1

PROPOSED PLAN FOR

PALMER BARGE LINE SUPERFUND SITE

PORT ARTHUR, TEXAS

U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 6

JULY 27, 2005

THE U.S. EPA ANNOUNCES A PROPOSED PLAN

PURPOSE

The purpose of this proposed plan is to:

• Identify and define the remedial alternatives

evaluated by EPA to address contamination at

the Palmer Barge Line Superfund Site (Site).

• Present EPA’s Preferred Alternative.

• Solicit public comment on the remedial action

alternatives and supporting analyses, as well as

on information contained in the Administrative

Record.

• Provide information on how the public can be

involved in the remedy selection process.

EPA PROPOSES FINAL REMEDY FOR THE

PALMER BARGE LINE SITE

In this Proposed Plan, the U.S. Environmental

Protection Agency (EPA) describes a proposed final

remedy for the Palmer Barge Line Superfund site

(Site) and provides the rationale for this preference. In

addition, this Proposed Plan includes summaries of

other alternatives evaluated for use at this Site. This

document is issued by the U.S. Environmental

Protection Agency (EPA), the lead agency for Site

activities, and the Texas Commission on

Environmental Quality (TCEQ), the support agency. 

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

final remedy for the Site after reviewing and

considering all information submitted during the 30-

day public comment period. The EPA, in consultation

with the TCEQ, may modify the proposed remedy or

select another response action presented in this

Proposed Plan based on new information or public

comments. Therefore, the public is encouraged to

review and comment on all the alternatives presented

in this Proposed Plan. The Feasibility Study report for

this Site should be consulted for more detailed

information on these alternatives.

The EPA is issuing this Proposed Plan as part of its

public participation responsibilities under section

117(a) of the Comprehensive Environmental,

Response, Compensation, and Liability Act

(CERCLA) of 1980, as amended by the Superfund

Amendments and Reauthorization Act of 1986

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

of the National Oil and Hazardous Substances

Pollution Contingency Plan (NCP). This Proposed

Plan summarizes information that can be found in

greater detail in the Remedial Investigation and

Feasibility Study reports and other documents

contained in the Administrative Record file for this

Site. The EPA and TCEQ encourage the public to

review these documents to gain a more comprehensive

understanding of the Site and the Superfund activities

that have been conducted at the Site.

Community Participation

The public is invited to review and comment on this

Proposed Plan and the documents contained in the

Administrative Record file. This Proposed Plan

highlights key information from the RI and FS reports,

but it is not a substitute for those or other documents

contained in the Administrative Record. EPA

encourages the public to review those documents to

obtain more information about the Site. The

Administrative Record file is available at the

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following information repositories:

Port Arthur Public Library

4615 9th Avenue

Port Arthur, Texas 77642

(409) 985-8838

Monday-Friday (8:00 a.m. to 4:30 p.m.)

U.S. Environmental Protection Agency Region 6

Seventh Floor Reception Area

1445 Ross Avenue, Ste 12D13

Dallas, Texas 75202-2733

(214) 665-6427

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

Texas Commission on Environmental Quality 

12100 Park 35 Circle

Building E, 1st Floor 

Austin, Texas 78753

(512) 239-2920

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

During the public comment period, written comments

should be submitted to:

Carlos A. Sanchez

Remedial Project Manager

EPA Region 6 ( 6SF-A)

1445 Ross Avenue

Dallas, Texas 75202-2733

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

The public comment period is scheduled to begin on

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

has scheduled a public meeting on August 11, 2005, to

discuss the Proposed Plan and receive comments from

the community. The public meeting will be held at

the West Groves Education Center, located at 5840

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

PM. A court reporter will be present to record oral

comments. EPA will conduct a short presentation

and afterward will be available to meet with citizens. 

EPA will respond to all comments received during the

public comment period using a document called a

Responsiveness Summary. This document will be

attached to the ROD and will be made available to the

public in the information repository.

SITE BACKGROUND

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, 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

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.

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, 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,

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, de-gassing, 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 thick accumulations of sludges were

removed. De-gassing activities involved the removal

of explosive vapors from vessel holds using nitrogen

or boiler exhaust. Maintenance and inspection

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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 burn

excess gases and liquids produced during facility

operations.

