AMENDED FINAL CLOSE OUT REPORT 

STATE MARINE OF PORT ARTHUR SUPERFUND SITE 

PORT ARTHUR, JEFFERSON COUNTY, TEXAS 

EPA ID# TXD099801102 

REGION 6 
CONCURRENCE PAGE 

AMENDED FINAL CLOSE OUT REPORT 

STATE MARINE OF PORT ARTHUR SUPERFUND SITE 

EPA ID# TXD099801102 

Rafael Casanova, P.G.; Remedial Project Manager Date 

Compton, Office of Regional Counsel, Superfund Branch Date 

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Carlos Sanchez, Chief, Arkansas/Texas ection Date 

Donald Williams, Deputy Associate Director, Superfund Division 

Charles Faultry, Associate Director 

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Date • ,Office of Regional Counsel, Superfund Branch 
AMENDED FINAL CLOSE OUT REPORT 

STATE MARINE OF PORT ARTHUR SUPERFUND SITE 

PORT ARTHUR, JEFFERSON COUNTY, TEXAS 

I. INTRODUCTION 

This Amended Final Close Out Report documents that the U. S. Environmental 

Protection Agency (EPA) and the Texas Commission on EilVironmental Quality (TCEQ) have· 

completed all of the cleanup activities for the State Marine of Port Arthur Superfund Site 

(hereinafter "the Site" or "SMP A Site") in accordance with the EPA's guidance document titled, 

"Close Out Procedures for National Priorities List Sites" (OSWER Directive 9320.2-22, May 

2011). 

II. SUMMARY OF SITE CONDITIONS 

Background 

The SMPA Site (CERCLIS ID - TXD09980 11 02), a former barge-cleaning operation and 

municipal landfill, occupied a 17-acre industrial tract of land located approximately 4.5 miles 

east-northeast of the City of Port Arthur on Old Yacht Club Road on Pleasure Islet. Pleasure 

Islet is a peninsula located approximately 0.5 miles southwest of the mouth of the Neches River. 

The Site is bordered by the Palmer Barge Line Superfund Site (hereinafter "the PBL Site") to the 

north, by Old Yacht Club Road to the west, by undeveloped property to the south, and Sabine 

Lake to the east. 

Pleasure Islet is a manmade landmass consisting of dredge spoils generated during the 

construction and maintenance of the Sabine-Neches canal, also called the Intracoastal Waterway. 

The canal was constructed between 1898 and approximately 1920 in the vicinity of Sabine Lake 

and the Neches River, between the current Site location and the mainland. Between 1955 and 

1957, a portion of the canal along the western side of Pleasure Islet was abandoned, and a new 

canal was cut along the eastern and southern sides of Pleasure Islet. Pleasure Islet was created 

when a land bridge was constructed across the abandoned portions of the canal, between the 

northern tip of Pleasure Island and the mainland. Vehicle access to the Site is limited to a single 

dirt road starting at the western Site border along Old Yacht Club Road. 

Ownership of Pleasure Islet was transferred from the State of Texas to the City of Port 

Arthur, Texas, in 1955. Development of the islet and the Site began after 1957, following 

construction of the land bridge across the abandoned portions of the Sabine-Neches Canal. In 

approximately 1963, the City of Port Arthur began municipal landfill operations in the northern 

and central portions of the islet. Initially, the landfill consisted of a bum pit in whichwastes 
were incinerated. By December 1969, bum operations were discontinued, and the landfill was 

used solely for disposal of wastes. Between 1969 and 1972, landfill disposal operations 

expanded to include the central and northern portions of the Site and the property north of the 

Site. Between 1972 and 1974, disposal activities were generally concentrated in the northern 

partsofthe islet. In December 1974, the City of Port Arthur closed the landfill in accordance 

with Texas Department of Health regulations, which required covering the entire landfill with 

approximately two feet of fine-grained fill material. The cover material is believed to be dredge 

spoils that originated on the islet. Site operations began about 1973 under the names of State 

Welding and Marine Works and the Golden Triangle Shipyard. The construction of wastewater 

impoundments in the northwestern portion of the Site was also reported. The impoundments 

were reportedly unlined earthen dike areas approximately two acres in size used to store oil and 

wastewater from barge-cleaning operations. Inspection reports indicate that wastewater from the 

barge-cleaning operations was directed to two aboveground storage tanks and then pumped to the 

wastewater impoundments. Some of the oil from the tanks was diverted to an old ship, docked 

. on the land, that was used as an oil/water separator. Oil from the separator was collected for 

reuse, potentially on the Site. The Site is currently being operated by the owner as an industrial 

property for metal scrapping activities. 

