1

PROPOSED PLAN FOR

STATE MARINE SUPERFUND SITE

PORT ARTHUR, TEXAS

U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 6

JULY 27, 2005

THE U.S. EPA ANNOUNCES PROPOSED PLAN

PURPOSE

The purpose of this proposed plan is to:

• Identify and define the remedial alternatives

evaluated by EPA to address contamination at

the State Marine Superfund Site (Site).

• Present EPA’s Preferred Alternative.

• Solicit public comment on the remedial action

alternatives and supporting analyses, as well as

on information contained in the Administrative

Record.

• Provide information on how the public can be

involved in the remedy selection process.

EPA PROPOSES FINAL REMEDY FOR THE

STATE MARINE SITE

In this Proposed Plan, the U.S. Environmental

Protection Agency (EPA) describes the proposed final

remedy for the State Marine Superfund Site (Site) and

provides the rationale for this preference. In addition,

this Proposed Plan includes summaries of other

alternatives evaluated for use at this Site. This

document is issued by the U.S. Environmental

Protection Agency (EPA), the lead agency for site

activities, and the Texas Commission on

Environmental Quality (TCEQ), the support agency. 

The EPA, in consultation with the TCEQ, will select a

final remedy for the Site after reviewing and

considering all information submitted during the 30-

day public comment period. The EPA, in consultation

with the TCEQ, may modify the proposed remedy or

select another response action presented in this

Proposed Plan based on new information or public

comments. Therefore, the public is encouraged to

review and comment on all the alternatives presented

in this Proposed Plan. The feasibility Study Report

for this Site should be consulted for more detailed

information on these alternatives.

The EPA is issuing this Proposed Plan as part of its

public participation responsibilities under section

117(a) of the Comprehensive Environmental,

Response, Compensation, and Liability Act

(CERCLA) of 1980, as amended by the Superfund

Amendments and Reauthorization Act of 1986

(SARA), and to the extent practicable, §300.430(f)(2)

of the National Oil and Hazardous Substances

Pollution Contingency Plan (NCP). This Proposed

Plan summarizes information that can be found in

greater detail in the Remedial Investigation,

Feasibility Study, and other documents contained in

the Administrative Record file for this Site. The EPA

and TCEQ encourage the public to review these

documents to gain a more comprehensive

understanding of the Site and the Superfund activities

that have been conducted at the Site.

Community Participation

The public is invited to review and comment on this

Proposed Plan and the documents contained in the

Administrative Record file. This Proposed Plan

highlights key information from the RI and FS

reports, but it is not a substitute for those or other

documents contained in the Administrative Record. 

EPA encourages the public to review those documents

to obtain more information about the Site. The

Administrative Record file is available at the

following information repositories:

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Port Arthur Public Library

4615 9th Avenue

Port Arthur, Texas 77642

(409) 985-8838

U.S. Environmental Protection Agency Region 6

Seventh Floor Reception Area

1445 Ross Avenue, Ste 12D13

Dallas, Texas 75202-2733

(214) 665-6427

Monday- Friday (7:30 AM to 4:30 PM)

Texas Commission on Environmental Quality 

12100 Park 35 Circle

Building E, 1st Floor 

Austin, Texas 78753

(512) 239-2920

Monday- Friday (8:00 AM to 5:00 PM)

During the public comment period, written comments

should be submitted to:

Carlos A. Sanchez

Remedial Project Manager

EPA Region 6 ( 6SF-A)

1445 Ross Avenue

Dallas, Texas 75202-2733

(214) 665-8507 or 1-800-533-3508 ( Toll free)

The public comment period is scheduled to begin on

July 27, 2005, and end on August 25, 2005. The EPA

has scheduled a public meeting on August 11, 2005,

to discuss the Proposed Plan and receive comments

from the community. The public meeting will be held

at the West Groves Education Center, located at 5840

West Jefferson, in Groves ,Texas, beginning at 6:00

PM. A court reporter will be present to record oral

comments. EPA will conduct a short presentation

and afterward will be available to meet with citizens. 

EPA will respond to all comments received during the

public comment period using a document called a

Responsiveness Summary. This document will be

attached to the Record of Decision (ROD) and will be

made available to the public in the information

repository.

SITE BACKGROUND AND DESCRIPTION

The State Marine Site is located approximately 4.5

miles east-northeast of the City of Port Arthur in

Jefferson County, Texas, on Old Yacht Club Road on

Pleasure Islet, a peninsula located approximately 0.5-

mile southwest of the mouth of the Neches River, see

Figure 1-1. Overall, the Site encompasses

approximately 17 acres and is bounded to the north by

the Palmer Barge Line Site (PBLS), to the west by

Old Yacht Club Road, to the south by undeveloped

property, and to the east by Sabine Lake. 

Pleasure Islet is a manmade landmass consisting of

dredge spoils generated during the construction and

maintenance of the Sabine-Neches Canal, also called

the Intercoastal Waterway. The canal was constructed

between 1898 and approximately 1920 in the vicinity

of Sabine Lake and the Neches River, between the

current site location and the mainland. Between 1955

and 1957, a portion of the canal along the western side

of Pleasure Islet was abandoned, and a new canal was

cut along the eastern and southern sides of Pleasure

Islet. Pleasure Islet was created when a land bridge

was constructed across the abandoned portions of the

canal, between the northern tip of Pleasure Island and

the mainland. Vehicle access to the Site is limited to a

single dirt road starting at the western site border

along Old Yacht Club Road.

Ownership of the Pleasure Islet was transferred from

the State of Texas to the City of Port Arthur, Texas, in

1955. Development of the islet and the Site began

after 1957, following construction of the land bridge

across the abandoned portions of the Sabine-Neches

Canal. In approximately 1963, the City of Port Arthur

began municipal landfill operations on the northern

and central portions of the islet. Initially, the landfill

consisted of a burn pit in which wastes were

incinerated. By December 1969, burn operations

were discontinued, and the landfill was used solely for

disposal of wastes. Between 1969 and 1972, landfill

disposal operations expanded to include the central

and northern portions of the Site and the property

north of the Site. Between 1972 and 1974, disposal

activities were generally concentrated in the northern

parts of the islet. In December 1974, the City of Port

Arthur closed the landfill in accordance with Texas

Department of Health (TDH) regulations, which

required covering the entire landfill with

approximately 2 ft of fine-grained fill material. The

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cover material is believed to be dredge spoils that

originated on the islet.

SMS operations began about 1973 under the names of

State Welding and Marine Works and the Golden

Triangle Shipyard. The construction of wastewater

impoundments in the northwestern portion of the Site

was also reported. The impoundments were

reportedly unlined, earthen diked areas approximately

two (2) acres in size used to store oil and wastewater

from barge-cleaning operations. Inspection reports

indicate that wastewater from barge-cleaning

operations was directed to two ASTs and then pumped

to the wastewater impoundments. Some of the oil

from the tanks was diverted to an old ship (on land)

that was used as an oil/water separator. Oil from the

separator was collected for reuse, potentially on-site.

The Site included the locations of the former

wastewater impoundments, tar burn area, distillation

column, and former location of the Lauren Refining

Company (LRC) Tank Farm, see Figure 1-2.

The EPA proposed the State Marine Site for listing on 

National Priorities List (NPL) of Superfund sites on

March 6,1998. On July 28, 1998, the Site was listed

as Final on the NPL. 

SITE CHARACTERIZATION

Previous Investigations

In 1995, the TNRCC initiated an Expanded Site

Inspection (ESI) at the SMS. The objective of the

TNRCC ESI was to collect sufficient data to develop

an understanding of the Site contaminants and to

identify the potential migration pathways, primary

contaminant sources, exposure pathways, and

presence of potential human health and ecological

receptors. The following reports were completed as a

result of the data obtained from the field work during

the ESI:

• 1996 Expanded Site Investigation Report

(TNRCC).

