statement, r-e mayor shall
incorporate the statement in a notice to be executed and acknowledged by him and filed with
the county ciertt, setting forth the claim of the city for expenses incurred ir plugging, sealing
ittp:A'lt*aif,aBmicoie.cooi.'"priat.as|}x?li=&cleatlI>=11794&IItt>IRecpiest=littp%3a%2C4,. «/2M2
C-8
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Muoicode
Page 3 of 3
or casing the wel; and upon the filing of the notice, it shall constitute a ien agatnst the
property on which the we!', is located, and a personal charge agairst f e owner. A suit nay
be thereon, and tne lien foreclosed as provided by iaw for the foreclosure of other liens.
Notice sha'i be given to any person in possession of the property on which the defective we,'I
is located by na lirg a copy of the publ.shed notice to the person.
Sec. 26-55. - Filling and plugging when defect uncorrectable.
Any «l' or other open ng now constructed penetrating the underground water supply, and
wmch pollutes or contaminates, or tends in the judgment of the c ty manager to pollute or
conarr.rate tie city's water supply, and which cannot be corrected in the judgnent of the cfty
narage', is 'weby deciarec a nuisance. Or notice to the owner of the wel or opening, cr to his
agent in charge of it or of tie property on which ft is situated, issued by be c :cy manager tne
nuisance s"all be abated by the owns* within sixty (60) days from date of t"e notice ty fi.ling and
Plugging the ml or opening in the manner provided for in this article for abandoned wells, upor which the we' is situated, and abate tne ruisance in tne rranne'
above provided; and the cwrer of he well shall be table to the city for re cost of the work.
Sec. 26-56, - Filing statement of correction of defects.
Upon completion of the worft correcting the defects of any well, and before putting it into
operation, the owner of the wel shall file with the city manager a swot statenent fat ail defects
rave beer co^ected to comply with this article in accordance with nstuctions issued by the city
manager ana faiure to file such a statement within thirty (30) days after completion of correct-on of
the defects sha! be deer.eo a violation of this article.
.¦."••v !-: ¦; I '-4-3-0
Sees. 26-57—26-73. - Reserved.
http://Iibcary municode.coin/pript.aspx?h=«S:clieiitn>-l 1 ?94&HTMReqgest=htlp%3'a%2l%— 6/6/2012
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Figure C-5: 2014 TRRP Deed Notice for (he Main Site Property
'r(/ r't '7/, 7,1'it 'ft
' ~~ 256415 D: QPR V: 1G00 P; 976 MSC
05/2fl/2flH 17:34 Ph Total r.ig««. 1? F>r 06
'W Ci-tr<' < £{«~ * - ,!ssrff * it f e«.i &
¦III MlimMmfilfiHWftmWMi II 111
i*nx as Risic Reduction Program
Dekd Noticf.
STATE OF TEXAS I
I
COUNTY OF JASPER S
This Deed Notice Is filed to provide information concerning certain environmental conditions
mid use limitations pursuant to the Texas Commission mi Environmental Quality (TCEQ) Texas
I Risk Reduction Program (TORS') Rule found at 30 Texas Administrative ("ode (TAC), Chapter
1 350, and affects the real property (Property) described on Exhibit A and shown on Exhibit I!,
which are attached hereto and incorporated herein by referents.
Pot tions of the soil and groundwater of the Propei ty contain certain Identified chemicals of
concern, causing those portions of the Property to bo considered an Affected Property as that
term Is defined in the TRRP. The portion considered to be ihe Affected Properly is described on
Exhibits C and I) and shown on Exhibits Fi and D, which are attached hereto and incorporated
herein by reference.
The following is a list of chemicals of concern that exceed -protective concentration levels in the
soil and groundwater within lite Affected Property: arsenic; iron; thallium; vanadium; xylene
ucenaphthene; benzo(a)anthraccnc; benzo(n)pyrenc; bciwo(b)fluoranthene; chr>'selltr: bciuicne;
I bcii/.o(k)f!uoranthenc; dibem{a,h)ant)iraecne; mdem>{i,s,;i-c.,d)pyrene; naphthalene;
phenunthrene; r.irhazole; 2,.|-dtmethv]phenol; z-niethyluaphthalene, pentaehlnrophenol; and
nt- & p, 2.3,7,8-Tf'DD (TEQ).
'I his Deed Notice is required for the: [allowing reuions:
1. The Affected Pro pert)' is subject to the TRRP requirements for properties continuing
concentrations of chemicals of concern in soil and is subject to the requirements in 30
TAC § 350,m{<'){2) to prevent exposure lo soils that contain a chemical of concern lit
excess of the protective concentration level. The attached Exhibits H itm.1 I) describe and
provide the location of the physical control, "Containment Cell Area," and extent of the
soil that exceeds the TCEQ-approvcd protective concentration levels for certain
chemicals of concern. The attached Exhibit E describes the required maintenance and
monitoring required for the physical control. The maintenance and monitoring must he
implemented unless and until TCEQ approves any modification, This Deed Notice and
Containment Cell Area must not be removed or modified without prior approval from
TCEQ.
2, The Affected Property is subject to ihe TRRP requirements ior properties where the
concentrations of chemicals of concent in the groundwater exceed the TCEQ-approvcd
protective concentration levels. The TCF.Q concurred with EI'A that it is not feasible
from a physical perspective using currently available remediation technologies dtie either
to hydrogeologic or chemical-specific factors to reduce the concentration of these
chemicals of concei n throughout all or a portion of die groundwater affected by the
chemicals to the TCEQ-approvcd protective concentration levels within a reasonable
time. Tile attached Exhibits B nnd C provides the location and extent of the groundwater
exceeding TCEQ-approvcd protective concent rat ion levels in the Technical
impracticability Zone (TtZ) Within the TfZ, the groundwater under the Affected
J'iigf j of 3
Deed Noiive
Jasper (Treasuring Campanv 1 edenil SnprMfutuJ Srtc
A CTR t".ciED COPY f-g 1 of 17
AH«t C^um.l iJ" 4f> \! I'M
utmit npa'Man. lua'mty citric
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flyt'tOt-- j
Henee
(Viitun
C-10
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256415 B:OPRV: 1000 P: 979 05/20/2014 12:34:17 PM Page 2 ol 17
Property contains a body of Non-Aqueous Phase Liquid (MAPI.) as depicted in a
conceptual drawing on the attached Exhibit B, NAPL is defined as a liquid solution, in
this case comprised of creosoting hydrocarbon constituents, that does not dissolve
readily in water. These immiscible hydrocarbons in the subsurface can partially dissolve
into the groundwater at very slow rates, hut they are anticipated to remain in the
subsurface for exceedingly long periods of time. The attached Exhibit E describes the
required maintenance and monitoring required for the T1Z, The maintenance and
monitoring is required until TCEQ approves some modification of those requirements.
Use of and exposure to the affected groundwater for any purpose is not advised unless
otherwise approved in writing by the TCEQ or until such time as all the chemicals of
concern no longer exceed their protective concentration levels. This Deed Notice must
not be removed or modified without prior approval from TCEQ.
3. The Affected Property is subject to the TRRP requirements for properties with an area
overlying a TCEQ approved plume management wine. A plume management zone is
defined as an area of groundwater containing concentrations of chemicals of concern
exceeding the TCEQ-approved protective concentration levels, plus any additional area
allowed by the TCEQ in accordance with 30 TAC g 350.33(f)(4). A plume management
zone was established so that Hie chemicals of concern in the groundwater are managed
such that human exposure is prevented and other groundwater resources are protected.
The attached Exhibits B and C provide the location and extent of the plume management
zone. The attached Exhibit E describes the required maintenance and monitoring
required for the plume management zone. The maintenance and monitoring is required
until TCEQ approves same modification of those requirements. Exposure to
groundwater within the plume management zone for any purpose is not advised until
such time when all of the chemicals of concern no longer exceed their respective
protective concentration levels. This Deed Notice must not be removed or modified
without prior approval from TCEQ.
4. The Affected Property currently meets TR.RP standards for commercial/industrial use.
Based on the reports, the chemicals of concern pose no significant present or future risk
to humans or the environment based on commercial/industrial land use. No further
remediation of the Affected Property is required by the TCEQ as long as the Affected
Property is not to be used for residential purposes. If any person desires in tire future to
use the Affected Properly for residential purposes, lite TCEQ must be notified at least 60
days in advance of such use and additional response actions may be necessary before the
Affected Property may be used for residential purposes as the property may not be
protective for residential use. Persons contemplating a change in land use for the
Property are encouraged to review the definitions for commercial/industrial and
residential land use contained in TRRP as the definition of residential land use is broad.
As of the date of this Deed Notice, the record owner of fee title to the Property is Jasper
Creosoting Company with a mailing address of 600 North McQueen Street, Jasper, Texas,
75951.
Page a of 3
Deed Notict;
JasperCrcwsolbig Company Federal Supgrfund Sift4
Renee Barron
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256415 B: OPR V: 1000 P: 980
05/20/2014 12:34:17 PM
Page 3 of 17
For additional information, contact:
TCEQ
Central Records
12100 Park 35 Circle, Building E
Austin, Texas 78753
Mail: TCEQ - MC199
l'.O. Box 13087
Austin, Texas 78711-3087
TCEQ Program and Identifier No: Superfund SUP044
EPA Program No, TXD008096240
This Deed Notice may be rendered of no further force or effect only by a superseding deed notice
executed by the TCEQ or its successor agencies and filed in the same Real Property Records as
those in which this Deed Notice is filed.
Executed this j \lay of , M014.
Texas Commission <111 Environmental Quality
Signature:.
ilssion <111 Euviromncnlnl Q
.juAA-
Printcd Name: Beth Seaton
Title: Director, Remediation Division
STATE OF TEXAS
COUNTY OK TRAVIS
BEFORE ME, on this the lay of M&L
2014, personally appeared Beth Seaton,
Director, Remediation Division of the Texas-Commission on Environmental Quality, known to
me to bo the person whose name is subscribed to the foregoing instrument, and she
acknowledged to me that she executed the same for the purposes and consideration therein
expressed.
. „ GIVEN UN DER MY HAND AND SEAL OF OFFICE, this the of
/Yldcj aoH.
MELISSA SEBEK
COf\ Notary Public
yKy STATE OF TEKAS
CommllilM Eip. OCT. II, Ml?
Notary without Bond
k£kiAM&
Signature, Notary Public in and for the Statopf Texas
Typed or Printed Name:
My Commission Expires: /kfdbtT' 3oj ,-}Q/7
Page 3 of,!
Demi Notice
Jasper Crcusutuig Company Federal Superfuml Site
A CERTIFIED COPY Pg 3 o?1?
AUest: 05/20/2014 12:46:1 \ PM
DEBBIE NEWMAN. COUNTY CLERK
jasperCoimty, Texas
Renee Barron
. Oeptty
C-12
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256416 B. OPR V: 1000 P; 981 05/20/2014 12:34:17 t'M Page 4 of 17
Exhibit A
Restrictive Covenant for Environmental Conditions
Jasper Creosoting Company Federal Superfund Site
Property Description
11.153 Acre Tract
C-13
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25S415 B; OPR V: 1000P 982 05/20/2014 12:34 17 PM Page 5 of 17
Mark Kirdwdl Surveying
POBon 1142
Hwy. 87 & Market
Hemphill, Twos 7594H
I'liune (.1119) 7B7-272Z
In* (489) 787-9986
State of Texas
County of Jasper
Legal Description
la a
II.1S3 Acre Tract
Being b legal description to 11.153 acre tract in the Thomas Green Survey A-158, Jasper County,
Texas and being all of a called 11.26 acre tract described in a Special Warranty Deed from Donald
Ray Ealand and Frank A, Ealand In Jasper Crewsoting Company recorded in Volume 284 Page 230
of the Deed Records (DR) of said eounly and is described by metes and bounds as follows lo-wit;
IWGINNING: At a 1/2" iron rod found for the Northeast comer oftliis tract,
the Southeast aimer of the remaining portion of Noilh Star RMS LLC. 's called
94,056 acre trad recorded in Volume 744 Page 759 Official Public Records (OPH),
and in the West itighl-of-Wity (ROW) line oro.C. & S.F. Railroad;
THENCE; S 21°03'54" W 2218,86" with (he West ROW of said railroad to a point
lor the Southeast corner of this tract;
THENCEI N 82°55'37" W 12.97' to a [joint for the Southwest comer of this tract
and in the East edge of McQueen Street;
THENCE: N 05°48'54" E 325.40' to a point for on angle comer oftliis tract;
THENCE; N 87°52"54" E 85,00' lo an interior angle comer of litis trad;
THENCE: N 16'M6'S4" E 179.30' to an interior angel comer oftliis tract;
THENCE: N 77*00'06" W 124.00" to an angle corner on llic West side of said rood;
THENCE: N 08°3I'(M" E411.57' with said road to an angle corner of this tract;
THENCE; S 77°06"37" E 201,70' to a Rail Road Iron found on or about the West
boundary line of tire Thomas Green Survey A-15S, and on or about the East
boundary line of Pamela Childers Survey A-102 for an angle comer of Ibis Intel;
found for an angle corner oftliis tract; front which a found concrete monument bears
N 77°40*59" W 211.30*
THENCE; N 20°00'00" E 46.3!)' continuing with said survey line to ti concrete
monument found for a interior angle corner for this tract;
THENCE: N 6G°39'22" W 130,81' to a point for an angle comer for this tract;
THENCE; N 30°4I'54" I- 193,50' to a point for an interior comer oftliis tract;
THENCE; N
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256415 0: OPR V: 1000 P; 983 05/20/2014 12:34:17 PM Page 6 of 17
THENCE: N 21 °01 '54" E 113.90' to a (joint for an interior angle corner of this tract;
THENCE; N 68°58'06" W 132.00* on the East side of McQueen Street to a point
for an interior angle comer of this tract;
THENCE: N 08°43'06" W 75.00' to a point in said street for an angle comer of this
tract.