EPA Region VI conducted an Expanded Site

Inspection (ESI) of the Palmer Barge Line site during

October 1999 to determine the presence, nature and

extent of contamination on-site and off-site, and to

determine migration routes and routes of exposure of

site related constituents. During August of 2000, EPA

Region 6 conducted a Removal Action to remove

material stored on-site. Activities included waste

removal, water treatment, oil/water separation, and

sludge stabilization.

The Site was placed on the National Priorities List on

July 27, 2000. On September 30, 2002, EPA Region

VI issued an Administrative Order on Consent to

Potentially Responsible Parties (PRPs).

SITE CHARACTERIZATION

EPA conducted an Expanded Site Inspection in 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 indicated the presence of

volatile organic constituents (VOCs), semi-volatile

organic compounds (SVOCs), pesticides,

polychlorinated biphenyls (PCBs), and metals. As

part of the ESI, a site reconnaissance was performed

which identified the following Areas of Concern

(AOCs) at the Site:

• Wastewater Above-ground Storage Tanks

(ASTs);

• Boiler House ASTs;

• Open Top Slop tanks;

• Horizontal ASTs;

• 12 ASTs; and

• Flare.

Based on the findings of the ESI, EPA conducted a

Removal Action in August of 2000 and removed all of

the above-ground storage tanks and their contents. 

One large tank remained on the northern portion of the

site that contains sludge. The remaining large tank

and sludge materials will be addressed in this

Proposed Plan.

URS Corporation (URS), on behalf of the 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. A summary of the RI findings is listed

below:

Hydrogeologic Findings

The majority of the Site sub-soil is derived from

dredge sediment from Sabine Lake. As part of the

island use as a municipal landfill by the City of Port

Arthur, a layer of cap material was placed over the

areas used as landfill. 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. Waste was

encountered sporadically in the fill between about one

foot to five feet below ground surface (BGS). The

items encountered were primarily brick, metal, rubber

and some glass. Beneath the fill that contained trash

was additional fill, ranging from silty clay to silty

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.

Groundwater was encountered in the sandy portions of

the dredge fill unit. 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. Groundwater flow direction

is toward Sabine Lake. 

Remedial Investigation Findings

Wastewater AST Area

Test samples were collected from four test trenches

excavated on the north, south and east sides of the

Wastewater Tank AST. VOCs detected included

benzene at levels up to 39 ug/kg, isopropylbenzene up

to 0.003 mg/kg, and methyl tertiary-butyl ether

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(MTBE) at levels up to 0.030 mg/kg. Other

constituents detected near the Wastewater AST area

included seventeen (17) SVOCs, two (2) PCBs, and

twelve (12) pesticides were detected. 

Pentachlorophenol (PCP) was encountered at the 2 to

4-foot interval at a concentration of 150 mg/kg.

Boiler House ASTs

Soil sampling conducted nearest to the former Boiler

House found minimal VOCs, although two surface

locations contained concentrations of 0.046 and 0.043

mg/kg of benzene. Other constituents detected

included fifteen (15) SVOCs, eight (8) pesticides, and

two (2) PCBs (Arochlor-1254 and 1260). The highest

number of constituents were encountered at the 2 to 4-

foot interval. Several metals were detected above the

background levels near the Boiler House ASTs area. 

Eight of the ten samples had lead and zinc

concentrations above the background.

Open Top Slop Tanks Area

Two test trenches were excavated and sampled in the

vicinity of this former unit and AOC Flare. Unrelated

to the AOC itself was the discovery of a drum of thick

black sludge that the backhoe encountered during the

initial excavation. A sample of this material and the

soil it was in contact with was collected and found to

contain 45 mg/kg of isopropylbenzene, 42 mg/kg of

2-methylnapthalene, 10 mg/kg of fluorene, 13 mg/kg

of napthalene, 36 mg/kg of phenanthrene, and .190

mg/kg of heptachlor epoxide. This material was

immediately excavated, drummed and was disposed of

as a presumed hazardous waste. A few metals were

detected and background levels were slightly exceeded

for aluminum, chromium, and vanadium.

Horizontal ASTs

The ESI sampling did not identify site-related

constituents in the Horizontal ASTs area and sampling

for this area was not included in the RI. However,

sampling was conducted for the Twelve ASTs area

located adjacent to the Horizontal ASTs area. 