• 1997 Hazardous Ranking System

Documentation Report (TNRCC).

• 1999 Technical Memorandum (CH2M HILL).

Other Investigations Adjacent to the SMS included a

Preliminary Assessment (PA), a Screening Site

Inspection (SSI), and an ESI were conducted

immediately adjacent to the Site at the PBLS. The

PBLS is located on Pleasure Islet immediately north

of the SMS. These investigations did not involve

collecting soil, sediment, or ground water directly

from the SMS; however, some sediment data obtained

from the PBLS at near-shore and offshore locations

were used in the human health and ecological

screening risk assessment.

Remedial Investigation

A RI was conducted by WESTON in 2001, consisting

of two sampling events in the fall of 2001, where

sediment samples from off-site locations in Sabine

Lake and soil and ground water samples from on-site

locations on the SMS were collected.

 Former Wastewater Impoundments

Nine (9) surface soil samples were collected and

analyzed for target analyte list (TAL) metals and

target compound list (TCL) semi-volatile organic

compounds (SVOCs) from the Former Wastewater

Impoundments Area. Based on the comparisons to the

Texas Risk Reduction Program (TRRP) Tier 1

Commercial/Industrial Protective Concentration

Levels (PCLs) for soils, the following contaminants

with the associated maximum reported concentrations

were detected at levels exceeding GWSoil PCLs: 20.5

mg/kg antimony, 7.4 mg/kg arsenic, 534 mg/kg

barium, 210 mg/kg lead, and 0.16 mg/kg mercury.

The remaining TAL metals were either not detected or

were detected at concentrations below Tier 1 PCLs. 

No TCL SVOCs were detected at levels exceeding

PCLs.

Wastewater Treatment Facility

Eight (8) surface soil samples were collected and

analyzed for TAL metals and TCL SVOCs from the

Wastewater Treatment Facility. The following TAL

metals exceeded TRRP Tier 1 Commercial/Industrial

GWSoil PCLs with maximum concentrations of 10.4

mg/kg arsenic, 150 mg/kg lead, 0.98 mg/kg mercury ,

and 1.4 mg/kg silver. The remaining TAL metals

were either not detected or detected at concentrations

below Tier 1 PCLs. No TCL SVOCs were detected at

any sample location in the Wastewater Treatment

Facility.

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Tar Burn Area

Four (4) surface soil samples were collected and

analyzed for TAL metals and TCL SVOCs from the

Tar Burn Area. The following TAL metals exceeded

TRRP Tier 1 Commercial/Industrial GWSoil PCLs

with maximum reported concentrations of 967 mg/kg

lead, 0.31 mg/kg mercury, and 1.0 mg/kg silver. The

remaining TAL metals were either not detected or

detected at concentrations below Tier 1 PCLs. No

TCL SVOCs were detected at concentrations

exceeding risk based levels. Constituents that were

detected, but did not exceed risk based levels included

the following PAHs: benzo(a)pyrene,

benzo(b)fluoranthene, and butylbenzylphthalate.

Aboveground Storage Tank Area

Six (6) surface soil samples were collected and

analyzed for TAL metals and TCL SVOCs from the

AST area. The following TAL metals exceeded

TRRP Tier 1 Commercial/Industrial GWSoil PCLs

with maximum concentrations of 7.9 mg/kg arsenic,

558 mg/kg lead, 0.13 mg/kg mercury, and 0.96 mg/kg

silver. The remaining TAL metals were either not

detected or detected at concentrations below Tier 1

PCLs. The TCL SVOC analysis detected the

following two constituents at concentrations above

Tier 1 PCLs: 2.7 mg/kg benzo(a)pyrene, and 0.28

mg/kg pentachlorophenol.

Maintenance Shed Area

Five (5) surface soil samples, including one field

duplicate, were analyzed for TAL metals and TCL

SVOCs from the Maintenance Shed Area. The

following TAL metals exceeded TRRP Tier 1

Commercial/Industrial GWSoil PCLs with maximum

concentrations of 5.8 mg/kg antimony, 19 mg/kg

arsenic, 290 mg/kg lead, 0.11 mg/kg mercury, and 1.6

mg/kg thallium. The remaining TAL metals were

either not detected or detected at concentrations below

Tier 1 PCLs. For TCL SVOCs, no constituents were

detected above laboratory quantitation limits.

Former Lauren Tank Farm Area

Six (6) surface soil samples were analyzed for TAL

metals and TCL SVOCs from the Former Lauren

Tank Farm Area. The following TAL metals

exceeded TRRP Tier 1 Commercial/Industrial

GWSoil PCLs with maximum concentrations of 26.4

mg/kg arsenic and 1030 mg/kg lead. Antimony,

cadmium, copper, mercury, nickel, selenium, silver,

and thallium were also detected at concentrations

exceeding the GWSoil PCLs. The remaining TAL

metals were either not detected or detected at

concentrations below risk-based levels.

For TCL SVOCs, benzo(a)pyrene at a concentration

of 5.1 mg/kg was the only constituent to exceed Tier 1

PCLs. The majority of the remaining constituents

were not detected at levels above laboratory reporting

requirements.

Non-source Areas

A majority of the sample locations at the Site came

from areas that did not fall within the defined source

areas. These sample locations were defined as

non-source sample locations. A total of 66 surface soil

samples were analyzed for TAL metals and TCL

SVOCs from the non-source area. Arsenic and lead

exceeded the TRRP Tier 1 Commercial/Industrial

GWPCLs for soils with maximum reported

concentrations of 48.7 mg/kg and 2040 mg/kg,

respectively. Seven additional TAL metals were

detected at concentrations exceeding GWSoil PCLs. 

These metals with the associated maximum reported

concentrations included antimony (26.3 mg/kg),

barium (744 mg/kg), beryllium (1.2 mg/kg), cadmium

(16.4 mg/kg), copper (5480 mg/kg), mercury (0.54

mg/kg), silver (8.3 mg/kg) and thallium (2.9 mg/kg).

The remaining TAL metals were either not detected or

were detected at concentrations below risk-based

levels.

For TCL SVOCs, three PAH compounds were

detected at two locations that exceeded

TOTSoilComb and/or GWSoil PCLs. These PAHs

and associated concentrations included

benzo(a)anthracene (24 mg/kg), benzo(b)fluoranthene

(25 mg/kg) and benzo(a)pyrene (19 mg/kg).

Carbazole and PCP were also detected at 7.5 mg/kg

and 0.060 mg/kg, respectively, at one location, which

exceeds the GWSoil PCL. The remaining TCL

SVOCs were either not detected or were detected at

levels below risk-based levels.

Sediment

Nine (9) intertidal sediment samples were collected

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and analyzed for TAL metals and TCL SVOCs. Lead

and mercury were detected at concentrations

exceeding the TRRP Tier 1 Commercial/Industrial

GWSoil PCLs for soils with maximum concentrations

of 942 and 0.18 mg/kg, respectively. Antimony,

arsenic, cadmium, and selenium were also detected at

concentrations above Tier 1 PCLs. The remaining

TAL metals were either not detected or detected at

concentrations below Tier 1 PCLs.

For the TCL SVOCs, Pentachlorophenol (PCP)

exceeded the TRRP Tier 1 Commercial/Industrial

GWSoil PCLs at two (2) intertidal locations at

concentrations of 0.82 mg/kg and 0.160 mg/kg. The

majority of the remaining constituents were not

detected at levels above laboratory reporting

requirements.

