UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 6

1445 ROSS AVENUE, SUITE 1200

DALLAS, TX 75202-2733

May 8, 2000

MEMORANDUM

SUBJECT:

FROM:

TO:

THRU:

Request for a Removal Action at the Palmer Barge Line Superfund Site, City of Port

Arthur in Jefferson County, Texas

Lon Biasco, On-Scene Cooi

Response & Prevention B

Myron O. Knudson, P.E., Director

Superfund Division (6SF)

Charles A. Gazda, Chief (__

Response & Prevention Branch (6SF-R)

I. PURPOSE

This memorandum requests approval for a Time Critical Removal Action pursuant to the

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended, 42

U.S.C. §9601 etseq.. at the Palmer Barge Line Superfund Site ("Site") located approximately 4.5 miles

east - northeast of the City of Port Arthur in Jefferson County, Texas. The proposed action involves Site

stabilization with the subsequent removal and off-site disposal of hazardous substances, pollutants, and

contaminants that are present in numerous tanks, containers, and drums present upon the property.

This action meets the criteria for initiating a removal action under the National Contingency Plan

(NCP), 40 C.F.R. §300.415. This action is expected to require less than twelve months-and$2.million to

complete.

144453 Page 1 of 9

00070 1

Internet Address (URL) • http://www.epa.gov

Recycled/Recyclable . Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)

000701
II. SITE CONDITIONS AND BACKGROUND

CERCLIS#: TXD068104561

Category: Time Critical

Site ID #: BK

A. Site Description

I. Removal site evaluation

The Palmer Barge Site began operations sometime in 1981 and continued until the middle of

1997. The Palmer site operated under two permit exemptions: permit exemption X-3226 and X-3346.

According to permit exemption X-3226, issued on 7 January 1982, the following products were stored

within the 12-tank AST battery: fuel oil, gasoline, naphtha, and toluene. Primary operations conducted at

the Palmer site included cleaning, degassing, and maintenance and inspection of barges and other marine

equipment. Typical cleaning operations, also referred to as stripping, included the removal of sludge,

liquid (heels), and all other residual constituents. This cleaning was accomplished by pressure steaming

the vessel holds, engines, and boilers. Waste materials generated from these operations have remained

onsite in various structures.

Structures remaining at the site include various-sized steel above ground storage tanks (ASTs),

several open-top slop tanks, roll-off boxes, and 12 55-gallon drums. Free standing oily liquids and

stained soils have also been observed at the site. These containers are detailed below.

Several investigations have been conducted by the Texas Natural Resource Conservation

Commission (TNRCC) and the EPA since 1998: Preliminary Assessment (PA)/Screening Site Inspection

(SSI), Expanded Site Inspection (ESI),and a Removal Assessment. Analysis of samples taken during

these investigations has detected numerous contaminants. Site-related contaminants of concern include

volatile organic compounds, semi volatile organic compounds, polychlorinated biphenyls, pesticides, and

metals. Laboratory analytical results for sediment samples obtained from Sabine Lake confirmed that

site-attributable contamination was present in Sabine Lake. Sabine Lake is considered a fishery and used

for contact and recreational uses. An estimated total volume of 546,000 gallons exist in the containers

and drums on site.

Tanks, drums, and containers contain numerous hazardous substances. No maintenance program

exists to inspect and maintain the storage containers. Due to the type, location, and capacity of the

facility, the facility is required under Federal law (As per 40 C.F.R. § 112 and Section 311(J) of Clean

Water Act (CWA)) as amended by Oil Pollution Act (OPA) to have a Spill Prevention, Control, and

Countermeasure (SPCC) plan as well as a Federal Response Plan (FRP). These plans detail the

appropriate management plan of the facility and how the facility would respond to a worst case

discharge. An SPCC and FRP plan are the first steps in providing information regarding the ability to

mitigate a worst case discharge. The lack of operational maintenance of the storage containers,

accompanied by the recent fire and the inability of the owner to address or mitigate a release should it

occur, poses a substantial endangerment to human health and the environment.

