Superfund Record of Decision

Palmer Barge Line Superfund Site

Port Arthur, Jefferson County, Texas

September 2005

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 6

195673

003997
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003998
PALMER BARGE LINE SUPERFUND SITE

PORT ARTHUR, JEFFERSON COUNTY, TEXAS

RECORD OF DECISION

TABLE OF CONTENTS

DECLARATION 1

SITE NAME AND LOCATION 1

STATEMENT OF BASIS AND PURPOSE 1

ASSESSMENT OF THE SITE 1

DESCRIPTION OF THE SELECTED REMEDY 1

STATUTORY DETERMINATIONS 2

ROD DATA CERTIFICATION CHECKLIST 2

AUTHORIZING SIGNATURE 3

DECISION SUMMARY 7

SITE NAME, LOCATION, AND BRIEF DESCRIPTION 7

SITE HISTORY AND ENFORCEMENT ACTIVITIES 7

Site History 7

History of Federal and State Investigations 8

History of CERCLA Removal Actions 9

History of CERCLA Enforcement Activities 9

National Priorities List 9

COMMUNITY PARTICIPATION 9

SCOPE AND ROLE OF RESPONSE ACTION 10

SITE CHARACTERISTICS 10

Sources of Contamination 10

Remedial Investigation Summary 11

Geologic Setting 12

Hydrogeologic Findings 13

Sediment Sampling - Sabine Lake 13

Surface Water Sampling - Sabine Lake 14

CURRENT AND POTENTIAL FUTURE LAND AND GROUND WATER USES . . 14

SUMMARY OF SITE RISKS 14

Identification of Chemicals of Concern 15

Exposure Assessment 16

Toxicity Assessment 19

Risk Characterization 21

Off-Site Worker 22

Data from Historic Investigations and Uncertainty 23

Screening Level Ecological Risk Assessment 25

Preliminary Remediation Goals 27

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Human Health PRGs 27

Ecological Safe Soil Concentrations 28

Basis for Action 28

REMEDIAL ACTION OBJECTIVES AND GOALS 28

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS 29

DESCRIPTION OF REMEDIAL ALTERNATIVES 38

Statutory Requirements/Response Objectives 38

Technology and Alternative Development and Screening 38

Common Elements 39

Summary of Remedial Alternatives for Soils 39

COMPARATIVE ANALYSIS OF ALTERNATIVES 43

PRINCIPAL AND LOW-LEVEL THREAT WASTES 46

SELECTED REMEDY 46

Description of the Selected Remedy 46

Remedial Action Areas 47

SLERA Response Areas 47

Approximate Volume Requiring Remedial Action 49

Summary of Estimated Remedy Costs 49

Expected Outcomes of Selected Remedy 50

STATUTORY DETERMINATIONS 50

Protection of Human Health and the Environment 51

Compliance with Applicable or Relevant and Appropriate Requirements 51

Cost Effectiveness 51

Utilization of Permanent Solutions and Alternative Treatment (or Resource

Recovery) Technologies to the Maximum Extent Practicable 52

Preference for Treatment as a Principal Element 52

Institutional Controls 52

Five-Year Review Requirements 52

DOCUMENTATION OF SIGNIFICANT CHANGES 53

RESPONSIVENESS SUMMARY 54

STAKEHOLDER COMMENTS AND LEAD AGENCY RESPONSES 54

TECHNICAL AND LEGAL ISSUES 56

APPENDICES

Appendix A: TCEQ Concurrence Letter

u

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LIST OF FIGURES

Figure 1-1 Site Location Map

Figure 1-2 Location of AOCs

Figure 3-2 Identified Response Areas for Soil Remedy

Figure 3-3 Identified Response Areas - Areas of Potential Ecological Risks

LIST OF TABLES

Table Page

1 Summary of Chemicals of Concern and Exposure Point Concentrations 15

2 Exposure Assumptions - Industrial Worker 17

3 Exposure Assumptions - Recreational Fisherman 17

4 Cancer Toxicity Data Summary 19

5 Non-Cancer Toxicity Data Summary 21

6 Cumulative Cancer Risk and Noncancer Hazard Indices - On-Site Worker 22

7 Cancer and Noncancer Hazard Indices - Off-Site Recreational Angler 22

8 Upper End Risk Estimate From RI and ESI Soil Data 24

9 Preliminary Remediation Goals 27

10 SLERA Safe Soil Concentrations 28

11 Action Specific ARARs 31

12 Chemical Specific ARARs 34

13 Location Specific ARARs 37

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14 To Be Considered Guidelines 37

15 Present Worth Cost Summary of the Alternatives 45

16 Response Areas for Human Health Risk 47

17 Response Areas for Ecological Safe Soil Levels 48

18 Estimate Capital Cost for Selected Remedy 49

IV

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004003
PALMER BARGE LINE SUPERFUND SITE

PORT ARTHUR, JEFFERSON COUNTY, TEXAS

RECORD OF DECISION

PARTI: DECLARATION

SITE NAME AND LOCATION

The Palmer Barge Line Superfund Site is located in Port Arthur, Jefferson County, Texas. The

National Superfund Database (CERCLIS) identification number for this Site is TXD068104561.

This Site has not been divided into separate operable units and all areas and media within the Site

are addressed together in this Record of Decision.

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for the Palmer Barge Line

Superfund Site located in Port Arthur, Jefferson County, Texas, which was chosen in accordance

with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980

(CERCLA), 42 USC § 9601 et seq.. as amended by the Superfund Amendments and

Reauthorization Act of 1986 (SARA), and, to the extent practicable, the National Oil and

Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300 et seq.. as amended.

This decision was based on the Administrative Record, which has been developed in accordance

with Section 113(k) of CERCLA, 42 U.S.C. § 9631(k), and is available for review at the Port

Arthur Public Library, 4615 9th Avenue, Port Arthur, Texas; at the Texas Commission on

Environmental Quality (TCEQ) offices in Austin, Texas; and at the United States Environmental

Protection Agency (EPA) Region 6 offices in Dallas, Texas. The Administrative Record Index

(Appendix B to the Record of Decision) identifies each of the items comprising the

Administrative Record upon which the selection of the remedial action is based.

The State of Texas, through the TCEQ, concurs with the Selected Remedy.

ASSESSMENT OF THE SITE

The response action selected in this Record of Decision (ROD) is necessary to protect the public

health or welfare or the environment from actual or threatened releases of hazardous substances

into the environment.

DESCRIPTION OF THE SELECTED REMEDY

This ROD sets forth the selected remedy for the Site, which will protect human health and the

environment by removing contaminated materials that exceed risk based levels from the Site.

004004
The major components of this remedy are:

• Excavation of approximately 1,204 cubic yards of the upper two feet of soil that exceed

risk-based levels at each of the response areas;

• Confirmation sampling at each of the response areas. Confirmation samples will be

collected from each response area and analyzed for Contaminants of Potential Concern

(COPC);

• Backfilling of excavated areas that exceed risk based levels with clean soil;

Off-site disposal of the excavated soils at a permitted disposal facility;

• Implementation of Institutional Controls to restrict future land use to industrial purposes

only. The Institutional Control shall be a restrictive covenant by the property owner, to

the benefit of the State of Texas and the United States Government, recorded in the real

property records of Jefferson County, Texas;

Abandonment of existing monitoring wells - Five (5) existing monitoring wells at the Site

will be abandoned; and

• Wastewater Above-ground Storage Tank (AST) demolition and sludge removal - Sludge

contained within one remaining Wastewater AST will be removed and disposed of

off-site. The tank will be decontaminated and reused as scrap metal by the site owner.

STATUTORY DETERMINATIONS

The selected remedy for the soil and sediment contamination is protective of human health and

the environment, complies with Federal and State requirements that are applicable or relevant

and appropriate to the remedial action, and is cost-effective. The contaminated soil and sediment

"hot spots" in several areas of the Site are considered to be "low-level threat wastes" based on

the absence of a highly toxic or highly mobile characteristic. Since the soil and sediment

contamination represents a low-level threat waste, the selected remedy does not utilize treatment

to reduce the toxicity, mobility, or volume of contamination and therefore does not satisfy the

statutory preference for treatment as a principal element of the remedy.

Since the selected remedy will result in hazardous substances remaining on-site above levels that

allow for unlimited use and unrestricted exposure, a statutory review will be conducted to ensure

that the remedy remains protective of human health and the environment. Pursuant to CERCLA

Section 121(c), 42 U.S.C. § 9621(c), and as provided in the current guidance on Five Year

Reviews [OSWER Directive 9355.7-03B-P, Comprehensive Five-Year Review Guidance (June

2001)], the EPA will conduct a statutory five-year review within five years from initiation of the

remedial action.

ROD DATA CERTIFICATION CHECKLIST

The following information is included in the Decision Summary section of this Record of

Decision. Additional information can be found in the Administrative Record file for this Site.

004005
Chemicals of concern (COCs) and their respective concentrations (see the Identification

of Chemicals of Concern Section);

The baseline risk represented by the COCs (see the Risk Characterization Section);

• Cleanup levels established for the COCs and the basis for these levels (see the Remedial

Action Objectives and Goals Section and the Expected Outcomes of Selected Remedy

Section);

• Source materials constituting principal threat wastes have not been identified in the soil

and sediment at this Site (see the Principal and Low-Level Threat Wastes Section);

• Current and potential future beneficial land and water uses used in the ROD (see the

Current and Potential Future Land and Ground Water Uses Section);

Potential land and water use that will be available at the Site as a result of the Selected

Remedy (see the Expected Outcomes of Selected Remedy Section);

• Estimated capital, annual operation and maintenance (O&M), and total present worth

costs; discount rate, and the number of years over which the remedy cost estimates are

projected (see the Summary of Estimated Remedy Costs Section); and,

• Decisive factor(s) that led to selecting the remedy (see the Summary of the Rationale for

the Selected Remedy).

AUTHORIZING SIGNATURE

By: ^rWV. \<4foA^ , U^

 Date:

San/fuel Coleman, P.I

Superfund Division

U.S. EPA Region 6

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004007
By:

By:

RECORD OF DECISION

PALMER BARGE LINE SUPERFUND SITE

CONCURRENCE LIST

Date:

Carlos A. Sanchez

RemediaLProject Manager

Omstavo T. Chavarria, Chief

AR/TX Project Management Section

JohmHepola, Chie

X Branch

By: d-

,.,,

Date: 27/os

Date:

Date:

Mark A. Peyckq^Chief

Superfund Branch, Office of Regional Counsel

By:

By:

June Buzzell, Writer

Superfund Division

PafAela Phillips, Deputy Direct

Superfund Division

Date:

Date:

004008
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004009
PALMER BARGE LINE SUPERFUND SITE

PORT ARTHUR, JEFFERSON COUNTY, TEXAS

RECORD OF DECISION

PART 2: DECISION SUMMARY

SITE NAME, LOCATION, AND BRIEF DESCRIPTION

The Palmer Barge Line Superfund Site is located on Pleasure Islet on the western shore of Sabine

Lake, in Jefferson County, Texas. The site is located approximately 4.5 miles east-northeast of

the City of Port Arthur. A site location map is provided in Figure 1-1. The Palmer Barge Site

encompasses approximately 17 acres and is located on Old Yacht Club Road on the South

Industrial Islet. The Site is bounded to the north by vacant property, to the west by Old Yacht

Club Road, to the south by the State Marine Superfund Site, and to the east by Sabine Lake.

There is very little topographical relief to the Site. The Site is located approximately 0.5 miles

southwest of the confluence of the Neches River and the Sabine Neches Barge Canal.

SITE BACKGROUND AND ENFORCEMENT ACTIVITIES

Site History

The Site, along with the adjacent properties to the north and south, were used as a Municipal

Landfill for the City of Port Arthur from 1956 to 1987. Although disposal at the landfill has long

since ceased and the landfill contents have been covered with dredged sediments, the contents are

still present on the Site in the subsurface soils.

In April 1982, John Palmer, President of Palmer Barge Line, Inc., purchased approximately 17

acres from the City of Port Arthur, for the purpose of servicing and maintaining barges and

marine vessels. In July 1983, Barker Phares, a trustee of Jefferson County, placed a lien on the

Palmer Barge Line Property. In October 1994, Wrangler Capital assumed all claims from the

Palmer Barge Line, Inc. In July 1997, Wrangler Capital purchased Palmer Barge Line from

receivership, and the company ceased operations on the property. The current owner is Mr.

Chester Slay. At present, the Site is used by Mr. Slay for industrial purposes. Metal structures

on-Site are being salvaged, and the salvaged metal is being used by the current owner to

construct marine equipment on the Site.

During operation, the typical activities performed at the Site included cleaning, degassing,

maintenance, and inspection of barges and other marine equipment. Cleaning operations

included the removal of sludge and other residual material by pressure steaming the vessel holds,

engines and boilers. Engines were degreased, and accumulations of sludges were removed.

Degassing activities involved the removal of explosive vapors from vessel holds using nitrogen

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or boiler exhaust. Maintenance and inspection activities included the replacement and/or repair

of valves, engine repairs, and line leak repairs followed by pressure tests. A flare was located

on-site to bum excess gases and liquids produced during facility operations.

cHistory of Federal and State Investigations

Previous investigations of the Site include the following:

• December 1996: Texas Natural Resource Conservation Commission (TNRCC, now

named the Texas Commission on Environmental Quality, or TCEQ) Region 10 Field

Office personnel conducted a multi-media investigation. The purpose of this study was to

determine the compliance status of the facility.

March 1998: TNRCC Region 10 Field Office with EPA Region 6 conducted an

investigation to identify potential sources and to sample soil and sediment. Five areas of

stained soil were identified on-site, which included the following: stained soils near

sumps, stained soil near the boiler house, stained soil near the flare, stained soil near

aboveground storage tanks, and stained soil near wastewater tanks. Sample results

indicated the presence of inorganic constituents such as metals, semi-volatile organic

constituents (SVOCs), and pesticides in on-site soil. Metals and SVOCs were detected in

offshore sediment adjacent to the Site.

• July 1999: TNRCC Region 10 Field Office sampled aboveground storage tanks, roll

off-boxes and "slop" tanks to characterize materials stored.

October 1999: EPA Region 6 conducted an Expanded Site Inspection (ESI; Weston 2000)

to determine the presence and nature of constituent occurrence on-site and off-site and to

determine migration routes and routes of exposure of site related constituents. Results of

the inspection indicated the presence of volatile organic constituents (VOCs), SVOCs,

pesticides, polychlorinated biphenyls (PCBs), and metals.

• In 2000, the Site was ranked and was placed on the National Priority List (NPL). The

Hazard Ranking concluded that constituents present in Sabine Lake sediments adjacent to

the Site were a potential threat to human health primarily via the fish consumption

exposure pathway (USEPA, 2000).

2003: URS Corporation (URS), on behalf of the Potentially Responsible Parties (PRPs),

conducted a remedial investigation (RI) at the Site in July 2003, which characterized the

nature and extent of constituents present in environmental media at the Site and in

adjacent Sabine Lake surface water and sediments (URS, 2004d).