THENCE; N 20°3I *06" E 378,32' with said street to a 1/2" iron rod found in the
approximate projected center line of Lynn Street for an angle corner of this tract and
the said 94.056 acre tract;
THENCE: N 23°03'I3" E 341.70' continuing with said street lo a 60D Nail found
for the Northwest corner of this tract and an angle corner of said 94.056 acre tract;
THENCE: S 70°51'28" E 179.07' to a 1/2" iron rod found for and angle corner of
said 94.056 acre tract;
THENCE: N 87°54'06" E 216,76* to the point of beginning containing 11,153
acres of land.
NOTE:
Surveyor did not abstract for title or easements and did not locate any underground
utilities.
All hearings herein recited are referenced to the Texas State Plane Coordinate
System (Central Zone) NAD 83 W\ the 99 Adjustment.
Reference is made to survey of plat of even date. If this document is not signed and
scaled in red, it is deemed void by the above signed.
Wm. MarkBirdwell
R.P.L.S #5148
September 16, 2013
Job#JASPER01 Drawing# J ASPER00J 1.153
C-15
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256415 B: OPR V: 1000 P; 984 05/20/2014 12:34:17 PM Page 7 of 1?
Exhibit B
Survey Plat to a 11.153 Acre Tract and to a
5.888 Acre Trad "Plume Management Zone"
A CERTIFIED COPY: Pg 7 ot 17
AI,Bst: 05/20/201 -1 12:48:11 PM
DEBBIE NEWMAN. COUNTY CLERK
Jasper County, Texas
Depuly
C-16
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256415 B; OPR V: 1000 P: 985 05/20/2014 12:34:17 PM Page 8 of 17
SURVEY PLAT
TO A
11.153 ACRE TRACT
BEUfi All OF CAIUO 11,26 AC. TR.
ACCORDED IN VOL, 284 PC. 211 CR
AWOA
5,888 ACRE TRACT
"PLUME MANAGEMENT ZONE"
GEIttG OUt OF AMD PA*T 0' SAID
iL!53A£Rf TRACT
IN Hit
THOMAS GREEN SURVEY A 158 P.
CHILDERS SURVEY A-102
JASPER COUNTY, TEXAS
SOUTHERN PORfIGN
OriHE R€MAMNGPOPTWNOf
NORTH STAfi RW^LIC
CAUE0540S6ACRKinACT
744PG.7S9 0PR
PCI 60X75'/
MSPfR. TX 75551
0*
POINT
mo vr jron rod
FND \a- JRON ROD
fNDftOONAIL
O - FNPCONCRF-l ffi MONUMENT
@ AXLG
— - BOUNDARY LINE
— « ADJOINING PROPERTY UOUNDAflY
— ^SURVEVLINE
— » ill BOUNDARY'
— -CfcNTF.R LINT. ROAD
— *» POWER UNC.
PZ^r/ZVsTZ] ~ PLUME MANAGEMENT AREA
PLUME MANAGEMENT £ONR(PMZ>
CONTAINMENT CELL
NAPL BOUNDARY
INFILTRATION TREMCHGS
UNDERGROUND MPE. IA»liR0U_
t'HJM f
ALL BEARINGS HIIKKiN RECITED ARB RJjreRFNCISrnOTHE
JfjCAS STATE PLANE CtJORD INAT6 SYSTEM (camzAL urn j
KAD 83 WV TUB 9? ADAJSTMElf f.
SURVEYOR DID HOT ABSTRACT FOR
TITLE OR BASEMENTS AND DID NOT
LOCATE ANY UNDEROROUND UTILITIES
TlifhttATE Of VPXAS
coumrt#*
IWM M«K BiRDWRit a p,c«i?Jtato mortssiONAl
WTHfcSIAlCOr J£.KA5.DOI>:--'?f:.»VC£BTlFV"^"'~
"JHUl V m At'CII* A1EI.Y OM'tfiS A SURV6V •
UAVUNDCR StY RlRPttS
12-97'
W»2^5'37-(v
¦ ?/ WJc /f- -
0'
200'
400'
eoo1
RfLS.. MHS
R5ffMMR ISM-NDCTOA ICfiAt.UFJfRifTKKf OFtVKN »A11
A CERTIFIED COPY: Pg 9 &f 17
Altost- O5tfOJ2014 12:46 12 PM
DEBBIE NCWMAN, COUNTY CLERK
. DrjiiHV
"0m ¦<
C-17
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256415 B' OPR V: 1000 P; 986 05/20/2014 12:34:17 PM Page 9 of 1?
Exhibit C
Legal Description to a 5.888 Acre Tract "Plume Management Zone"
A CERTIFIED COPY. Pfl9o117
Attest; D5H0H0H 12,48:12 PM
DEBBIE NEWMAN, COUNTY CLERK
Jaspsrjjounty, T« xns
er I2(UK*W--- DfiPytv
C-l 8
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256415 B: OPR V 1000 P: 9B7 05/20/2014 12:34:1? PM Page 10 of 17
Mark Birdwell Surveying
PO Box 1142
i)«) . 87 & Market
Hemphill, Texas 75948
rhmie (409) 787-2722
Fax (409) 787-9986
Thomas Green Survey
A- 158
Sale of Texas
County of Jasper
Legal Description
!o a
5.888 Acre Tract
"flume Management Zone"
Being a legal description to 5.888 Here tract (Plume Management Zone) in the Thomas Green
Survey A-158, Jasper County, Texas ami being out of ami part of a called 11.26 acre tract described
in a Special Warranty Deed from Donald Ray Enfant! and Frank A. Kaland to Jasper Creosoting
Company recorded in Volume 284 Page 230 of the Dees! Records (DR.) ofsoicl county, surveyed
this day to contain 11.153 acres of land, and is described by metes and bounds as follows to-vvit:
BEGINNING: A! a 1/2" uon rod found for the Northeast comer of this tract, the
Southeast corner of the remaining portion of North Star RMS LLCs called 94.056
acre tract recorded in Volume 744 Page 759 Official Public Records (OI'R), and in
the West Right-of-way (ROW) lineofO.C. & S.F, Railroad;
THENCE: S 2lo03'54" W 709.81' to a point for the Southeast corner of this tract, in
the West ROW line of said Railroad, and along the East boundary line of said 11.153
acre tract;
THENCE; N 29*01 *45" W I U.R2' to a point for an single comer if this tract;
THENCE". N 68"54*45" W 289.05' to a point for the Southwest comer of this tract;
THENCE; N 20"00*21" E 086,96' lo si point lor the NoMitwest earner of this tract
and along the North boundary line of snid 11.153 acre tract; from which a 60D nail
found lor the Northwest comer o f said 11,153 aero tract bears N 70°5I*28" W
17.03';
THENCE: S 70°51 '28" li 162.04*. to a 1/2" iron rod found for and angle comer of
this tract, an angle comer of said 11.153 acre tract, and an angle cornet of said
94.056 acre tract;
THENCE; N S7aS4 W E 216.76' to the point of beginning containing 5.888 acres
offend.
NOTE;
1.) Surveyor did not abstract for title or casements and did not locate any
underground utilities.
2.) All bearings herein recited are referenced to the Texas State Plane Coordinate
System (Central Zone) NAD 83 W\ the 99 Adjustment.
Reference is made to survey ofplal of even date. If Ibis document Is not signet! and
sealed in red, it is deemed void by (he above signal
CM 9
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256415 B: OPR V: 1000 P: 988 05/20/2014 12 34:17 PM Page 11 of 17
Exhibit D
Legal Description to a 3,152 Acre Tract "Containment Cell Area" with Survey Pint to a
3.152 Acres Total
A CERTIFIED COPY; Po 11 of 17
Atles! O5/2W2014 12:46:12 PM
DEBBIE NEWMAN, COUNTY CLERK
Jasper County, Texas
B r
¦K !)?/, ; k" l'i.Hi\ I i-A
, Deputy
C-20
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256415 B: OPRV: 1000 P: 689 05/20/2014 12:34:17 PM Paga12of17
Mark Birdwell Surveying
PO Bo* 1142
ttwy. 87 & Market
Hemphill, Texas 75948
Phone (409) 787-2722
Fax (409) 787-9186
Thomas Green Survey
Stale of Texas
County of Jasper
A- 158
Legal Description
to a
3,151 Acre Trail
"Containment Cell Area'
Being a legal description to 3.152 acre tract in the Thomas Green Survey A-158, fcper County,
Texas and being out of and part of it called 11,26 acre tract described in a Special Warranty Deed
from Donald Ray Enland and Frank A. Etilnnd to Jasper Cteosoting Company recorded in Volume
284 Page 230 ofthe Deed Records (DR) of said county surveyed this day to contain 11.153 acres of
land, and is described by metes and bounds as follows to-wit:
BEGINNING: At a fence corner post found for the Northeast comer of (his tract;
from which a W iron rod found for the Northeast comer of said 11,153 acre tract
bears N 34028WB 343.1 1';
THENCEl S 19°08*01" W 488,25' to a fence comer post found for the Southeast
comer of this tract;
THENCE: N 7I°49'44" W 282.40' lo a fence corner post found tot the Southwest
comer of this tract;
THENCEi N 19°55*12" E 496,08' to a fence comer post found for the Northwest
comer of this tract; front which a COD nail found in the Pavement for the Northwest
corner of said 11,153 acre tract bears N M°49,54"E 265,13';
TIIBNCE; S 70"i4'10" E 275.71' to the point of beginning containing 3.152 acres
of land.
NOW:
1.) Surveyor did not abstract for title or easements and did not locate any
underground utilities.
2.) All bearings herein recited are referenced to the Texas Stale Plane Coordinate
System {Central Zone) NAD 83 VA the 99 Adjustment.
Reference is made to survey of pint of even date. If this document is not signed and
scaled in red, it is deemed void by the above signed,
h CERTIFIED COPY; Pg 12 of i l
C-21
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256415 B: OPR V: 1000 P: 990 05/20/2014 12:34:17 PM Page 13 of 1?
A CERTIFIED COPY pfl UoP 17
AU?st; 059W2014 12:46 12 PM
OeaBfE NEWMAN, COUNTY CLERK
Jaspsr Couf%, Texas
By
'c
€-22
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256415 B: OPR V: 1000 P; 991 0500/2014 12:34:17 PM Page 14 of 17
Rxlilbil E
Maintenance and Monitoring Program for the Engineered Control and the oilier
Remedial Components on the Affected Property
A CERTIFIED COPY: Pg M o( 17
Attest; 05/20/2014 12:46:12 PM
DEBBIE NEWMAN. COUNTY CLERK
Jasper County, Texas
} .. '"""'l
By: ,A**i )nUij' A' t sit ,\UA . Deputy
C-23
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256415 B; OPRV; 1000 P: 992 05/20/2014 12:34:1? PM Page 15 of 17
MAINTENANCE AN!) MONITORING PROGRAM FOR THE ENGINEERED
CONTROL AND THE OTHER REMEDIAL COMPONENTS ON THE
AFFECTED PROPERTY
Jasper Creosotirig Company Federal Superfund Site
5.88B Acre Tract "Plume Management Zone"
3,15a Acre Tract "Containment Cell Area"
The Texas Commission on Environmental Quality (TCEQ) will implement a maintenance
and monitoring program for each clement of the engineered control and eacii element of
the other remedial components on the Affected Property as detailed below.
Tile soil cap overlays the Containment Cell Area and is part of the engineered control on
the Affected Property and is located on 3,152 Acres out of 11.153 Acres of the Property as
depicted in Exhibits B and D and described in Exhibit D. The point of access for
sampling ofleachate collected In the containment cell underneath the soil cap is an in-
ground concrete vault located at the southern end of the containment cell ns depicted in
the attached Exhibits B and D. The concrete vault provides access to an 18-lnch
diameter leachate collection system (ICS) pipe and a 12-inch diameter leachate detection
system (LDS) pipe. TheTCEQ's maintenance and monitoring program will include the
following activities:
¦Inspection and maintenance of the vegetative cover on the soil cap to ensure that the
cap remains in place and is not disturbed or eroded, the vegetative cover remains intact,
and fire ant mounds are treated so that the soil cap continues to prevent human
exposure to soil and groundwater with chemicals of concern (COCs) above critical
protective concentration levels (1'CI.s).
¦Regular upkeep and repair of the soil cap, including maintaining the grass cover over
the cap and mowing the grass as needed. Regular inspection and maintenance of the
concrete pad and pipes as needed,
The groundwater recovery and treatment system is a part of the engineered control on
the Affected Property, The groundwater recovery and treatment system includes other
remedial components: above-ground piping, underground piping, pumps, Waste Water
Treatment Plant (WWTP), storage tank area, and infiltration trenches. The features of
the groundwater recovery and treatment system are located on the Affected Property as
depicted on Exhibit B,
The underground piping is located on 5-888 Acres out of the 11.153 Acres of the Property
between the WWTP building and tank storage area. The WWTP building is located on
the Affected Property in the west, center of the Affected Property as shown on Exhibits 1!
and D marked as BLDG. The storage and treatment tanks arc located inside the WWTP
building.
Rerteo Bniroil
C-24
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256415 B: OPR V; 1000 P: 993 05/20/2014 12:34:17 PM Page 16 of 17
The TCEQ's maintenance and monitoring program will include the following activities:
¦inspection and maintenance of the groundwater recovery and treatment system and its
remedial components to ensure that the system and its components remain in place and
are not disturbed. This will ensure that the groundwater recovery and treatment system
and Its remedial components continue to treat the groundwater containing COCs above
PCLs and continue to prevent human exposure to groundwater with COCs above PCLs.
•Regular upkeep and repair of the groundwater recovery and treatment system and its
remedial components as needed.