Samples were collected from one test pit and soil in

the vicinity of the test pit. Constituents detected

included: chromium, copper, lead, and zinc above

background concentrations and MTBE at a

concentration of 0.029 mg/kg. Antimony at a

concentration of 0.168 mg/kg exceeded background.

Twelve ASTs Area

Samples near the Twelve ASTs area contained

detections of benzene and MTBE up to 0.087 mg/kg. 

Numerous SVOCs were detected with 2-

methylnapthalene, bis(2-ethylhexyl)phthalate,

chrysene, and pyrene being detected above the

practical quantitation limit (PQL). Several metals

were detected above background at concentrations of

15.1 mg/kg antimony and 91.3 mg/kg arsenic.

Flare Area

One sample dug immediately next to the flare area

contained detections of benzene, 4,4’-DDE, Arochlor1254 and Arochlor-1260. No metals exceeded the

background concentrations in the surface sample, but

nine metals exceeded background in the sample from

the 2 to 4-foot interval.

Area east of Flare in center of site

One sampling location was performed in

approximately the middle of the site, to the east of

Flare area and southeast of Wastewater ASTs area. 

Two samples from this location contained: low

concentrations (less than 8.7 ug/kg) of benzene,

pesticides and PCBs (Arochlor-1254 at 4.18 mg/kg). 

Metals were detected at concentrations as high as

1,640 mg/kg for lead, 5,950 mg/kg for zinc, and 45.6

mg/kg for mercury.

Sediment Sampling – Sabine Lake

Sediment sampling results indicated low levels of

several PAHs. No pesticides, PCBs or VOCs were

detected in the sediment samples collected. Metals

detected in the sediment samples included chromium,

copper, lead, manganese, nickel, and vanadium. 

Barium and zinc results had more variation, and there

were some detections of mercury. Organic carbon

results ranged from 8,630 mg/kg to 16,300 mg/kg.

SCOPE AND ROLE OF RESPONSE ACTION

This response action is the final site remedy and is

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intended to fully address the threats to human health

and the environment posed by the contaminants of

concern identified at the Palmer Barge Site. The

purpose of this response action is to implement a

remedy that prevents exposure to contaminated soils

and sediments at the Site. The proposed remedy

would also reduce or eliminate future surface run-off

of site contaminants to Sabine Lake that may

accumulate in the sediments and pose a risk to

ecological receptors.

SUMMARY OF SITE RISKS

The EPA considers two types of risk: cancer risk and

non-cancer risk. Excess lifetime cancer risks that

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

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

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

considered unacceptable. For non-cancer risks, a

hazard index less than 1 for an individual target organ

or system is below the threshold for predicted health

effects.

A baseline risk assessment was completed to

determine the current and future effects of

contaminants on human health and the environment. 

Based on current zoning and surrounding area, future

land use for the former facility will be limited to

industrial and/or commercial use after completion of

the remedial action. Therefore, the human health risk

assessment focused on health effects for future

industrial and construction workers that could result

from direct contact (incidental ingestion, inhalation,

and dermal contact) with on-site soils, sediments in

the drainage ditches and pond, and surface water.

Baseline Human Health Risk Assessment

The primary sources of information used in the human

health baseline Human Health Risk Assessment

(HHRA) are the Expanded Site Inspection Report

(ESI) and the Remedial Investigation Report for the

Palmer Barge Line Superfund Site. 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 of fish from Sabine Lake that may have

accumulated site-related constituents from nearby

sediments.

 

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 the six AOCs

based on analytical data reported in the RI. Risks for

the recreational 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 (1x10-6

to 1x10-4 cancer risk and a non-cancer 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

collected by the Texas Department of Health from

Sabine Lake in 1995 indicates that fish consumption

from Sabine Lake does not represent a threat to human

health.

Several surface soil sample locations with

concentrations exceeding target cleanup levels were

identified as "hot spots" to be addressed in the FS. 

The HHRA concluded that remedial action which

addressed these identified "hot spots" would result in a

reduced level of risk such that surface soils at the Site

would be within the acceptable risk range.

Screening Level Ecological Risk Assessment

As part of the Screening Level Ecological Risk

Assessment (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

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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 require

significant remedial action. Therefore, the SLERA

recommended to allow degradation to naturally

attenuate organic COPCs and to implement on-site

source control to prevent potential for future inputs 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 paucity of

vegetation and minimal site use by terrestrial receptors

justifies the conclusion that ecological risks are

negligible and therefore exposure is low. However, as

future long-term industrial use of the Site is uncertain,

and potential exposure could occur if ecological

succession were to proceed naturally. Thus, the

SLERA proposed that soil remediation would be

completed to adequately 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. As a result, several

ecological "hot spots" were identified as response

areas in the FS.