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History of CERCLA Removal Actions

In August 2000, EPA Region 6 conducted a Removal Action to remove source materials stored

on-site. Activities included waste removal, water treatment, oil/water separation, and sludge

stabilization. Approximately 250,000 gallons of water were treated on site; 500 cubic yards of

sludge stabilized; and 100,000 gallons of oil/styrene were separated and removed from the site.

All of the above-ground storage tanks were removed except for a 25,000 gallon AST on the

northern portion of the site that contains sludge. Several of the concrete AST foundations remain

along with gravel throughout the Site.

History of CERCLA Enforcement Activities

On September 30, 2002, EPA Region 6 issued an Administrative Order on Consent to conduct

the remedial investigation and feasibility study (RJ/FS) for the Palmer Barge site. Voluntary

respondents to the Order were: E. I. du Pont de Nemours and Company, Chevron/Texaco Inc.;

Kirby Inland Marine, LP; Kirby Inland Marine, Inc. of Louisiana; and Ashland Inc.

National Priorities List

The EPA published a proposed rule on May 11, 2000, to add the Palmer Barge Line Site to the

National Priorities List (NPL) of Superfund sites. The Site was added to the NPL in a final rule

published on July 27, 2000 [Federal Register Listing (FRL-6841-3), Volume 65, Number 145,

Pages 46096-46104].

COMMUNITY PARTICIPATION

The Remedial Investigation and Feasibility Study Report, along with the Proposed Plan for the

Palmer Barge site in Port Arthur, Texas, were made available to the public on July 27, 2005.

These and other Site documents can be found in the Administrative Record file and the

information repositories at the following locations: Port Arthur Public Library located at 4615 9th

Avenue, Port Arthur, Texas; the U.S. Environmental Protection Agency Region 6 located at

1445 Ross Avenue, Dallas, Texas; and the Texas Commission on Environmental Quality located

at 12100 Park 35 Circle, Building E, 1s1 Floor, Austin, Texas. The notice of the availability of

these documents was published in the Port Arthur News on July 28, 2005. A public comment

period was held from July 27, 2005 to August 25, 2005. The EPA and the Texas Commission on

Environmental Quality conducted a public meeting on August 11, 2005, to discuss the Proposed

Plan and receive comments from the community. The public meeting was held at the West

Groves Education Center, located at 5840 West Jefferson, in Groves, Texas. These activities

meet the community participation requirement of CERCLA 300.430(f)(3) and the NCP. In the

Responsiveness Summary, EPA responded to all comments received during the public comment

period. The Responsiveness Summary is included as part of this ROD.

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SCOPE AND ROLE OF RESPONSE ACTION

In August 2000, EPA conducted a Time Critical Removal Action at the site to remove, transport,

and dispose off-site all hazardous substances (except for approximately 233 cubic yards),

pollutants, and contaminants located on the Site. The removal action consisted of waste removal,

water treatment, oil/water separation, and sludge stabilization. Approximately 250,000 gallons

of water were treated on site; 500 cubic yards of sludge stabilized; and 100,000 gallons of

oil/styrene were separated and removed from the site. All of the above-ground storage tanks

were removed except for a 25,000 gallon AST on the northern portion of the site that contains

approximately 233 cubic yards of sludge that may be hazardous. Several of the concrete AST

foundations remain along with gravel throughout the Site.

This response action is the final Site remedy and is intended to address the remaining 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 that prevents exposure to contaminated soils and

sediments and prevents future runoff of contaminants to the Sabine Lake sediments. This

response action addresses the remaining "hot spots" at the Site that pose a risk to human health

and ecological receptors that were not addressed by the prior removal action. This remedial

action will also remove approximately 233 cubic yards of sludge from the remaining AST.

SITE CHARACTERISTICS

Sources of Contamination

As part of the ESI conducted in October 1999, a site reconnaissance was performed to identify

Areas of Concern (AOCs) on the Site. The following AOCs were identified on site:

• Wastewater Aboveground Storage Tanks (ASTs): Four ASTs were located in the

northeastern portion of the Site. The four ASTs included one 25,000-gallon tank and

three 5,000-gallon tanks. They were constructed of steel and surrounded by an earthen

berm. The tanks were used for bulk storage during barge cleaning operations.

• Boiler House ASTs: Four ASTs were located adjacent to the boiler house located in the

southwestern portion of the Site. The ASTs were approximately 7,000-gallon capacity

each. Three of the four boiler house ASTs were reportedly used to store diesel fuel for

steam boilers that were operated as part of the barge cleaning process. The fourth boiler

house AST was used to store fresh water. The ASTs were located on the ground surface

and did not have containment berms or dikes.

• Open Top Slop Tanks: Four open top slop tanks were located on the western portion of

the Site near the flare area. The tanks were constructed of steel and measured 8 feet by 5

feet by 4 feet. The tanks were placed on the ground and did not have secondary

containment.

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004013
• Horizontal ASTs: The horizontal ASTs were located in the southeastern portion of the

Site near the Sabine Lake shoreline. The three ASTs had a capacity of 10,000 gallons

each. A concrete berm surrounded the three ASTs. The tanks were used as part of the

barge cleaning and degassing system.

• Twelve ASTs: Twelve (12) ASTs were located in the eastern portion of the Site near the

shoreline of Sabine Lake. Each tank was approximately 7,000 gallons in capacity. The

tank farm is surrounded by a concrete berm measuring 95 feet by 30 feet lateral

dimension by 1 foot in height. The tanks were likely used for liquid transfer and liquid

separation activities during cleaning operations.

• Flare: A flare was located in the central portion of the Site. The flare was used to bum

excess gases produced during cleaning operations.

Locations of these AOCs are shown in Figure 1-2. EPA's removal action in August 2000,

removed all above-ground storage tanks except for a large tank on the northern portion of the site

that contains sludge. Several of the concrete AST foundations remain along with gravel

throughout the Site.

Remedial Investigation Summary

The following summarizes findings related to the extent of constituents identified during the RI

conducted in July 2003:

• Generally, there appear to be a number of metals present in soil above the background

95% upper confidence limit (UCL). These concentrations are quite variable with high

metals often being present in soil with obvious signs of municipal waste and other times

in soil with no apparent sign of "impact." The background data set itself had some

results that appeared to be "outliers" from the rest of the background set suggesting that

the soil used as "cap material" for the site may not be uniform. The origin of this cap

material could not be determined, therefore it is unknown if constituents found in the cap

material are naturally occurring or from another contaminated site.

• Wastewater AST Area: Soil contained a large number of semivolatile constituents as

well as pesticides such as pentachlorophenol (PCP). It is unknown if the PCP was related

to the Wastewater activities, because the highest concentrations of PCP were found in soil

that also contained municipal waste. The groundwater impact downgradient is minimal

as indicated by the MTBE detected concentration of 32 ug/1.

Boiler House ASTs: Soil contaminated with SVOCs was detected in this area. There is

no apparent ground water impact downgradient from this area.

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• Open Top Slop Tanks: Soil from near the Slop Tanks contained SVOCs and metals. The

high concentrations were not associated with the soil near the unit, but rather the soil that

surrounded a drum of black sludge that was formerly buried near this area. The

groundwater impact downgradient is minimal.

Horizontal ASTs: Concentrations of benzene and isopropylbenzene were detected near

this area. However, there were no constituents in soil above residential criteria in this

area.

• Twelve ASTs: Soil near this area contained VOCs, SVOCs, and metals. The distribution

of these results suggest more VOCs are present in soil from the north and east sides of the

unit. The ground water impact downgradient from this area appears minimal based on the

low detection of 18 ug/1 of MTBE. Metals detected in ground water were comparable to

those from the background well.

• Flare: Soil samples from this area indicated that surface soils did not contain detectable

constituents related to the Flare, except for a "J-value" concentration of benzene, which

indicates that the concentration is an estimated value below levels that can be reliably

quantified. The deeper soil that contained municipal waste contained numerous metals

above the background 95% UCL and three "J-value" pesticide/PCBs. The ground water

impact downgradient appears minimal as indicated by the "J-value" concentration of 3

ug/1 of MTBE. Metals detected in groundwater were comparable to those from the

background well.

• Surface Water: Samples of surface water did not contain any site-related VOC

constituents. The only SVOC detected was bis(2-ethylhexyl)phthalate, which appeared in

the lab blank associated with these samples. Four metals were detected above the

practical quantification limit in surface water (aluminum, manganese, mercury, and zinc).

Four additional metals were detected at "J-value" concentrations (barium (J), copper (J),

chromium (J), and nickel (J)).

Sediment: Site-related VOCs were not detected in the eight sediment samples collected

adjacent to the Palmer Site. The largest number of quantifiable detections of

SVOCs/pesticides/PCBs were at a location closest to the south end of the sheet piling.

Geologic Setting

The Palmer Barge Site is located on the seaward margin of the southeastern Gulf Coastal Plain of

Texas, hi general, the sediment in this area is tens of thousands of feet thick at the coastline.

The unconsolidated sediment sequence consists of sand, silt, and clay and represents depositional

marine and non-marine environments. As a result of subsidence of the Gulf Coast basin these

sediments thicken toward the Gulf.

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In general, the near surface soils along waterways in this area of the Coastal Plain consist of fill

and spoil material dredged from Sabine Lake. In the subsurface, the Coastal Plain sediments are

primarily Quaternary alluvium, composed of clay and silt. The Beaumont Clay, Montgomery

Formation, and Willis Sand make up the underlying Chicot Aquifer. Based on historical

information, the Palmer Barge Site and associated barge cleaning operations have been built on

top of fill and sediment that was removed during dredging of the Intercoastal Waterways and the

Sabine-Neches ship channel. This dredged material was placed adjacent to the shipping canals.

The former municipal landfill was developed on this small manmade island.

Surface soils are a variable mixture of dark brown to black clay, sand, and silt often with shell

material. The majority of the site subsoil is derived from dredge sediment from Sabine Lake.

Part of the islands was use as a municipal landfill by the City of Port Arthur and a layer of cap

material was placed over the landfill areas. The origin of the cap material has not been

determined. Aside from areas that are mowed or have gravel, or concrete foundations, most of

the soil is covered by tall grasses. No distinct soil horizons have formed, nor is there a clearly

distinct "trash layer" of municipal waste. The upper 1-2 feet of surface soil consists of sand and

silt and are typically free of municipal waste material. This upper cover often has roots from site

vegetation or shell from dredging. Waste was encountered sporadically in the fill between about

one foot to five feet below ground surface (bgs). The interval from about five feet bgs to

approximately 18 feet is a mix of dark gray to gray clay, silt, and fine sand. At a depth of about

18 feet bgs, the top of the native Sabine Lake sediments is encountered. This gray silty clay is

much more homogeneous than the overlaying dredge fill and becomes firmer with depth. This

unit is much more consistent than the dredge spoil unit and extends to at least 30 feet bgs.

Hydrogeologic Findings

Groundwater was encountered in the sandy portions of the dredge fill unit. The first shallow

water-bearing zone at the Palmer Barge Site is typically encountered at depths of approximately 4

feet bgs. Static water levels ranged from almost 9 feet above Mean Sea Level (MSL) at an

upgradient well to slightly over 1 foot above MSL at the edge of Sabine Lake. This water

bearing zone is not part of the deep Chicot Aquifer that is generally used as a drinking water

source. The surficial shallow water-bearing zone resulted from the adjacent shipping channel

dredge materials that were used to build the island where the site is located. Groundwater in this

unit also includes infiltrated precipitation. This groundwater flows towards and discharges to

Sabine Lake.

Sediment Sampling - Sabine Lake

Sediment sampling results indicated the presences of several polycyclic hydrocarbons (PAHs) at

low concentrations. No pesticides, PCBs or VOCs were detected in the sediment samples

collected. Several metals were detected in the sediment samples. Most of these such as

chromium, copper, lead, manganese, nickel, and vanadium were reasonably consistent. Barium

and zinc results had more variation, and there were some detections of mercury. Organic carbon

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results ranged from 8,630 mg/kg to 16,300 mg/kg (0.8% to 1.6%). The ratio of simultaneously

extracted metal/acid-volatile sulfide (SEM/AVS) ranged from 0.06 to 0.30. The SEM/AVS ratio

can be used to infer the bioavailability of divalent metals to benthic organisms. The lower the

SEM/AVS ratio, the lower the bioavailability of the metal.

Surface Water Sampling - Sabine Lake

The only constituents detected in surface water from Sabine Lake were "J-value" concentrations

of bis(2-ethylhexyl)phthalate (believed to be due to blank contamination), and aluminum,

barium, manganese, and zinc. Mercury (0.00008 ug/L) was detected at one location. Calcium

carbonate hardness was also measured, and it ranged from 1000 mg/L to 1080 mg/L.

CURRENT AND POTENTIAL FUTURE LAND AND GROUND WATER USES

Land Uses

The former Palmer Barge site is currently being operated by the site owner as an industrial

property for metal scraping activities. Future use of the Site is also anticipated to be limited to

industrial use due to its location and other surrounding industrial sites. The closest school is

located approximately 2.7 miles from the site. There are only fourteen (14) residential properties

located within a 1-mile radius.

Ground Water Uses

There is no current or anticipated future use of the shallow ground water at the site. The shallow

ground water at the site is not considered a potential drinking water source. The shallow ground

water resulted from the dredging activities that formed the isle where the former Palmer Barge

site is located.

SUMMARY OF SITE RISKS

Baseline Human Health Risk Assessment

The primary sources of information used in the Baseline Human Health Risk Assessment

(BHHRA) conducted in June 2005, are the Expanded Site Inspection Report (ESI) (Weston,

2000) and the Remedial Investigation (RI) Report for Palmer Barge Line Superfund Site (URS,

2004d). The Site Conceptual Exposure Model for the risk assessment indicates that the primary

exposure scenarios of interest are on-site industrial worker exposure to constituents present in

surface soil and off-site exposure to a recreational fisherman primarily via consumption offish

from Sabine Lake that may have accumulated site-related constituents from surface water and

sediment.

The primary constituents of concern detected at the Site are polycyclic aromatic hydrocarbons

(PAHs), pesticides, and metals. Baseline risk calculations for surface soil were performed for

each of six AOCs based on analytical data reported in the RI. Risks for the recreational

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004017
fisherman were estimated using data from the RI report supplemented by data from other

investigations of Sabine Lake sediment and fish tissue concentrations. Each of the media and

pathways evaluated in the baseline calculations resulted in risk estimates within the range of risk

management criteria typically employed in the Superfund program (10"6 to 10"4 cancer risk and a

noncancer hazard index of 1.0), with one exception. The maximum concentration of

benzo(a)pyrene present in sediment resulted in an estimated cancer risk via fish consumption that

is slightly above the upper end of the target risk range. However, actual fish tissue data from

Sabine Lake indicates that the benzo(a)pyrene result does not represent a threat to human health.