Fifty-eight (58) sediment samples were collected and

analyzed for TAL metals and TCL SVOCs from the

near-shore locations. Arsenic, lead, and mercury were

detected at concentrations exceeding the TRRP Tier 1

Commercial/Industrial GWSoil PCLs for soils with

maximum reported concentrations of 14.3, 29.9 and

0.075 mg/kg, respectively. Barium, beryllium, and

cadmium were also detected at concentrations above

Tier 1 PCLs. The remaining TAL metals were either

not detected or detected at concentrations below risk

based levels.

For TCL SVOCs, 3,3-dichlorobenzidine was the only

constituent to exceed risk-based levels. This

constituent was reported at a concentration of 0.075

mg/kg, which exceeds the GWSoil PCL. The

majority of the SVOC constituents were not detected

at levels above laboratory reporting requirements.

A total of twelve (12) sediment samples were

collected and analyzed for TAL metals and TCL

SVOCs from the offshore locations. Arsenic, lead and

mercury were consistently detected at concentrations

exceeding the TRRP Tier 1 Commercial/Industrial

GWSoil PCLs for soils with maximum reported

concentrations of 8.9, 15.1, and 0.072 mg/kg,

respectively. The remaining TAL metals were either

not detected or detected at concentrations below Tier

1 PCLs.

For the TCL SVOCs, no constituents exceeded the

comparison values. Only two constituents

[benzo(a)pyrene and bis(2-ethylhexyl)phthalate] were

detected above laboratory reporting limits.

Ground Water

The shallow ground water appears to be a mix of fresh

and brackish water from the lake, making it unsuitable

for human consumption. In addition, the ground water

exists at depths where the landfill material exists.

Therefore, ground water may be affected by

constituents of concern from landfill wastes and not

suitable for household drinking water use. Based on

the high TDS concentrations, the proximity of the Site

to brackish surface water, and the presence of the

underlying landfill, there is no current or anticipated

future use of ground water as a source of potable

water at the Site.

SCOPE AND ROLE OF RESPONSE ACTION

This response action is the final site remedy and is

intended to address fully the threats to human health

and the environment posed by the conditions at this

Site. The purpose of this response action is to

implement a remedy to prevent exposure to

contaminated soils and sediments and minimize future

potential runoff of contaminated to that may

accumulate in the Sabine Lake sediments.

SUMMARY OF SITE RISKS

A baseline risk assessment was completed to

determine the current and future effects of

contaminants on human health and the environment.

Based on current zoning and surrounding area, future

land use for the former facility will be limited to

industrial and/or commercial use after completion of

the remedial action. Therefore, the human health risk

assessment focused on health effects for future

industrial and construction workers that could result

from direct contact (incidental ingestion, inhalation,

and dermal contact) with on-site soils and sediments

Human Health Risk Assessment 

In summary, dieldrin and heptachlor epoxide were

identified as COCs in soil in the Maintenance Shed

Area and the Non-source Areas, respectively. In

addition, copper, zinc, and Aroclor 1242 were

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identified as COCs in sediment based on protection of

fish ingestion exposures. However, the modeled fish

tissue concentrations used in this Human Health Risk

Assessment (HHRA) are much higher than the

measured fish tissue concentrations from Lake Sabine

as reported by the Texas Department of Health in data

collected in 1995, and therefore are overly

conservative. 

The following areas of potential concern were

identified for the Site:

• Wastewater Impoundment Area

• Wastewater Treatment Facility

• Tar Burn Area

• Current Aboveground Storage Tank Area

• Maintenance Shed Area

• Lauren Tank Farm

• Non-Source Area

The Site shallow groundwater is not considered a

potential drinking water source and does not represent

an exposure pathway. Likewise, no surface water

locations were identified at the Site and therefore,

surface water does not represent an exposure pathway. 

Ground water and surface water were not evaluated in

the HHRA.

The following receptors were identified and were

evaluated for significant exposure pathways in the

HHRA:

• Current onsite - industrial/commercial worker

(Site owner), adult trespasser (although very

infrequent since the Site is remote in relation

to residential areas).

• Current off-site - adult or child eating fish

caught in Lake Sabine.

• Future onsite - industrial/commercial worker,

construction worker, and adult trespasser

(although very infrequent since the Site is

remote in relation to residential areas)

• Future off-site - adult or child eating fish

caught in Lake Sabine.

Direct contact exposures to sediment were not

quantified since there are currently no complete

exposure pathways for sediment.

Chemical of Potential Concern

The following chemicals of potential concern

(COPCs) were identified for soil and sediment.

Soils:

• benzo(a)pyrene

• dibenzo(a,h)anthracene

• indeno(1,2,3-cd)pyrene

• benzo(a)anthracene

• benzo(b)fluoranthene

• Aroclor-1254

• dieldrin

• p,p'-DDD

• p,p'-DDE

• p,p'-DDT

• alpha-chlordane

• heptachlor epoxide

Sediment

• Aroclor-1242

• copper

• zinc

Risk Characterization

The EPA considers two types of risk: cancer risk and

non-cancer risk. Excess lifetime cancer risks that

range from 1x10-6 to 1x10-4 (one-in-one-million to a

one-in-ten-thousand risk) are considered by the EPA

to be acceptable. Risks greater than 1x10-4 are

considered unacceptable. For non-cancer risks, a

hazard index less than 1 for an individual target organ

or system is below the threshold for predicted health

effects.

Potential excess lifetime cancer risks (ELCRs) and

hazard indices (HIs) were calculated using reasonable

maximum exposure (RME) assumptions for the

receptors and exposure pathways identified above. 

The following potential risks were identified:

• Current/Future onsite Industrial/Commercial

Worker - Ingestion, dermal contact, and

inhalation exposures to soil COPCs in the

former Wastewater Impoundment Area and

former Wastewater Treatment Facility were

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quantified. Risks are within acceptable levels.

• Current/Future onsite Industrial/Commercial

Worker - Ingestion, dermal contact, and

inhalation exposures to soil COPCs in the

former Tar Burn Area, former Lauren Tank

Farm Area, and Current Aboveground Storage

Tank Area were quantified. Risks are within

acceptable levels.

• Current/Future onsite Industrial/Commercial

Worker - Ingestion, dermal contact, and

inhalation exposures to soil COPCs from all

non-source areas were quantified. An ELCR of

9x10-5 and HI of 2 were calculated. One

COPC (heptachlor epoxide) exceeded an

individual ELCR of 1x10-5 and HI of 1. 

Therefore, risks exceed acceptable levels and

one COC (heptachlor epoxide) was identified

for this receptor and exposure area. Estimated

risks were also evaluated using CT exposure

assumptions. An ELCR of 1x10-5 and HI of

0.9 were calculated. No COPCs exceeded an

individual ELCR of 1x10-5 or HI of 1. 

Therefore, risks are within acceptable levels

and no COCs were identified for this receptor

and exposure area using CT exposure

assumptions.

• Current/Future onsite Industrial/Commercial

Worker #5 - Ingestion, dermal contact, and

inhalation exposures to soil COPCs in the

former Maintenance Shed Area were

quantified. An ELCR of 2x10-4 and HI of 0.7

were calculated. One COPC (dieldrin)

exceeded an individual ELCR of 1x10-5; no

COPCs exceeded an individual HI of 1. 

Therefore, risks exceed acceptable levels and

one COC (dieldrin) was identified for this

receptor and exposure area. Since a COC was

identified, estimated risks were also evaluated

using CT exposure assumptions. An ELCR of

2x10-5 and HI of 0.4 were calculated. 

Dieldrin exceeded an individual ELCR of

1x10-5. Therefore, risks exceed acceptable

levels and one COC (dieldrin) was identified

for this receptor and exposure area using CT

exposure assumptions.