.1.) Infiltration Trench
An infiltration trench is located on the Affected Properly as shown on Exhibit li. Hie
TCEQ's maintenance and monitoring program will include the following activities:
•Inspection and cleaning of the infiltration trench to ensure the trench continues to be an
effective component of the groundwater treatment system.
•Regular upkeep and repair of the infiltration trench will be completed as needed.
4.1 Monitoring Wells
Monitoring Wells, MW-ii and MVV 21, are located on the Affected Properly as shown on
Exhibit B, The TCEQ's maintenance and monitoring program will include the following
activities:
•Inspection and maintenance of the monitoring wells to ensure the monitoring wells
continue to be effective in monitoring the groundwater in order to prevent human
exposure to groundwater with COCs above PCLs.
•Sampling of the water from the monitoring wells located on the Affected Properly, to
ensure that the plume management xone (PMZ) boundary remains stable and is not
expanding and that groundwater with COCs above PCLs remains at current levels or
decrease in order to prevent human exposure to the groundwater with COCs above PCLs.
• Regular upkeep and repair of the monitoring wells will be completed as needed.
The TCEQ's maintenance and monitoring program will include inspecting the Affected
Property to ensure that the Affected Property is being used for commercial/industrial
land use only.
The frequency, scope, and duration of the maintenance and monitoring activities under
this program will be established and adjusted or revised by the TCEQ as appropriate to
ensure the continued effectiveness of the engineered and institutional controls designed
to protect human health and the environment. This program will be initiated and
implemented in accordance with the schedule approved by the TCEQ, including any
subsequent modification.
C-25
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256415 B: OPR V: 1000 P: 994 05/20/2014 12:34:17 PM Page 17 of 17
FILED AND RECORDED
Instrument Number; 2S6415 a: OPR V: 1000 P: 978
Filing and Recording Dale; 05/20/2014 12:34:17 PM Pages: 17 Recording Fee; $86,00
I hereby certify thai this instrument was FILED on (tie dale and Urns stamped heron and
RECORDED in (ha PUBLIC RECORD of Jasper County, Texas.
«
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Figure C-6; Excerpts From a 2014 TRRP Restrictive Covenant for an Off-Site Property
$o{>at{L(7£Acf$>3
*256418 Bi OPH-Vi t0W P> 1028 HISC ' ""
mmmu xtiu m Total r**i 74.09
D(M>la 6ft. County Cieffc - 3»9p*r C«unly, fo*?s
I ii Miimmitfim nw mm ¦ ii
Texas Bjsk RnmicnoN Proqimm '
IinsTwcnvK Covenant foii envi ronm bntaj . conditions
STATE OF TEXAS §
§
COUNTY OF JASPER §
This Restrictive Covenant for Environmental Conditions is filed to provide Information
concerning certain environmental conditions and use limitations pursuant to the Texas
Commission on Environmental Quality (TCEQ) Texas Risk Reduction Program (TRRP} Rule
found at 30 Texas Administrative Coda (TAC), Chapter ago, and affects the real property
(property) described on Exhibit A end shown on Exhibit B, which are attached hereto and
incorporated herein by reference.
Portions of the groundwater underlying the Properly contain certain identified chemicals of
concern, causing those portions of fee Property to be considered an Affected Property as that
term is defined in the TRW, Hie portion considered to be the Affected property is described on
Exhibit C and shown on Exhibit B, which are attached hereto and Incorporated herein by
reference.
This Restrictive Covenant for Environmental Conditions is required tor the following reasons:
i» The Affected Property Is subject to the TrRP requirements for properties where the
concentrations of chemicals of concern in the groundwater exceed Ihe TCEQ-approved
protective concentration levels. The TCEQ concurred thai It Is not feasible from a
physical perspective using currently available remediation technologies due either to
hydrogeologie or chomicaL-speeifia factors to reduce the concentration of these chemicals
of concern throughout all or a portion of the groundwater affected by the chemicals to
the TCEQ-appioved protective concentration levels within a reasonable time, The
attached Bxhibit B provides the location and extent of the groundwater exceeding TCEQ-
appioved protective concentration levels In the Technical Impracticability Zone CTIZ).
Within the TJZ, the groundwater under the Affected Property contains a tody of Non-
Aqueous Phase Liquid (NAPL) as depicted in a conceptual drawing on the attached
Exhibit B, NAPL is defined as a liquid solution, in this case comprised of oreosoting
hydrocarbon constituents, that does not dissolve readily In water. Those immiscible
hydrocarbons in tho subsurface can partially dissolve into the groundwater at very slow
rates, but they are anticipated to remain in the subsurface for exceedingly long periods of
time,
2, The Affected I'roperly is subject to the TRRP requirements for properties with an area
overlying a TCliQ-approved plume management zone. A plume management zone Is
defined as an area of groundwater containing concentrations of chemicals of concern
exceeding the TCEQ-approved protective concentration levels, plus any additional area
allowed by the TCEQ in accordance with 30 TAC §350,33(0(4). A plume management
zone was established so that the chemicals of concern in the groundwater iwa managed
such that human exposure Is prevented and oilier groundwater resources are protected.
The attached Exhibits B and C provide the location and extent of the plume management
zone.
Page 1 of "I
Restrictive Covenant for Environmental Conditions
Jaipur Greosoling Company Federal Supetfnr.'J Site
ACERTIFIED COPY: P01 0(14
Attest; OSKOffiQU 12:63:22 PM
DEBBIE NEWMAN, COUNTY CLERK
Jasper County, T«M "
4Dapi%
C-27
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256418 B:OPRV: 1000 Pi 1027 05/20/2014 12:34:1/ I'M Pago 2 of 14
tte attached Exhibit D describes the required OMinteuaneo and monitoring for each remedial
component, This maintenance and monitoring will be implemented unless and until TCEQ
approves any modification.
The following is a list of chemicals of concern that exceed protective concentration levels in the
groundwater witMn the Affected Property; arsenic; icon; thallium; vanadium; acenaphtlwne;
beMo(a)anthracera; ben?o(a)pyrenc; benzofljjfluoranthane; benzo(k)HuoranthsM; chrysene;
dlbenz(a,!i)anthraoane; indiino{i,a,3-c,
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266418 B: OPR V: 1000 P: 1028 05/20/201412:34:17 PM Page 3 of 14
This Restrictive Covenant for Environmental Conditions may bo rendered of no further force or
effect only by a release executed by the TCEQ or its successor agencies and filed lit the same Real
Property Records as those In which this Restrictive Covenant for Environmental Conditions is
fill
Executed this oU day of Fah , 8014.
Nortli Star RMS, LLC
o:. J&uL
Signature:.
J
Printed Name: it/t> b C^i/^
Tithr.^/nPjVL^.e.f: .j/.MXj-C-
Accepted as Third Party Beneficiary this |"3 day of 37S
Pegu 3 of 4
Restrictive Covcnml Jbr Environment*! Conditions
Jasper Crtttoting Company federal SttperAittd Site
@
A CERTIFIED COPY; Pfl 3 Of 14
Attest: 05/20/2914 12:63:22 PM
DEBSli NEWMAN, COUNTY CLERK
.iBaporftfUflty. T8«|S
(.'-29
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258418 B; OPRV: 1000 P; 1029 05/20/201412:34:17 PM Page 4 of 14
STATE OF TEXAS
COUNTY OFTRAV1S
BEFORE ME, oil this the _
Director, Remediation Division of the TexoaSmmisslon on Envjroumental Quality, known to
me to be the person whose name is subscribed to the foregoing instrument, and they
acknowledged to me that they executed the same for the purposes and consideration therein
expressed.
ay of.
J%L_
"ex os'Coil
2oi4, personally appeared Beth Scaton,
GIVEN UNDER MY HAND AND SEAL OP OFFICE, tills the /J day of
MlU ,MU.
T
A
MELISSA SBBGK
Notary FiiMc
STATE OF TEXAS
CoamlMlon E*|>, 0C£ JJ, H7
Notary without BoiwJ
Signature, Notary Public in an^ for tlie State of wwn
Typed or Printed Name:./ * '
My Commission Expires:,
Ptgo 4 of 4
ReslricUvj CttVwnnt for Envlionmanlul Condlliim
taper Creosotlng Company Fedttal Supermini She
#A certified COPY; Pb 4 of 14
AlUlt: OSOT/iiOI-i 12I53.2R PM
DEBBIE NtWMAN, COUNTY CI
C-30
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266418 B; OPR V; 1000 P: 1038 05/20/201412.34 17 PM Page 13 of 14
Jasper Creosoting Company Federal Soperftmd Site
2,416 Acre Tract
The Texas Commission on Environmental Quality (TCEQ) will Implement maintenance
nnd monitoring program for each element of the remedial components on the Affected
Property as detailed below.
Monitoring Wells, MW-S and MW-12, are located on the Affected Property as shown on
Exhibit B, The TCEQ's maintenance and monitoring program wilt Include the following
activities:
•Inspection and maintenance of the monitoring wells to ensure the monitoring walls
continue to ba effective in monitoring the groundwater In order to prevent humnn
exposure to groundwater with chemicals of concern (COC) above protective
concentration levels (FCLs),
•Sampling of lire water from the monitoring wells located on the Affected Properly to
ensure that the plume management zone (I'MZ) boundary is not expanding and that
groundwater with COCb above PCLs continues to be treated in order to prevent human
exposure to the groundwater with COCs above PCLs.
•Regular upkeep and repair of the monitoring wells will be completed as needed.
The frequency, scope, and duration of the maintenance and monitoring activities wider
this program will ba established and adjusted or revised by the TCEQ rs appropriate to
ensure the continued effectiveness of the engineered and inntltntlonal controls designed
to protect human health and the environment, This program will be initialed and
Implemented In accordance with the schedule approved by the TCEQ, including any
subsequent modification.
A CERTIFIED COPY'. P913 of 14
A1te«to6/20fi014 12:83:24 PM
DEBBIE NEWMAN, COUNTY CLERK
C-31
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APPENDIX D - PRESS NOTICE
Jasper Creosoting Company and Hart Creosoting Company Superfund Sites
Public Notice
U.S. Environmental Protection Agency, Region 6
The U.S. Environmental Proiection Agency Region 6 (EPA) will
be conducting the Second five-year reviews of the
implementation and performance of the remedies at the Jasper
Creosoting Company and Hart Creosoting Company Super-fund
sites in Jasper, Texas.
Jasper Creosoting Company
From 1946 to 1986, a wood-treating facility operated at the 11.3-
acre site. Facility operations contaminated soil, sediment, surface
water and groundwater with polycyclic aromatic hydrocarbons
(PAIls), pentaehlorophenol (PCP) and dioxini/fttrans. EPA added
the site to the Superfund program's National Priorities List (NPL)
in July 1998. Between 1996 and 2006, three removal actions by
EPA addressed immediate threats to human health and the
environment. The removal actions involved the construction of a
Resource Conservation and Recovery Act (RCRA) containment
cell (RCC) and the excavation and removal of contaminated soil,
sediment and surJface water firom a drainage ditch, wetland water
inlet area and waste eel!. EPA disposed of the contaminated
media in the RCC. HPA selected the site's long-term remedy in a
2006 Record of Decision (ROD). It included land and
groundwater use restrictions, construction aud opjrctxion of a
hydraulic containment system and dense aon-aqueous phase
liquid (DNAPL) recovery system and long-term groundwater
monitoring. Hie remedy also included the establishment of a
technical impracticably zone (TIZ) where restoration of
groundwater quality to drinking water standards is not required.
Hart Creosoting Company
From 1958 to 1993, a wood-treating facility operated at the 23.4-
acre site. Facility operations contaminated soil, sediment,
groundwater and surface water with creosote and PCP. A 1995
removal action by EPA addressed immediate threats to human
November 2017
health and the environment. The removal action involved the
drainage of four waste disposal ponds, sludge stabilization, and
the consolidation and placement of the sludge and visibly
contaminated soil in a natural clay-lined temporary waste cell on
site. EPA added the site to the NPL in July 1999. EPA selected
the site's long-term remedy in a 2006 ROD. It included removal
and treatment of contaminated surface water, excavation of
impacted soil and sediment and placement of the materials in an
on-site RCRA containment cell, land and groundwater use
restrictions, and long-term groundwater monitoring. The remedy
also included the construction and operation of a DNAPL
recovery system and the establishment of a TIZ where restoration
of groundwater quality to drinking water standards is not
required.
The five-year reviews will determine if die remedies arc still
protective of human health and the environment. The fivc-yeai
reviews are scheduled for completion in September 2018.
The reports will be made available to the public at the following
local information repository;
Jasper Public Library
175 Water Street
Jasper, Texas 75951
(409)384-3791
Site status updates arc available on the Internet «t
https:/'Www.iii>a.Ct>v'supcifiifid/te^pa-creowti?a.uovfeupiTttmril1liirt-<^«nsnt«ip
All media inquiries should be directed
to the EPA Press Office at (214) 665 2200
For more information about the sites, contact
Bob Sullivan/Remedial Project Manager
(214)665-2223
or I-800-533-350S(toJl-free)
or by email at s
Andy Bajwa/TCEQ Project Manager
(713)422-8926
or by email at i
Janettii Coats/Community Involvement Coordinator
(214) 665-7308
or 1-800-533-3508 (toll-free)
or by email at coats. i anctta@epa. pov
D-l
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APPENDIX E - INTERVIEW FORMS
Jasper Creosoting Company, Inc. Five-Year Review Interview Form
Superfund Site
Site Name: Jasoer Creosotine Commuiv, Inc.
EPA ID No.: 1X1)008096240
Interviewer Name: Erie Marsh
Affiliation: Skeo
Subject Name: Denise Kellv
Affiliation: Jasper Citv Manager
Subjeet Contact Information:
Time: 9:00 A.M.