Page 2 of 9

00070 2

000702
Recently, a fire occurred at the adjacent State Marine Superfund site. The current owner of

Palmer Barge Line is also the owner of the State Marine site. The fire caused the evacuation of a nearby

business. Furthermore, since the site is a Superfund site, the fire department had additional concerns

regarding fire suppression. Fire suppression efforts were delayed until a Federal On-Scene Coordinator

from Dallas could assist the fire department with air monitoring.

2. Physical location

The Palmer Barge Line site is the location of a facility that serviced and maintained barges and

other vessels. The site is currently inactive. The site is located approximately 4.5 miles east - northeast

of the City of Port Arthur in Jefferson County, Texas. The site encompasses approximately 17 acres and

is located on Old Yacht Club Road on the Southeast Industrial Inlet. The site is bounded to the north by

vacant property, to the east by Sabine Lake, to the south by the State Marine Superfund site, and to the

west by Old Yacht Club Road. Drainage from the site empties directly into Sabine Lake. The site is

situated approximately 0.5 mile southwest of the point where the Neches River enters the Sabine-Neches

Canal.

The EPA Region 6 Environmental Justice Computer Model was run for this Site. Within a one

mile radius of the Site, the percent minority is 0% and the percent economically stressed is 0%. Within a

50 mile radius of the Site, the percent minority is 22.8% and the percent economically stressed is 26.8%.

In comparison, the State of Texas percent minority is 39.4% and the percent economically stressed is

27.6%.

3. Site characteristics

The site encompasses 17 acres adjacent to the Sabine-Neches Canal in an industrial development.

The site has a 6 foot chain link fence around portions of the site. The fence is missing large sections and

does not prevent access.

Structures at the site include 23 various-sized steel above ground storage tanks (ASTs), several

open-top slop tanks, roll-off boxes, and 12 55-gallon drums. Free standing oily liquids and stained soils

are present at the site.

Four ASTs are located in the northeastern portion of the site. The four ASTs, one estimated at

425,000-gallon capacity and three 50,000-gallon capacity tanks, are constructed of steel and surrounded

by a poorly constructed earthen berm. These four ASTs were used for bulk waste storage during barge

cleaning operations at the site. The four ASTs are rusting near the base. One foot of oily liquid was

observed inside the berm during a site visit. Due to over 50 inches/year on average of rainfall in the

area, berms containing product could overflow and release into the lake.

Four ASTs are located adjacent to the boiler house in the southwestern portion of the property.

The estimated average capacity of each of these ASTs is 7,000 gallons and the ASTs are reportedly full

of liquid. The ASTs are located directly on the ground and no containment features are associated with

these ASTs.

Three horizontal ASTs are located near the southeast corner of the site. The estimated capacity

of the three tanks is 10,000-gallons each. This area does have a concrete berm for secondary

Page 3 of 9

00070 3

000703
containment; however, the berm could not hold the contents of all the tanks during a failure. These tanks

are in poor condition and have leaked/released a significant amount of contents into the containment

area.

Twelve ASTs are located in the eastern portion of the site. All of the ASTs are identical in size

(estimated capacity is 8,800 gallons each) and shape and are surrounded by a concrete berm measuring

approximately 95 feet by 30 feet by 1 foot high. There are numerous pipes and valves connecting the

tanks which were used in the liquid transfer and separation activities. A current owner alleges that

subsurface pipes were used to empty tank contents into Sabine Lake. Portions of this piping network

have been verified to lead into the lake. Additional areas include miscellaneous 55-gallon drums,

compressed gas cylinders, paint cans and 5-gallon buckets, and areas of contaminated soils. Soil areas

have been contaminated from leaking tanks and past operator error.

4. Releases or threatened release into the environment of a hazardous substance, pollutant or

contaminant

Investigations at the site have determined that various hazardous substances are present at the

site. Toxic constituents include barium, lead, benzene, ammonia, hexane and chromium. Numerous

tanks, drums, and containers are of poor integrity. Several spills and releases have been documented.