• Current/Future off-site Fisher - Ingestion

exposures to COPCs in sediment

(bioaccumulated by fish in Lake Sabine) were

quantified for an adult. An ELCR of 2x10-4

and HI of 7 were calculated. One COPC

(Aroclor 1242) exceeded an individual ELCR

of 1x10-5 and copper and zinc exceeded an HI

of 1. Therefore, risks exceed acceptable levels

and three COCs (Aroclor 1242, copper, and

zinc) were identified for this receptor and

exposure area. Since COCs were identified,

estimated risks were also evaluated using CT

exposure assumptions. An ELCR of 8x10-5

and HI of 7 were calculated. One COPC

(Aroclor 1242) exceeds an individual ELCR of

1x10-5 and two COCs (copper and zinc)

exceed an HI of 1. Therefore, risks exceed

acceptable levels and three COCs (Aroclor

1242, copper, and zinc) were identified for this

receptor and exposure area using CT exposure

assumptions.

Uncertainty Assessment

Pesticides in Soil

Dieldrin and heptachlor epoxide were identified as

COCs in soil. Based on knowledge of historic site

operations, these chemicals may to be associated with

site activities. There is uncertainty in the risk

estimates by inclusion of these chemicals.

Aroclor 1242 in Sediment

Aroclor 1242 is a risk driver for sediment in the

HHRA. However, there is much uncertainty in the

risk calculations, primarily due to the available

dataset. No source has been identified onsite. 

Available data from all areas of the Site indicate no

detections of Aroclor 1242. Aroclor 1242 was

detected in one of seven sediment samples; it was the

only Aroclor detected. PCBs were not analyzed in the

background sediment dataset. The fish ingestion risk

calculations are based on a single, detected PCB

concentration in sediments. This concentration is not

expected to represent the PCB concentrations that a

fish comes in contact with during its lifetime since a

fish's home range is much larger than the single

location. Therefore, using one location to model fish

uptake is extremely conservative. 

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The TDH prepared a risk assessment of Sabine Lake

under EPA's Near Coastal Water Grant. Although

these data were gathered for a broader study, the data

were reportedly collected in accordance with EPA's

Guidance for Assessing Chemical Contaminant Data

for Use in Fish Advisories, Fish Sampling and

Analysis. Aroclor 1242 was not detected in fish

samples.

Copper in Sediment

Copper is a risk driver for sediment in the HHRA. 

However, there is much uncertainty in the risk

calculations because no significant source of copper

has been identified onsite. The calculated HI is 2

using both reasonable maximum exposure and central

tendency exposure scenarios. This level is only

slightly higher than the acceptable HI of 1. The TDH

prepared a risk assessment of Sabine Lake under

EPA's Near Coastal Water Grant. Aquatic species

were collected to represent commonly consumed

edible tissue taken by the public from sample

locations in Sabine Lake (South), Sabine Lake

(North), and Sabine Pass. Copper was detected in 3

of the 10 fish samples. The maximum detected

concentration of copper in fish tissue of 19 ppm is

much lower than the modeled fish tissue concentration

of 150 ppm used in the risk calculations. 

Zinc in Sediment

Zinc is a risk driver for sediment in the HHRA. 

However, there is much uncertainty in the risk

calculations because no significant source of zinc has

been identified onsite. The calculated HI is 5 using

both reasonable maximum exposure and central

tendency exposure scenarios. This level is slightly

higher than the acceptable HI of 1. The TDH

prepared a risk assessment of Sabine Lake under

EPA's Near Coastal Water Grant (TDH, 1995). 

Aquatic species were collected to represent commonly

consumed edible tissue taken by the public from

sample locations in Sabine Lake (South), Sabine Lake

(North), and Sabine Pass. Zinc levels were detected

in all 10 fish tissue samples. The maximum detected

concentration of zinc in fish tissue of 344 ppm was

much lower than the modeled fish tissue concentration

of 4,300 ppm zinc used in the conservative risk

calculations for the State Marine Site.

Ecological Risk Characterization

Hazard quotients (HQ) for ecological risk analysis

were calculated by dividing exposure point

concentrations (EPC) by ecological risk-based

screening levels for benthic invertebrates and

exposure doses by toxicological reference values for

wildlife. HIs were calculated for total low molecular

weight polycyclic aromatic hydrocarbons (LPAHs)

and high molecular weight polycyclic aromatic

hydrocarbons (HPAHs) as the sum of HQs for

individual PAHs.

Terrestrial Omnivorous/Insectivorous Mammals: 

The no observed adverse effect level (NOAEL)-based

HQ for the white-footed mouse exceeded unity at the

following locations:

• Former Wastewater Impoundments

• Wastewater Treatment Facility

• Above Ground Storage Tanks 

• Maintenance Shed Area

• Tar Burn Area 

• No lowest observable adverse effects level

(LOAEL)-based HQs exceeded unity.

• Risk to the omnivorous/ insectivorous

mammal feeding guild for the above areas lies

in the risk management area between the

NOAEL and LOAEL, therefore these risks

was considered margin and not evaluated in

the risk analysis for the Site.

• Lauren Tank Farm area exceeded NOAELbased HQs unity for several contaminants. 

LOAEL-based HQs also exceeded unity for

endrin aldehyde. Therefore, risk to the

omnivorous/ insectivorous mammal feeding

guild from endrin aldehyde was included in

the risk analysis for the Site.

• Non-source Area exceeded NOAEL-based

HQs unity for several contaminants. 

LOAEL-based HQs also exceeded unity for

dieldrin, endrin aldehyde, and heptachlor

epoxide. Therefore, risks to the omnivorous/

insectivorous mammal feeding guild from

dieldrin, endrin aldehyde, and heptachlor

epoxide were evaluated in the risk analysis for

the Site.

005948
9

Terrestrial Omnivorous/Insectivorous Birds: 

HQs for the northern bobwhite quail exceeded

NOAEL-based HQs unity for several contaminants. 

However, all HQs were below 10. No LOAEL-based

HQs exceed unity. Therefore, the risk to the

omnivorous/ insectivorous bird feeding guild lies in

the risk management area between the NOAEL and

LOAEL. These risks are considered marginal and

were not included in the risk analysis for the Site.

Terrestrial Carnivorous Mammals:

No NOAEL-based or LOAEL-based HQs exceeded

unity for the coyote. Therefore, there is no risk to the

carnivorous mammal feeding guild.

Benthic Invertebrates: 

Sediment concentrations from all three exposure areas

in Sabine Lake were compared to primary and

secondary effects levels indicative of toxicity to

benthic invertebrate communities. Benthic

invertebrates range from immobile to having fairly

small home ranges; therefore, each exposure area was

evaluated independently. 

 

• The analysis of the Intertidal Area indicates

marginal or lower risk exists for all chemicals

of potential ecological concern (COPECs)

except lead. The maximum magnitude of

exceedance of the primary effect levels is less

than 10 for all COPECs. Lead exceeded the

secondary effect level. Risks to benthic

invertebrates for all COPECs except lead are

marginal, and were not included in the risk

analyses for the Site. The risk to benthic

invertebrates for lead was included in the risk

analysis.

• The analysis of the Nearshore Area indicates

marginal or lower risk exists for all COPECs. 

The maximum magnitude of exceedance of the

primary effect levels is less than 10 for all

COPECs. Risks for all COPECs for the

Nearshore Area were not included in the risk

analysis for the Site.

• The analysis of the Offshore Area indicates

marginal or lower risk exists for all COPECs. 

The maximum magnitude of exceedance of the

primary effect levels is less than 10 for all

COPECs and no sample concentrations

exceeded secondary effect levels. Risks to

benthic invertebrates for all COPECs are

marginal and were not included in the risk

analysis for the Site.

Omnivorous/Insectivorous Birds:

• No NOAEL-based or LOAEL-based HQs

exceeded unity for the spotted sandpiper in the

Intertidal Area.