Date: 12/7/2017
Interview Location: Jasper City HaU
Interview Format (circle one): (^hPerson^)
Phone Mail Other:
Interview Category; Local Government
1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken
place to date?
Yes,
2. Do you feel well-informed regarding the Site's activities and remedial progress? If not, how might EPA
convey site-related information in the future?
Yes, very informed.
3. Have there been any problems with unusual or unexpected activities at the Site, such as emergency
response, vandalism or trespassing?
No. The city is there all the time and we would see any problems.
4. Are you aware of any changes to state laws or local regulations that might affect the protectiveness of the
Site's remedy?
No.
5. Are you aware of any changes in projected land use(s) at the Site?
No.
6. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can
EPA best provide site-related information in the future?
Yes. I have all relevant contact info.
7. Do you have any comments, suggestions or recommendations regarding the project?
No, the O&M manager has always been great to work with. Our city workers are very observant, so
there's never any issues.
E-l
-------
Do you give permission for the following to be included in the FYR Report and appendices, which
becomes a public document? Please initial below,
a) Your name? Yes X No
b) Your affiliation? Yes X No
c) Your responses? Yes X No
E-2
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Jasper Creosoting Company, Inc. Five-Year Review Interview Form
Superfund Site
Site Name: Jasper Creosoting Comoanv, Inc.
EPA ID No.
: TXD00S096240
Interviewer Name: Eric Marsh
Affiliation:
Skeo
Subject Name: Mark Allen
Affiliation:
Jasoer County Judge
Subject Contact Information:
Time: 10:30 A.M.
Date: 12/7/2017
Interview Location: Jasoer Citv Hall
Interview Format (circle one): (^nPerson^)
Phone
Mail Other:
Interview Category: Local Government
1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken
place to date?
Yes.
2. Do you feel well-informed regarding the Site's activities and remedial progress? If not, how might EPA
convey site-related information in the future?
So far, so good. It's been going on for a while.
3. Have there been any problems with unusual or unexpected activities at the Site, such as emergency
response, vandalism or trespassing?
No.
4. Are you aware of any changes to state laws or local regulations that might affect the protectiveness of the
Site's remedy?
No.
5. Are you aware of any changes in projected land use(s) at the Site?
No.
6. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can
EPA best provide site-related information in the future?
Yes, EPA comes and talks to me every five years.
7. Do you have any comments, suggestions or recommendations regarding the project?
EPA and TCEQ are doing a great job.
-------
8. Do you give permission for the following to be included in the FYR Report and appendices, which
becomes a public document? Please initial below.
a) Your name? Yes X No
b) Your affiliation? Yes X No
c) Your responses? Yes X No
E-4
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Jasper Creosoting Company, Inc.
Superfund Site
Five-Year Review Interview Form
Site Name; Jasper Creosoting Company, Inc.
EPA ID No.: TXD008096240
Interviewer Name:
Affiliation:
Subject Name: Darren Davis
Subject Contact Information:
Time:
Date: 5/11/2018
Affiliation: C1I2M HILL
Interview Location:
Interview Format (circle one): In Person Phone Mail
Other:
Interview Category: EPA LTRA Contractor
1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?
The groundwater extraction and treatment system successfully meets the treatment criteria for the
dissolved phase contaminants in groundwater. Surface water and sediment data collected from Sandy
Creek show that the creek is not impacted above the remediation goals set in the ROD.
2. What is your assessment of the current performance of the remedy in place at the Site?
The groundwater extraction and treatment system continues to perform as expected. Annual operational
uptime continues to be above 85%, and the system meets the treatment requirements for discharge. Sandy
Creek continues to be protected. NAPL is present in both light and dense phases, and is highly emulsified,
which has made separation from the groundwater difficult. After testing several methods, the current
system being pilot tested has allowed for operation of the recovery trench (R-10) and well R-l 1, and
removal of NAPL. NAPL removal from the hydrostratigraphic zones P-l and P-3 will accelerate progress
of the remedy.
3. What are the findings from the monitoring data? What are the key trends in contaminant levels that are
being documented over time at the Site?
. Sampling of surface water and sediments demonstrates that there are no impacts to Sandy Creek above
remediation goals from the site. Groundwater monitoring results indicate the following:
a. The capture zone for recoveiy well R-4 does not span the full width of the dissolved phase plume
allowing the plume to migrate towards recoveiy well R-5. Per the remedial design, recoveiy well R-5
was expected to operate for only a few years.
b. Significant NAPL remains in the area underlying the railroad tracks,
4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities.
Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if
there is not a continuous on-site O&M presence.
There is an operator onsitc five days a week. He splits his time between the Hart Creosoting Company
site and the Jasper Creosoting Company Site, which results in an overall cost savings to both projects. He
also has the ability to monitor the system remotely. Responsibilities include maintaining and operation of
the groundwater extraction and treatment system.
5.
I lave there been any significant changes in site O&M requirements, maintenance schedules or sampling
routines since start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of
the remedy? Please describe changes and impacts.
-------
The NAPL management system currently being pilot tested has been in operation since July 2017. The
system has been successful at separating LNAPL recovered from wells R-l, R-l 1, and the recovery
trench (R-10). All recovery wells and the recovery trench have been operating since that time. Due to the
absence of NAPL, extracted groundwater from well R-l is no longer being processed through the NAPL
management system. The first treatment vessel in each treatment train inside the water treatment plant
was initially filled with organoclay and then zeolite. Both medias had swelling issues and the treatment
system required more downtime due to a higher backwash frequency. In addition, neither media provided
the desired contaminant removal rates (both were less than 5%), so the first vessel was changed to hold
granular activated carbon. The change-out schedule for the granular activated carbon has remained
unchanged with the increase in pumping and higher contaminant concentrations in the groundwater being
treated. The majority of the site monitor wells are now sampled annually instead of semiannually.
Sampling of surface water and sediment was implemented as recommended by the first five-year review.
6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If
so, please provide details.
The biggest challenge has been the presence of LNAPL and DNAPL and the highly emulsified nature of
both. It has taken time to find a system that has been able to separate both from the groundwater. Also,
the majority of the recoverable NAPL at the site is present beneath the railroad tracks. The location
restricts the ability to recover the NAPL or utilize in-situ methods to address the NAPL.
7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes
and any resulting or desired cost savings or improved efficiencies.
Changing from semiannual to annual sampling at most monitor wells has resulted in approximately
$20,000 annually in cost savings. A new vendor was found for the cartridge filters used, resulting in
approximately $ 19,000 per year in savings. Also, better cartridge filter performance has decreased
downtime associated with high pressure alarms. A compressor was added to the system to operate the
pneumatic pumps in the NAPL recovery wells (R-10 and R-l 1), replacing use of compressed gas
cylinders. The cost impact has been minimal, but it has eased the operation of the system.
8. Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at
the Site?
None at this time.
9. Do you give permission for the following to be included in the Five-Year Review Report and appendices,
which becomes a public document? Please initial below.
a) Your name? Yes X No
b) Your affiliation? Yes X No
c) Your responses? Yes X No
E-6
-------
Jasper Creosoting Company, Inc.
Superfund Site
Five-Year Review Interview Form
Site Name: Jasper Creosoting Company.. Inc. EPA ID No.: TXD008096240
Interviewer Name: .
Subject Name: Andy Bajwa
Subject Contact Information: _
Time: _
Interview Location:
Affiliation:
Affiliation:
TCEO Project Manager
Date:
5/9/2018
Interview Format (circle one);
In Person
Phone
Mail
Other: (Email)
Interview Category: State Agency
1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?
Although the groundwater containment and DNAPL recovery aspects are not operating as intended, the
Site's remedy is currently protective of human health and the environment. Additional actions are needed
for the remedy to be protective over the long term.
2. What is your assessment of the current performance of the remedy in place at the Site?
Hydraulic containment system for groundwater - The EPA has been performing LTRA for groundwater at
the Site since 2008. Due to several issues, such as the unforeseen presence of ail emulsion, the
groundwater removal system has seldom operated at its design flow rate and the hydraulic containment
system lias not prevented plume expansion and migration of COCs in groundwater.
DNAPL Removal - The DNAPL recoveiy system has been mostly ineffective in recent years and needs
to be optimized as well.
RCRA Containment Cell - The remedy included excavation of soil and sediment containing COCs from
the former process area and tributaiy, and consolidation of contaminated site media into the RCC. The
TCEQ performs O&M activities that involve RCC cap inspection and maintenance. The TCEQ believes
that the RCC is performing as it was designed,
3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial
activities from residents in the past live years?
No.
4. Has your office conducted any site-related activities or communications in the past five years? If so,
please describe the purpose and results of these activities.
As part of the O&M Plan, the TCEQ has been performing RCC inspections on a semi-annual basis since
2010. The TCEQ O&M activities include: semi-annual inspections of the RCC and adjoining areas to
verify the integrity of the cell; checking the vegetation on the cap to insure it is providing adequate
protection from erosion or cracking to the cap; measuring leachate levels; and, inspecting the condition of
the fence, gate and signage. In 2013, the TCEQ pumped approximately 21,000 gallons of leachate from
the LCS and LDS that was then treated and disposed by the onsite water treatment system. As part of the
routine maintenance of the landfill cap, the TCEQ has scheduled leachate removal to occur before the end
of August 2018. Also, the TCEQ is planning to modify the access area for the LCS and LDS so that
leachate measurement can be performed without entering a confined space.
lv-7
-------
5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy?
No,
6. Are you comfortable with the status of the institutional controls at the Site? If not, what are the associated
outstanding issues?
Yes.
7. Are you aware of any changes in projected land use(s) at the Site?
No.
8. Do you have any comments, suggestions or recommendations regarding the management or operation of
the Site's remedy?
Due to the problems with implementation of the groundwater containment and DNAPL removal remedies,
the TCEQ believes that the LTRA period should be extended. Although the EPA is currently conducting
an optimization study, the TCEQ fears that the costly and mostly ineffectual systems will be simply
turned over to the TCEQ to operate when the LTRA period expires in 2020.
9. Do you give permission for the following to be included in the Five-Year Review Report and appendices,
which becomes a public document? Please initial below.
a) Your name? Yes X No
b) Your affiliation? Yes X No
c) Your responses? Yes X No .
E-8
-------
Jasper Creosoting Company, Inc. Five-Year Review Interview Form
Superfund Site
Site Name: Jasper Creosoting Company, Inc. EPA ID No.: 1X1)008096240
Interviewer Name: Affiliation: :
Subject Name: Chuck Neelev Affiliation: AECOM
Subject Contact Information: Phone: 512-419-6295
Email: chuck.neelev@aecom.com
Time: Date: 5/8/18
Interview Location: By Email ;
Interview Format (circle one): In Person Phone Mail Other: (Kmaii)
Interview Category: State O&M Contractor
1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?
O&M activities of the RCRA cell are performing as intended.
2. What is your assessment of the current performance of the remedy in place at the Site?
O&M activities are effective,
3. What are the findings from the monitoring data (if applicable)?
Leachate levels and cap are monitored semi-annually. The cap is mowed semi-annually as well.
4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities.
Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if
there is not a continuous on-site O&M presence.
AECOM staff perform inspections of the RCRA cell and measure leachate twice per year.
5. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling
routines since start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of
the remedy? Please describe changes and impacts.
Leachate removal and treatment is proposed for the site this fiscal year. The cap is mowed semi-annually
as well.
6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If
so, please provide details.
No.
7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes
and any resulting or desired cost savings or improved efficiencies.
No.
8. Do you have any comments, suggestions or recommendations regarding O&M. activities and schedules at
the Site?
E-9
-------
Leachate removal.
Do you give permission for the following to be included in the Five-Year Review Report and appendices,
which becomes a public document? Please initial below.
a) Your name? Yes CBN No
b) Your affiliation? Yes CBN No
c) Your responses? Yes CBN No :
E-10
-------
APPENDIX F - ADDITIONAL FIGURES AND 2016 MONITORING RESULTS
Figure F-l: Surface Water Monitoring Locations
F-l
-------
Table F-l: TP AH Concentrations In Groundwater, 2008 to 2016
Table 3-4. Groundwater Total Ptrfycyeftc AromaSk Hydrocarbon CoiKcntrsttori Summary
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F-2
-------
TaW« 3-4, GraimdvwatarTotil Polyeycik Aromatic Hydrocarbon Concentration Summary
Miefcoint Screen
Total PAH Cefveetitration {jig/L}
WeJi
2one
Elevation (feet)
Jus-06
Dee-OS
ton-OS
Jun*10
Am-U
May-12
May-13
Nov-13
May-14
Nsv-14
luo-lS
Notf-lS
Marl®
Nw-16
MW-1S-2
P-3
192.0
ws
1,440
4,770
4,300
2,450
1,730
2,270
1,970
X8QQ
4,340
5,290
SJ10
3,550
6,140
MW-1S-3
P-3
185.0
NS
5,303
262
8
56 U
i
41
46
IS U
116
123
m
30 U
129
MW-1S-4
P-3
177.0
m
6,180
30
S
28 U
3
56
33
2S
50
50
69
31
29
MW-1S-5
P-3
163,0
NS
1,270
2S U
17
31
1
57
21
20 U
S3
S3
62
5S J
31
MW-1S-6
p-3
161.0
27 U
1 J
2
1
21
1
41
42
40
52 Jv
66
77
63
41
MW-1S-7
P-3
153,0
25 U
14
5
I
21
16
30
23
2S JV
2$
46
90
92
117 u
MW-20
P-3
IBS,6
%.m
KS
70
2,920
271
1310
610
177
330
XSSO
3,530
5,420
S3S
NS
MW-21
P-3
2153
2370
NS
5,240
8,010
1,S30
2,260
5,210
5,310
5,300
6,020
4,440
NS
5,720 J
NS
MW-22
P-3
13L1
Ni
NS
Hi
6,730
20,400
4,460
4,460
3,650
MS
NS
3,480
7.270 J
3.970 1
NS
ws
R-l
P-3
2S9.S
NS
4,930
NS
NS
Sr2S0
X1.SC0
NS
5.440
6,950
7,990
17,800
J
NS
NS
NS
R-2
P-3
184.5
NS
41
NS
m
408
SSS
NS
1,100
S7S
7SS
11,000
1
NS
MS
NS
R-3
P-3
IMA
NS
7,720
NS
NS
7,360
SfSQ0
NS
6,420
6,330
7390
9,670
1
NS
NS
NS
R-4
P-3
ms
NS
4,2*0
NS
NS
NS
NS
NS
2*550
NS
3.S50
2,760
J
1,110
NS
NS
R-5
P-3
173*
NS
4410
NS
NS
460
129
NS
S?
m
1,100
47
J
115
NS
NS
R-6
P-l
212.1
NS
3,690
NS
NS
10,SOD
39S
NS
9,410
4,450
6,220
22,500
J
NS
NS
NS
ft-7
P-l
2123
NS
6,360
NS
NS
2.S70
3,410
NS
4,500
m
2,130
7,170
i
NS
NS
NS
Ml
P-3
199.9
NS
NS
NS
NS
m
NS
237,000
12.000
a mo
24,300
531,000
j
NS
NS
NS
Irsfilttation Trench
P-l
212.0 lestlowie^
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Notes:
*Fieid dupFfcate result was 250 w/l
Ftesu Its for parent samples are shown
S^g/L » microgram per liter
J a TMf analyte was positively identified; the result is estimated.