Approximately 546,000 gallons of bulk waste materials remain on-site. These materials are hazardous

substances as defined in Section 101(14) of CERCLA, 42 U.S.C. §9601(14), and 40 CFR §302.4.

The advanced deterioration of tanks, drums, and containers and the unattended storage of

hazardous materials upon the property, pose a potential and continuous threat of release of hazardous

substances into the environment.

5. NPL status

This Site is not presently on the National Priorities List (NPL). However, should the Site be

placed on the NPL, the proposed removal actions are consistent with any remedial cleanup that might be

taken, due to the fact that the proposed actions constitute site access and source control and removal

measures.

6. Maps, Pictures and other graphic representations

Attachment 1 - Enforcement Addendum (Confidential).

Attachment 2 - TNRCC Site referral letter.

Attachment 3 - Site map.

B. Other Actions to Date

1. Previous actions

There has not been an EPA removal action conducted at the Site. The EPA and TNRCC have

conducted several investigations at the facility during the last several years.

2. Current Actions

There are no current response actions taking place at the Site.

Page 4 of 9

00070 4

000704
C. State and Local Authorities' Roles

1. State and local actions to date

The TNRCC has conducted several inspections at the Site since 1996. The local fire department

recently fought a fire at the adjacent State Marine Superfund site.

2. Potential for continued State/local response

The TNRCC referred the Site to the EPA for removal action cleanup because existing state

resources would not facilitate a timely response action.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND

STATUTORY AND REGULATORY AUTHORITIES

A. Threats to Public Health or Welfare

The conditions at the Site meet the following factors that indicate the Site is a threat to the public

health, welfare and the environment and that a removal action is appropriate under Section 300.415(b)(2)

of the National Contingency Plan, 40 C.F.R. § 300.41 5(b)(2). Any or all of these factors may be present

at a Site, yet any one of these factors may determine the appropriateness of a removal action.

1. Exposure to Human Populations, Animals or the Food Chain, NCP Section 300.415

There is potential for human exposure to arsenic, benzene, chromium, xylene, lead, corrosives,

reactives, ignitables, and a number of other known and unknown chemical hazards from this Site. Leaks

from tanks and containers are documented and the potential for further releases into the environment is

likely. The Sabine is a documented fishery with an estimated 300,000 Ibs of commercial fish harvested

every year. Fishery catches include 10,000 Ibs of shrimp, 266,000 Ibs of Blue crab, 2,000 Ibs of flounder

and 8,000 Ibs of other commercial fish. A release from the site to the fishery would directly impact the

human food chain.

2. Contamination of Drinking Water Supplies or Sensitive Ecosystems, NCP Section

300.415 (b)(2)(ii)

Hazardous substances leaking from several containers, including drums and large storage tanks; -

have contaminated the soils around the Site and migration during rainfall will impact sensitive

ecosystems/environments surrounding the site. There are subsurface pipe networks for discharging waste

directly into Sabine Lake. As described above, Sabine Lake is a documented fishery and is used for

recreational purposes. In addition, the area has several federally listed endangered species, such as: Bald

Eagle, Black Rail, and American Swallow Tail Kite. Several bird rookeries exist within a mile of the

site. Fifteen miles of listed wetlands surround the site.

-v.

3. Hazardous Substance in Drums or Tanks, NCP Section 300.415 (b)(2)(iii)

There are 23 aboveground storage tanks with an estimate 546,000 gallons of aggregate waste

containing various hazardous substances at the Site. These tanks are in varying stages of deterioration

and many have shown evidence of releasing contents into the environment.

Page5of9

 00070 5

000705
4. Contaminants in Soils, NCP Section 300.415 (b)(2)(iv)

Due to deteriorating containers, leaking materials from drums and tanks have been discharged

onto surrounding soils. Site soils on the property contain elevated concentrations of volatile organic

compounds, semivolatile organic compounds, polychlorinated biphenyls, pesticides, and metals.