• The NOAEL-based HQs in the Nearshore

Area exceeded unity for several contaminants. 

No LOAEL-based HQs exceeded unity.

• The combined total NOAEL-based HQs for

the spotted sandpiper representing

omnivorous/ insectivorous shore birds

foraging in both the Intertidal and Nearshore

areas exceeded unity for several contaminants. 

No LOAEL-based HQs exceed unity. Risks to

omnivorous/ insectivorous shore birds are

marginal, and were not included in the risk for

the Site.

Piscivorous Birds:

• NOAEL-based HQs for the belted kingfisher

from the combined Intertidal, Near Shore, and

Offshore Areas exceeded unity only for zinc. 

No LOAEL-based HQs exceeded unity. The

risk to the piscivorous bird feeding guild is

considered marginal and was not included in

the risk analysis.

Uncertainty Assessment

The nature and magnitude of the uncertainties depend

on the amount and quality of data available, the

degree of knowledge concerning site conditions and

the assumptions made to perform the assessment. A

qualitative evaluation of the major general

uncertainties associated with this screening

assessment is outlined below:

• No avian and mammalian life history data

specific to the site were available; therefore,

exposure parameters were either modeled

based on allometric relationships or were

based on data from these same species in other

portions of its range. As a consequence, risk

005949
10

may be either overestimated or

underestimated.

• No site-specific data on concentrations in prey

items were available. Therefore,

concentrations in these prey items were

estimated using literature-derived

bioaccumulation models. As a consequence,

concentrations of COPECs in actual prey may

be either higher or lower than the data used in

this screen.

• Literature-derived toxicity data based on

laboratory studies were the only available

toxicity data used to evaluate risk to all

receptor groups. Consequently, the risk may

be either overestimated or underestimated.

• Dietary compositions were simplified for the

site receptors to estimate concentrations in

food items using bioaccumulation models. It

was assumed that concentrations were similar

in comparable food types. Consequently, risk

may be either overestimated or

underestimated.

• Because toxicity data specific for bird and

mammal species at the site were not available,

it was necessary to extrapolate toxicity values

from test species to site receptor species. As a

consequence, risk may be either overestimated

or underestimated.

• In this screen, risks for most chemicals were

each considered independently. Because

chemicals may interact in an additive,

antagonistic, or synergistic manner, the

evaluation of single-chemical risk may either

underestimate or overestimate risk associated

with chemical mixtures. The risk from PAHs

and organochlorine pesticides were summed to

determine the combined risk.

• Detection limits for some data were

insufficient because they were greater than

ecological screening values. These compounds

were carried forward in the risk assessment

and evaluate for effects on wildlife using 1/2

the detection limit as a proxy value for

non-detects. This assumption could either

under- or overestimate risk depending on the

true concentration of those constituents. 

• All sediment data used in the risk assessment

is a minimum of four years old. The Site is

located along Sabine Lake adjacent to a canal

that receives regular boat traffic and is dredged

every two to three years. The sediments in this

area are also subject to tidal movements.

Sediments located in such an active area are

not likely to remain constant, and as such, the

available data from are not necessarily

reflective solely of site-related influence, nor

are they definitively representative of existing

conditions.

• There is a lack of spatial coverage for

pesticide data at the Site. Pesticides were

detected in some of the source areas; however,

there was insufficient sample coverage to

determine if a site related gradients exist. In

these areas, risk could be either under or over

estimated.

• Risk was not calculated for reptiles and

amphibians due to insufficient toxicological

data and site-specific data. Some species of

omnivorous birds have similar diets to those of

omnivorous reptiles and amphibians. Hence,

conclusions for the omnivorous bird feeding

guild were considered representative of the

reptiles and amphibians likely living on the

Site. 

• Risk was not calculated for terrestrial plants or

invertebrates. No endangered plant or

invertebrate species were identified within the

area. These lower trophic level organisms

were not considered assessment endpoints for

the Site.

• Toxicity information adequate to quantify

ecological risks was not available for some

detected constituents. Consequently; these

constituents could not be evaluated. The

uncertainty of risk to one class of receptors in

these cases is reduced by the lack of

quantifiable risk to the other class of

organisms.

• The exposure dose estimates in this screening

risk assessment assume that one hundred

percent of the chemical concentrations to

which receptors are exposed are in the

bioavailable form. Most chemicals will not be

one hundred percent bioavailable. In the cases

where bioavailability is less than one hundred

percent, risk is overestimated.

REMEDIAL ACTION OBJECTIVES

005950
11

The Remedial Action Objectives (RAOs) are based

on the future redevelopment of this Site for industrial

or commercial use, protecting future industrial

workers and construction workers, and ecological

receptors. Although future planned industrial use will

likely not support ecological habitat, ecological risks

may be a factor. The preliminary remedial action

objectives for the SMS:

• Prevent exposure to contaminated

soil/sediment via ingestion, inhalation, or

dermal contact that would result in an excess

carcinogenic risk of 1 x 10-5 or a hazard index

(HI) of 1. 

• Prevent exposure of contaminated

soil/sediment to aquatic or terrestrial

organisms via direct contact or indirect

ingestion of bioaccumulative chemicals that

would result in a hazard quotient of 1.

• Prevent or minimize migration of soil

contaminants to ground water.

• Prevent or minimize further migration of soil

and sediment contaminants to surface water

that could result in exceedance of ambient

water quality criteria.

Preliminary Remediation Goals

Preliminary Remediation Goals (PRGs) were

developed for COPCs and exposure areas where the

total risk for a receptor exceeded 1x10-5 or an HI of

1. The target risk levels used to develop the PRGs

were an ELCR equal to 1x10-5 and an HI of 1.

• Maintenance Shed Area - A PRG of 1.2 mg/kg

for dieldrin was identified for protection of

ingestion, dermal contact, and inhalation

exposures to soil by current and future

industrial/commercial workers. 

Concentrations in two samples collected from

this area exceed the PRG.

• Non-Source Areas - A PRG of 2.1 mg/kg and

HI less than 1 for heptachlor epoxide was

identified for protection of ingestion, dermal

contact, and inhalation exposures to soil by

current and future industrial/commercial

workers. Concentration in one sample

collected from this area exceeds the PRG.

• Sediments in Lake Sabine - A PRG was

identified for protection of exposures to

Aroclor 1242, copper, and zinc in edible fish

tissue by current and future receptors eating

fish caught in Lake Sabine. The PRG of

1.5x10-4 mg/kg for Aroclor 1242 is based on a

1x10-5 ELCR for this receptor. The detected

concentration of Aroclor 1242 in one sample

collected from sediment exceeds the PRG. 

The PRGs of 91 and 734 mg/kg for copper and

zinc, respectively, are based on a HI of 1 for

this receptor. Concentrations in four and two

locations, respectively, exceed the PRGs for

copper and zinc.

SUMMARY OF REMEDIAL ALTERNATIVES

Remedial alternatives were developed to address the

remedial action objectives and goals for the Site soils

and sediments.

Soil Alternatives

Alternative 1: No Further Action

Estimated Capital Cost: $0

Estimated Annual O&M Costs: $0

Estimated Present Worth (7%): $0

Regulations governing the Superfund program, 40

C.F.R. § 300.430(e)(6) require that the “no action”

alternative be evaluated at every Site to establish a

baseline for comparison. Under this alternative, there

would be no additional remedial actions conducted at

the Site to control the continued release of COCs.