Jv s The analyte was positively detected- the result: t lew biased.
L=The anatyte was positive^ identified, but the associated numerical value may be biased low.
N5 = net sampled
PAH-polvcyclte aromattc hydrocarbon
y = The anatyte was analyzed for but not detected.
F-3
-------
Table F-2: VOC and SVOC Concentration in Groundwater, 2016
Table 3-3, Yew 201S Groundwater VOC and SVCC laboratory Analysis Summary
topper CreGSOim Comport SupetfaM 5>te, sospet, Texm
RemetDil Goat
(2006 ROQ)
¦ftitalytt
S/23/2016
S/23/201S
S/lS/2016
S/24/201&
5/13/2516
5/23/231S
5/19/2016
5/15/7016
S/23/20I6
Benzene
Xylgrtftlm.p)
svoc-raarfaw*
Tola! PAH
TnM I.PAH
rof.il HfAH
MP Tig
WA
Hg/l
707
es.6
"""'"139'j"
2 u
4 U
2 (I
4 U
2 II
4 U
Z U
4 U
«buL
a?i"
2 U
4 II
2 U
4 U
MfiA
veA
veA
EgA-
NS
NS
NS
NS
NS
NS
NS
KS
7&3G J
JfilO !
).1,7
0 II
•8??0
8730
51.7
0 U
18 I?
10.? Ii
7^2 1.1
QU
iO.S u
fi.fr U
24.? U
SU
500
2iM\3
Q U
18 31
101 u
J£S o
on
18.1 U
10.1 II
7.83 U
DU
GiSQ
6550
57.6
OU
ia.7 u
m« u
7.82 ii
q u
18.1 M
10.3 IJ
7.8S U
0 U
2 y
4 u
20 u
11 8 n
8.18
8 U
5/23/201*
2 U
4 U
16,1 U
*U4 »
?.»5 (J
0 U
SM3C - iw Mateeaiar Wtight PAHs
HuOfPMC' Jl£/l MS
Acen.ipWhpfi* \if/i 130
AtetMpWhykms jig/l NS
Anthracene pg/i NS
NapWJwfcrw pgfl 10Q
Phenanthieno wA- 29®
SVOC - tfgfr Moleatfar Weighs PAHi
m
J S3
1,667
2QQ
if 2 I
14*
10.3
y.u
jto0
81.9
72 f
47J
« *
2X4
7240
iU
% U
su
0.012 U
0.1S
_liL
22 u
?.? o
2.2 U
2.2 U
2.2 U
_2£JL.
3/
2.3 u
2.? U
jtr
bu
su
$u
0.0096 U
S 0
$ u
5 U
0.025 Li
¦k;
M?
' 2S
10s
S u
s u
S u
S U
5 U
5 U
0.52? LJ
CJ5
Me/t
o.oss
m"
u
U
0.1 y
1SB
8cnro{a^pyfrnp
Q,2
0-093
5^ U
5.3 U
0.1 y
5.S U
S.4U
8«tio(e,h,i)p4rtyJer»
P&l
NS
tfi
5i»U
S.3 U
su
5.SU
5-4 U
6 en,'o{ b | Huoranlhcnc
vzfi
0.05
0,053
S.&U
5,1 y
04 u
5.1B
S.4 O
BeR2o|kf fluoianthenc
vzfi
12
O.0D3
S.6U
5.3 y
0.1 u
S.5 U
S.4 ~
C.1 U
ChryseET?
pe/i-
S.5
46.7
5.6 0
S.3U
su
s,s u
5 .4 U
s u
DJfacn^QlaJit^nthiacpno
Vg/L
0.12
12
y
S.1U
0.1 u
5.S U
SJi 0
0-1 II
indeno( 1^.3-cdJpvfene
itg/L
0.05
0.093
5.6 y
5.3 u
0.1 0
5.S I*
S.4 U
0.1 u
rtuoianlteiw
wA
I&
m
A2
1^.4
0.015 ti
U
2.? U
0.1 u
Pwene
mfi
NS
HS
22 U
ii-i
s u
22 U
22 U
$ u
SU
? ? y
s u
<5,16
0.22
148
5W
s y
0.1 u
5.5 U
04 U
04 0
04 0
04 U
5 5 U
04 U
04 U
04 U
5 U
S.5 U
5 u
S U
5 U
04 J
s.s u
0.1 if
04 y
04 U
0.1 U
s.su
04 U
04 U
04 y
s u
5 50
5 u
su
su
04 U
5.SU
0.1 y
04 U
04 U
04. 0
5 5 II
0,1 u
04 U
04 U
a.t»5 ii
10.4
0.016 Lj
04 y
0-^S
5 W
5.2
so
su
su
5 U
n.4 ij
5 u
0.015 U
0.35
5 U
~3Ttr
04 o
su
0.1 u
0.1 u
5 U
0.1 u
0.1 u
&i u
su
Carbajote $yj/L 43
Oibenjolaran n^/L 4.3
2-Methy in aphtha Je ne jig/i. 57
2,4-Dto«tfrylpliet>oJ Kgft. 250
3&4-fiaethv^henoi(m&p-Cje5»S) [igji 710
Penxachlorophenoi wsft. 1
1,f-Elphenyl m
379
49)
420
700
1,S13
34^
NS
(t&l j
97 JL
231
s;j* j
4CJ
374 S
in
80S
?T7
896
4M
117
10 u
5,5*1
29.1 J
19.1
10 U
10 u
sm 1
10 ur
10 U
su
5,5 U |
5U
su
193
5 U
SU
s«
22 U
37.S
^ U
su
SM
SU
s u
su
S.SU
40.5
SU
s u
304
S U
so
io y
S.5 U
" *
10 u
iew
"ii.
10 u
10 u
0.2 y
5.5 U
21 J
u
o.os5 y
320
0.2 U
02 u
su
S,5 U
8.5
so
so
78-6
511
s u
2.C.J
LSU
5U
s u
10 0
0^ 0
su
10 u
hU
; u
s u
10 u
Q-l U
5 U
8lp^HrToiat iPAHand Total HPAHare- calcuiite<{ reiultx usin^ detected coniliiuenls and haH &! ihc icpoiifri^&nh lor noiidete
-------
Tabl e 3-3. Year 2016 Groundwater VOC »d SWOC Ubontwy Analysis Summary
Jasper Cf eoso*iit$ Compotr/ Supeffwitf Sitt. ittiptt. Texas
RtmetflalGot!
(2006 ROD)
MW-14-S
MW-14-?
MW15Z
MW-2S-4
MW-iS-S
M W-16-I
msW'16-s
MW-K-7
viW'Xr*i
MW-17-S
MW-17-7
MW.1S41
Arwlyie
Units
Gr«mdw*t«r to Surfei
GreimlwMar Water
r«
S/23/20I6
5/23/20S€
5/24/2016
S/24/201S
5/24/2Blfi
S/24/2S16
5/24/2016
5/24/2015
5/14/Zm
5/24/2016
S/24/2016
6/24/2016
Stnzene
raft.
S
m?
2 U
2 U
2 y
2 U
2 U
2 U
2 U
2 U
2 U
2 U
2 If
20.7
iwl
10,000
8.993
4 «
4 U
4 U
4 U
4 u
4 U
4 U
4 U
4 U
4 U
4 U
4 U
TOt.ti RAH
itg/L
m
NS
36.1 LI
18.1 U
4S.4 U
66. S U
102 U
18.1 ii
IS u
18 U
18.1 U
1S.1 u
is.i u
221
Total tPAH
UgA-
NS
NS
10.3 U
103 U
40.3 U
S8.S U
os3 a
10.2 y
104 U
2Ql2 U
10.3 II
10.2 u
U
198
lolal HPAB
NS
NS
7.SSU
7.8S U
8.17
7.97
6.62 U
7-85. U
7.85 U
7JSS Vt
7.8SU
75 S U
7.8SU
22.g U
fiAPTEQ
ae/i
NS
NS
0U
ou
0 U
0 U
0 u
OU
0 u
QU
0 u
0 U
on
ou
SVOC - lew Molecular Weiaht PAHs
Fiuorene
yg/t
NS
NS
& U
su
0.52 U
6.3
15
5U
s u
5 U
su
S U
su
21-2
Aeenaphtheae
Mfl
im
1S3
5 u
s u
45
30
s u
su
su
5 U
3 U
su
30.3
M&t
m
NS
5U
5 U
SU
0,54 U
0.96 U
su
S u
su
s u
5 U
5 u
5.1
Anfhawne
HS
HS
0.0076 U
0.CKWSU
oas
0 37
0.73
0.009? U
0,00*9 U
0.011 u
0.016 (J
0.03 5 U
0.015 U
3-6
Naphthalene
100
1,667
0,26
0.2S
MS
0.23
0.71
0.22
0.15
0.15
0.2?
Q2
Dj£I
IS,?
Phenantluene
naA
290
200
SU
s u
SU
s u
0,49 U
SU
s u
SU
SU
h U
SU
34.3
8i^«zo{33anthracenc
C.0SS
S.4
0.1 U
0.1 u
0.1 u
G,1 u
0.3 U
0.1 u
0.1 u
0.1 u
a.iu
0.1 u
D.1U
5.2 U
SetGo(a|pvfene
we/l
0.2
0.093
0.1 u
01 U
0.1 u
0.1 u
0.1 u
0.1 u
0.1 u
0.1 u
0.1 u
0.1 u
O.IU
5,2 U
Serco(g,h,i)pcrYienc
NS
NS
su
s u
su
su
S U
su
su
su
5 U
su
su
5.2 U
Bcn26[b! Buoranlhenc
ng/t
O.OS
0.0D3
0.1 u
0.1 II
0.1 u
0.1 u
0.1 U
0.1 u
0.1 u
OJU
0.1 u
0.1 u
0.1 u
SJ u
oeneo[k]flu£>ramhtne
12
0.093
0,1 u
0.1 u
0.1 u
0.1 u
0.1 U
oa u
0.1 u
0.1 U
0.1 u
0.2 U
O.IU
S2 U
Chryserw
8,S
46.7
su
5 U
su
s u
s a
su
su
su
su
S U
SU
s^ u
Dlberero[a,hJ.inlhrsctPt
0.12
13
0.1 u
0.1 u
0-1 u
0.1 u
0.1 u
D4 U
0.1 u
0.1 U
o.l u
s^ u
Huorantficne
M2/t
NS
KS
oa y
0.3 U
B37
0.17
0,9?
0.1 u
0.1 u
0.1 u
0.1 u
0.1 U
0.1 u
2.1 u
Pyirene
W5/L
HS
MS
su
su
su
s u
OJ»U
& u
S LI
su
su
S U
5 u
2.1 U
Carbszole
43
J7S
10 U
10 u
2.1 U
15
Z"
ID U
10 u
10 u
10 u
10 u
10 u
U£ |
DiiW«Z8fUian
wgfl.
4.3
493
s u
su
1,3 U
8.1
24
SU
s u
s u
5 U
su
5 U
45.5
2-Met hylnaphltelcne
57
420
s u
su
su
S U
s u
S U
5 U
su
5 U
su
5 U
G.5
2.4.I>imeth¥lpl5eno1
iiga
250
im
s u
s u
su
s u
5 U
SU
5 U
5 U
SU
su
5 U
S.2 U
3 S4 -Met hviphenol p-Grew!)
Mefl-
no
1,813
10 u
30 0
tou
io a
10 u
10 o
10 u
JO u
30 U
10 u
10 u
S-2 U
PentechloTopti^nol
S»«/l
1
34.9
0.2 U
0.2 U
0^8
02 U
04 u
0.2 U
02 it
0.2 U
0.2 U
0,2 U
0,2 U
5.2 U
l.l'-IWtJtenyl
HS
NS
b u
SU
4.4 U
bS
9.9
S U
a j
SU
s u
s u
SU
S,2 U
F-5
-------
Table 3-3, Year 2016 Groundwater VOC and SVOC Laboratory Analysis Summary
JesptrCrevsotlng C&mpcw $uf>erfutKl$ite, Jasper, Texas
RemetHt! So*}
(zpcgkoo)
Analyte
Rpoww
Xylene frn,p)
«A
wA
SVOC- Total PAH*
Total PAN
Total LP AM
Total HPAH
BAP ICQ
SVOC - Low MrtecuiarWdshZ PAHs
{Jg/i
|4ga
»SfL
11/9/2016
5/24/2316
11/3/2016
S/24/202S
U/9/2S16
Sft*/ZQU
11/9/2EI6
S/25/2QU
13/9/2016
5f2S/2DlS
11/3/2016
707
7 U
4 u
«K
NS
~
_4JL_
NS
7 U
4 U
} U
4 U
NS
190
1S7
524 U
0 l>
3760
SSU
£JL
73.5 U
2JL
29.6 U
6.3 y
253 U
Q"
12S
10?