REMEDIAL ACTION OBJECTIVES

Remedial Action Objectives consist of

medium-specific goals for protecting human health

and the environment. Based on the conclusions of the

HHRA and the SLERA, Remedial Action at the Site is

required to reduce risk to human health and potential

ecological receptors due to COPCs exceeding

acceptable risk levels in surface soils. Human

receptors susceptible to exposure include the on-site

industrial worker. Exposure of the on-site industrial

worker is assumed to occur by way of contact with

constituents in surface soil by way of accidental

ingestion, dermal contact, inhalation of wind blown

dust from soil, and inhalation of vapors emanating

from soil. The Remedial Action Objectives for the

Site are as follows:

• Prevent ingestion/inhalation or direct contact

with surface soil containing high

concentrations of COPCs which may pose an

unacceptable level of risk to human health.

• Prevent direct contact with surface soil

containing high concentrations of COPCs

which may pose an unacceptable level of risk

to potential future ecological receptors.

• Prevent offsite migration of contaminated soils

to surface water and Sabine Lake sediments.

As part of the HHRA and SLERA, a list of

site-specific COPCs was developed. The list of

site-specific COPCs and corresponding human health

target cleanup levels is presented in the table below.

Contaminant

Human Health Risk

Target Cleanup

Level mg/kg

Heptachlor epoxide 8.9

Benzo(a)pyrene 2.3

Naphthalene 210

Lead 800

Remedial objectives for addressing future potential

ecological risk were developed based on safe soil

concentrations for the worst case exposure to a

sensitive ground feeding bird, the American robin. 

Risk-based PRGs and safe soil concentrations to

address potential ecological risk are also presented in

the table below.

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Contaminant

Ecological Risk

Target Cleanup

Level mg/kg

4,4-DDD 0.0864

4,4-DDE 0.0864

4,4-DDT 0.0865

Methoxychlor 0.09

Lead 497

SUMMARY OF REMEDIAL ALTERNATIVES

The remedial alternatives were developed to address

the remedial action objectives and goals for the Site. 

For alternatives 2, 3, and 4 the common elements

include: 

• Deed Restriction - The current owner of the

Site has agreed to allow the state to place a

deed restriction on the Site, which would limit

future use of the property to industrial

purposes;

• Abandonment of existing monitoring wells -

As the HHRA 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 left on site. The property

owner plans to reused the tank for scrap metal.

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, no

action would be taken to prevent exposure to the

remaining contaminated soils and sediment at the Site.

ALTERNATIVE 2 - Institutional Controls

Estimated Capital Cost: $135,000

Estimated Annual O&M Costs: $500

Estimated Present Worth (7%): $141,000

Alternative 2 includes the following activities:

• Deed Restriction - 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. 

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ALTERNATIVE 3 - EXCAVATION / ON-SITE

DISPOSAL / SOIL COVER / ICs

Estimated Capital Cost: $305,000

Estimated Annual O&M Costs: $10,000

Estimated Present Worth (7%): $499,000

Alternative 3 includes the following activities:

• Excavation of approximately 1,061 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 10,395 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) may

be 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).

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 1,061 cubic yards of contaminated soils

is approximately 10,395 square feet or a 110-foot by

110 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 / ICs

Estimated Capital Cost: $335,000

Estimated Annual O&M Costs: $500

Estimated Present Worth (7%): $411,000

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Alternative 4 consists of the following activities:

• Excavation of approximately 1,061 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 proprietary controls to

restrict future land use to industrial purposes

only.

• 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.

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 TCLP

analysis for waste characterization will determine

whether incineration or disposal in a 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.

EVALUATION OF ALTERNATIVES

Nine criteria are used to evaluate the different

remediation alternatives individually and against each

other in order to select a remedy. The nine evaluation

criteria are (1) overall protection of human health and

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

long-term effectiveness and permanence; 4) reduction

of toxicity, mobility, or volume of contaminants

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

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

acceptance; and (9) community acceptance. This

section of the Proposed Plan profiles the relative

performance of each alternative against the nine

criteria, noting how it compares to the other options

under consideration. The nine evaluation criteria are

discussed below.