Alternative 2: Institutional Controls

Estimated Capital Cost: $182,000

Estimated Annual O&M Costs: $7,000

Estimated Present Worth (7%): $343,000

The objectives of institutional controls are to prevent

direct exposure to the contaminated soils. Institutional

controls would consist of access and deed restriction

for the areas exceeding PRGs. A restrictive fence

would be placed to provide access restrictions. A

statement would be added on the deed of the property

identifying the area and specifying the following: 

• Excavation within the area must comply with

Occupational Safety and Health Act (OSHA)

005951
12

requirements for health and safety protection

• Any excavated soils should be managed as

either solid or hazardous waste in accordance

with applicable laws

• Buildings are not permitted within the

contaminated soil area

• Shallow ground water, if it is available, may

not be used

• Future land use will be limited to commercial

or industrial uses

The time to implement this remedy is approximately

one month.

Alternative 3: Onsite Soil Cover

Estimated Capital Cost: $784,000

Estimated Annual O&M Costs: $17,000

Estimated Present Worth (7%): $1,203,000

This alternative consists of a clean soil cover used in

conjunction with grading and vegetative cover over

the three soil hot spot areas. A total area of

approximately 53,600 square feet will be covered

assuming a minimum overlap of 10 feet beyond the

limits of the contaminated soil hot spot areas. The

soil cover consists of the following components:

• Separation geotextile

• 24-inch layer of compacted clay

• 6-inch layer of topsoil

• Vegetative cover

After removing existing vegetation and grading, a

separation geotextile would be placed over the

prepared sub-grade to provide a visual delineation

between contaminated soils and the clean soil cover. 

The clay cover would be placed and compacted to a

minimum thickness of 24-inches. A 6-inch topsoil

layer would be placed to support the vegetative cover. 

The cover system would be designed to reduce

infiltration to ground water to minimize the potential

for further migration of COCs to shallow ground

water. Following construction, the condition of the

soil cover system will be visually monitored annually

as part of the O&M plan.

The time to implement this remedy is expected to be

approximately 6 months.

Alternative 4: Excavation, Treatment and Offsite

Disposal

Estimated Capital Cost: $1,881,000

Estimated Annual O&M Costs: $17,000

Estimated Present Worth (7%): $2,431,000

The excavation, treatment (if needed), and off-site

disposal alternative consists of excavating

contaminated soils that exceed PRGs within the three

soil hot spot areas. The major remedial components

of this alternative include the following:

• Excavation of soils containing COCs that

exceed PRGs.

• Backfill of the areas excavated with clean, low

permeability soil to meet landfill cover

requirements

• Ex situ treatment (on or offsite as appropriate)

to meet land disposal restrictions (if needed)

• Off-site disposal of removed/treated material

This alternative will meet the cleanup objectives by

removing the soil with contaminant concentrations

exceeding PRGs. The area to be excavated is defined

by the limits of excavation shown on Figure 3-3. This

alternative will include removal of soil overlying the

landfill waste, which is estimated at an average

thickness of 2 feet. It is assumed that excavation will

not proceed into the landfill waste. The approximate

(in place) volume of soil to be disposed off-site is

assumed to be 2,750 cubic yards. Confirmatory

sampling will be conducted to minimize the

excavation area; however, confirmatory samples will

not be collected within the underlying landfill waste. 

Excavated soils exceeding the PRGs will be sampled

and analyzed for TCLP parameters. Soils not failing

TCLP will be disposed at an off-site facility. Soils

exceeding TCLP limits will be treated prior to off-site

disposal. 

After completion of excavation, a soil backfill and

cover system will be constructed to meet landfill

cover requirements. Since contaminated soils are

removed, minimal overlap of the cover area would be

required beyond the limits of the soil hot spot

excavation areas. A total area of approximately

39,200 square feet will be covered.

The time to implement this remedy is expected to be 6

005952
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to 9 months.

Sediment Alternatives

Alternative 1: No Further Action

Estimated Capital Cost: $0

Estimated Annual O&M Costs: $0

Estimated Present Worth (7%): $0

Regulations governing the Superfund program, 40

C.F.R. § 300.430(e)(6) require that the “no action”

alternative be evaluated at every site to establish a

baseline for comparison. Under this alternative, there

would be no additional remedial actions conducted at

the site to control the continued release of COCs.

Alternative 2: Monitored Natural Attenuation

Estimated Capital Cost: $68,000

Estimated Annual O&M Costs: $6,000

Estimated Present Worth (7%): $286,000

The objectives of this alternative are to prevent direct

exposure to the contaminated sediments while the

natural attenuation process occurs. Natural

attenuation relies on natural physical, chemical, or

biological processes that, under favorable conditions,

act without human intervention to reduce the mass,

toxicity, mobility, volume, or concentration of

contaminants in soil, sediment or ground water. 

These in situ processes include bio-degradation;

dispersion; dilution; sorption; volatilization; chemical

or biological stabilization, transformation, or

destruction of contaminants. For sediment,

continuing deposition of clean sediment on top of

contaminated sediments would limit direct contact to

contaminated sediments. This mechanism is

particularly relevant to the State Marine Site due to

the close proximity of the Sabine-Neches Canal which

is routinely dredged. The major components of this

alternative are:

• Review of existing characterization data and

collection of additional site characterization

data to adequately define the nature and extent

of sediment contamination to establish a

baseline from which to evaluate the degree to

which natural attenuation is occurring

• Performance monitoring to assess the

effectiveness of natural attenuation processes

over time.

Existing site characterization would need to be

supplemented to further delineate the sediment hot

spots. Additional sampling would be conducted to

determine the areal extent of the hot spot as well as

performing site specific bioassays. Once the current

nature and extent of COCs is adequately defined,

performance monitoring would be conducted to assess

the rate at which natural attenuation processes are

achieving remedial action objectives. The

performance monitoring would include annual

sampling events for the first 5 years, and could

include follow up events less frequently until PRGs

are achieved.

Alternative 3: Excavation, Treatment and Offsite

Disposal

Estimated Capital Cost: $1,360,000

Estimated Annual O&M Costs: $0

Estimated Present Worth (7%): $1,524,000

The excavation, treatment, and off-site disposal

alternative consists of excavating sediments with

contaminant concentrations that exceed PRGs within

the sediment hot spot areas. The major remedial

components of this alternative include the following:

• Excavation of sediments containing COCs that

exceed PRGs

• Sediment de-watering

• Ex situ treatment to meet land disposal

restrictions

• Off-site disposal

This alternative will meet the cleanup objectives by

removing the sediment with contaminant

concentrations exceeding PRGs. This alternative will

include removal of sediment to an assumed depth of 1

foot. The approximate volume of sediment to be

disposed off-site is assumed to be 800 cubic yards. 

Excavation of sediment would be accomplished by

barge or pontoon mounted mechanical excavation

equipment (track-hoe or back-hoe). Excavation of

sediments would require installation of a containment

area to isolate remedial actions from the surrounding

surface water for turbidity/re-suspension management. 

 The containment area would consist of installing a

floating turbidity screen around the work area, and

005953
14

may require double containment through use of a

turbidity screen curtain if site-specific conditions

require an added measure of protection. Excavated

sediments exceeding the PRGs will be sampled and

analyzed for TCLP parameters. Sediments not failing

TCLP will be disposed at an off-site facility. 

Sediments exceeding TCLP limits will be treated prior

to off-site disposal.

The time to implement this remedy is expected to be 6

to 9 months.

EVALUATION OF ALTERNATIVES

Nine criteria are used to evaluate the different

remediation alternatives individually and against each

other in order to select a remedy. The nine evaluation

criteria are (1) overall protection of human health and

the environment; (2) compliance with ARARs; (3)

long-term effectiveness and permanence; 4) reduction

of toxicity, mobility, or volume of contaminants

through treatment; (5) short-term effectiveness; (6)

implementability; (7) cost; (8) State/support agency

acceptance; and (9) community acceptance. This

section of the Proposed Plan profiles the relative

performance of each alternative against the nine

criteria, noting how it compares to the other options

under consideration. The nine evaluation criteria are

discussed below. The “Detailed Analysis of

Alternatives” can be found in the FS.