22.4 U
_00_
30.7
7.35
233 U
_£JL
29.3
213
SU
ou
54.5 J
31.? J
23.2 Ul
GUI
213
233
8 U
ou
64.5
42,1
22,4 U
0U
<10.6
32. S
S.15 u
ou
5/2S/JQ16
52.4
70
22.4 13
0U
ffeKHene
Arenaphthene
Asenaphtfrylerw
Anthracene
Napftthaterte
Phenantlwone
SVOC ' High Mefttutcr Wright PAHs"
mbA-
MS/L
«A
^/L
W?A
NS
130
NS
H$
100
290
NS
153
NS
m
I.QG7
200
29,3
54.3
2.4
2.1
592
20
463
07-5
3570
Tsl
77,1
15J
6 > U
57W
'~&£7
2.i u
?.J u
2.1 U
21 U
2.1 U
2-i y
2U
7,7
ZV
2 y
im
2 U
2,1 U
2.1 U
2.1 U
2.5 U
2.1
2.1 U
53 U
S.1 U
5.1 U
01 U
11
S3 ir
2.1 Ul
7-A Ui
2.1 UJ
23 UJ
25.33
2,1 UJ
5.1 U
S-2 u
5.1 y
o.i u
ii
s,i u
2«
7 U
I U
1 u
37.1
2 U
5.2 U
s.7 u
52 U
0.1 u
22
i.2 o
2 U
7 O
2 U
2 U
CS
2 y
0.OS6
5,1
5.1 U
20 u
16.7 u
53 y
5.1 y
53 u
Bcrui^ajpv'6^
0.2
0.033
5.1 U
20 U
36.7 U
53 y
si y
53 U
Bcnzs(g.h,i>peryfcne
V4/1
NS
NS
5.1 U
20 U
1G.7 y
53 U
51 U
B«tus(b] f!i»rj nt t»fx?
V&l
0,05
0.003
5.1 y
20 U
3S.7 U
S3 U
5.1 U
S3 U
8cnJi>[k^fuoranlhe?»
m/l
12
0.093
5.1 U
20 V
16.7 U
53 O
53. U
5.3 U
Chfysene
WBfl
8.5
46,7
5.1 U
?ou
16.7 U
53 U
5.1 U
S3 U
Dfi»mo{a,NlanthracBiie
ViJl
0.12
13
5.1 O
20 U
16.7 U
53 U
53. O
(ndeno{i23-c4^vr
-------
Table 3-3. Year 2016 Groundwater VOC and SVOC laboratory Analysis Summary
Remedial Goal
(2006 ROD)
MW-18-07
MW-20
MW-21
MW-22
G round water to Surface
Analyte
Units
Groundwater Water
11/9/2016
5/24/2016
5/24/2016
5/24/2016
VOCs
Benzene
Mg/t
5
707
NS
2 U
99.8
31.6
Xylene (m,p)
Mg/t
10,000
8,99*
NS
H.4
109
43.8
SVOC-Total PAHa
total PAH
l«g/t
NS
NS
117 U
838
5720 J
39701
Total tPAH
yg/t
NS
NS
110 U
812
5610
3940
Ma! HPAH
jig/t
NS
NS
7.98 U
26.1
10/1
38.8 J
BAP TEQ
HB/t-
NS
NS
0 u
Otf
0 u
OU
SVOC * Low Molecular Weight PAHs
FhiOfcne
t'B/t
NS
NS
5.1 U
41.5
161
AcenaplUhene
JlgA
iao
153
18 U
60.7
155
289
AcenaphMiytene
|i«/L
NS
NS
5.1 U
9.9
12.5
11.7
Anthracene
t'8/l-
NS
NS
0.1 U
2.2 U
11.2
17.0
Naphthalene
WE/l
100
1,667
100
6? 6
5190
3290
Phenanthrcne
tl#L
230
200
5.1 U
72 3
160
166
SVOC• HIqH Molecular Weight PAHs
Be rwof a)an t h race n e
tlg/l
0,085
5.4
0,1 U
5.5 U
20 U
5.5 U
Benzo|a)pyrene
tlg/l
0.2
0.093
0.1 u
5.5 U
20 U
5,5 U
Benzo(g,h,t)peiYlene
tig/L
NS
N5
5.1 U
5.5 U
20 U
5,5 U
Be ruo[i>]l1uarantfte m
PR"
0,05
0.093
01 U
5.S U
20 U
5.5 U
Oenzo[kjflumant heme
ilg/l
12
0.093
0 1 U
S,5 II
20 U
5.5 U
Chrysone
t'SA
8.5
46.7
5.1 U
5.5 U
20 U
s.su
D]ben20[afh]arilht scene
Pg/l
042
1.2
0.1 u
5.5 U
20 U
5.5 U
lndeno(l»2,3-cd)pyrerie
Mgfl-
0,05
0.033
0-1 u
5.5 U
20 U
5,5 U
FluoranUiene
H8/L
NS
NS
o.oi y
3
18.1
11.1
Pyiene
[lg/l
NS
NS
5,1 U
2.2 U
9,2 j
5.7 i
SVOC - Other Creosote Related
tarbazote
i«g/L
43
379
6,6 y
? 1
176 J
209 J
Dibenzofuran
|lg/t
4.3
493
1,5 U
69.5
165
192
2-Melliy?nhenvl
|1«/L
NS
NS
5,1 U
22.9
34.7
72.8
calculated results using detected constituents at
Notes:
'Total PAH. Total I PAH. and Total HPAH an
Bold/shaded minus exceed rwnadlal GOil.
\\fj\ - microgram per liter
J «Tlie identification of the analyte is acceptable; however, the repotted value is an estimate
U * The Identification of the analyte is acceptable; however, the reported value Is an estlma
NS not spec fled, not a contaminant of concern
PAII = poiycytlic aromalic hydrocarbon
PRG = preliminary remediation goal
ROD = Record of Decision
SVOC » semlvolatile organic compound
U » The analyte was not detected at or above the reported value.
VOC = volatite organic compound
F-7
-------
Table F-3: Surface Water Monitoring Results, 2016
tabl» 3-7. Y«ar 2016 Surfae* Water Sampfe Laboratory Analysis Summary
Jasper Creosoting Company Superfwd Site. Jasper, Texas
Surface Water ^
SW01
SWQ1
SW02
SW02
SW03
SW03
sum
SW04
1M1 (Forested
V/eUand|
Analyle
Units
Remedial Goal
5/19/2016
5/25/2016
sfwftms
5/25/7016
S/19/201S
5/25/2015
5/19/2016
5/25/2016
1/25/2017
SVOC-Toi&PAH*
Total PAH
iiZfl
NS
16 U
1SU
18 U
17.9 U
18 U
18 U
18
18.1
2.54 J
Total LPAH
MS/1-
NS
101 u
mi u
mi u
10,1 U
10.1 u
102 u
10.2
10.2
2.19 J
Total HPAH
«TL
MS
7.&S U
7.85 U
7.85 U
7.85 U
7.S5U
7.ss y
7,85 y
7.S5 y
0347 1
upim
NS
0 u
ou
OU
ou
OU
o u
o y
ou
0,0364 J
SWK-lvw MoitKuksr Weight PAHs
Fiuorene
Wg/t
NS
5 U
5 u
5 U
5 U
5 U
5 U
s U
5 U
OAS* J
Acenaphthene
ue^L
23
s u
51!
5 U
5 U
SU
SU
5 u
5 U
0162 J
Acenaphthyiene
Mfi/t
NS
5 U
5 U
5 U
S U
s u
SU
$ u
SU
0-045 }
Anthracene, tow level
W/L
NS
01 u-
0.1 U
0.1 U
0.1 U
0.1 y
O.OOB7 U
0.1 U
0.1 u
0321 J
Naphthalene, low level
Hb/L
250
Ol u
0,1 U
0.1 U
0.01* u
0.034 U
0.18
0,13
OJS
0JB47 J
Pftenamhrene
vtfi
30
s u
5 u
5 U
5 U
5 U
5 U
5 U
5 U
0121 J
SVOC-H'tgh Mrtecukir Wttghl PAHS
Senzotajanihraeeae, lev/ level
w/i
0.S1
QJL U
0,2 y
01 U
0,1 u
0.1 U
ai u
0.1 U
0^ U
0V03S J
Bcnzo(a)pyrcnc, low tevef
nsfl
0-0X4
0,1 U
0,1 u
0,1 U
eu u
0.1 U
0.3 U
04 U
0.1 U
0^)14 J
Benzo(e.hJ)peryfene
ioft
NS
5 y
su
5 U
5U
5 U
50
5 U
s y
0X129 J
Ber>2o[b]f| ucrBnthe ne. low level
M£/t
0,014
0.1 U
0,1 u
0.1 U
0.1 u
0,1 u
0.1 u
0.1 y
0.1 U
0X190 J
Ben2o[fc]fiyo?«rrthene, tow level
nefl
0.014
0,1 u
ai u
o.i y
0.1 u
0.1 u
0.1 u
o.i y
0.1 u
0.018 :
Chrysene
wfl
7
5 U
5 u
5 U
5 U
su
5 u
5 y
su
004S UJ
01 ben*o(a, hjanthraeene, low level
piA
o,ia
0.1 u
o.i u
0.1 u
0.2 0
04 U
0.1 u
o.i y
0.1 u
nn*
if?defioClJZ3*td)pyreFie, low level
wfl
0.014
0.1 is
ai y
on u
0.1 U
0.1 u
0.1 u
0.1 u
ai u
0.029 J
. PI uotantfie r>et tow level
Mg/S-
NS
0.1 u
0.1 u
0.1 u
0.1 U
0.1 u
OJ. u
0.1 u
0.1 y
0.112 i
h^ene
MS/i
MS
5 U
5 U
su
5 U
5 U
5 u
5 if
5 u
0.044 1
Si/OC-OthtrC'easoTe Kekxied
Carb«ole
56,8
10 u
10 U
ID U
10 u
10 U
10 u
io y
10 u
6.25 U
Dibemofurafi
Wfl
74
5 U
s y
5 U
SU
SU
5 U
s y
5 u
0,102 J
2-Meth^naphthalene
W|[/l
S3
s u
5 U
5 U
5 U
5 U
SU
SU
su
0.135 J
2,4-Dlmethyiphe nol
Wg/L
5 U
50
3&4»Methytahe»Ql (m&p«Cresp[)
10 u
io u
io y
Pcntachlorophcnol, low Jewel
ue/i
532
02 U
0,2 U
Q2 U
Notes;
"Total PAW, Total LPAH, snd Total HPAH are cafculated results tuting detected constituent sand 1/2 reporting limit for nondelcctconstiti
Bold = detected ccnstftu«trts
Bold font/gray shading ihdiur.i* mncenVHtion detected a bow die remedial xmI
microgram liter
SaPTEQs benzol)pyrene toxidty equivalent
F0 s Field duplicate
HPAH k high raeleeujar weight PAH
S ~ The identification of the awlytG is acceptable; however, the reported va^ue is an estimate.
U = The fdeRtifleation of the analyte is acceptable; however, the reported value 5s an estimate and biased few.
LPAH = low itioiecular weight PAH
NS - not specified. Rot a conta mfrwrK of concern
PAH * polyeyelleaioraatichydfocafboft
SVOC = scmlvolati le orga rsie compound
U * The ana iyte was nof detected at or above the reported value.
1.47 J
F-8
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APPENDIX G - SITE INSPECTION CHECKLIST
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST
I. SITE INFORMATION
Site Name: Jasper Creosoting Company, Inc.
Date of Inspection: 12/07/2017
Location and Region: Jasper, Texas/EPA Region 6
EPA ID: TXD008096240
Agency, Office or Company Leading the Five-Year
Review: EPA Region 6
Weather/Temperature: Cloudy and 50° F
Remedy Includes: (Check all that apply)
H Landfill cover/containment
I I Access controls
[3 Institutional controls
13 Groundwater pump and treatment
[H Surface water collection and treatment
U Other:
1~1 Monitored natural attenuation
[Xl Groundwater containment
[~~| Vertical barrier walls
Attachments:
Inspection team roster attached
[~1 Site map attached
II. INTERVIEWS (check all that apply)
1, O&M Site Manager
DairenSavis
Name
I'il'A LTKA Contractor with 5/11/2018
C112M HILL Date
Title
Interviewed ~ at site ~ at office ^ via email Phone:
Problems, suggestions ~ Report attached: Completed interview form is included^ih#^ehdix;B:-Inferoew
question responses are summarized in section IV.
2. O&M Staff Chuck Neelcv
Name AEG(3M
Title
Interviewed ~ at site ~ at office ^5 via email Phone:
Problems/suggestions Q Report attached: Completedihtervie\
question iespbhses;are .isuimnarizedmsection IV
3. Local Regulatory Authorities ana response Agencies (i.e., state and tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office, recorder of
deeds, or other city and county offices). Fill in all that apply.
5/8/2018
Date
in is included m'Appeih5ix^E::Interview
Agency TCEO
Contact Ajiclv'Baiwa
Name
TCEO Project
fojananer
Title
5/9/2018
Date
Phone No.
Problems/suggestions Q Report attached: Completed interview/foimls:iiicludecl in-j^roesridixlB;
Mterview-duestioh'responfies^are summarized m-seQidhlV.
4.' Other Interviews (optional) El Report attached: Completed interview forms are-included in Appendix
K.