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1. Overall Protection of Human Health and the

Environment determines whether an alternative

eliminates, reduces, or controls threats to public

health and the environment through institutional

controls, engineering controls, or treatment.

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 exposure of site contaminants

through institutional controls. Alternative 1 does not

reduce or control risks from potential exposure at the

Site.

2. Compliance with ARARs evaluates whether the

alternative meets Federal and State environmental

statutes, regulations, and other requirements that

pertain to the Site or whether a waiver is justified.

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

considers the ability of an alternative to maintain

protection of human health and the environment over

time.

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. Alternatives 2, 3, and 4

do not satisfy the statutory preference for remedies

that employ treatment that reduces toxicity, mobility,

or volume as a principal element. Since Principal

Threat waste are not present at the Site, treatment of

contaminated materials is not warranted.

5. Short-term Effectiveness considers the length of

time needed to implement an alternative and the risks

the alternative poses to workers, residents, and the

environment during implementation.

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. 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 implementing the

alternative such as relative availability of goods and

services.

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.

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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

$335,103 for Alternative 4. Annual operation and

maintenance costs for the Site range from $500 for

Alternatives 2 and 4 to $10,000 for Alternative 4.

8. State/Support Agency Acceptance considers

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

and recommendations of the RI/FS and the Proposed

Plan.

TCEQ has been provided the opportunity to review

the RI/FS reports and the Proposed Plan. TCEQ’s

support for the preferred alternative will be evaluated

during the public comment period.

9. Community Acceptance considers whether the

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

preferred alternative. Comments received on the

Proposed Plan are an important indicator of

community acceptance.

Community acceptance of the preferred alternative

will be evaluated after the public comment period

ends and will be described in the ROD for the Site.

SUMMARY OF THE PREFERRED

ALTERNATIVE

Each of the four (4) alternatives presented in the FS,

was evaluated on its ability to meet the nine

evaluation criteria. The alternative that best meets the

evaluation criteria is Alternative 4. This alternative

consists of the excavation of impacted soils and

disposal at an off-site permitted facility.

• Alternative 4 achieves Remedial Action

Objectives and does so within a reasonable

time frame;

• This alternative ensures long-term

effectiveness and permanence with no O&M

issues;

• Major components of this alternative are all

well-demonstrated to be implementable and

reliable technologies for remediation of sites

having similar COPCs;

• This alternative eliminates potential sediment

runoff that may contain COPCs from entering

Sabine Lake.

• Alternative 4 is easily implemented; 

• Alternative 4 is cost-effective.

In summary, Alternative 4 is the most protective of

human health ecological receptors, easily

implemented, and cost-effective alternative evaluated

in the FS.

The preferred alternative can change in response to

public comment or new information presented during

the public comment period.

For specific information about the Palmer Barge

Line Site or the Superfund process, please contact:

Carlos A. Sanchez.

Remedial Project Manager

EPA Region 6 (6SF-A)

1445 Ross Avenue

Dallas, Texas 75202-2733

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

Inquires from the news media are to be directed to

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

665-2208.

The local Information Repository containing the

RI/FS and other Site documents is located at:

Port Arthur Public Library

4615 9th Avenue

Port Arthur, Texas 77642

(409) 985-8838

Monday-Friday (8:00 a.m. to 4:30 p.m.)

On the Web

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

Superfund Program can be found at:

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

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

U.S. EPA Region 6 Superfund Program: 

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GLOSSARY OF TERMS

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

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

translation of this fact sheet.

* * *

Para recibir una traducción en español de esta Hoja de

Datos, comunicarse con la Agencia de

Protección del Medio Ambiente de los EEUU (la

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

Administrative Record - All documents which the

EPA considered or relied upon in selecting the

response action at a Superfund site, culminating in

the Record of Decision for a Remedial Action or, an

Action Memorandum for a Removal Action.

Human Health Risk Assessment (HHRA) -

Estimates the current and possible future risks if no

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

Superfund risk assessors determine how threatening a

hazardous waste site is to human health and the

environment. They seek to determine a safe level for

each potentially dangerous contaminant present (e.g.,

a level at which ill health effects are unlikely and the

probability of cancer is very small). Living near a

Superfund site doesn’t automatically place a person at

risk, that depends on the chemicals present and the

ways people are exposed to them.