Site History 

In 1995, the Texas Natural Resource Conservation Commission (TNRCC), now the 

TCEQ, initiated an Expanded Site Inspection (ESI) at the Site. The objective of the TNRCC's 

ESI was to collect sufficient data to develop an understanding of the Site contaminants and to 

identify the potential migration pathways, primary contaminant sources, exposure pathways, and 

the presence of potential human health and ecological receptors. 

Other investigations adjacent to the Site included a Preliminary Assessment (PA), a 

Screening Site Inspection (SSI), and an ESI that were conducted immediately adjacent to the Site 

at the PBL Site. The PBL Site is located on Pleasure Islet immediately north of the Site. These 

investigations did not involve collecting soil, sediment, or ground water directly from the Site; 

however, some sediment data obtained from the PBL Site at near-shore and offshore locations 

were used in the human health and ecological screening risk assessments for the Site. 

The EPA -determined that the Site warranted further investigation to assess the nature and 

extentofthe human health and environmental risks associated with the Site's previous bargecleaning and landfill activities. The investigations of the Site included the locations ofthe former 

wastewater impoundments, wastewater treatment facility, tar bum area, above ground storage 

tank area, maintenance shed area, Lauren Refining Company tank farm area, non-source areas of 

the Site, ground water, and the sediments of Sabine Lake. 

The EPA published a proposed rule on March 6, 1998 (63 FR 11340), to add the Site to 

the National Priorities List (NPL). The Site was added to the NPL in a final rule published on 

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July 28,1998 (63 FR40182). The surface water migration pathway was scored as part of the 

Hazard Ranking System Documentation Record. 

History of CERCLA Enforcement Activities 

On October 29, 1998, the EPA issued Special Notice Letters to potentially responsible 

parties (PRP) requiring them to conduct the Remedial Investigation and Feasibility Study 

(RIfFS). In February 1999, the EPA issued 104(e) Information Request letters to the PRPs 

regarding the Site. The EPA did not receive positive responses to these letters and began a fundlead RIlFS. 

Removal Actions Performed and Cleanup Activities 

In 2001, a Remedial Investigation was conducted at the Site to determine the nature and 

extent of contamination present at the Site. The EPA completed a Time Critical Removal Action 

in August 2001 (USACE 2001) to remove source materials stored on-site. Activities included 

the removal and off-site disposal of waste materials, water treatment, oil/water separation, and 

stabilization .and off-site disposal of sludge materials. This Removal Action addressed the 

materials that posed a risk to human imd ecological receptors. 

Twenty~two (22) aboveground storage tanks (ASTs) of varying sizes, several oil pits, 27 

drums, and debris materials scattered throughout the Site were identified during the Removal 

Action. Materials removed and disposed off-site included 26,000 gallons of waste oil, water, 

diesel fuel, and kerosene; 3,800 gallons of heavy sludge; 27 drums; 28 compressed gas cylinders; 

and 14 batteries. After disposing of liquids and sludge materials from the ASTs, the tanks were 

decontaminated utilizing a degreaser solution and a pressure washer. The decontamination rinse 

water was disposed off-site. 

Remedial Investigation and Supplemental Remedial Investigation 

In May and June 2006, the EPA conducted a Supplemental Remedial Investigation to 

determine if the former surface impoundments were a continuing source of contamination to the 

Sabine Lake sediments by movement through the shallow ground water. The objectives of the 

Remedial Investigation (RI, Weston 2003) for the Site were to: 

• To determine the nature and extent of contamination known or suspected onsite and off-site locations, and 

• To assess the potential human health and ecological risks associated with the 

Site. 

The objectives of the Supplemental Remedial Investigation (SRI, CH2M 2006) for the 

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Site were to: 

• Collect and analyze sediment samples to determine if contaminants in Sabine 

Lake sediments posed an unacceptable risk to benthic organisms. 

• Collect and analyze subsurface soil samples from the wastewater 

impoundment area to determine if contaminants in the impoundment soil 

could serve as a potential source of contamination to the ground water and 

eventually to benthic organisms in the sediments of Sabine Lake. 

• Collect and analyze subsurface soil samples from the wastewater 

impoundment area to determine if contaminants in the impoundment soil 

posed 'an unacceptable risk to future onsite construction workers. 

• Install and develop monitoring wells at two of the soil boring locations in the 

wastewater impoundment area for associated ground water sampling. 

• Collect and analyze ground water samples to determine if Site ground water 

was a current or potentially future source of contamination to benthic 

organisms in Sabine Lake. 

• Store, analyze, and properly dispose of any investigation-derived waste that 

was produced during field activities in support ofthe SRI. 

The RI scope of work focused on collecting additional information not obtained during 

previous investigations. The 200 I RI investigation consisted of two sampling events. The first 

sampling event consisted of collecting sediment samples from off-site locations inSabine Lake. 