Denise Kelly, Jasper City Manager
Judge Mark Allen, Jasper County Judge
III. ON-SITE.DOCUMENTS AND RECORDS VERIFIED (check all that apply)
O&M Documents
G-l
-------
1X1 O&M manual [^] Readily available ^ lip to date
~ n/a
IXl As-built drawings H Readily available ^ Up to date
~ n/a
1)<3 Maintenance logs 23 Readily available fx] Up to date
~ N/a
Remarks:
2. Site-Specific Health and Safety Plan ^ Readily available
1X1 Up to date
~ N/A
22 Contingency plan/emergency response plan £3 Readily available
H Up to date
~ n/a
Remarks: A copy of the site's Health and Safety Plan is maintained in the aroundwatcr treatment plant
ooerations room.
3. O&M and OSHA Training Records ^ Readily available
1X1 Up to date
~ n/a
Remarks: O&M and OSHA training records are stored online in CH2M HILL's database. Training records for
all site contractors can be accessed at anv time.
4. Permits and Service Agreements
~ Air discharge permit ~ Readily available
}~~] Up to date
IE] N/A
EH Effluent discharge ~ Readily available
~ Up to date
~ N/A
1X1 Waste disposal, POTW j 1 Readily available
K1 Up to date
~ N/A
l~l Other permits: ~ Readily available
~ Up to date
Sn/a
Remarks: An agreement is in place with the cilv to discharge to the POTW. if needed.
5. Gas Generation Records f~| Readily available
ED Up to date
Ki N/A
Remarks:
6. Settlement Monument Records [~l Readily available
E] Up to date
0N/A
Remarks:
7. Groundwater.Monitoring Records ^ Readily available
H Up to date
~ N/A
Remarks:
8. Leachate Extraction Records ^3 Readily available
[XI Up to date
~ n/a
Remarks: TCEO routinely inspects the I.CS and last removed leachate from the system in 2013. TOKO
documented the leachate removal process in the Aue.usL'2013 Leachate Removal Field Activity Kcport.
9. Discharge Compliance Records
O Air ~ Readily available Q Up to date
N/A
~ Water (effluent) EH Readily available ~ Up to date
Kl
N/A
Remarks:
10. Daily Access/Security Logs ~ Readily available '
n Up to date
In/a
Remarks;
IV. O&M COSTS
1. O&M Organization
~ State in-house (X] Contractor for state
~ PRP in-house Q Contractor for PRP
EH Federal facility in-house Q Contractor for Federal facility
G-2
-------
S TCEO contracts with AHCOMto perform RCC-related O&M activities al llic Site. HP A contractor. CII2M
HILL performs .1 ,TR A activities at the Site.
2. O&M Cost Records
[x] Readily available H Up to date
n Funding mechanism/agreement in place ~ Unavailable
Original O&M cost estimate: See Tables 3 and 4 in the Systems Operations/O&M section of this FYR Report
Ibr O&M cost information. CD Breakdown attached
3. Unanticipated or Unusually High O&M Costs during Review Period
Describe costs and reasons: See the Systems Ocerafions/O&M section-of tinsReport for
information abbut 0&M:fcosts^durinetliis¥YR period.
V. ACCESS AND INSTITUTIONAL CONTROLS
23 Applicable ~ N/A
A.
Fencing
1.
Fencing Damaged ~ Location shown on site map £<
Remarks: Site fencing atmeared to be in sood condition.
3 Gates secured ~ N/A
B.
Other Access Restrictions
1.
Signs and Other Security Measures ~ Location shown on site map ~ N/A
Remarks: Signs arc clearly oosted on the fence neat the main entrance to the Site.
C.
Institutional Controls (ICs)
1. Implementation and Enforcement
Site conditions imply ICs not properly implemented I I Ves § No GN/A
Site conditions imply ICs not being fully enforced ~ Yes 0 No [] N/A
Type of monitoring (e.g., self-reporting, drive by):
Frequency:
Responsible party/agency: TCEO
Contact Andy Baiwa Project Manaser
Name Title
Date
Phone no,
Reporting is up to date
~ Yes
~ No
Bn/a
Reports are verified by the lead agency
~ Yes
~ No
EI N/A
Specific requirements in deed or decision documents have been met
g] Yes
~ No
~ n/a
Violations have been reported
~ Yes
~ No
Hn/a
Other problems or suggestions: ~ Report attached
2. Adequacy [3 ICs are adequate ~ ICs are inadequate [J N/A
Remarks: 'I'he 2014 TRR1' deed notice applies to the main site property and informs the property owner of site-
rciated contamination on the property, informs them of site-related maintenance and monitoring requirements,
and prohibits groundwater use and residential land use. For off-site properties within the T1Z and PMZ. the 2014
TRRP restrictive covenants inform property owners ofsite-rclatcd groundwater contamination affecting their
properties, inform them of site-related maintenance and monitoring requirements, and prohibit groundwater use.1
Local ordinances also prevent exposure to site-reialed groundwater contamination.
G-3
-------
D. General
1. Vandalism/Trespassing [~1 Location shown on site map
Remarks:
13 No vandalism evident
2. Land Use Changes On Site N/A
Remarks:
3. Land Use Changes Off Site [X] N/A
Remarks:
VI. GENERAL SITE CONDITIONS
A, Roads Applicable 0 N/A
1. Roads Damaged ~ Location shown on site map
Remarks:
[Xj Roads adequate Q N/A
B. Other Site Conditions
Remarks:
VII. LANDFILL COVERS Applicable ' ~ N/A
A. Landfill Surface
1. Settlement (low spots) Q Location shown on site map
Area extent:
Remarks:
[X] Settlement not evident
Depth:
2. Cracks 0 Location shown on site map
Lengths: Widths:
Remarks:
[2 Cracking not evident
Depths:
3. Erosion [I] Location shown on site map
Area extent:
Remarks:
[X] Erosion not evident
Depth:
4, Holes 0 Location shown on site map
Area extent:
Remarks:
13 Holes not evident
Depth:
5. Vegetative Cover [2 Grass [X] Cover properly established
13 No signs of stress [2] Trees/shrubs (indicate size and locations on a diagram)
Remarks: Vegetation is well-established and in aood condition.
6. Alternative Cover (e.g., armored rock, concrete)
Remarks:
H N/A
7. Bulges Q Location shown on site map
Area extent:
Remarks:
[3 Bulges not evident
Height:
8. Wet Areas/Water Damage ^ Wet areas/water damage not evident
G-4
-------
~ Wet areas
0 Ponding
F~1 Seeps
[~1 Soft subgrade
Remarks:
~ Location shown on site map Area extent.
~ Location shown on site map Area extent.
f~1 Location shown on site map Area extent
~ Location shown on site map Area extent:
9. Slope Instability
Kl No evidence of slope instability
Area extent:
Remarks:
dl Slides
f~l Location shown on site map
B, Benches
~ Applicable N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order
to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
C, Letdown Channels
O Applicable [3 N/A
(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side slope of
the cover and will allow the runoff water collected by the benches to move off of the landfill cover without
creating erosion gullies.)
D, Cover Penetrations
[ ) Applicable [X] N/A
E. Gas Collection and Treatment
D Applicable ^ N/A
F. Cover Drainage Layer
tX] Applicable ~ N/A
1. Outlet Pipes Inspected
Remarks:
O Functioning
[x]n/a
2, Outlet Rock Inspected
Remarks:
EX] Functioning
~ n/a
G. Detention/Sedimentation Ponds Q Applicable
KI N/A
11. Retaining Walls
0 Applicable [3 N/A
I. Perimeter Ditches/Off-Site Discharge Applicable
~ n/a
1. Siltation
Area extent:
Remarks:
O Location shown on site map
tXl Siltation not evident
Depth:
2. Vegetative Growth Q Location shown on site map [X] N/A
[~~1 Vegetation does not impede flow
Area extent: Type:
Remarks:
3, Erosion
0 Location shown on site map
[X] Erosion not evident
Area extent:
Depth:
Remarks:
4, Discharge Structure
[X] Functioning
~ n/a
G-5
-------
Remarks:
VIII. VERTICAL BARRIER WALLS ~Applicable gN/A
IX. GROlfNDWATER/SURFACE WATER REMEDIES [X] Applicable ~ N/A
A. Groundwater Extraction Wells, Pumps and Pipelines Applicable Q N/A .
1. Pumps, Wellhead Plumbing and Electrical
[X] Good condition [x] All required wells properly operating O Needs maintenance Q N/A
Remarks:
2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances
[>3 Good condition ~ Needs maintenance
Remarks:
3. Spare Parts and Equipment
[Xl Readily available 0 Good condition O Requires upgrade O Needs to be provided
Remarks:
B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable N/A
C. Treatment System ^ Applicable |~~| "N/A
1. Treatment Train (check components that apply)
[~~1 Metals removal H Oil/water separation O Bioremediation
[~i Air stripping Q Carbon adsorbers
Kl Filters: The system includes cartridge and manular activated carbon filters.
K1 Additive (e.g., chelation agent, floceulent): System additives include anti-scalant and iron adjuster.
I-! Others:
Good condition Q Needs maintenance
H Sampling ports properly marked and functional
[X] Sampling/maintenance log displayed and up to date
0 Equipment properly identified
S Quantity of groundwater treated annually: 12.4 million gallons of groundwater treated during the 2016
reporting period.
~ Quantity of surface water treated annually:
Remarks: Annual amounts of treated groundwater are listed in annual Q&M reports.
2. Electrical Enclosures and Panels (properly rated and functional).
f~l N/A [X] Good condition Q Needs maintenance
Remarks:
3. Tanks, Vaults, Storage Vessels
ON/A 13 Good condition £
-------
I"~l N/A Good condition 0 Needs maintenance
Remarks:
5. Treatment Building(s)
l~~l N/A 22 Good condition (esp. roof and doorways) Q Needs repair
Chemicals and equipment properly stored
Remarks:
6. Monitoring Wells (pump and treatment remedy)
[3 Properly secured/locked [2 Functioning £5 Routinely sampled [x] Good condition
13 All required wells located ~ Needs maintenance Q N/A
Remarks:
D. Monitoring Data
1. Monitoring Data
[X] Is routinely submitted on time
IXl Is of acceptable quality
2. Monitoring Data Suggests:
IXl Groundwater plume is effectively contained
|~| Contaminant concentrations are declining
E. Monitored Natural Attenuation
1. Monitoring Wells (natural attenuation remedy)
0 Properly secured/locked Q Functioning d Routinely sampled Q Good condition
I I All required wells located Q Needs maintenance [3 N/A
Remarks:
X. OTHER REMEDIES
If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
XI. OVERALL OBSERVATIONS
A . Implementation of the Remedy •
Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin
with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume,
minimize infiltration and gas emissions).
The remedy was designed to prevent direct contact with contaminated soil and sediment, ingestion of
contaminated groundwater bv potential future residents, and contaminated groundwater initi ation and entry to
surface water.: All contaminated soil has cither been excavated and disposed of off site, or ^contained within the
RCO. The PMZ restricts groundwater use within and adjacent to the T1Z. The 2014 TRRP deed notice and
restrictive covenants prevent exposure to contaminated groundwater and soil and ensure the integrity of the
remedy. The Site's hydraulic containment system helps prevent expansion of the plume beyond the PMZ,
However, there is uncertainty concerning the effectiveness of the hydraulic plume containment system; emulsified
oil and LlSlAPL. not originallv identified during tlie RI. are complicating remedial efforts.1
B . Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In particular,
discuss their relationship to the current and long-term protectiveness of the remedy.
O&M efforts are underway for the operation of the around water treatment system and maintenance of the
containment.cell_cap. O&M efforts lor these activities appears adequate although remedy optimization is needed.
C. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of
unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the Mure,
EPA is cutfentlv'evaluating-optiohs .to :optimize:the remedy. A TarGOST inrostigatioh is being ^planned to help
Blither identify , creosote .and creosote-type compounds'ini groundwater.-
-------
IX Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Opportunities tor optimization are being evaluated.
Bob Sullivan, EPA Region 6
Andy Bajwa, TCEQ
Terry Andrews, TCEQ
Xiaoxia Lu, TCEQ
Darren Davis, CH2M HI 1,1,
Eric Marsh, Skeo
15 rice Robertson, Skeo
G-8
-------
APPENDIX H - REMEDIAL ACTION AND SITE INSPECTION PHOTOS
BEFORE - Pre-Remedial Action
Treated wood stored on site
Site conditions prior to cleanup
H-l
-------
BEFORE - RCC Construction, 2006
H-2
-------
H-3
-------
Treatment building exterior and parking area
<'r' '' •
% -::'v
HWH
H-4
-------
Influent equalization tank
Granular activated carbon treatment tanks
H-5
-------
Groundwater remediation control system
Treatment plant fencing
H-6
-------
m
Monitoring well MW-11, locked and functioning
MW-11, properly labeled
H-7
-------
BNSF railroad track area and area of potential remedy optimization
Recovery well R-2, locked and functioning
H-8
-------
»¦ *»xaLlj|]
- R2 >:
4287498.2 -
10361873.7
.
Recovery well R-2, properly labeled
Recovery well field area
H-9
-------
Sandy Creek
- *
RCC leachate collection system
H-10
-------
RCC fencing and signage
RCC cap
H-ll
-------
APPENDIX I - ARARS REVIEW
As stated in the 2006 ROD, it is technically impracticable to restore groundwater quality to meet MCLs and risk-
based groundwater cleanup levels due to the presence of PAHs and free phase and residual DNAPL in the
subsurface. Therefore, the Site's T1 waiver waives Safe Drinking Water Act ARARs for the area within the TIZ.
The ROD established the TIZ as the area where the TI waiver will be applied; therefore, groundwater beyond the
TIZ would be subject to groundwater ARARs and must meet MCLs. This PYR compares groundwater ARARs
identified in the ROD to current federal standards to determine if any changes have occurred (Table 1-1), There
have been no changes to MCLs since EPA issued the ROD.