1. Overall Protection of Human Health and the

Environment determines whether an alternative

eliminates, reduces, or controls threats to public

health and the environment through institutional

controls, engineering controls, or treatment.

The No Further Action Alternative does not provide

protection of human health or environment. The

Institutional Controls Alternative provides some

protection for human health but no protection for the

environment. The Soil Cover Alternative provides

adequate protection by eliminating the direct contact

pathway and mobility. The Excavation Alternative

provides the highest level of protection for human

health and the environment by removing COCs from

the Site and treating (if needed) them to meet LDRs,

and provides clean cover over the existing landfill

waste under the soil remedy.

2. Compliance with ARARs evaluates whether the

alternative meets Federal and State environmental

statutes, regulations, and other requirements that

pertain to the Site or whether a waiver is justified.

No Further Action and the Institutional Controls

Alternatives do not comply with ARARs. The Soil

Cover and Excavation Alternatives comply with

ARARs.

3. Long-term Effectiveness and Permanence

considers the ability of an alternative to maintain

protection of human health and the environment over

time.

The No Further Action Alternative does not provide

long term effectiveness or permanence. The 

Institutional Controls Alternative provides minimal

effectiveness for human health, but no effectiveness

for ecological receptors (environment). The Soil

Cover Alternative provides long term effectiveness

and permanence provided operations and maintenance

are ongoing. The Excavation Alternative provides the

highest degree of effectiveness and permanence due to

the removal (and treatment if needed) of COCs.

4. Reduction of Toxicity, Mobility, or Volume of

Contaminants through Treatment evaluates an

alternative’s use of treatment to reduce the harmful

effects of principal contaminants, their ability to move

in the environment, and the amount of contamination

present.

The No Further Action and Institutional Controls

Alternative do not reduce TMV. The Soil Cover

Alternative reduces mobility. The Excavation

Alternative reduces mobility and toxicity, but could

increase volume if treatment is implemented.

5. Short-term Effectiveness considers the length of

time needed to implement an alternative and the risks

the alternative poses to workers, residents, and the

environment during implementation.

The Institutional Controls Alternative provides

minimal effectiveness. The Soil Cover Alternative

easily mitigates risks to workers and the community

and achieves RAOs in a short time. The Excavation

Alternative easily mitigates risks to workers and the

005954
15

community and achieves RAOs in a short time, but

increases risk due to off-site transportation of

contaminated materials and provides a slightly higher

risk to workers during construction than capping.

6. Implementability considers the technical and

administrative feasibility of implementing the

alternative such as relative availability of goods and

services.

The Institutional Controls Alternative is easily

implemented. The Soil Cover Alternative is easily

implemented using standard construction methods. 

The Soil Excavation Alternative is easily

implemented using standard construction methods. 

This alternative is somewhat more complex than

capping due to the existence of landfill waste and may

require treatment of hazardous materials prior to offsite disposal. The Sediment Excavation Alternative is

most difficult to implement due to in-water

construction.

7. Cost includes estimated capital and operation and

maintenance costs as well as present worth costs.

Present worth cost is the total cost of an alternative

over time in terms of today’s dollar value. Cost

estimates are expected to be accurate within a range

of +50 to -30 percent.

Capital Costs for Soil alternatives evaluated range

from $560,000 to $2,458,000. 

Capital Costs for Sediments alternatives evaluated

range from $429,000 to $1,471,000 .

8. State/Support Agency Acceptance considers

whether the State agrees with U.S. EPA’s analyses

and recommendations of the RI/FS and the Proposed

Plan.

TCEQ and the Federal and State Natural Resource

Trustee have been provided the opportunity to review

the RI/FS reports and Proposed Plan and their support

for the preferred alternative will be evaluated during

the public comment period.

9. Community Acceptance considers whether the

local community agrees with U.S. EPA’s analyses and

preferred alternative. Comments received on the

Proposed Plan are an important indicator of

community acceptance.

Community acceptance of the preferred alternative

will be evaluated after the public comment period

ends and will be described in the Record of Decision

for the Site.

SUMMARY OF THE PREFERRED

ALTERNATIVE

The preferred remedial alternative for site soil is

Alternative 4, Excavation, Treatment and Offsite

Disposal. This alternative best meets the cleanup

objectives by removing contaminated soils with

concentrations exceeding PRGs from the Site. 

Alternative 4 provides the highest degree of

effectiveness and permanence due to the removal (and

treatment if needed) of COCs. This alternative

reduces mobility and toxicity at the Site by removing

and disposing of contaminated materials at an off-site

landfill. Although the soil alternative has the highest

costs, very conservative estimates were made in the

estimated volume of materials that would require

excavation. Additionally, conservative assumptions

were made regarding materials requiring treatment

and disposal in a hazardous waste landfill. 

Alternative 4 includes removal of soil to an estimated

depth of two (2) feet. The approximate (in place)

volume of soil to be disposed off-site is assumed to be

2,750 cubic yards. Excavated soils exceeding the

PRGs will be sampled and analyzed for TCLP

parameters. Soils not failing TCLP will be disposed

at an off-site facility. Soils exceeding TCLP limits

will be treated prior to off-site disposal.

Alternative 4 offers the best permanent protection for

human health and the environment by removing

contaminated soils from the Site that pose a risk to

human health and prevents runoff of contaminated

soils to the sediments in Sabine Lake.

The preferred remedial alternative for Site Sediments

is Alternative 2, Monitored Natural Attenuation.

While this alternative does not remove contaminated

sediments from the Site, it provides long term

protection to ecological receptors through natural

attenuation of contaminated sediments. Excavation

and removal of contaminated site soils will prevent

further accumulation of contaminated sediment and

005955
16

help accelerate the attenuation process. Excavating

contaminated sediments could result in damaging

ecological receptors and their environment and cause

more harm than the benefit that the excavation remedy

provides.

The preferred alternatives can change in response to

public comment or new information.

For specific information about the State Marine

Site or the Superfund process, please contact:

Carlos A. Sanchez.

Remedial Project Manager

EPA Region 6 (6SF-A)

1445 Ross Avenue

Dallas, Texas 75202-2733

(214) 665-665-8507 or 1-800-533-3508 (Toll-free)

Inquires from the news media are to be directed to

Dave Bary, U.S. EPA Region 6 Press Office, at (214)

665-2208.

The local Information Repository containing the

RI/FS and other Site documents is located at:

Port Arthur Public Library

4615 9th Avenue

Port Arthur, Texas 77642

(409) 985-8838

On the Web

On the internet, information about U.S. EPA and the

Superfund Program can be found at:

U.S. EPA Headquarters: http://www.epa.gov

U.S. EPA Region 6: http://www.epa.gov/region6

U.S. EPA Region 6 Superfund Program: 

http://www.epa.gov/region6/superfund

Call U.S. EPA at 1-800-533-3508 to receive a Spanish

translation of this fact sheet.

* * *

Para recibir una traducción en español de esta Hoja de

Datos, comunicarse con la Agencia de

Protección del Medio Ambiente de los EEUU (la

EPA) al número de teléfono 1-800-533-3508.

005956
GLOSSARY OF TERMS

Administrative Record - All documents which the

EPA considered or relied upon in selecting the

response action at a Superfund site, culminating in

the Record of Decision for a Remedial Action or, an

Action Memorandum for a Removal Action.

Human Health Risk Assessment (HHRA) -

Estimates the current and possible future risks if no

action were taken to clean up a site. The EPA’s

Superfund risk assessors determine how threatening a

hazardous waste site is to human health and the

environment. They seek to determine a safe level for

each potentially dangerous contaminant present (e.g.,

a level at which ill health effects are unlikely and the

probability of cancer is very small). Living near a

Superfund site doesn’t automatically place a person

at risk, that depends on the chemicals present and the

ways people are exposed to them.