An uncertainty analysis was performed to identify sources of uncertainty in the baseline risk

calculations. A significant observation of the uncertainty analysis was that historic pre-RI soil

data would likely produce risk estimates approximately an order of magnitude greater than the

estimates developed based on the RI soil data. Therefore, Site soil concentrations from both the

historic and RI data were compared to risk-based preliminary remediation goals (PRGs) that were

developed for the range of applicable target risk criteria (10~6 to 10"4).

Several surface soil sample locations with concentrations exceeding PRGs for the 10"5 target risk

range were identified as "hot spots" to be addressed in the selected remedy. Addressing the

identified "hot spots" in the selected remedy will result in a risk level that is protective of human

health and the environment.

Identification of Chemicals of Concern

Chemicals of potential concern (COPCs) were identified from the remedial investigation which

exceeded commercial/industrial medium specific screening level (MSSL) values to prepared the

site specific Human Health Risk Assessment (HHRA). Table 1 summarizes the COPCs and

contains the exposure point concentrations used to evaluate the reasonable maximum exposure

scenario (RME) in the baseline risk assessment. Lead was analyzed separately.

Table 1

Summary of Chemicals of Concern and Exposure Point Concentrations from RI

Receptor

Industrial

Worker

Exposure

Medium

On-Site

Surface Soil

Chemical of

Concern

Aroclor-1254

Benzene

Benzo(a)pyrene

Benzo(b)

fluoranthene

Dieldrin

Pentachlorophenol

Maximum

Concentration

(rag/kg)

4.18

2.02

3.3

2.73

0.4

150

Exposure Point

Concentration

(mg/kg)

4.18

2.02

3.3

2.73

0.4

150

Statistical Measure

Maximum Detection

Maximum Detection

Maximum Detection

Maximum Detection

Maximum Detection

Maximum Detection

15

004018
Table 1

Summary of Chemicals of Concern and Exposure Point Concentrations from RI

Receptor Exposure

Medium

Chemical of

Concern

Arsenic

Maximum

Concentration

(mg/kg)

120

Exposure Point

Concentration

(mg/kg)

120

Statistical Measure

Maximum Detection

Key: mg/kg: milligrams per kilogram

The table presents the COCs and exposure point concentration for each of the COCs detected in the media (i.e., the

concentration that will be used to estimate the exposure and risk from each COC in the soil). The table includes the maximum

concentrations detected for each COC, the exposure point concentration (EPC), and how the EPC was derived.

Exposure Assessment

The exposure scenarios evaluated for Human Health Risk are:

On-site Industrial Worker exposed by way of:

• Incidental ingestion of soil;

• Dermal contact with soil;

• Inhalation of airborne dust; and

Inhalation of vapors emanating from volatile constituents in soil;

Recreational Angler exposed by way of:

• Dermal contact with surface water during angling; and,

Ingestion of fish harvested from Sabine Lake.

In accordance with Risk Assessment Guidance for Superfund (RAGS), exposure assumptions for

the risk assessment were selected to represent the reasonable maximum exposure (RME) that

could occur at the Site. For the industrial worker scenario, these assumptions were taken from

EPA's Region 6 MSSLs. A summary of these assumptions is presented on Tables 2 and 3

below.

The concentration that an individual would be exposed to over the chronic exposure periods

assumed in the risk assessment would be best represented by an arithmetic average of the

concentrations present throughout the medium where the exposure would occur over that time

period. To account for uncertainty in what the true average concentration is based on the limited

sample data available, risk assessments often utilize an upper confidence limit (UCL) of the

mean to represent the exposure concentration. However, statistical evaluation of this sort for the

Palmer Barge Site was complicated by the presence of non-detect results in the sample data set.

This was particularly the case for this site since constituents were not detected in a majority of

the samples analyzed for the many COPCs identified for the Site. For the Palmer Barge Site, the

simple and conservative approach taken for this assessment was generally to assume that the

16

004019
receptor was exposed to the maximum detected concentration of the COPC. This approach will

probably result in an overestimation of actual risks associated with the Site.

One exception to the use of maximum detected concentrations in the risk assessment was for the

evaluation of lead (Pb) in soil. Since the distribution of lead concentrations in soil ranged from

below background to above MSSLs, and the frequency of detection was high, a 95% UCL was

utilized to represent the exposure concentration of lead in soil.

Exposure Assumptions for Industrial Worker

Table 2

Exposure Assumptions for Industrial Worker

Symbol

EF

ED

IRs

BW

ATc

ATnc

IRa

SA

AF

PEF

Definition

Exposure Frequency

Exposure Duration

Ingestion Rate of Soil

Body Weight

Averaging Time-carcinogenic

effects

Averaging Time-noncancer effects

Inhalation Rate of Air

Surface Area of Skin Exposed

Adherence Factor

Particulate Emission Factor

RME Value

225

25

100

70

70

25

20

3300

0.2

1.32xl09

Units

days/yr

yrs

mg/day

kg

yrs

yrs

mVday

cnrVday

cmVday

mg3/kg

Source

a

a

a

a

a

a

a

a

a

a

Exposure Assumptions for Recreational Fisherman Scenario

Table 3

Exposure Assumptions for Recreational Fisherman Scenario

Symbol

EFf

EFd

ED

Definition

Exposure Frequency for Fish

Consumption

Exposure Frequency for Dermal

Contact

Exposure Duration

RME Value

365

100

30

Units

days/yr

days/yr

yrs

Source

a

d

a

17

004020
Table 3

Exposure Assumptions for Recreational Fisherman Scenario

Symbol

IRf

BW

ATc

ATnc

SA

Isc

Definition

Ingestion Rate of Fish

(annual average)

Body Weight

Averaging Time-carcinogenic

effects

Averaging Time-noncancer effects

Surface Area of Skin Exposed

Thickness of Strateum Corneum

RME Value

0.0175

70

70

30

5170

0.001

Units

kg/day

kg

yrs

yrs

cm2/day

cm

Source

b

a

a

a

c

c

Notes:

a - EPA Region 6 Medium-Specific Screening Levels, January 2004

b - Methodology for Deriving Ambient Water Quality Criteria for the Protection of Human Health, EPA 2000

c - Supplemental Guidance for Dermal Risk Assessment, RAGS Part E, EPA 2001

d - Conservative assumption for a recreational angler fishing 2 times per week 50 weeks/year

Fish Tissue Concentrations

Evaluation of potential exposures via fish consumption as a result of impacts in groundwater,

surface water, and sediment data involves use of a bioaccumulation model to estimate the

concentration of COPCs in fish tissue. Use of bioconcentration factors (BCFs), bioaccumulation

factors (BAFs), and biota-sediment accumulation factors (BSAFs) are a significant source of

uncertainty in the risk assessment due to the complex metabolic processes being simulated by

these published factors. Therefore, the risk assessment relied preferentially on measured fish

tissue concentrations from the 1995 Texas Department of Health (TDH) study in lieu of modeled

estimates where possible. While use of measured fish tissue concentrations eliminates the

uncertainty of the modeled estimates, it also results in an evaluation of risks associated with all

sources of loading to the fish tissue that is not limited to impacts that might have originated

specifically from the Palmer Barge Site. Although samples in the TDH were collected from

various locations throughout Sabine Lake, the risk assessment utilized the maximum detected

concentration identified in any species from any sample location in Sabine Lake as a

conservative measure to account for any uncertainty associated with the age or quality of the

data.

Since the TDH study did not analyze all Palmer Barge COPCs, modeled fish tissue

concentrations were generated for these constituents as necessary. In addition, in cases where the

maximum measured fish tissue concentrations were reported as not detected, modeled fish tissue

concentration estimates were generated and compared to the detection limit. If the modeled

estimate was lower than the measured detection limit, the modeled estimate was used to

18

004021
represent the fish tissue concentration as an estimate of the censored concentration that might be

present below the analytical detection. If the modeled estimate resulted in a fish tissue

concentration that was higher than the detection limit in the non-detect analysis, then the

measured result was used to represent the fish tissue concentration in the risk assessment since

the measured result is considered more reliable than the estimated result.

Toxicity Assessment

Excess lifetime cancer risks were determined for each exposure pathway by multiplying a daily

intake level with the chemical specific cancer slope factor. Cancer slope factors have been

developed by the EPA from epidemiological or animal studies to reflect a conservative "upper

bound" of the risk posed by potentially carcinogenic compounds. That is, the true risk is unlikely

to be greater than the risk predicted. The resulting risk estimates are expressed in scientific

notation as a probability (e.g. 1 x 10"6 for 1/1,000,000) and indicate (using this example), that an

average individual is not likely to have greater that a one in a million chance of developing

cancer over 70 years as a result of site-related exposure to the compound at the stated

concentration. All risks estimated represent an "excess lifetime cancer risk" - or the additional

cancer risk on top of that which we all face from other causes such as cigarette smoke or

exposure to ultraviolet radiation from the sun. The chance of an individual developing cancer

from all other (non-site related) causes has been estimated to be as high as one in three. The

EPA's generally acceptable risk range for site related exposure is lO^to 10"6. Current EPA

practice considers carcinogenic risks to be additive when assessing exposure to a mixture of

hazardous substances.

Carcinogenic and noncarcinogenic risk estimates were calculated using a reasonable maximum

exposure (RME). Excess lifetime cancer risk is calculated from the following equation: Risk =

GDI x SF, where:

• Risk = a unitless probability (e.g., 2 x 10"5) of an individual's developing cancer

GDI = chronic daily intake averaged over 70 years (mg/kg-day)

• SF = slope factor, expressed as (mg/kg-day)-1.

A summary of the cancer toxicity data relevant to the COCs is presented in Table 4.

Table 4

Cancer Toxicity Data Summary

Chemical of

Concern

Benzene

Pentachlorophenol

Benzo(a)anthracene

Oral Cancer

Slope Factor

(mg/kg)/day

5.5E-02

1.2E-01

7.3E-01

Dermal Cancer

Slope Factor

(mg/kg)/day

N/A

1.2E-01

7.3E-01

Inhalation

Cancer Slope

Factor

(mg/kg)/day

2.9E-02

N/A

N/A

Weight of

Evidence/Cancer

Guideline

Description

A

B2

B2

Source

IRIS

IRIS

NCEA

Date of

Publication

01/28/2005

01/28/2005

07/01/1993

19

004022
Table 4

Cancer Toxicity Data Summary

Chemical of

Concern

Benzo(a)pyrene

Benzo(a)fluoranthene

Dieldrin

Heptachlor epoxide

PCB-1254

Arsenic

Oral Cancer

Slope Factor

(mg/kg)/day

7.3E+00

7.3E-01

1.6E+01

9.1E+00

2.0E+00

1.5E+00

Dermal Cancer

Slope Factor

(mg/kg)/day

7.3E+00

7.3E-01

1.6E+01

9.1E+00

2.0E+00

1.5E+00

Inhalation

Cancer Slope

Factor

(mg/kg)/day

3.1E+00

N/A

1.61E+01

9.IE+00

2.0E+00

1.51E+01

Weight of

Evidence/Cancer

Guideline

Description

B2

B2

B2

B2

N/A

A

Source

IRIS

NCEA

IRIS

IRIS

IRIS

IRIS

Date of

Publication

01/28/2005

07/01/1993

01/28/2005

01/28/2005

01/28/2005

01/28/2005

Key: EPA Group:

IRIS: Integrated Risk Information System, U.S. EPA A - Human carcinogen

NCEA: National Center for Environmental Assessment Bl - Probable human carcinogen - Indicates that limited human data

are available

HEAST: Health Effects Assessment Summary Tables B2 - Probable human carcinogen - Indicates sufficient evidence in

animals and inadequate or no evidence in humans

N/A: Not available D- Not classifiable as a human carcinogen

The potential for non-carcinogenic effects is evaluated by comparing an exposure level over a

specified time period (e.g., life-time) with a reference dose (RfD) derived for a similar exposure

period. An RfD represents a level that an individual may be exposed to that is not expected to

cause any deleterious effect. The ratio of exposure to toxicity is called a hazard quotient (HQ).

An HQ < 1 indicates that a receptor's dose of a single contaminant is less than the RfD, and that

toxic noncarcinogenic effects from that chemical are unlikely. The Hazard Index (HI) is

generated by adding the HQs for all chemical(s) of concern that affect the same target organ (e.g.,

liver) or that act through the same mechanism of action within a medium or across all media to

which a given individual may reasonably be exposed. A HI< 1 indicates that, based on the sum

of all HQs from different contaminants and exposure routes, toxic noncarcinogenic effects from

all contaminants are unlikely. A HI > 1 indicates that site-related exposures may present a risk to

human health.

The HQ is calculated as follows: Non-cancer HQ = CDI/RfD, where:

GDI = Chronic daily intake

RfD = Reference Dose.

GDI and RfD are expressed in the same units and represent the same exposure period (i.e.,

chronic, subchronic, or short-term). Table 5 lists the COCs and their respective non-cancer

toxicity data.

20

004023
Table 5

Non-Cancer Toxicity Data Summary

Chemical of

Concern

Benzene

Pentachlorophenol

Dieldrin

Heptachlor epoxide

PCB-1254

Arsenic

Chronic Oral

RfD Value

(mg/kg-day)

4.0E-03

3.0E-02

5.0E-05

1.3E-05

2.0E-05

3.0E-04

Chronic

Dermal RfD

(mg/kg-day)

N/A

3.0E-02

5.0E-05

I.3E-05

2.0E-05

3.0E-04

Chronic

Inhalation RfD

(mg/kg-day)

3.0E-02

N/A

N/A

N/A

N/A

N/A

Primary Target

Organ

Bone Marrow

Liver/ Kidney/

Liver

Liver

Skin/immune

system

Vascular

system/skin

Sources of

RfD:

Target Organ

NCEA

IRIS

IRIS

IRIS

IRIS

IRIS

Dates of

RfD:

—

01/28/2005

01/28/2005

01/28/2005

01/28/2005

01/28/2005

Key:

N/A: Not available

IRIS: Integrated Risk Information System, U.S. EPA

NCEA: National Center for Environmental Assessment

Risk Characterization

Using the elements of the Site Conceptual Exposure Model (SCEM) and associated exposure

assumptions, constituent-specific cancer risk and noncancer hazard were calculated as well as

cumulative cancer risk and noncancer hazard. The detailed results of the calculations are

included in Appendix B of the Baseline Human Health Risk Assessment (BHHRA) RAGS Part

D spreadsheets.

For all carcinogens, cumulative cancer risk, assuming simultaneous exposure to multiple

carcinogens, was assumed to be additive (that is, the individual cancer risks for all carcinogenic

constituents present in soil were summed). For simultaneous exposure to multiple

noncarcinogens in soil, the target noncancer hazard index of 1.0 is applicable on a per

organ/system basis rather than on the cumulative hazard index for an exposure scenario.

Noncancer hazards are apportioned by target organ in Appendix B of the BHHRA RAGS Part D

tables.