Table 1-1: Groundwater ARAR Comparison
coe
2010 ROD
2017 MCL
Change
MCL (ng/L)h
(|ig/L)c
Metals
Arsenic
10
10
no change
Thallium
2
2
no change
PAHs
Benzo(a)pyrene
0.2
0.2
no change
Others
Benzene
5
5
no change
Pentachlorophenol
1
1
no change
Xylene, M- & P-
10,000
10,000
no change
Notes;
a. Groundwater COCs listed in Table 3 of the 2006 ROD for which the PRGs are
MCLs.
b. MCLs in effect at the time of ROD signature, as listed in Table 3 of the ROD;
cleanup goals for those COCs without MCLs were risk-based and are evaluated
separately in this FYR.
c. National Primary Drinking Water Regulations available at:
htipy_ \yu w ^roiind-\vater^antt:4npkiii^>va'^L,i^ti.0JuJ_-primaO."
d i i u k i n u - v \ a t e l -n. y u i j I ij > / (accessed 1/31/2018).
Some soil ARARs specified in the 2006 ROD were relevant during the remedy's construction but may not be
relevant to its continued protectiveness, EPA calculated cleanup goals for soil COCs based on protection of
human health, ecological receptors and groundwater. See Section 7.2 for a discussion of soil cleanup goals.
The ROD established Texas Surface Water Quality Standards (30 TAC §307) as an ARAR applicable to the
discharge of groundwater co-extracted with NAPL, if discharge of groundwater to surface water is necessary.
Effluent from the treatment system is compared to groundwater and surface water PRGs. While not required by
the ROD, routine monitoring now includes sampling of surface water in the forested wetland area and in Sandy
Creek. Therefore, this FYR compared surface water PRGs established by the 2006 ROD to current surface water
standards for protection of human health and ecological receptors (Table 1-2). Current standards used for
comparison were selected using the same selection process used to determine the surface water PRGs, as
described in the ROD. The current standards for benzo(a)anthracenc, benzo(b)fluoranthene,
dibenz(a,h)anthracene, indeno(l ,2,3-cd)pyrene, benzene and PCP are more stringent than they were at the time of
the ROD. Based on this review, surface water PRGs for those constituents may no longer be valid. Additional
evaluation is recommended to determine whether the surface water PRGs need to be revised to protect human
health and ecological receptors.
1-1
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Table 1-2: Surface Water ARAR and Cleanup Goal Review
COC"
2006 ROD
Surface
Water PRGb
(P-g/L)
2017 Texas
Surface
Water
Quality
Standards'
(fig/L)
20!7 National
Recommended
Ambient Water
Quality Criteria'1
(fig/JL)
TCEQ Aquatic
Life Surface
Water
Benchmarks"
(jig/L)
Change
PAHs
Acenaphthene
23
70
23
no change
Benzo(a)anthracene
0.81
0,68
*ll
34.6
more stringent
Benzo(a)pyrene
0.014
0.068
*h
0,014
no change
Benzo(b)fluoranthene
0.014
—
0,0128
—
more stringent
Benzo(k)fl uoranthene
0.014
0.12®
less stringent
Chrysene
7
68.13
*h
7
no change
Dibenz(a,h)anthracene
0.18
—
0.0012^
5
more stringent
Indeno( 1,2,3-ed)pyrene
0.014
—
0.012*
more stringent
Naphthalene
250
__
— .
250
no change
Phenanthrcne
30
—
__
30
no change
Others
2,4-DimethyIphenol
105
257
105
no change
2-Methylnaphthalerie
63
_
__
63
no change
Benzene
106
5
*h
130
more .stringent
Carbazole
56.8
—
—
..
no change
Cresols, M- & P-
272
1,041
—
272r
no change
Dibenzofuran
74
..
—
94
less stringent
Pentachlorophenol
5.23
0.8
2.45
more stringent
Xylene, M- & P-
1,340
—
1,340
no change
Notes:
a. Surface water COCs listed in Table 3 in the 2006 ROD, Surface water PRGs for protection of human health and
ecological receptors were calculated according to TCEQ guidelines in the guidance document Determining Protective
Concentration Levels for Surface Water and Sediment, Surface water PRGs represent the lower of two surface water
screening values - those protective of human health and ecological health. Human health values were selected with the
following hierarchy - Texas Surface Water Quality Standards (30 TAG §307), then National Recommended Ambient
Water Quality Criteria - and calculated according to the TCEQ guidance document. Ecological screening values are
those presented in a TCEQ guidance document Guidance for Conducting Ecological Risk Assessments at Remediation
Sites in Texas (2006 revision) or were developed according to the method provided in the guidance.
b. Surface water PRGs established by the 2006 ROD.
c. Texas Surface Water Quality Standards for Human Health Protection (consumption of water and fish) available at:
k-\reu >ute.t\.iis luls 201400713-2.pdf (accessed 1/24/2018).
d. National Recommended Ambient Water Quality Criteria available at: hiips: '\s~n wvpa.uov wiic national-
rtc<>rnuKiKk*d-\va!er-qualit3 -criiei iu-bumun-he'akh-ci :leria-nthle (accessed 1/24/2018).
e. January 2017 TCEQ Aquatic Life Surface Water Benchmarks (freshwater chronic benchmarks) available at:
hup.' »\\v\\.tccq.tcxus.jiovWels public rcnunlhilion'eeu Rti2<>3B 'S»^(IBencH.njai%s.xis\ (accessed 1/24/2018),
f. Standard for 4-methylphenol (p-cresol).
g. Criterion based on cancer risk of 1x10*5 in accordance with acceptable risk level indicated in the ROD.
h. The ROD selected Texas Surface Water Quality Standards (30 TAC §307) as surface water standards protective of
human health. If a Texas Surface Water Quality Standard was not available for a particular COC, the National
Recommended Ambient Water Quality Criteria was selected as the surface water standard protective of human health.
For fields above marked u*h" the Texas Surface Water Quality Standard was used as the surface water standard
protective of human health.
-- = standard not established.
Bold shaded value indicates a more stringent, current standard.
1-2
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APPENDIX J - TOXICITY REVIEW
Surface Soil PRGs
The 2006 ROD selected surface soil cleanup goals based on an anticipated industrial land use. Table J-l evaluates
the current validity of those cleanup goals using 2017 EPA RSLs; the RSLs incorporate current toxicity values
and standard default exposure factors.
The evaluation demonstrates that all surface soil PRGs remain valid for commercial/industrial use. Concentrations
are within EPA's risk management range of 1 x 10"6 to lxl 0"4 and below EPA's benchmark of 1 for
noncarcinogens.
Table J-l: Review of Surface Soil PRCs - Human Health Direct Contact
coc
Surface
Soil PRC*
(mg/lcg)
Composite Worker RSL1,(m«/k»)
Risk®
HQd
(Hazard
Quotient)
Cancer-Based
RSL
(10 " Risk)
Non-Caneer RSL
(HQ - i.o)
PAlIs
Acenaphthene
34
—
45,000
NA
0.0008
Benzo(a)anthracene
21
21
—
1 x 10'6
NA
Benzo(a)pyrene
2.1
2.1
220
1 x lO"6
0.01
Benzo(b)fluoranthene
21
21
—
1 x 10"6
NA
Benzo(k)fluoranthene
210
210
1 X 10"6
NA
Chrysene
52
2,100
—
2.5 x 10"8
NA
Dibenz(a, h)anthracene
2.1
2.1
__
1 x lO"6
NA
Indeno(1,2,3-cd)pyrene
21
21
—
1 x 10^
NA
Naphthalene
240
17
590
1.4 x 10"s
0.4
Phenanthrene
82
—
__
NA
NA
Others
2,4-i')iniethylph.cnol
4.2
..
16,000
NA
0.0003
2-MethyhiaphthaIene
76
—
3,000
NA
0.03
Benzene
0.21
5.1
420
4.1 x 10"8
0.0005
Carbazole
' 21
...
NA
NA
Cresols, M- & P-
3.6
__
41,000e
NA
0.00009
Dibenzofuran
47
—
1,000
NA
0.05
Pentachlorophenol
6,2
4
2,800
1.6 x 10~6
0.002
Xylene, M- & P-
61
2,400
NA
.0.03
2,3,7,8-TCDD (TEQ)
0.00052
0.000022
0.00072
2.4 x 10"5
0.7
Notes;
a. Surface soil PRG listed in Table 3 in the 2006 ROD.
b. EPA's composite worker RSLs, dated November 2017, available at
htips:>emstuib,ena,s3ov 'work'! 10 197033,pelf, accessed 1/24/17,
c. Cancer risk calculated using the following equation, based on the fact that RSLs are derived based on I J U
risk: cancer risk = (remedial goal + cancer-based RSL) * 10~6.
d. Noncancer HQ calculated using the following equation: 11Q - (remedial goal ^ noncancer RSL).
e. RSL for ni-Cresol.
NA = not applicable.
- = P.PA has not finalized a carcinogenic or noncarcinogenic toxicity value for this compound.
J-l
-------
Groundwater PR( is
As required by the ROD. I -PA defined a TIZ that identifies the area where restoration of groundwater quality to
drinking water standards has been determined to be impractical. However, site-related groundwater beyond the
TIZ still needs to meet groundwater PRGs. The ROD selected MCI .s and risk-based concentrations as
groundwater PRGs. To determine if the risk-based PRGs for groundwater remain protective, the values were
compared to EPA's 2017 tapwater RSI s (Table J-2).
Based on the evaluation, (he PRG for the eareinogenie COG naphthalene falls outside of EPA's acceptable risk
management range of I x 10"6 to 1x10PRGs for naphthalene and 2-methylnaphthalene result in HQs that
exceed EPA's benchmark of 1 for nonearcinogens. HPA may wish to revisit those groundwater PRGs to
determine if they remain protective of human health over the long term. However, these changes do not affect
current protectiveness. There are no complete exposure pathways between contaminated groundwater and
receptors. While naphthalene is detected at wells outside of the TIZ, detections at most of those locations are
routinely below 1 pg/L. In 2016, 2-methylnaphthalene was not detected at any well outside of the TIZ.
Table .1-2: Re\ ie\v of Groundwater i'RGs
coc
Risk iutswl
Tapwater RSLh
Risk''
HQ'
Remedial t.oal"
10' Risk
HQ - 1.0
Metals
Arsenic
NA
NA
NA
NA
NA
Iron
4,240
-
14,000
—
0.3
Thallium
NA
NA
NA
NA
NA
Vanadium
H
—
86
„
0.2
1'AHs
Acenaphthcne
130
__
530
...
0.2
Benzo(a)anthracene
0.085
0.03
—
2.8 x 10-°
--
Ben/,o(a)pyrene
NA
NA
NA
NA
NA
Ben/o(b)fluoranthene
0.05
0.25
2x10'
..
Ben/.o(k)fluoi"anthcne
12
2.5
—
4.8 x Kb"
..
Chrvsene
8.5
25
~
3 4 x 10"
Dibenz(a,h)anthracene
0.12
0.025
...
4.8 x I0-6
..
indenot, 1,2,'!-c,d)pyrene
15
0.25
„
2 x 10"'
..
Naphthalene
100
0.17
6.1
5.9 x 104
16.4
Phcnanthrene
290
__
"
..
—
Other*
2,4-1 )iniethyIphenol
250
..
360 J
0.7
2-Methylnaphthalcne
57
--
36
1.6
Buu/ene
NA
NA
NA
NA
NA
Carbazole
43
..
..
„
Cresols, M- & P-
710
—
930C
—
O.S
Dibenzohiran
4.3
--
79
...
0.5
Pcntachlorophenol
NA
NA
NA
NA
NA
Xylene, M- & P-
NA
NA
NA
NA
NA
Notes:
a. Risk-based lemedial goal listed in Table 3 of the R( >D,
b F.PA's tapwater RSI,s, dated November 2017, available at
www.epa "o\_ 1i.1- ieymn i!-seieoi:in>„-
i?vc.»-i • N-.vncr ic-l.tliR'*-
V "".accessed 1/31/17
J-2
-------
c. Cancer risk calculated using the following equation, based on the fact that RSLs are derived based on 1 x 10"
6 risk: cancer risk = (remedial goal cancer-based RSL) * 10~6.
d. Noncancer HQ calculated using the following equation: HQ = (remedial goal + noncancer RSL),
e. RSL for m-cresol, as the value is lower/more conservative than the RSL for p-eresoi
NA = not applicable; remedial goal for this COC is the MCL and is not a risk-based concentration.
— = EPA has not finalized a carcinogenic or noncarcinogenic toxicity value for this compound.
Bold = risk exceeds EPA's risk management range of 10"6 to 10'4 or HQ exceeds 1.
Subsurface SoU-lo-Groundwater PRGs
The ROD developed soil-to-groundwater protection PRGs to ensure that the leaching of COCs from contaminated
soil into groundwater does not result in an increase of COC concentrations within the existing groundwater
plume. The soil-to-groundwater protection PRGs were selected as subsurface soil PRGs because soil to
groundwater is the only exposure pathway of concern for subsurface soil. The review of surface soil PRGs shows
that they remain protective of human health. As all surface soil PRGs are either equivalent to or more stringent
than subsurface soil-to-groundwater PRGs, a review of subsurface soil-to-groundwater PRGs was not required.
Subsurface soil-to-groundwater PRGs remain valid and protective of human health.
Grounc/water-fo-Surface Water PRGs
The ROD developed site-specific groundwater-to-surface water PRGs to ensure that the migration of COCs from
groundwater to surface water will not result in the exceedance of surface water PRGs. This FYR includes a
review of surface water PRGs (see Appendix I, Table 1-1). The groundwater-to-surface water PRGs were site-
specific; therefore, a review of these values could not be conducted.
J-3
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