Ecological Risk Assessment - A process that

evaluates the likelihood that adverse ecological

effects may occur or are occurring as a result of

exposure to one or more chemical, physical, or

biological stressors.

Feasibility Study (FS) - A detailed evaluation of

alternatives for cleaning up a site. A FS is usually

performed concurrently with the Remedial

Investigation.

Five-Year Reviews - A review generally required by

statute or program policy when hazardous substances

remain at a site above levels which permit

unrestricted use and unlimited exposure. Five-Year

Reviews provide an opportunity to evaluate the

implementation and performance of a remedy to

determine whether it remains protective of human

health and the environment. Reviews are performed

five years following the initiation of a Superfund

response action, and are repeated every succeeding

five years so long as future uses at a site remain

restricted.

Ground Water - Water found beneath the ground

surface that fills pores between soil, sand, and gravel

particles to the point of saturation. When it occurs in

a sufficient quantity and quality, ground water can be

used as a water supply.

Institutional Controls (ICs) - Non-engineered

instruments, such as administrative and/or legal

controls, that help to minimize the potential for

human exposure to contamination and/or protect the

integrity of a remedy. ICs work by limiting land or

resource use and/or by providing information that

helps modify or guide human behavior at a site. 

Some common examples of ICs include zoning

restrictions, building or excavation permits, well

drilling prohibitions, and easements or covenants.

Microgram per Deciliter (μg/dL) - Units of

measure used to express the concentrations of metals

(e.g., lead) or organics in liquids.

Milligram per Kilogram (mg/kg) - Units of

measure used to express the concentrations of metals

(e.g., lead) or organics in soil or sediments. As an

example, one mg/kg of lead in soil would be

equivalent to one cent in $10,000.

National Priorities List (NPL) - The EPA’s list of

the most serious uncontrolled or abandoned

hazardous waste sites identified for possible longterm Remedial Action (RA) under Superfund. A site

must be on the NPL to receive money from the Trust

Fund for a RA. The NPL is based primarily on the

score a site receives from the Hazard Ranking

System. The EPA updates the NPL at least once a

year.

Potentially Responsible Parties (PRP) - Any

individual or company, including owners, operators,

transporters or generators, who is potentially

responsible for, or contributing to a spill or other

contamination at a Superfund site.

Record of Decision (ROD) - The final Remedial

Action plan for a site. The purpose of the ROD is to

document the remedy selected, provide a rationale for

the selected remedy, and establish performance

005957
18

standards or goals for the site or the operable unit

under consideration. The ROD provides a plan for

site design and remediation, and documents the

extent of human health or environmental risks posed

by the site or operable unit. It also serves as legal

certification that the remedy was selected in

accordance with the requirements of the Superfund

statute and regulations. The ROD is one of the most

important documents in the remedy selection process,

because it documents all activities prior to selection

of a remedy and provides a conceptual plan for

activities subsequent to the ROD.

Remedial Investigation (RI) - An investigation to

determine the nature and extent of contamination at a

site. The scope of an RI can vary widely from a

small specific activity to a complex study. The next,

or concurrent step, following an RI is a Feasibility

Study.

Removal Action - An action based on the type of

situation, the urgency and threat of the release or

potential release, and the subsequent time frame in

which the action must be initiated. The Removal

Actions for the State Marine Superfund Site

consisted of “time-critical” Removal Actions where

the EPA determined, based on the evaluation of the

Site, that a Removal Action was appropriate to

contain and/or prevent release of contaminants that

pose a risk to human and the environment.

Responsiveness Summary - A summary of oral

and/or written public comments received by the EPA

during a public comment period on key EPA

documents, such as the Proposed Plan for the State

Marine Site, and the EPA’s response to those

comments. A responsiveness summary is included in

the Record of Decision for a site.

005958
ATTACHMENT 1

COMMENT SHEET

Your comments on the Proposed Plan for the State Marine Superfund Site are important to the EPA and

the TCEQ and will help us evaluate EPA’s preferred alternative for the State Marine Site. You may use the

space below to write your comments. Use additional sheets if necessary. Please mail your comments to:

Carlos A. Sanchez, Remedial Project Manager

U.S. Environmental Protection Agency; Superfund Division (6SF-A)

1445 Ross Avenue, Suite 1200; Dallas, TX 75202-2733

Your comments must be postmarked on or before August 25, 2005, the end of the 30-day public

comment period. You may also provide oral or written comments during the scheduled public meeting

announced in this Proposed Plan. Those with computer communications capabilities may submit their

comments to the EPA via the internet at “sanchez.carlos@epa.gov” (without quotation marks). The EPA will

respond to all significant comments in a “Responsiveness Summary” that will be included with the Record of

Decision, identifying the Selected Remedy, for the Site. If you have any questions about the comment period or

the State Marine Site, please contact Carlos A. Sanchez at (214) 665-8507 or the EPA’s toll-free number at 1-

800-533-3508.

Name: Address:

City: State: Zip Code:

Telephone No.: E-Mail Address:

005959
PROJECT

LOCATION

FILENAME: J:\State_Marine\Project\MXD\FIG_1-1.mxd

200 100 0 200

SCALE IN FEET

Figure 1-1

Site Location Map LEGEND

State Marine

Superfund Site

DATE: 7/13/2005

Streets

Property Boundary

PROJECT LOCATION

Austin

Dallas

Houston

Fort Worth

San Antonio

PROJECT

LOCATION

Port Arthur

005960
PALMER BARGE SITE

STATE MARINE SUPERFUND SITE

TAR BURN AREA

FORMER WASTEWATER

IMPOUNDMENTS

MAINTENCE SHED AREA

WASTEWATER

TREATMENT FACILITY

APPROXIMATE BOUNDARY OF THE

FORMER LAUREN REFINING CO. TANK FARM

CURRENT ABOVE GROUND

STORAGE TANK AREA

FORMER

OFFICE BUILDING

DISTILLATION

COLUMN SABINE-NECHES NAVIGATION CHANNEL

FILENAME: J:\State_Marine\Project\MXD\FIG_1-2.mxd

200 100 0 200

SCALE IN FEET

Figure 1-2

1998 Aerial Photograph

Current Site Features Map

LEGEND

State Marine

Superfund Site

DATE: 7/13/2005

Area of Interest

Landfill Area

Property Boundary

Road

Navigation Channel

Sunken Barge

 Nearshore Area

Intertidal Area

Offshore Area

005961
R = 25'

R = 50'

R = 50'

SO-4

SO-5

Hot Spot Area 2

Limits of Excavation

and Backfill

134'

100'

238'

R = 50'

R = 50'

SO-7

SO-30

SO-18

Hot Spot Area 1

Limits of Excavation

and Backfill

Hot Spot Area 3

Limits of Excavation

and Backfill

47'

50'

100'

100'

100'

100'

Limits of Soil Cover

Limits of Soil Cover

Limits of Soil Cover

2350 Sq. Ft.

10,000 Sq. Ft.

10,000 Sq. Ft.

13400 Sq. Ft.

FILENAME: J:\State_Marine\Project\MXD\Figure_3-3_Area1.mxd

100 50 0 100

SCALE IN FEET

Figure 3-3

Alternative A-4:

Excavation/Treatment/

Off-Site Disposal Plan

LEGEND

State Marine

Superfund Site

DATE: 7/13/2005

Area of Interest

Landfill Area

Property Boundary

Road

Navigation Channel

Sunken Barge

Soil Samples that

Exceed PRG Criteria

Buffer Around

Hot Spot Area

Excavation Area

005962