5. Weather Conditions That May Cause the Release or Migration of Hazardous Substances,

NCP Section 300.415 (b)(2)(v)

The area is subject to several types of extreme weather conditions which could cause the further

release of hazardous substances. Thunderstorms and heavy rain will entrain material which has leaked

and spilled from containers around the property and transport them off-site. The area is prone to

hurricanes which could cause a catastrophic release of all contents of the tanks.

6. Threat of Fire or Explosion, NCP Section 300.415 (b)(2)(vi)

Because of the ignitable hazardous constituents present on-site and the recent fire at the

adjoining site there is a continued potential threat of fire and explosion at the Site. A fire at the Site has

the potential to release organic vapors to the atmosphere and may require the evacuation of nearby

facilities.

7. Availability of Other Mechanisms, NCP Section 300.415 (b)(2)(vii)

The TNRCC has requested EPA removal action assistance at the Site. Due to the site

characteristics, future listing of the site on the Superfund NPL would not address the site in a timely

fashion to prevent a potential release to the environment.

B. Threats to the Environment

The Site is located adjacent to Sabine Lake. The Site poses a potential threat to the environment

due to possible hazardous substances migrating into the lake that is a fishery and contains sensitive

environments.

IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances, pollutants, or contaminants from this Site,

if not addressed by implementing the response action selected in this Action Memorandum, presents an

imminent and substantial endangerment to the public health, welfare, or the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Proposed action description

As discussed below, all of the actions to be taken at the Site during this removal will comply

with all applicable or relevant and appropriate requirements (ARARs) to the extent practicable,

considering the exigencies of the situation, and provide an effective mitigation of the imminent and

substantial threats posed to the public health and the environment.

Page6of9 00070 6

000706
The proposed action involves the removal, transportation, and off-site disposal of all hazardous

substances, pollutants, and contaminants located on the Site. The removal action will be conducted in

two phases. Phase one is a time critical action to secure Site access and stabilize leaking containers and

tanks on-site and complete the waste characterization. A fence will be built to control access and the site

will be cleared and grubbed.

Phase two action will be the transportation and off-site disposal of the containerized and secured

materials. No materials will be stored, by the EPA, on site for greater than 90 days; therefore, RCRA

262.34 is not applicable. Disposal options will be evaluated following material sampling and disposal

profiling. Such profiles will then be sent to the appropriate RCRA Subtitle C or Subtitle D waste

treatment, storage, and disposal facilities. Site structures, tanks, and process equipment which pose a

hazard will be dismantled, decontaminated, and removed off-site.

All hazardous substances, pollutants, or contaminants removed off-site pursuant to this action for

treatment, storage, or disposal shall be treated, stored, or disposed of, at a facility in compliance, as

determined by the EPA, with CERCLA Section 121(d)(3), 42 U.S.C. § 9621(d)(3), and the following

rule: "Amendment to the National Oil and Hazardous Substances Pollution Contingency Plan;

Procedures for Planning and Implementing Off-Site Response Action: Final Rule." 58 FR 49200

(September 22, 1993), and codified at 40 C.F.R. § 300.440. RCRA empty containers will be disposed

off-site, as appropriate.

All materials to be sent off-site for disposal will be packaged and labeled in accordance with

RCRA requirements found at 40 C.F.R. §§ 262.30-32 and will be properly manifested in accordance with

the requirements set out at 40 C.F.R. §§ 262.20-23. All transportation will be in accordance with

Department of Transportation (DOT) rules and regulations. See generally, 40 C.F.R. § 263.

Off-site RCRA disposal of hazardous substances at the Site is the most effective action to take

for mitigating threats posed by the Site. Chemical hazards identified and potential exposure pathways

documented support this rationale. Site stabilization without ultimate off-site disposition of

contaminants is a temporary remedy which is not protective of public health and the environment. The

proposed time critical removal action will provide protection of public health in a timely, feasible, and

appropriate manner.