The second sampling event consisted of collecting soil and ground water samples from on-site 

locations. The following tasks were completed during the RI: 

• Completion of five shallow and six deep borings ranging in depths from 4.0 to 

9.0 and 25.0 to 60.0 feet below the ground's surface (bgs), respectively. 

• Installation of six ground water monitoring wells. 

• Collection of surface soil samples from 87 locations ranging in depth from 0.0 

to 6.0 inches bgs. 

• Collection of intertidal samples from nine locations ranging in depth from 0.0 

to 6.0 inches bgs. 

• Collection of sediment samples from 46 locations ranging in depth from 0.0 to 

6.0 feet bgs. 

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The RI analytical results were compared to commercial/industrial protective 

concentration levels (PCLs) established by the Texas Risk Reduction Program (TRRP), and 

where appropriate, to background levels for the Site's contaminants of concern (COCs). 

The most frequently detected COCs for all sediment samples collected were metals 

including arsenic, lead, and mercury. For intertidal sediments, six metals (antimony, arsenic, 

cadmium, lead, mercury, and selenium) and one semi-volatile organic compound (SVOC, 

pentachlorophenol) exceeded their respective PCLs, the default cleanup standards under TRRP. 

Constituents that exceeded PCLs for nearshore sediments included six metals (arsenic, barium, 

beryllium, cadmium, lead, and mercury) and one SVOC (3,3 dichlorobenzidine). Only arsenic, 

lead, and mercury exceeded PCLs for off-shore sediments. 

The most frequently detected COCs for soils were metals including antimony, arsenic, 

barium, lead, mercury, and silver. These metals consistently exceeded the GwSoil PCL (Exposure 

pathway: i.e., the soil-to-ground water leaching of COCs to ground water). Based on the 

distribution of these constituents, their occurrenc.e is most likely a result of the former 

incineration and landfill operations. In general, the metals were widely distributed across the Site 

and not limited to the Site's source areas. 

Isolated detections of the SVOCs (benzo[a]pyrene, benzo[a]anthracene, 

benzol a ]fluoranthene, and pentachlorophenol) were reported at relatively low concentrations for 

on-site soils. Because the SVOC exceedances were only detected at isolated locations, impact 

from operations on the Site appeared minimal. 

Nine constituents including eight metals (antimony, arsenic, barium, beryllium, lead, 

manganese, silver, and thallium) and one SVOC (pentachlorophenol) exceeded GwSoilrng PCLs 

(Exposure pathway: soil-to-ground water leaching COCs to ground water). Based on a 

preliminary comparison of ground water analytical results to Class 3 ground water criteria, no 

constituents exceeded Class 3 ground water PCLs and it is unrealistic to assume any beneficial 

use of the shallow ground water. The State of Texas defines ground water resources based Qn 

water quality and sustainable well yield. A Class 3 ground water-bearing unit is not capable of 

producing greater than a 150 gallon/day ground water flow with a Total Dissolved Solids content 

less than 10,000 milligramslliter. 

The SRI included an investigation of the former wastewater impoundments to determine 

if waste materials were still present that could be a source of contamination to the Sabine Lake 

sediments. Soil samples were analyzed for metals and SVOCs. The SRI also included the 

installation of groimd water monitoring wells downgradient of the former wastewater 

impoundments and the collection of sediments samples from Sabine Lake. These samples were 

also analyzed for metals and SVOCs. 

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The screening level ecological risk assessment indicates that selenium concentrations in 

the Site sediments from the SRI may pose a risk to benthic invertebrates; however, the selenium 

concentrations are within one order of magnitude of the primary effects screening level. 

Furthermore, results from the soils and ground water data do not indicate that a selenium 

pathway exists from the Site to the sediments as the potential source of selenium contamination. 

Therefore, the EPA has determined that no Remedial Action is warranted for the Site soils to 

prevent contamination of the Site sediments. Based on selenium concentrations in the sedirpents, 

no Remedial Action is warranted for the Site sediments to protect ecological receptors. 

Record of Decision Findings 

The EPA's Record of Decision (ROD, EPA 2007) was signed on April 27, 2007. Based 

on the results of the Baseline Human Health Risk Assessment (BHHRA, CH2M 2005b), 

Screening Level Ecological Risk Assessment (SLERA, CH2M 2005c), and the EPA's Time 

Critical Removal Action, the EPA's Selected Remedy identified in the ROD for the SMP A Site 

was "No Further Action is Necessary." An institutional control (IC), in the form of a Restrictive 

Covenant, was selected to ensure that the current and future use of the Site remains for industrial 

or commercial purposes. The "No Further Action is Necessary" remedy is based on an 

industrial/commercial land use scenario. 