Due to the unique biokinetic metabolism of lead, a cancer risk or hazard index was not calculated

for lead in the same manner as the other COPCs. For lead in soil, risk characterization consisted

of comparison of the 95% UCL of soil lead concentrations to the Region 6 industrial worker

MSSL for lead of 800 mg/kg. The Region 6 MSSL for lead used in this assessment is based on

industrial land use and exposure of a developing fetus within an adult worker assumed to work at

the site during pregnancy. Thus, exceedence of the Region 6 MSSL for lead in industrial soil

would suggest that a target blood lead level in a developing fetus would be exceeded. Because

the target organ (e.g. blood) for lead in adults is different from target organs for other

noncarcinogenic constituents, there are no additive assumptions necessary for lead. Thus, the

21

004024
risk-based evaluation of lead in soil consisted of comparison of the Region 6 MSSL for lead with

the 95% UCL of concentrations found at the Site.

On-Site Worker

The resulting cancer risk and hazard index estimates for the industrial worker scenario, based on

the RI data, for each of the six soil AOCs are presented on Table 6. The cancer risk results range

from 3x10-6 to 7x10-5 and Hazard Index results range from 0.02 to 0.5. Risk and Hazard Index

results by constituent and pathway for this scenario are shown in Appendix B of the BHHRA

RAGS Part D formatted tables. For lead in site soils, the 95% UCL of 590 mg/kg lead from the

RI soil data is less than the Region 6 industrial worker Medium-Specific Screening Level

(MSSL) for lead of 800 mg/kg.

Table 6

Cumulative Cancer Risk and Noncancer Hazard Indices for Soil from RI Data

Area of Concern

Wastewater AST Area

Boiler House ASTs

Former Open Top Slop Tanks

Horizontal ASTs

Twelve ASTs

Flare

Cumulative Cancer Risk

4xlO'5

9xlO'6

4xlO'6

3xlO-6

7xlO'5

IxlO'5

Hazard Quotient

0.1

0.09

0.02

0.02

0.5

0.4

Off-Site Recreational Angler

The resulting cancer risk and hazard index estimates for the recreational angler scenario are

presented on Table 7.

Table?

Cancer Risk and Noncancer Hazard Indices

Source Medium

Ground Water

Surface Water

Sediment

Cancer Risk

7xlO'9

No carcinogen COPCs

2x1 0-4

Hazard Index

0.5

0.003

1.5

22

004025
For the off-site recreational angler, the primary contributors to the 2xlO"4

 cancer risk associated

with sediment was benzo(a)pyrene. However, interpretation of this result should consider the

following factors:

• The calculated benzo(a)pyrene cancer risk was associated with a modeled fish tissue

concentration. The actual measured fish tissue concentration for benzo(a)pyrene was

non-detect in all samples collected from Sabine Lake in the 1995 TDH study.

• The modeled fish uptake was based on the maximum detected benzo(a)pyrene

concentration in sediment (0.29J mg/kg). The maximum detected concentration of

benzo(a)pyrene in sediment was a "J"-flagged result indicating that the concentration is

an estimated value below levels that can be reliably quantified. Benzo(a)pyrene was not

detected above laboratory detection limits in over 60% of the sediment samples analyzed.

The assumption that fish uptake is based on the maximum detected concentration in

sediment results in an artificially elevated estimate of the concentration that could be

present in fish tissue.

• The benzo(a)pyrene in sediments adjacent to the Site may be present as a result of sources

other than the barge cleaning operations performed at the site. Other potential sources

may include barge traffic, and other industrial and urban runoff sources in the vicinity.

• The rapid metabolism of polycyclic aromatic hydrocarbons (PAHs) in fish into readily

excreted substances prevents substantial bioaccumulation from occurring. Partitioning of

PAHs from surface water and sediment into fish tissue can result in an overestimation of

risk due to ingestion of fish assumed to be exposed to PAHs in surface water and/or

sediment.

The primary contributors to the noncancer hazard index of 1.5 are Aroclor-1254, arsenic,

cadmium, copper, mercury, and zinc. However, when apportioned out on a target organ basis the

hazard index for each target organ is less than 1.0. Therefore, noncancer risk associated with

PCBs and metals in sediment does not appear to be an issue from a human health perspective.

Data from Historic Investigations and Uncertainty

Although the data collected during the ESI were not combined with data collected during the RI

for evaluation of soil in the body of the risk assessment, the ESI soil data were evaluated as part

of the uncertainty analysis to further define any areas on or off site that exceeded risk-based

target criteria.

To evaluate the significance of the ESI soil data set, concentrations from both the RI and ESI

data sets were screened against Region 6 MSSLs. A review of these concentrations reveals that

the maximum concentrations for each constituent on the list originates from samples collected

during the ESI.

23

004026
A simple baseline risk calculation performed based on the identified maximum concentrations

results in risk estimates more than 10 times greater (i.e., 2x10~3 cancer risk and 4.3 hazard index)

than those presented in the risk assessment based on the RI soil data only. The results of this risk

calculation are shown on Table 8 below.

Table 8

Upper end Risk Estimate from RI and ESI Soil Data

Constituents (a)

4,4'-DDE

4,4'-DDT

Aldrin

Aroclor 1254

Aroclor 1260

Arsenic

Benzene

Benzo(a)anthracene

Benzo(a)pyrene

Benzo(b)fluoranthene

Benzo(k)fluoranthene

Dibenzo(a,h)anthracene

Dieldrin

Heptachlor

Heptachlor Epoxide

Indeno(l ,2,3)cd-pyrene

Naphthalene

Pentachlorophenol

Max Sitewide Soil

Concentration

(mg/kg) (f)

12

11

9.2

4.18

0.85

120

3.1

280

240

220

190

110

4.4

1.0

9.5

280

370

570

Soil Concentration

forHI=1.0

mg/kg (b)

—

474

20.5

11.8

—

284

183

—

...

—

—

—

34.2

342

8.89

—

210

12900

Soil Concentration

forTR=lxlO^

(mg/kg) (c)

7.8

7.8

0.11

0.83

0.83

1.8

1.6

2.3

0.23

2.3

23

0.23

0.12

0.43

0.21

2.3

...

10

SUM

Hazard

Quotient

(d)

....

2.32E-02

4.48E-01

3.54E-01

—

4.22E-01

1.69E-02

— -

—

—

—

—

1.29E-01

2.92E-03

1.07E+00

—

1 .76E+00

4.43E-02

4.27E+00

Cancer

Risk (e)

1.54E-06

1.41E-06

8.36E-05

5.04E-06

1.02E-06

6.67E-05

1.94E-06

1.22E-04

1.04E-03

9.57E-05

8.26E-06

4.78E-04

3.67E-05

2.33E-06

4.52E-05

1.22E-04

—

5.70E-05

2.17E-03

Notes:

a - All constituents withdetected concentrations in soil exceeding Region 6 MSSLs for an Industrial worker. Lead is evaluated

separately.

b - Derived by ratios from baseline risk calculations, except Naphthalene based on published MSSL.

c - Region 6 MSSLs

d - Derived by Max Soil Concentration/Soil Concentration for HI = 1.0

e - Derived by Max Soil Concentration x lE-6/Soil Concentration for TR = 1E-6

f - includes both RI and ESI soils data.

24

004027
These results demonstrate that exclusion of the ESI data set from the baseline risk assessment for

soil is a significant source of uncertainty in the soil risk assessment conclusions. Therefore,

preliminary remediation goals (PRGs) were developed for the soil medium and soil

concentrations from both the RI and ESI investigations. The PRGs were compared to both the RI

and ESI soil test results to identify soil areas that will be addressed in the selected remedy.

Screening Level Ecological Risk Assessment

A Screening-Level Ecological Risk Assessment (SLERA) was performed for the Palmer Barge

Line Superfund Site (Site) located in Port Arthur, Texas in June 2005. Ecological exposure and

risk assessment for the Site were based on the 8-Step process outlined in EPA's Ecological Risk

Assessment Guidance for Superfund: Process for Designing and Conducting Ecological Risk

Assessments (1997), and was performed consistent with the Texas Commission on

Environmental Quality (TCEQ) document entitled Guidance for Conducting Ecological Risk

Assessments at Remediation Sites in Texas (2001; 2004 Draft). The SLERA consists of Steps 1

and 2 of the 8-Step process.

Initially, maximum concentrations of analytes detected in ecological exposure media were

identified and screened against highly conservative Ecological Screening Levels (ESLs) to select

constituents of potential concern (COPCs) for the Step 2 exposure and risk calculations.

Exposure and risk characterizations of COPCs for direct contact were performed using the

maximum detected concentrations and risks were characterized using Hazard Quotients.

Subsequently, wildlife ingestion exposure pathways were evaluated for all bioaccumulative

chemicals using dose modeling with the maximum concentrations and the 95%UCLs as

requested by EPA, TCEQ and the Trustees. Risks to wildlife were characterized using Hazard

Quotients (HQs) calculated for No-Observable-Adverse Effect Levels (NOAEL) and LowestObservable-Adverse Effect Levels (LOAEL) endpoints.

Results of the SLERA showed that the COPCs identified in Sabine Lake surface water and

sediment do not pose risks of sufficient magnitude to require remedial action. Risks of COPCs

to aquatic biota by a direct contact pathway were few and Hazard Quotients based on highly

conservative ESLs were low, with few exceedances. Hazard quotients for COPC exposure to

wildlife by a food/prey ingestion pathways were all less than 1.0 based on the comparison of the

95%UCL versus the LOAEL endpoint. Therefore, the proposed ecological risk management

decision for sediment is to allow degradation to naturally attenuate organic COPCs and to

implement on-Site source control to prevent potential for future inputs to Sabine Lake. In

addition, potentially unacceptable risks will be addressed either in part or wholly by actions

undertaken as part of the Natural Resource Damage (NRD) process.

The COPCs identified in On-Site surface soil could pose an unacceptable risk to terrestrial biota

by a direct contact pathway and to wildlife by a food/prey ingestion pathway if receptors were

25

004028
present. The current paucity of vegetation and minimal site use by terrestrial receptors in the

former industrial portions of the Site justify the conclusion that ecological exposure is low.

As part of the SLERA, maximum concentrations of analytes detected in ecological exposure

media were identified and screened against highly conservative Ecological Screening Levels

(ESLs). The screening was completed to select constituents of potential concern (COPCs) for the

Step 2 exposure and risk calculations. Exposure and risk characterizations of COPCs for direct

contact were performed using the maximum detected concentrations and risks were characterized

using Hazard Quotients. Wildlife ingestion exposure pathways were evaluated for

bioaccumulative chemicals using dose modeling with the maximum concentrations and the 95%

UCLs. Risks to wildlife were characterized using Hazard Quotients calculated for

no-observable-adverse-effect-levels (NOAELs) and lowest-observed-adverse-effect-level

(LOAEL) endpoints.

Results of the SLERA showed that the COPCs identified in Sabine Lake surface water and

sediment do not pose risks of sufficient magnitude to warrant remedial action. Therefore, the

selected remedy to address ecological risk will consist of allowing degradation to naturally

attenuate organic COPCs and to implement on-site source control to prevent future run off of soil

contaminants to Sabine Lake.

Results of the SLERA indicated that the COPCs identified in on-site surface soil could pose an

unacceptable risk to terrestrial biota by a direct contact pathway and to wildlife by a food/prey

ingestion pathway, if receptors were present. The lack of vegetation and minimal site use by

terrestrial receptors justifies the conclusion that ecological risks are negligible and therefore

exposure is low. However, future long-term industrial use of the Site is uncertain, and potential

exposure could occur if ecological succession were to proceed naturally. Therefore, the selected

remedy will include soil remediation to address uncertainty associated with the potential for

future on-site ecological risk.

In order to evaluate potential response areas, Site soil concentrations from the ESI and RI data

were compared to safe soil concentrations for worst case exposure to the American robin. Safe

soil concentrations were back calculated for COPCs that exceeded LOAEL values. Several

ecological "hot spots" were identified as response areas. Based on these results, Preliminary

Remediation Goals were developed for on site contaminants that pose a risk to ecological

receptors. A safe soil concentration of 497 mg/kg lead in surface soil was calculated. These safe

soil concentrations factor in site-specific conditions of current and future commercial/industrial

land use and the paucity of vegetation and minimal usable habitat available to the robin and other

terrestrial receptors.

26

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Preliminary Remediation Goals (PRGs)

Human Health PRGs

Based on the risk characterization, quantitative risks at the Palmer Barge Site appear to be

generally within the range of risk management criteria typically employed in the Superfund

program, that is a cumulative cancer risk in the range from IxlO"6 to IxlO'4 and a hazard index of

1. However, soil concentration data from a historic investigation not included in the baseline risk

calculations indicate that site contaminants may pose a risk to human health at the Site.

Criteria were developed for all soil COPCs that were detected in either the ESI or RI data sets

above MSSLs. However, uncertainties associated with background, occurrences of arsenic at

concentrations exceeding the MSSL are prevalent at the Site yet most of these results are at

concentrations that are below background. Therefore, site soil arsenic concentrations from the RI

and ESI were compared to site-specific background levels. The target cleanup level for lead is

based on the MSSL concentration of 800 mg/kg for an industrial/commercial site.

PRGs for the 10'6 level were taken directly from the Region 6 MSSL tables. Site-specific PRGs

were calculated for the 10"5 and 10-4 target risk levels. Any COPCs on the list that are not

considered carcinogenic, or in cases where the COPC exhibits both cancer and noncancer effects,

the noncancer PRG based on a hazard index of 1.0 was used as the PRG if that concentration was

lower than the cancer-based PRG.

In consultation with TCEQ, EPA chose a 10"5 target cleanup level for the Palmer Barge site based

on exposure to contaminants that exceed those levels at surface soils (0 to 2 feet). The

contaminants of concern and the selected PRGs are presented in Table 9. The results indicate

that four (4) locations have concentrations exceeding the 10"5 PRGs.

Table 9

Human Health Preliminary Remediation Goals for 10

 5 Target Risk Level

Constituent

Aldrin

Benzo(a)pyrene

Benzo(a)anthracene

Dieldrin

Heptachlor Epoxide

Naphthalene

Pentachlorophenol

Maximum Concentration

mg/kg

9.2

240

280

4.4

9.5

370

570

PRG Cleanup Level

mg/kg

1.1

2.3

23

1.2

2.1

210

100

27

004030
Table 9

Human Health Preliminary Remediation Goals for 1Q'S Target Risk Level

Lead 5050 800

Note: A safe soil concentration of 497 mg/kg lead in surface soil was calculated. These safe soil concentrations factor in sitespecific conditions of current and future commercial/industrial land use and the. paucity of vegetation and minimal usable habitat

available to the robin and other terrestrial receptors.

Ecological Safe Soil Concentrations

Based on the results of the Screening Level Risk Assessment, safe soil concentrations were

developed for on site soils that would be protective of ecological receptors. The ecological safe

soil concentrations for on site soils are presented in Table 10. The results indicate that seven (7)

locations exceed the target cleanup levels for the site surface soils (0 to 2 feet).