2. Contribution to remedial performance

The proposed action will contribute to any remedial action necessary at the site since it will

provide source of contamination. This is consistent with any potential remedial action that may be

proposed for the Site.

3. Description of alternative technologies

There are no alternative technologies which could be feasibly applied at the Site.

4. Applicable or relevant and appropriate requirements

This removal action will be conducted to eliminate the actual or potential release of a hazardous

substance, pollutant, or contaminant to the environment, pursuant to CERCLA, 42 U.S.C. § 9601 et seq..

and in a manner consistent with the NCP, 40 C.F.R. Part 300, as required at 33 U.S.C. § 1321(c)(2) and

42 U.S.C. § 9605. As per 40 C.F.R. § 300.415(i), Fund-financed removal actions pursuant to CERCLA

Section 104, 42 U.S.C. § 9604, and removal actions pursuant to CERCLA Section 106, 42 U.S.C. § 9606,

Page 7 of 9

00070 7

000707
shall, to the extent practicable considering the exigencies of the situation, attain the applicable or relevant

and appropriate requirements under Federal environmental law.

Due to the fact that consolidation and off-site disposal are the principal elements^of this removal

action, RCRA waste analysis requirements found at 40 C.F.R. §§ 261.20 and 261.30, RCRA manifesting

requirements found at 40 C.F.R. § 262.20, and RCRA packaging and labeling requirements found at 40

C.F.R. § 262.30 are deemed to be relevant and appropriate requirements for this removal action.

5. Project schedule

The initial time critical phase one action will secure Site access, stabilize leaking containers and

tanks, test material profiles, and prepare for off-site transportation and disposal of Site chemicals. Phase

one action is expected to require approximately six weeks. All hazardous substances, pollutants, or

contaminants will be properly manifested and transported to the appropriate disposal facilities as a phase

two action. The entire duration of the project is expected to be approximately six months from initial

Site mobilization.

B. Estimated Costs

Extramural Costs

USAGE $1,200,000

START $ 55,000

Subtotal, Extramural Costs $ 1,255,000

Extramural Costs Contingency

(20%) $ 251,000

TOTAL, EXTRAMURAL COSTS $ 1,506,000

Intramural Costs

EPA Direct Costs $ 30,000

EPA Indirect Costs $ 48,000

TOTAL, INTRAMURAL COSTS $ 78,000

TOTAL, REMOVAL PROJECT CEILING $ 1,584,000

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT

TAKEN

If immediate action is not taken at the Site, the tanks and storage structures will continue to

deteriorate, posing a threat to Sabine Lake's sensitive ecosystem as well as human exposure to nearby

workers from a release of hazardous substances, pollutants, or contaminants.

Page8of9

 00070 8

000708
VII. OUTSTANDING POLICY ISSUES

There are no outstanding policy issues associated with this Site.

VIII. ENFORCEMENT

See Attachment 1.

IX. RECOMMENDATION

This decision document represents the selected removal action for the Palmer Barge Line

Superfund Site, City of Port Arthur in Jefferson County, Texas, developed in accordance with CERCLA,

as amended, and is not inconsistent with the NCP. This decision is based on the administrative record for

the Site.

Conditions at the Site meet the criteria as defined by 40 C.F.R. § 300.415(b)(2) of the NCP for a

removal, and I recommend your approval of the proposed removal action. The total project ceiling, if

approved, will be approximately $1,584,000. Of this, an estimated $1,506,000 comes from the Regional

removal allowance.

APPROVED Signed by Myron 0. Knudson.

Attachments (3)

Page9of9 00070 9

000709
FIGURE 2-2

PALMER BARGE LINE SITE

US EPA REGION 6

CERCLA ID NO. TXD068104561

SITE AREA MAP

EXPANDED SITE INSPECTION

AQTLJI m iITt~rrrrnc-r\k.i rrii IIIIT\/ Trv/A

0007