Ecological Risk Assessment - A process that

evaluates the likelihood that adverse ecological

effects may occur or are occurring as a result of

exposure to one or more chemical, physical, or

biological stressors.

Feasibility Study (FS) - A detailed evaluation of

alternatives for cleaning up a site. A FS is usually

performed concurrently with the Remedial

Investigation.

Five-Year Reviews - A review generally required by

statute or program policy when hazardous substances

remain at a site above levels which permit

unrestricted use and unlimited exposure. Five-Year

Reviews provide an opportunity to evaluate the

implementation and performance of a remedy to

determine whether it remains protective of human

health and the environment. Reviews are performed

five years following the initiation of a Superfund

response action, and are repeated every succeeding

five years so long as future uses at a site remain

restricted.

Ground Water - Water found beneath the ground

surface that fills pores between soil, sand, and gravel

particles to the point of saturation. When it occurs in

a sufficient quantity and quality, ground water can be

used as a water supply.

Institutional Controls (ICs) - Non-engineered

instruments, such as administrative and/or legal

controls, that help to minimize the potential for

human exposure to contamination and/or protect the

integrity of a remedy. ICs work by limiting land or

resource use and/or by providing information that

helps modify or guide human behavior at a site. 

Some common examples of ICs include zoning

restrictions, building or excavation permits, well

drilling prohibitions, and easements or covenants.

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Microgram per Deciliter (μg/dL) - Units of measure

used to express the concentrations of metals (e.g.,

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

Milligram per Kilogram (mg/kg) - Units of measure

used to express the concentrations of metals (e.g.,

lead) or organics in soil or sediments. As an

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

equivalent to one cent in $10,000.

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

the most serious uncontrolled or abandoned

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

must be on the NPL to receive money from the Trust

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

score a site receives from the Hazard Ranking

System. The EPA updates the NPL at least once a

year.

Potentially Responsible Parties (PRP) - Any

individual or company, including owners, operators,

transporters or generators, who is potentially

responsible for, or contributing to a spill or other

contamination at a Superfund site.

Record of Decision (ROD) - The final Remedial

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

document the remedy selected, provide a rationale for

the selected remedy, and establish performance

standards or goals for the site under consideration. 

The ROD provides a plan for site design and

remediation, and documents the extent of human

health or environmental risks posed by the site. It

also serves as legal certification that the remedy was

selected in accordance with the requirements of the

Superfund statute and regulations. The ROD is one

of the most important documents in the remedy

selection process, because it documents all activities

prior to selection of a remedy and provides a

conceptual plan for activities subsequent to the ROD.

Remedial Investigation (RI) - An investigation to

determine the nature and extent of contamination at a

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

specific activity to a complex study. The next, or

concurrent step, following an RI is a Feasibility

Study.

Removal Action - An action based on the type of

situation, the urgency and threat of the release or

potential release, and the subsequent time frame in

which the action must be initiated. The Removal

Actions for the Palmer Barge Site consisted of a

“time-critical” Removal Actions where the EPA

determined, based on the evaluation of the Site, that a

Removal Action is appropriate to contain and/or

prevent releases of contaminants that may pose a risk

to human health and the environment.

Responsiveness Summary - A summary of oral

and/or written public comments received by the EPA

during a public comment period on key EPA

documents, such as the Proposed Plan for the Palmer

Barge Site and EPA’s response to those comments. 

A responsiveness summary is included in the Record

of Decision for a site.

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ATTACHMENT 1

COMMENT SHEET

Your comments on the Proposed Plan for the Palmer Barge Line Superfund Site are important to the

EPA and the TCEQ and will help us evaluate the EPA’s preliminary recommendation of the Preferred

Alternative for the Site. You may use the space below to write your comments. Use additional sheets if

necessary. Please mail your comments to:

Carlos A. Sanchez, Remedial Project Manager

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

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

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

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

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

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

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

Decision, identifying the Selected Remedy, the Palmer Barge Site. If you have any questions about the

comment period or the Palmer Barge Site, please contact Carlos A. Sanchez at (214) 665-8507 or the EPA’s

toll-free number at 1-800-533-3508.

Name: Address:

City: State: Zip Code:

Telephone No.: E-Mail Address:

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