Table 10

SLERA Safe Soil Concentrations

Constituent

Butyl Benzyl Phthalate

4,4-DDD

4,4-DDE

4,4-DDT

Methoxychlor

Lead

Maximum Concentration

mg/kg

24

51

26

11

4.7

5050

Target Cleanup Levels

mg/kg

5.37

0.0864

0.0864

0.0865

0.09

497

Basis for Action

The response action selected in this Record of Decision (ROD) is necessary to protect the public

health or welfare or the environment from actual or threatened releases of hazardous substances

into the environment. The response action will address remaining "hot spots" that were not

addressed during the Time Critical Removal Action conducted in August 2000.

REMEDIAL ACTION OBJECTIVES AND GOALS

Remedial action objectives (RAOs) were developed for the Palmer Barge Site for those COCs

that pose a carcinogenic risk above EPA's target cancer risk range or non-carcinogenic hazard to

human health and the environment based on site-specific risk calculations. RAOs are also

28

004031
defined such that Applicable or Relevant and Appropriate Requirements (ARARs) are met. The

Remedial Action Objectives were developed based on the following:

• The reasonable anticipated land use scenario is based on the future redevelopment of this

Site for industrial or commercial use, consistent with current site use and surrounding

land use;

• Potential ecological risks were considered for site soils to prevent exposure to ecological

receptors and prevent surface runoff of contaminants to the Sabine Lake sediments.

The remedial action objectives for this Site are:

• Prevent direct contact, ingestion, and inhalation of surface soils that exceed human health

based levels, based on the industrial worker scenario, for the chemicals of concern;

• Prevent off-site migration of COCs to Sabine Lake sediments that exceed human and

ecological based levels for the chemicals of concern; and,

• Prevent exposure to site soils that may pose a risk to ecological receptors.

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

Under CERCLA and the NCP, the ROD is required to describe the "... federal and state

requirements that are applicable or relevant and appropriate to the site that the remedy will

attain." 40 C.F.R. 300.400(f)(5)(ii)(A). These ARARs derive from the potential ARARs that

were identified by EPA, which were identified as "requirements applicable to the release or

remedial action contemplated based upon an objective determination of whether the requirement

specifically addresses a hazardous substance, pollutant, contaminant, remedial action, location, or

other circumstance found at a CERCLA site." 40 C.F.R. 300.400 (g)(l). If not applicable to a

specific release, these federal or state requirements might still be determined to be "relevant and

appropriate to the circumstances of the release." See 40 C.F.R. 300.400(g)(2). See also

CERCLA, 42 U.S.C. §9621(d)(2)(A). An ARAR could be specific to a given action, chemical,

or location at a CERCLA site. The NCP defines "applicable requirements" as follows:

Applicable requirements means those cleanup standards, standards of control, and other

substantive requirements, criteria, or limitations promulgated under federal environmental

or state environment or facility siting laws that specifically address a hazardous

substance, pollutant, contaminant, remedial action, location, or other circumstance found

at a CERCLA site. Only those state standards that are identified by a state in a timely

manner and that are more stringent than federal requirements may be applicable. 40

C.F.R. 300.5.

The NCP then goes on further to define "relevant and appropriate requirements":

Relevant and appropriate requirements means those cleanup standards, standards of

control, and other substantive requirements, criteria, or limitations promulgated under

29

004032
federal environmental or state environmental or facility siting laws that, while not

"applicable" to a hazardous substance, pollutant, contaminant, remedial action, location,

or other circumstance at a CERCLA site, address problems or situations sufficiently

similar to those encountered at the CERCLA site that their use is well suited to the

particular site. Only those state standards that are identified in a timely manner and are

more stringent than federal requirements may be relevant and appropriate. (Emphasis

Added). 40 C.F.R. 300.5.

Thus, it is clear from the NCP that state requirements must be "substantive"; and as the statute

commands, they must be "more stringent" than any federal standard, requirement or limitation.

42 U.S.C. §9621(d)(2)(A)(ii). ARARs deal with the degree of cleanup, or levels and standards of

control and are not procedural or administrative requirements. See NCP Preamble, 55 Fed. Reg.

8666, 8756 (Mar. 8, 1990). See also State of Ohio v. United States Environmental Protection

Agency, 997 F.2d 1520, 1526-27 (B.C. Cir., 1993). In connection with state ARARs, the NCP

also amplifies and explains the nature of "promulgated" standards or limitations, where it

provides:

Only those state standards that are promulgated, are identified in a timely manner, and

are more stringent than federal requirements may be applicable or relevant and

appropriate. For purposes of identification and notification of promulgated state

standards, the term promulgated means that the standards are of general applicability and

are legally enforceable. (Emphasis Added). 40 C.F.R. 300.400(g)(4).

If a standard is not applicable, the question of whether the standard is relevant and appropriate to

the circumstances of the release is addressed by several enumerated factors, which "... shall be

examined, where pertinent, to determine whether a requirement addresses problems or situations

sufficiently similar to the circumstances of the release or remedial action contemplated, and

whether the requirement is well-suited to the site, and is therefore both relevant and appropriate."

40 C.F.R. 300.400(g)(2). Finally, there is a category of other federal or state advisories, criteria,

or guidance, which may be used to develop a CERCLA remedy that falls into a category called

"to be considered (TBC)" guidelines. 40 C.F.R. 300.400(g)(3).

ARARs are divided into three categories: chemical specific, action specific, and location

specific. These classifications are described as follows:

Action Specific ARARs are technology or activity based requirements or limitations on

actions taken regarding hazardous substances, pollutants, and contaminants.

Chemical Specific ARARs are promulgated values that include health or risk based

standards, numerical values, or methodologies that, when applied to site-specific

conditions, establish the acceptable amount or contaminant concentration that may be

detected in or discharged to the ambient environment. These values focus on protecting

30

004033
public health and the environment. However, technological or cost limitations may

influence some values, such as maximum contaminant levels (MCLs).

Location Specific ARARs relate to the geographical position of the site, such as state and

federal laws and regulations that protect wetlands or construction in flood plains. The

extent to which any location specific requirements may be considered depends solely on

the sensitivity of the environment and any possible impact caused by remedial activities.

The ARARs pertaining to RA activities at the Site are divided into action, chemical, and location

specific categories as described in the following tables. In addition, any TBCs and potential

waivers are discussed.

Table 11

Action Specific ARARs

Requirement Justification

Federal

Storm Water Regulations

40 CFR Parts 122, 125

National Pollution Discharge Elimination System (NPDES) permits are

addressed relative to storm water discharges associated with industrial

activity. These regulations require the development and implementation

of a storm water pollution prevention plan or a storm water best

management plan. Monitoring and reporting requirements for a variety of

facilities are outlined. Applicable to the Site.

Permits and

Enforcement; CERCLA

Section 121(e)

This section specifies that no federal, state, or local permit shall be

required for any portion of a CERCLA remedial action that is conducted

on the site of the facility being remediated.

This includes exemption from the RCRA permitting process. Applicable

to the Site.

Standards for Owners

and Operators of

Hazardous Waste

Treatment, Storage, and

Disposal Facilities; 40

CFR Part 264 Subparts

B, C, D and G

Subparts B, C, and D establish minimum standards that define the

acceptable management of hazardous waste for owners and operators of

facilities that treat, store, or dispose of hazardous waste. Subpart G

establishes standards for closure and post closure care for site design and

operation. These standards will be relevant and appropriate to the Site if

wastes onsite are identified as RCRA hazardous wastes or are sufficiently

similar to RCRA hazardous wastes.

National Contingency

Plan, 40 CFR Part

300.430; Baseline

Human Health Risk

Assessment,

RI/FS, and ROD

Evaluates baseline human health risk as a result of current and potential

future site exposures, and establishes contaminant levels in environmental

media for protection of public health. Also provides guidelines and

requirements for conducting RI/FS and ROD.

Applicable to the Site.

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004034
Exceptions to ARAR

Rules; CERCLA

Allows EPA to waive compliance with ARARs in six circumstances:

1. The selected action is only part of a total remedial action that will

comply with the ARAR requirements when completed.

2. Compliance with the ARAR requirements would present greater

health/environmental risks than alternative options.

3. Compliance with the ARAR requirements is technically impracticable

from an engineering perspective.

4. The selected remedy will attain a standard of performance that is

equivalent to an ARAR required standard through use of another method

or approach.

5. With respect to a state requirement, the state has not demonstrated

consistent application of the requirement in similar circumstances.

6. Where the remedy is to be fund-financed (as opposed to private-party

financed), meeting the ARAR standard would not provide balance

between the need for cleanup at the site in question considering the

amount of fund resources that must be used at other sites in need of

cleanup.

These provisions are applicable to the Site.

Permits and

Enforcement; CERCLA

Section 121 (e)

This section specifies that no federal, state, or local permit shall be

required for any portion of a CERCLA remedial action that is conducted

on the site of the facility being remediated.

This includes exemption from the RCRA permitting process. Applicable

to the Site.

Standards for Owners

and Operators of

Hazardous Waste

Treatment, Storage, and

Disposal Facilities; 40

CFR Part 264 Subparts

B, C, D and G

Subparts B, C, and D establish minimum standards that define the

acceptable management of hazardous waste for owners and operators of

facilities that treat, store, or dispose of hazardous waste. Subpart G

establishes standards for closure and post closure care for site design and

operation. These standards will be relevant and appropriate to the Site if

wastes onsite are identified as RCRA hazardous wastes or are sufficiently

similar to RCRA hazardous wastes.

Use and Management of

Containers Tank

Systems; 40 CFR Part

264 Subparts I and J

Subpart I sets operating and performance standards for container storage

of hazardous waste. These requirements would be relevant and

appropriate to the Site for containers used for storage of liquids, soil, or

other wastes as part of the remedial action. Subpart J outlines similar

standards but applies to tanks rather than containers.

Standards for Waste

Piles and Landfills; 40

CFR Part 264 Subparts L

andN

Subpart L sets design and operating requirements for the storage or

treatment of wastes in piles. If the waste piles are closed with wastes left

in place, Subpart N requirements must be met. Subpart N establishes

construction, design, performance, closure, and operation requirements

pertaining to hazardous waste landfills. If treatment, storage, or disposal

of RCRA waste in piles is included as part of the remedial action, Subpart

L and/or N would be relevant and appropriate to the Site. Subpart N

would be applicable to the Site in the event that hazardous wastes are

identified at the Site.

32

004035
Miscellaneous Units; 40

CFR Part 264 Subpart X

Relates to "miscellaneous" units that treat, store, or dispose of hazardous

wastes. Provides general performance standards for location, design,

construction, operation, monitoring, and closure/post closure. If the

remedial action includes treatment, storage, or disposal of hazardous

waste in a miscellaneous unit, these requirements would be relevant and

appropriate to the Site.

Land Disposal

Restrictions (LDRs); 40

CFR Part 268 Subpart C,

Prohibitions on Land

Disposal; Subpart D,

Treatment Standards

40 CFR Part 268 establishes restrictions on land disposal unless treatment

standards are met or a "no migration exemption" is granted. LDRs

establish prohibitions, treatment standards, and storage limitations before

disposal for certain wastes as set forth in Subparts C and D. Treatment

standards are expressed as either concentration-based performance

standards or as specific treatment methods. Wastes must be treated

according to the appropriate standard before wastes or the treatment

residuals of wastes may be disposed in or on the land. The Universal

Treatment Standards (UTS) establish a concentration limit for

300 regulated constituents in soil regardless of waste type. The LDRs are

applicable to the Site if hazardous wastes are identified.

Requirements for

Identification and Listing

of Hazardous Wastes; 40

CFR Part 261

These regulations establish the requirements for the identification and

listing of hazardous wastes. These requirements are applicable to the Site

and would require that potential hazardous wastes be tested for

identification and listed if appropriate.

Standards Applicable to

Generators and

Transporters of

Hazardous Waste; 40

CFR Part 262 and Part

263

Part 262 establishes the record keeping requirements and manifesting

requirements for the transport of hazardous wastes. Part 263 establishes

requirements for the transport of hazardous wastes. These requirements

would be applicable to the Site if hazardous wastes are identified and

shipped offsite for disposal.

Department of

Transportation

Requirements Governing

the Transportation of

Hazardous Materials;

49 CFR Parts 107 and

171-179

Establishes the requirements for the transportation of hazardous materials

as defined by the U. S. Department of Transportation. These

requirements would be applicable to the Site if the hazardous wastes are

identified and transported offsite for disposal.

State

TPDES Construction

Storm water Permit; 30

TAC 205

Requires submission of Notice of Intent (NOI) for coverage under the

general permit for storm water discharges resulting from construction

occurring on sites greater than 1 acre in size. This requirement will be

applicable to the Site during the site remedial construction.

33

004036
Spill Prevention and

Control; 30 TAG 327

Requires that releases of reportable quantities of listed materials be

reported to the agency (TCEQ) within 24 hours. The responsible person

shall submit written information, such as a letter, describing the details of

the discharge or spill and supporting the adequacy of the response action,

to the appropriate TCEQ regional manager within 30 working days of the

discovery of the reportable discharge or spill. The regional manager has

the discretion to extend the deadline. The rule is applicable to the Site if

during remedial activities a release greater than the documented

reportable quantity of a listed material occurs.

Control of Air Pollution

from Visible Emissions

and Particulate Matter;

30 TAG 111

Requires that all reasonable precautions shall be taken to prevent

particulate matter from becoming airborne, including use of water or

chemicals for control of dust in the construction operations, clearing of

land, and on dirt roads or stockpiles. Applicable during excavation

and transport of soils, or any other activity that may generate airborne

particulate matter at the Site.

Texas Industrial Solid

Waste and Municipal

Solid Waste Regulations;

30 TAC 335

Guidelines for generators to determine if a solid waste is a hazardous

waste. Requires adherence to record keeping and shipping requirements.

Applicable to the soils and wastes to be removed at the Site, which may or

may not be hazardous.

Table 12

Chemical Specific ARARs

Requirement Justification

Federal

American Conference of

Governmental Industrial

Hygienists-Threshold

Limit Values (TLV)

TLVs are based on the development of a time weighted average

(TWA) exposure to an airborne contaminant over an 8-hour work

day or a 40-hour work week. TLVs identify levels of airborne

contaminants at which health risks may be associated. These

values are applicable to work at the Site.

Clean Air Act (CAA)

40CFRPart61

The CAA is the primary federal legislation protecting air quality.

National Primary and Secondary Ambient Air Quality Standards

(NAAQS), National Emission Standards for Hazardous Air Pollutants

(NESHAP), and the New Source Performance Standards (NSPS) are

promulgated by EPA under the CAA. These requirements are relevant

and appropriate to the Site.

34

004037
National Primary and

Secondary Air Quality

Standards (NAAQS); 40

CFR, Part 50

The NAAQS specify the maximum concentration of a federally

regulated air pollutant (i.e., SO2, paniculate matter (PM10), NO2, CO,

ozone, and lead) in an area resulting from all sources of that pollutant.