The Remedial Action Objectives (RAOs) achieved by the Selected Remedy for the Site 

were based on the future redevelopment of the Site for industrial/commercial land use and 

protecting future industrial/construction workers and ecological receptors. The RAOs for the 

Site were: 

• Prevent exposure to contaminated soil/sediment via ingestion, inhalation, or 

dermal contact that would result in an excess carcinogenic risk of 1.0 x 10.5 or a 

Hazard Index of 1.0. 

• Prevent exposure of contaminated soil/sediment to aquatic or terrestrial organisms 

via direct contact or indirect ingestion of bioaccumulative chemicals that would 

result in a Hazard Quotient of 1.0. 

• Prevent or minimize migration of soil contaminants to ground water. 

• Prevent or minimize further migration of soil and sediment contaminants to 

surface water that could result in exceedance of ambient water quality criteria. 

The EPA has obtained an IC (i.e., Restrictive Covenant) from the landowner, which was filed on 

March 25, 2011, in the appropriate property records for the Site, indicating that the future use of 

the property is restricted to commercial/industrial purposes. 

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III. MONITORING RESULTS 

The cleanup goals, accomplished by the 2001 Time Critical Removal Action, included 

the removal, treatment, and off-site disposal of the liquids and sludges in the ASTs and drums. 

There were no cleanup goals selected in the "No Further Action is Necessary" ROD. Based on 

the results of the BHHRA, SLERA, and the EPA's Time Critical Removal Action, the EPA's 

Selected Remedy identified in the ROD for the SMPA Site of "No Further Action is Necessary" 

is protective of human health and the enviroument. The cleanup goals, accomplished by the 

2001 Time Critical Removal Action, included the removal, treatment, and off-site disposal of the 

liquids and sludges in the ASTs and drums. This Removal Action addressed the materials that 

posed a risk to human and ecological receptors. 

IV. SUMMARY OF OPERATION AND MAINTENANCE REQUIRED 

Operation and Maintenance activities include monitoring effectiveness of the recorded 

restrictive covenant. In addition, as a part of the Five-Year Reviews required for the Site, 

sediment sampling and monitoring will be considered in Sabine Lake adjacent to the Site to 

ensure that the "No Further Action is Necessary" remedy remains protective of ecological 

receptors. 

V. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND 

QUALITY CONTROL 

The U.S. Corps of Engineers (USACE), through the EPA's removal program, 

implemented the Removal Action for the Site. Roy F. Weston, USACE's contractor, conducted 

the field construction activities at the Site. 

The EPA's On-Scene Coordinator and USACE conducted field oversight throughout the 

Removal Action activities to ensure that the Removal Action met quality assurance and quality 

control guidelines consistent with the Action Memorandum for the Site's Removal Action. 

VI. FIVE-YEAR REVIEWS· 

Since remaining conditions at the Site will not allow for unlimited use and unrestricted 

exposure, a Five-Year Review (FYR) must be conducted no less than every five years from 

signing the "No Further Action" ROD to ensure that the remedy is, or will continue to be, 

protective of human health and the environment. The effectiveness of the recorded IC will be part 

of the FYR to ensure that future Site development is consistent with the industrial cleanup 

standards for which the remedy is based and that conditions remain protective of human health 

and the environment. As part of the FYR, sediment sampling and monitoring will.be considered 

in Sabine Lake adjacent to the Site to ensure that the remedy remains protective of ecological 

receptors. The EPA will conduct the first statutory FYRbefore April IS, 2012. 

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VII. . SITE COMPLETION CRITERIA 

Based on the results of EPA's Time Critical Removal Action, BHHRA and SLERA, the 

EPA selected a "No Further Action" ROD with institutional controls. The implemented 

restrictive covenant ensures future land use will remain commercial/industrial. Therefore, no 

further Superfund response is needed to protect human health and the environment. 

Samuel Coleman, P.E., Director 

Superfund Division 

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Date 
VIII. BIBLIOGRAPHY 

CH2M IDLL (CH2M). 2005a. 

Focused Feasibility Study, State Marine of Port Arthur Superfund Site. July. 

CH2M. 2005b. 

Human Health Risk Assessment, State Marine of Port Arthur Superfund Site. July. 

CH2M. 2005c. 

Screening Level Ecological Risk Assessment, State Marine of Port Arthur Superfund 

Site. July. . 

CH2M.2006. 

Supplemental Remedial Investigation, State Marine of Port Arthur Superfund Site. 

October. 

United States Army Corps of Engineers (USACE). 2001. 

Removal Action Report. State Marine of Port Arthur Superfund Site. February. 

United States Environmental Protection Agency (EPA). 2005. 

Proposed Plan. State Marine of Port Arthur Superfund Site. July. 

EPA. 2007. 

Record of Decision. State Marine of Port Arthur Superfund Site. April. 

Weston Solutions, Inc. (Weston). 2003. 

Remedial Investigation Report. State Marine of Port Arthur Superfund Site. April. 

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