No new construction or modification of a facility, structure or

installation may emit an amount of any criteria pollutant that will

interfere with the attainment or maintenance of a NAAQS (see 40 CFR

' 51.160). For the federal NAAQS standards, all measurements of air

quality are corrected to a reference temperature of 25EC and to a

reference pressure of 760 mm Hg (1,013.2 millibars). These

requirements may be applicable during the excavation and disposal

activities at the Site.

American Conference of

Governmental Industrial

Hygienists-Estimated Limit

Values (ELY)

ELVs are based on TLVs and converted to reflect exposure to

contaminants on a 24-hour per day basis. The calculation of an ELV

does not take into consideration the additive and synergistic effects of

contaminants and additional exposures from media other than air.

ELVs are not expected to be completely protective of the potential

effects of exposures to contaminants; however, they do provide some

indication of airborne contaminant levels at which adverse health

effects could occur. These values are relevant and appropriate for

the Site.

Safe Drinking Water Act 40

USC 399 Primary Drinking

Water Standards (Maximum

Contaminant Levels

[MCLs]); 40 CFR Part 141

Establishes MCLs for drinking water. Surface water near the site is

not designated for public or private water supply, but may be used for

recreational purposes. The shallow ground water at the site is not

considered as a drinking water supply source; therefore, MCLs are not

applicable to the Site.

Maximum Contaminant

Level Goals (MCLG); 40

CFR Part 141.50

These levels do not take into account cost or feasibility, and are fully

protective of human health. They are only enforceable under

CERCLA under specific community water system provisions that are

not applicable or relevant and appropriate to the Site.

Federal Clean Water Act

(CWA) Water Quality

Criteria; 40 CFR Part 131;

U.S. EPA Quality Criteria

for Water, 1976, 1980, and

1986

These criteria (ambient water quality criteria) apply to water classified

as a fisheries resource. These requirements are relevant and

appropriate to the surface water in Sabine Neches Channel. These

criteria are contained in Clean Water Act (CWA)' 303 and 304. As

non-enforceable criteria, these criteria are included as to be considered

only.

Hazardous Substances; 40

CFR Part 116.3 and 116.4

Establishes reporting requirements for certain discharges of reportable

quantities of hazardous substances. Creates no substantive clean up

requirement. May be relevant and appropriate to the Site based on the

chosen remedial alternative and if discharges of reportable quantities

of hazardous substances occur during implementation of the remedy.

35

004038
Solid Waste Disposal Act

Subtitle C Requirement; 40

CFR, Part 264, Subpart F

Governs the maximum concentration of constituents released to ground

water from solid waste management units (SWMU). Applicable to the

Site if the chosen remedy includes onsite disposal and ground water is

adversely affected.

Designation of Hazardous

Substances; 40 CFR, Part

302.4

This section provides tables of the following substances:

(a) Listed hazardous substances. The elements and compounds and

hazardous wastes appearing in Table 302.4 are designated as hazardous

substances under Section 102(a) of CERCLA.

(b) Unlisted hazardous substances. A solid waste, as defined in 40

CFR 261.2, which is not excluded from regulation as a hazardous

waste under 40 CFR 261.4(b), is a hazardous substance under Section

101(14) of CERCLA if it exhibits any of the characteristics identified

in 40 CFR 261.20 through 261.24. These requirements are applicable

to the Site because solid/hazardous wastes were previously disposed at

the site and hazardous substances are present in soil and sediment.

Land Disposal Restrictions

40 CFR, Part 268

Establish numerical treatment standards for disposal of hazardous

wastes. These requirements are potentially applicable if hazardous

wastes are identified and offsite disposal is a selected remedy.

State

Texas Surface Water

Quality Standards; 30 TAG

307

Establishes limits for constituents for the protection of surface water

quality. Requires the maintenance of the quality of water in the state

consistent with public health and enjoyment, propagation and

protection of terrestrial and aquatic life, operation of existing

industries, and economic development of the state. These

requirements are applicable for release of COCs from the Site into the

Sabine-Neches Channel.

Hazardous Metals (30 TAG

319, General Regulations

Incorporated into Permits,

Subchapter B)

Establishes allowable concentrations for discharge of hazardous metals

to inland waters (319.22). These'requirements are potentially

applicable for the Site as hazardous metals have been detected in soil

and sediment samples collected from the Site and the hazardous metals

may be discharged to waters of the state.

Waste Classification 30

TAG 335, Subchapter R

Establish numerical criteria for designating a waste as a hazardous

waste or as one of three classes of solid waste. These requirements are

applicable for classification of wastes generated during the

site remediation.

36

004039
Table 13

Location Specific ARARs

Requirement Justification

Federal

Executive Order on Flood plain

Management, Order No. 11988

Requires all federal agencies and associates to avoid long- and

short-term adverse impacts associated with occupancy and

modification of flood plains. Any actions taken to reduce the

risk or impact of remedial actions should accomplish the

following:

• Reduce the risk of flood loss.

• Minimize the impacts of floods on human safety, health, and

welfare.

• Restore and preserve the natural and beneficial values served

by flood plains.

This requirement is applicable only if the site lies within the

100-year flood plain or the remedy impacts a 100-year flood

plain.

Fish and Wildlife Coordination Act

16 USC'661 etseq.

16 USC'742 a

16 USC'2901

Requires consultation when a modification of a stream or other

water body is proposed or authorized and requires adequate

provision for protection offish and wildlife resources. These

requirements are relevant and appropriate to the Site for

removal of contaminated sediment from the Sabine Lake if the

remedy requires contaminated sediment to be removed.

Endangered Species Act; 16 USC '

1531 et. seq.

50 CFR Part 402

Requires that proposed action minimize impacts on endangered

species within critical habitats upon which endangered species

depend, including consulting with Department of Interior.

Endangered or threatened species have not been identified at the

Site; the Act is not an ARAR for the Site.

Table 14

To Be Considered Guidelines

Requirement Justification

Federal

References Doses (RfDs), EPA

office of Research and

Development

The EPA Office of Research and Development provides nonenforceable toxicity data for specific chemicals for use in public

health assessments. This data is used to assess the risks associated

with contaminated media at the Site.

37

004040
Risk Specific Doses (RSDs),

EPA Carcinogen Assessment

Group and EPA Environmental

Criteria and Assessment Office

RSDs represent the dose of a chemical in mg/kg of body weight

per day associated with a specific risk level (i.e., 10-6). RSDs are

determined by dividing the selected risk level by the cancer

potency factor (slope factor). This standard is used to assess the

risks associated with contaminated media at the Site.

State

Texas Risk Reduction Program

(TRRP) 30 TAG 350

TRRP establishes the TCEQ's minimum remediation standards for

present and past uncontrolled constituent releases. TRRP uses risk

evaluation to determine if corrective action is necessary for the .

protection of human health and the environment and to identify

acceptable constituent levels in the impacted media. TRRP defines

the land use categories, ground water classifications, requirements

for plume management zone, soil reuse issues, and tiered risk

evaluation for affected sites. This state regulation is not

applicable for the Federal superfund sites but should be considered

at the Site.

DESCRIPTION OF REMEDIAL ALTERNATIVES

Statutory Requirements/Response Objectives

Under its legal authorities, the EPA's primary responsibility at Superfund sites is to undertake

remedial actions that are protective of human health and the environment. In addition, Section

121 of CERCLA, 42 U.S.C. § 9621, establishes several other statutory requirements and

preferences, including: (1) a requirement that EPA's remedial action, when complete, must

comply with all applicable, relevant, and appropriate federal and more stringent state

environmental and facility siting standards, requirements, criteria or limitations, unless a waiver

is invoked; (2) a requirement that EPA select a remedial action that is cost-effective and that

utilizes permanent solutions and alternative treatment technologies or resource recovery

technologies to the maximum extent practicable; and (3) a preference for remedies in which

treatment permanently and significantly reduces the volume, toxicity, or mobility of the

hazardous substances. Response alternatives were developed to be consistent with these

statutory mandates. However, since Principal Threat wastes are not present at the site, the

statutory preference for remedies that employ treatment that reduces toxicity, mobility, or volume

as a principal element is not warranted.

Technology and Alternative Development and Screening

Construction and engineering controls were evaluated in the remedial alternatives since the

contaminated soils and sediments were identified as a low-level threat waste that can be reliably

contained and would present only a low risk in the event of release.

38

004041
CERCLA and the National Contingency Plan (NCP) set forth the process by which remedial

actions are evaluated and selected. In accordance with these requirements, a range of alternatives

were developed to address the soil and sediment contamination at the Palmer Barge Site. Four

remedial alternatives involving different construction and engineering control options for the soil

and sediment contamination were selected for detailed analysis. Detailed descriptions of the

remedial alternatives for addressing the contamination associated with the Site can be found in

the Feasibility Study Report. The construction time for each alternative reflects only the time

required to construct or implement the remedy and does not include the time required to design

the remedy or procure contracts for construction. The present-worth costs associated with the

ground water monitoring requirements are calculated using a discount rate of seven percent (7%).

Common Elements

Alternatives 2 through 4 contain the following common elements:

• Institutional Controls - Implementation of Institutional Controls to restrict future land use

to industrial purposes only. The Institutional Control shall be a restrictive covenant by

the property owner, to the benefit of the State of Texas and the United States

Government, recorded in the real property records of Jefferson County, Texas;

• Abandonment of existing monitoring wells - As the BLRA determined that groundwater

at the Site does not contribute significantly to Site risk, five existing monitoring wells at

the Site will be abandoned; and

• Wastewater AST demolition and sludge removal - Sludge contained within the

Wastewater AST will be removed and disposed of off-site. The tank will be

decontaminated, and reused as scrap metal by the property owner.

Summary of Remedial Alternatives for Soils

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, EPA would take no further action at the Site to prevent exposure to the remaining

contaminated soils and sediment at the Site.

39

004042
ALTERNATIVE 2 - Institutional Controls

Estimated Capital Cost: $135,000

Estimated Annual O&M Costs: $500

Estimated Present Worth (7%): $141,205

Alternative 2 includes the following activities:

• Institutional Controls - To limit future use of the property to industrial purposes;

• Abandonment of existing monitoring wells - Five (5) existing monitoring wells at the Site

will be abandoned; and

• Wastewater AST demolition and sludge removal - Sludge contained within the

Wastewater AST will be removed and disposed of off-site. The tank will be

decontaminated and left on site.

• The time to implement this remedy would be 1 to 3 months.

Alternative 2 involves no remedial action to address the contaminants that pose a risk to human

health and the environment. Structural controls, such as posting of "no excavation" signs and

fencing, would be implemented in addition to proprietary controls restricting future land use to

industrial purposes only.

Effectiveness

Alternative 2 provides no physical control of exposure to impacted soils and no reduction in risk

to human health. This alternative would not comply with any applicable or relevant and

appropriate requirements, such as PRGs developed during the HHRA or safe soil concentrations

developed based on the SLERA. The potential for sediment runoff from the Site that may

contain COPCs would not be eliminated. This alternative would not provide protection to

current or future site workers. Alternative 2 does not reduce the toxicity, mobility, or volume of

the waste.

Implementability

There are no implementability issues associated with this alternative.

ALTERNATIVE 3 - EXCAVATION/ON-SITE DISPOSAL/SOIL COVER/ICs

Estimated Capital Cost: $310,669

Estimated Annual O&M Costs: $10,000

Estimated Present Worth (7%): $504,759

40

004043
Alternative 3 includes the following activities:

Excavation of approximately 1,204 cubic yards of the upper two feet of soil that exceed

risk based levels at each of the response areas;

• Relocation of the excavated soils to a designated area on-site and consolidation. The area

required for consolidation encompasses approximately 12,800 square feet;

• Confirmation sampling at each of the response areas. Confirmation samples would be

collected from each response area and analyzed for COPCs.

• Backfilling of the response areas with clean soil;

• Placement of an isolation soil cover over the relocated and consolidated impacted soils

consisting of a synthetic root penetration barrier and 24-inches of clean soil, including 3

to 4 inches of topsoil suitable for vegetation growth; and

Installation of structural controls to protect human health. Structural controls to be

installed as part of this alternative include fencing around the area designated for disposal

and posting of "no trespassing" signs.

• The time to implement this remedy would be approximately 2 months.

Effectiveness

Placement of an isolation soil cover over surface soils reduces risk by eliminating potential

pathways identified in the HHRA that included ingestion, dermal contact, and inhalation of

dust/vapors. Alternative 3 complies with applicable or relevant and appropriate requirements by

preventing exposure to contaminants that present a risk to human health and the environment.

This alternative does not provide any reduction in the toxicity, mobility, or volume of impacted

soil. Alternative 3 would involve the disturbance of surface soils exceeding acceptable risk

levels. The potential for a slight, temporary increase of risk to the community and to field

personnel exists; however, engineering controls (e.g., water sprays) maybe implemented to

reduce risk due to fugitive dust during construction.

Under Alternative 3, five response areas would be excavated and backfilled with clean soil or

gravel. Therefore, the potential for sediment runoff from the Site that may contain COPCs will

be eliminated. The soil cover over the consolidation area containing impacted soils would

prevent or reduce the potential for runoff of contaminated soils.

To ensure long-term effectiveness of this alternative, maintenance of the isolation soil cover must

be completed. Failure to properly maintain the cover could result in the potential for direct

contact with impacted soils. This alternative would also rely on structural controls to reduce

potential for exposure, and long-term maintenance of these controls would be required. Because

this alternative would result in contaminated soils remaining onsite above health based levels,

five year reviews will be conducted to ensure that the remedy continues to be protective of

human health and the environment, in accordance with CERCLA 121 (c).

41

004044
Implementability

It is anticipated that no special techniques, materials, permits, or labor would be required to

implement this Alternative. The area required to contain approximately 1,204 cubic yards of

contaminated soils is approximately 12,800 square feet or a 115-foot by 115-foot cell. This

amount of land is readily available onsite. The cover soil, which will consist of 24 inches of low

permeability soil, is readily available, as is the synthetic root penetration barrier. The low

permeability soil and topsoil required for construction is available locally.

ALTERNATIVE 4 - EXCAVATION/OFF-SITE DISPOSAL

Estimated Capital Cost: $351,975

Estimated Annual O&M Costs: $500

Estimated Present Worth (7%): $428,180

Alternative 4 consists of the following activities:

Excavation of approximately 1,204 cubic yards of the upper two feet of soil that exceed

risk based levels at each of the response areas;

• Confirmation sampling at each of the response areas. Confirmation samples would be

collected from each response area and analyzed for COPCs.

• Backfilling of the response areas with clean soil;

• Off-site disposal of the excavated soils at a permitted disposal facility; and

• Implementation of Institutional Controls to restrict future land use to industrial purposes

only. The Institutional Control shall be a restrictive covenant by the property owner, to

the benefit of the State of Texas and the United States Government, recorded in the real

property records of Jefferson County, Texas;

• The time to implement this remedy is expected to be approximately 2 months.

The objective of this alternative is to protect human health and the environment by removing

materials that exceed risk based levels from the Site. Pending results of waste characterization, it

could be necessary to dispose of the excavated materials at a hazardous waste landfill.

Effectiveness

Alternative 4 is protective of human health by removing the source of the risk at the Site.

Alternative 4 complies with applicable or relevant and appropriate requirements by removing

contaminants from the site that exceed risk based levels for protection of human health and the

environment. This option does not provide any reduction in the toxicity, mobility, or volume of

impacted soil through treatment. Alternative 4 would involve the disturbance of surface soils

exceeding acceptable risk levels. The potential for a slight, temporary increase of risk to the

community and to field personnel exists; however, engineering controls (e.g., water sprays) may

be implemented to reduce risk due to fugitive dust during construction.

42

004045
As part of Alternative 4, the response areas would be excavated and backfilled with clean soil or

gravel. Therefore, the potential for sediment runoff from the site that may contain COPCs would

be eliminated. Alternative 4 ensures long-term effectiveness and permanence by removing the

source of the risk from the Site.

Implementability

Implementability issues associated with this alternative include land disposal restrictions (LDR).

Alternative 4 must be implemented in accordance with applicable State and Federal LDR rules.

Successful implementation of this alternative requires that the impacted soils be characterized to

determine the type of disposal facility that must be used. Should waste characterization results

indicate that the impacted soils are considered hazardous, disposal at a hazardous waste landfill

would be required. In addition, under Federal LDR rules, all hazardous waste must be treated

before land disposal to meet Universal Treatment Standards (UTS). The results of the Toxicity

Characteristic Leaching Procedure (TCLP) analysis for waste characterization will determine

whether incineration or disposal in a Resource Conservation and Recovery Act (RCRA)

hazardous waste landfill is necessary to meet the LDR requirements in the event that the soil is

found to be a hazardous waste. However, it is anticipated that the impacted soils on-site will be

characterized as non-hazardous waste. Non-hazardous soils will be transported to a solid waste

landfill. Safety concerns during transportation are minimal due to the relatively small volume of

soil to be transported, such that the volume of additional truck traffic should not constitute a

significant additional risk.

COMPARATIVE ANALYSIS 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 ROD 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.

1. Overall Protection of Human Health and the Environment addresses whether each

alternative provides adequate protection of human health and the environment and describes how

risks posed through each exposure pathway are eliminated, reduced, or controlled, through

treatment, engineering controls, and/or institutional controls.

Alternatives 3 and 4 are protective of human health and the environment through the use of

engineering controls to reduce or control the risk of accidental exposure to contaminated soils

and sediments that exceed risk based levels. Alternative 2 provides some controls from potential

43

004046
exposure of site contaminants through institutional controls. Alternative 1 does not reduce or

control risks from potential exposure at the Site.

2. Compliance with Applicable or Relevant and Appropriate Requirements ("ARAR").

Section 121(d) of CERCLA, 42 U.S.C. §962l(d), and NCP §300.430(f)(l)(ii)(B) require that

remedial actions at CERCLA sites at least attain legally applicable or relevant and appropriate

Federal and State requirements, standards, criteria, and limitations which are collectively referred

to as ARARs, unless such ARARs are waived under CERCLA section 121(d)(4), 42 U.S.C.

§9621(d)(4).

Alternatives 3 and 4 would meet their respective ARARs from Federal and State laws.

Alternatives 3 and 4 could trigger the RCRA land disposal restrictions through the excavation

and consolidation of the soils in an on-site location or the off-site disposal in a permitted RCRA

landfill. Alternatives 1 and 2 do not meet Federal or State ARARs.

3. Long-term Effectiveness and Permanence refers to expected residual risk and the ability to

maintain reliable protection of human health over time, once cleanup levels have been met.

Alternatives 3 and 4 achieve long-term effectiveness through the use of engineering controls to

prevent exposure to the soils and sediments. Alternative 4 provides the most effective and

permanent solution through the off-site disposal of soils that exceed the PRGs. Alternatives 3

and 4 also utilize institutional controls to prevent accidental exposure to the contaminated soils

and sediments. Alternatives 1 and 2 do not provide long-term effectiveness of permanence since

exposure to site contaminants would not be addressed. Alternative 2 only uses institutional

controls to prevent exposure to contaminated soils and sediments.

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 use of engineering controls for containment of the waste material in Alternatives 3 and 4 are

appropriate since the contaminated soils and sediments represent a low level threat at this Site.

Therefore, the statutory preference for remedies that employ treatment that reduces toxicity,

mobility, or volume as a principal element does not apply at this Site.

5. Short-term Effectiveness addresses the period of time needed to implement the remedy and

any adverse impacts that may be posed to workers, the community, and the environment during

implementation

Alternatives 3 through 4 would be effective within 2 months or less through actions to address all

or part of the contaminated soils and sediments. All of the alternatives have minimal impacts to

the on-site workers, the surrounding community, and the environment during implementation.

44

004047
The off-site disposal of contaminated materials in Alternative 4 would result in truck traffic

through the community during implementation.

6. Implementability considers the technical and administrative feasibility of a remedy such as

relative availability of goods and services and coordination with other governmental entities.

Alternative 1 and 2 can be easily implemented in a very short period of time. The technical

feasibility for consolidation and capping the materials in Alternatives 3 is the simplest in terms of

readily available materials and equipment. Disposal of contaminated materials at an off-site

facility under Alternative 4 will require additional actions to secure a disposal facility, costs,

transportation, and supporting documentation. There are no expected administrative problems

with any of the alternatives.

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 range from $135,000 for Alternative 2 to $351,975 for Alternative 4. Annual

operation and maintenance costs for the Site range from $500 for Alternatives 2 and 4 to $10,000

for Alternative 3. Cost summaries are found in Table 11 .

Table 15

Present Worth Cost Summary of the Alternatives

Remedial Alternative

1

2

3

4

Capital Cost

SO

$135,000

$310,669

$351,975

Present Worth of

Total O&M Cost

$0

$6,205

$124,090

$6,205

Estimated Years of

O&M

0

30

30

30

Total Present Worth

Cost

$0

$141,205

$504,759

$428,180

8. State Agency Acceptance considers whether the State agrees with U.S. EPA's analyses in the

FS Report and Preferred Remedy in the Proposed Plan.

The State of Texas, through the Texas Commission on Environmental Quality, supports

Alternative 4. The state's concurrence letter is included in Appendix A.

9. Community Acceptance considers whether the local community agrees with U.S. EPA's

analyses and preferred alternative described in the Proposed Plan.

The community provided comments on the proposed remedy components and no

recommendations were made to change the preferred alternative, Alternative 4. The EPA has

45

004048
considered these comments before making a final remedy selection. The EPA's response to

comments are included in the Responsiveness Summary.

PRINCIPAL AND LOW-LEVEL THREAT WASTES

Principal threat wastes are those source materials that are highly toxic or highly mobile that

generally cannot be reliably contained or would present a significant risk to human health or the

environment should exposure occur. The source materials include liquids and other highly

mobile materials (e.g., solvents) or materials having high concentrations of toxic compounds.

Low level threat wastes are source materials that generally can be reliably contained and that

would present only a low risk in the event of release. The NCP establishes an expectation that

EPA will use treatment to address the principal threats posed by a site wherever practicable.

The Site investigation did not identify liquids or semi-liquid wastes that would appear to be a

highly mobile source material. The sludge material in the remaining AST may contain waste

materials that could be considered principal threat waste. The sludge materials will be sampled

and disposed of at an off-site permitted facility. The disposal facility will be based on the

sampling results prior to disposal. The risk evaluation did not identify other wastes materials that

are highly toxic to human health under the industrial/commercial exposure scenario. Therefore,

the EPA has determined the contaminated soils and sediment to be a low-level threat waste based

on the overall risk posed by the contamination and the low mobility of the contaminants in the

soil and sediment.

SELECTED REMEDY

Description of the Selected Remedy

The selected remedy will achieve the remedial action objectives of: 1) prevent human exposure,

based on industrial/commercial worker scenarios, through dermal contact, ingestion, or

inhalation, to contaminated soil above risk-based standards; 2) prevent off-site migration of

contaminated soils to Sabine Lake; and, 3) prevent exposure to site soils that may pose a risk to

ecological receptors. The Selected Remedy consists of the following components:

• Excavation of approximately 1,204 cubic yards of the upper two feet of soil that exceed

human health and ecological risk based levels at each of the response areas;

• Confirmation sampling at each of the response areas. Confirmation samples would be

collected from each response area and analyzed for COPCs.

• Backfilling of excavated areas with clean soil;

• Off-site disposal of the excavated soils at a permitted disposal facility;

• Implementation of Institutional Controls to restrict future land use to industrial purposes

only. The Institutional Control shall be a restrictive covenant by the property owner, to

the benefit of the State of Texas and the United States Government, recorded in the real

property records of Jefferson County, Texas;;

46

004049
• Abandonment of existing monitoring wells - Five (5) existing monitoring wells at the Site

will be abandoned; and

• Wastewater AST sludge removal and decontamination - Sludge contained within the

remaining Wastewater AST will be removed and disposed of off-site. The tank will be

decontaminated and reused as scrap metal by the property owner.

Remedial Action Areas

Four (4) "hot spots" were identified at the site that exceeded the 10"5 human health risk-based

PRGs. The location are shown on Figure 3-2 and the estimate area and volume are presented on

Table 12.

Table 16

Response Areas for Human Health Risk

Response Area

HR-1- Open Top Slop

Tanks area

HR-2- Boiler House

ASTs area

HR-3- south of the

Wastewater ASTs

HR-4

Contaminant

PAHs

Lead

heptachlor epoxide

benzo(a)pyrene

TOTAL

Area

square feet (FtZ)

953

759

1,983

1,932

5627

Volume

Assuming two foot depth

cubic yards (Yd3)

71

56 (overlaps with ECO #1)

147 (overlaps with ECO #2

143

200

SLERA Response Areas

The SLERA identified on site surface soils that require response action to mitigate potential

future ecological risks at the Site. Analysis of on-site areas needing soil remediation to protect

ecological resources were performed by calculation of safe soil concentrations for the worst case

exposure to a sensitive ground feeding bird,, the American robin. Response areas were then

developed based on the locations where soil concentrations exceeded the safe soil values.

Safe soil concentrations for the American robin were back-calculated for all COPCs whose 95%

UCL concentration resulted in a dose that exceeded a LOAEL value in the evaluation of

bioaccumulative risks. Safe soil concentrations were back-calculated by interactively entering

soil concentrations into the dose rate model until the exposure point concentration resulted in a

dose equivalent to the toxicity reference value (TRY) LOAEL (i.e., a LOAEL-based HQ = 1.0).

The calculated safe soil concentrations, or ecological PRGs, were then compared to detected

concentrations to identify sampling locations where there is a potential for adverse effects to the

47

004050
American robin. Locations Contaminants exceeding the safe soil concentrations are shown on

Figure 3-3. Areas and volume of surface soils that exceed the safe soil concentrations are

presented on Table 13.

Lead was the only metal that had a 95% UCL concentration that exceeded the TRV LOAEL.

Back calculation from the TRV LOAEL resulted in a safe soil concentration of 497 mg/kg lead in

surface soil. These safe soil concentrations factor in site-specific conditions of current and future

commercial/industrial land use and the paucity of vegetation and minimal usable habitat

available to the robin and other terrestrial receptors. Comparisons of the safe soil concentration

to detected concentrations indicate that two locations from the RI data set and four locations from

the ESI data set exceed the safe soil concentration for the American robin.

The evaluation of pesticides indicated that the 95% UCL concentrations of methoxychlor and

DDT exceeded LOAEL doses for American robin. Detected concentrations of these pesticides

exceeded calculated safe soil concentrations at two RI locations and at four ESI locations. At

one location the exceedance of 4,4'-DDD is co-located with an exceedance of lead.

Based on the data presented in the SLERA, seven response areas were identified for remedial

action to address ecological site risk. Two of the ecological response areas overlap with areas

identified for response to human health risk.

Table 17

Response Areas for Ecological Safe Soil Levels

Response Area

ECO Area 1

ECO Area 2

ECO Area 3

ECO Area 4

ECO Area 5

ECO Area 6

ECO Area 7

Contaminant

lead and butyl benzyl phthalate

4,4'-DDD

4,4'-DDD and 4,4'-DDE

4,4'-DDD and 4,4'-DDE

4,4'-DDD, 4,4'-DDE, 4,4'-DDT, and

methoxychlor •

lead

4,4'-DDE and lead

TOTAL

Area

square feet (Ft2)

1,764

513

1,527

1,647

2,419

806

4,869

13,545

Volume

Assuming two foot depth

cubic yards (Yd3)

131

38

113

122

179

60

361

1,004

48

004051
Approximate Volume Requiring Remedial Action

Total soil volume to addressed locations that may pose a risk to both human health and

ecological receptors is approximately 1,204 cubic yards. This estimate is based on removing

contaminated soils down to a maximum depth of two (2) feet. Actual volume may be less if the

contaminants are not present down to the two-foot depth or the areal extent is less than what was

estimate in the Feasibility Study. The volume could increase if the areal extent of contamination

increases once remedial action activities are conducted, hi addition, the selected remedy includes

removing approximately 233 cubic yards of sludge contained within the Wastewater AST and

disposing of this material at an off-site permitted facility.

Summary of Estimated Remedy Costs

The cost estimate summary information in Table 14 is based on the best available information

regarding the anticipated scope of the selected remedy. Changes in the cost elements are likely to

occur as a result of changes in the qualifying bids for performance of the remedial action and

progress due to Site and weather conditions. Major changes may be documented in the form of a

memorandum in the Administrative Record file, an BSD, or a ROD amendment. The total

present worth cost is calculated using a 7% discount rate. This is an order-of-magnitude

engineering cost estimate that is expected to be within +50 to -30 percent of the actual project

cost.

Table 18

Estimated Capital Cost for Selected Remedy

Description

Mobilization

Site Preparation/Erosion Control

TCLP Testing

Excavation

Transportation and Handling

Disposal (Non-Hazardous)

Backfilling

Site Restoration and Demobilization

Implementation of ICs

Abandon Existing Monitor Wells

Wastewater AST Demolition and

Sludge Removal

Unit

Lump Sum

Lump Sum

Lump Sum

Cubic Yards

Ton

Ton

Cubic Yards

Lump Sum

Lump Sum

Each

Lump Sum

Estimated

Quantity

1

1

1

1,204

2,047

2,047

1,204

1

1

5

1

Unit Costs

($)

$50,000

$10,000

$10,000

$6.30

$8.30

$50.00

$12.50

$10,000

$5,000

$5,000

$100,000

Total

$50,000

$10,000

$10,000

$7,585

$16,990

$102,350

$15,050

$10,000

$5,000

$25,000

$100,000

49

004052
Table 18

Estimated Capital Cost for Selected Remedy

SUBTOTAL CAPITAL COSTS 351,975

Additional Construction Costs

Description

Design and Procurement Services

Construction Oversight

Reporting

Total Additional Construction Costs

$30,000

$20,000

$20,000

$30,000

$20,000

$20,000

$70,000

Operation and Maintenance Costs

Annual Maintenance of ICs

30 years O&M Net Present Value at 7.0%

TOTAL ESTIMATED REMEDIAL COST

$500 per year $500

$6,205

428,180

Expected Outcomes of Selected Remedy

The expected outcome of the selected remedy is that the contaminated soils and sediment will no

longer present an unacceptable risk to future industrial and construction workers via ingestion,

inhalation, or dermal exposure and the property will be suitable for redevelopment as an

industrial or commercial property. The remedial action is expected to achieve the remedial

objectives and goals within approximately 6 months. The Site will be available for socioeconomic or community revitalization projects following implementation of the selected remedy.

Site-specific soil concentrations protective of ground water were not developed because the Site

ground water is not considered a potential drinking water source. The site is located on" a isle

constructed from dredge materials and therefore, the site ground water does not represent a true

ground water transmissive zone. The site shallow ground water resulted from the dredging

operations that built the isle.

STATUTORY DETERMINATIONS

Under CERCLA section 121, 42 U.S.C. § 9621, the EPA must select remedies that are protective

of human health and the environment, comply with applicable or relevant and appropriate

50

004053
requirements (unless a statutory waiver is justified), are cost-effective, and utilize permanent

solutions and alternative treatment technologies or resource recovery technologies to the

maximum extent practicable. In addition, CERCLA includes a preference for remedies that

employ treatment that permanently and significantly reduce the volume, toxicity, or mobility of

hazardous wastes as their principal element. The following sections discuss how the selected

remedy meets these statutory requirements.

Protection of Human Health and the Environment

The selected remedy protects human health and the environment through the excavation and offsite disposal of contaminated soils that pose a risk to human health and ecological receptors.

Excavation and off-site disposal will provide a permanent solution to the contaminated soils that

pose a risk. The placement of a clean soil cover will also prevent direct contact with

contaminants that may remain on site below the two-foot depth. Placement of an institutional

control on the Site property would ensure that the site remains protective for the intended

industrial use. This will ensure future site development is consistent with the

industrial/commercial human health exposure scenario (i.e., non-residential usage) that is the

basis for the soil cleanup goals.

Compliance with Applicable or Relevant and Appropriate Requirements

The selected remedy complies with those Federal and State requirements that are applicable or

relevant and appropriate for this remedial action. There were no location-specific ARARs

pertinent to the selected remedy.

Cost Effectiveness

The estimated present worth cost of the selected remedy is $428,180. The selected remedy is

cost-effective and represents a reasonable value for the money to be spent. In making this

determination, the following standard was used: "A remedy shall be cost-effective if its costs are

proportional to its overall effectiveness." (NCP 300.430(f)(l)(ii) (D)). The overall effectiveness

of the remedy is determined by evaluating three of the five balancing criteria used in the detailed

analysis of the alternatives: (1) long-term effectiveness and permanence; (2) reduction in toxicity,

mobility, and volume through treatment; and (3) short-term effectiveness. Overall effectiveness

was then compared to costs to determine cost-effectiveness. The selected remedy best attains

long-term effectiveness than Alternatives 2 and 3; achieves an equal or greater reduction in

toxicity, mobility, and volume as the less expensive Alternatives 2 and 3 and an equal reduction

within an appropriate time frame as Alternatives 2 and 3; and, is equally effective in the shortterm when compared with all the alternatives. The relationship of the overall effectiveness of

this remedial alternative was determined to be proportional to its costs, and hence, this alternative

represents a reasonable value for the money to be spent.

51

004054
Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery)

Technologies to the Maximum Extent Practicable

The selected remedy meets the statutory requirement to utilize permanent solutions and

alternative treatment technologies to the maximum extent practicable. The EPA has determined

that the selected remedy provides the best balance of trade-offs in terms of long-term

effectiveness and permanence, reduction in toxicity, mobility, or volume achieved through

treatment, short-term effectiveness, implementability, and cost. The statutory preference for

treatment as a principal element is not warranted for this site since principal threat waste

materials were not identified during the remedial investigation.

Preference for Treatment as a Principal Element

Principal threat wastes were not identified at the Site and the contaminated soils are considered

low-level threat waste and therefore treatment is not warranted.

Institutional Controls

Institutional Controls (IC's) are required to maintain the permanence and effectiveness of the

Selected Remedy for soil and sediment at the Site. The objective of the 1C 's is to maintain a

future industrial or commercial land use scenario for the onsite impacted property.

The Institutional Control shall be a restrictive covenant by the property owner, to the benefit of

the State of Texas and the United States Government, recorded in the real property records of

Jefferson County, Texas.

The timing of implementation of the IC's will be consistent with the proposed remedial action

schedule, and IC's should be in place before signature of the Preliminary Closeout Report

(PCOR), signifying remedial action construction completion.

EPA will be responsible for implementing the IC's, with technical assistance from the TCEQ.

Future responsibilities for 1C management will be negotiated with the current property owner.

Five-Year Review Requirements

Since the selected remedy will result in hazardous substances remaining on-site above levels that

allow for unlimited use and unrestricted exposure, a statutory review must be conducted no less

often than every five years from initiation of the remedial action to ensure that the remedy is, or

will be, protective of human health and the environment. Pursuant to CERCLA Section 121(c),

42 U.S.C. § 9621(c), and as provided in the current guidance on Five Year Reviews [OSWER

Directive 9355.7-03B-P, Comprehensive Five-Year Review Guidance (June 2001)], EPA must

52

004055
conduct a statutory review no less often than every five years from the initiation of construction

at the Site.

DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for the Palmer Barge Site was released for public comment on July 27, 2005.

The Proposed Plan identified Alternative 4, Excavation and Off-Site Disposal, as the preferred

alternative for the contaminated soil and sediment. Based upon its review of the written and

verbal comments submitted during the public comment period, the EPA determined that no

significant changes to the remedy, as originally identified in the Proposed Plan, were necessary or

appropriate.

53

004056
PALMER BARGE LINE SUPERFUND SITE

PORT ARTHUR, JEFFERSON COUNTY, TEXAS

RECORD OF DECISION

PART 3: RESPONSIVENESS SUMMARY

STAKEHOLDER COMMENTS AND LEAD AGENCY RESPONSES

The EPA has prepared this Responsiveness Summary for the Site, as part of the process for

making a final remedy selection. This Responsiveness Summary documents, for the

Administrative Record, public comments and issues raised during the public comment period on

the EPA's recommendations presented in the Proposed Plan, and provides the EPA's responses to

those comments. The EPA's actual decisions for the Site are detailed in the ROD. Pursuant to

Section 117 of the Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA), 42 U.S.C. § 9617, the EPA has considered all comments received during the public

comment period in making the final decision contained in the ROD for the Site.

Overview of Public Comment Period.

The EPA issued its Proposed Plan of Action detailing remedial action recommendations for

public review and comment on July 27, 2005. These and other Site documents can be found in

the Administrative Record file and the information repositories at the following locations: Port

Arthur Public Library located at 4615 9th Avenue, Port Arthur, Texas; the U.S. Environmental

Protection Agency Region 6 located at 1445 Ross Avenue, Dallas, Texas; and the Texas

Commission on Environmental Quality located at 12100 Park 35 Circle, Building E, 1st Floor,

Austin, Texas. The notice of the availability of these documents was published in the Port

Arthur News on July 28, 2005. A public comment period was held from July 27, 2005 to August

25, 2005. The EPA and the Texas Commission on Environmental Quality conducted a public

meeting on August 11, 2005, to discuss the Proposed Plan and receive comments from the

community. The public meeting was held at the West Groves Education Center, located at 5840

West Jefferson, in Groves ,Texas.

This Responsiveness Summary summarizes comments submitted during the public comment

period and presents the EPA's written response to each issue, in satisfaction of community

relations requirements of the NCP. The EPA's responses to comments received during the

public meeting are provided below and in some cases include subsequent expanded responses to

those comments as appropriate.

Summary of Public Comments and EPA Responses

Comment: Question was asked if the remaining AST will be cleaned as part of the preferred

alternative.

54

004057
EPA Response: The sludge in the remaining AST will be removed and disposed of off-site and

the tank will be decontaminated in the preferred alternative and all alternatives except the no

action alternative.

Comment: All risks need to be considered. Digging around a landfill may present a risk. The

risk of excavation on Palmer may not have been properly assessed when you start considering the

difference between excavation and capping, and capping may actually provide certain

improvements to preexisting conditions as far as providing a better cap for the preexisting

landfill.

EPA Response: The excavation alternative will not dig into the landfill materials. Under the

excavation alternatives contaminated materials would be removed to a depth of two (2) feet

below ground surface and would not remove materials below this depth, which is where most of

the landfill materials are located. Furthermore, information from the investigations conducted at

the site indicate that the landfill materials are not found in thick layers and are mixed with the

dredge fill materials. Test results do not indicate that these mixed materials present a significant

risk at the Site. Areas that are excavated would be backfilled with clean soil and would be an

improvement to the materials that are presently located at the site. The backfilled materials

would provide a better cap for the site.

Comment: Although the Palmer Barge and State Marine sites are next to each other, you would

think in general they should come out pretty much the same result but they're different levels,

different type of contamination — as measured by the R.I. process.

EPA Response: The contaminated materials at both the State Marine and Palmer Barge sites are

similar since both sites were used for barge cleaning operations. After the removal action

conducted in August 2000, the remaining residual contaminated is at different concentrations at

both sites. Although not the same contaminants were identified as presenting a risk at each site,

were are present at both sites, but may not represent the same risk. Also the distribution of

contamination at the site was different. So, although the sites are next to each other and were

used for the same type of activities, the remaining contaminants are at different concentrations

and different risk levels.

Comment: Question was asked regarding the difference in O&M cost for the Palmer Barge site

and State Marine site sediment in Sabine Lake. The site soil excavation alternative for the State

Marine site includes monitored natural attenuation for the sediments while the soil excavation

alternative for the Palmer Barge does not. The concern raised was that all the cost for monitoring

of the Sabine Lake sediments was included in the State Marine alternative.

EPA Response: The monitored natural attenuation of the State Marine sediments does not

include monitoring of the sediments located next to the Palmer Barge site. The contaminant

levels found in the sediments next to the State Marine site were higher than those found next to

the Palmer Barge site. That is part of the reason that other alternatives are being considered for

55

004058
the sediments located next to the State Marine site. The monitoring of the sediments for the

State Marine site would be only for the sediment next to the site and would not include

monitoring for the sediments located next to the Palmer Barge site.

In addition, the preferred remedial alternative for the Palmer Barge Site will include excavation

and off-site disposal of site soil that may present a risk to ecological receptors. This will further

ensure that site soils do not migrate off-site to the Sabine Lake sediments and accumulate at

concentrations that may pose a risk to the environment.

TECHNICAL AND LEGAL ISSUES

The Selected Remedy is consistent with the potential property redevelopment for industrial or

commercial use. Institutional controls will be a necessary component of the long-term Site

management to ensure future property development is consistent with the soil cleanup levels.

56

004059
0 1000

" 2000'

SCALE IN FEET

SOURCE:

US GEOLOGICAL SURVEY, PORT ARTHUR NORTH

QUADRANGLE. 7.5 MINUTE SERIES (TOPOGRAPHIC).

ANO WEST OF GREENS BAYOU QUADRANGLE. TEXAS-

LOUISIANA. 1093.

Site Location Map

Feasibility Study Report

Patntef Baitfe Line SupeffuiKJ Site

Port Arthir .Wli»r*on Cnunly T^ita

Paknar B«s* Un Sup«rtund SM>

1-1

004060
004061
SMS PROPERTY

OPEN TOP

'I BK-11 SLOP TANKS

TP-09X

LEGEND

ESI SAMPLNG LOCATIONS

Rl SAMPLING LOCATION

Rl TEST PIT SAMPLING LOCATION

AREA OF POTENTIAL HUMAN HEALTH RISK (10 ••)

•-SABINE LAKE-.

PALMER BARGE SUPERFUND SITE

8700 Ferry Road

Port Arthur. TX

Figure 3-2

Identified Response Areas for

KT5 Risk Soil Remedy

004062
SMS PROPERTY

LEGEND

Rl SOL SAMPUNG LOCATION

Rl TEST PIT SAMPUNG LOCATION

AREA OF POTENTIAL ECOLOGICAL RISK

ESI SOIL SAMPLING LOCATION

"SABINE LAKE--

PALMER BARGE SUPERFUND SITE

8700 Ferry Road

Port Arthur. TX

Figure 3-3

Identified Response AreasAreas of Potential Ecological Risk

Jul 1Z 200S - 1:42pm

004063
APPENDIX A

004064
Hartnett White, Chairman

Larry R. Soward, Commissioner

Glenn Shankle, Executive Director

R. B. "Ralph" Marquez, Commissioner fSilNPfMfe:

.-,.._-

! 1 - ••-1 j. .- ^•, .

 ,

 •^ c •: v"" | I V - Kj -«* D

, \ K— "' ^

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY ,, 0;,-..., /, ^. bvu^cb wr r \ ! '.-' '

Protecting Texas by Reducing and Preventing Pollution

September 30, 2005

Mr. Samuel Coleman, P.E., Director oco '-f\

-. '.•; , '.""T1 Superfund Division ^

U.S. Environmental Protection Agency, Region 6 •;

1445 Ross Avenue ' r .^:

 ;

Dallas, Texas 75202 -vJg §.;

••r'i ?'E VO

Re: Palmer Barge Line, Jefferson County, Texas P;"

;

 c •

Record of Decision (ROD)

Dear Mr.

The Texas Commission on Environmental Quality (TCEQ) has completed our review of the above

referenced document. We concur that the remedial action for the Palmer Barge Line Site, described

in the September 2005, ROD, is the most appropriate for this site. However, the TCEQ does have

concerns that a fundamental aspect of the selected remedy relies on landowner permission. We trust

that if that permission cannot be obtained, the ROD will be formally amended to address the

situation in another manner.

Sincerely,

Vv. iihaiic

Executive Director

LV/TS

P.O. Box 13087 • Austin, Texas 78711-3087 • 512/239-1000 • Internet address: www.tceq.state.tx.us

prinli-j i?n iix'yck'J [^pi-r usin^ soy-h;ihcd ink

004065
Mr. Samuel Coleman, Director

Page 2

bcc: Mr. Dan Eden, Deputy Director, Office of Permitting

Ms. Jacqueline S. Hardee, P.E., Director, Remediation Division

Mr. Jay Carsten, P.O., Manager, Environmental Cleanup I Section

Ms. Cathy Remmert, Team Leader, Environmental Cleanup I Section

Ms. Luda Voskov, P.O., Project Manager, Environmental Cleanup I Section

004066