FINAL

FEASIBILITY STUDY

PALMER BARGE LINE SUPERFUND

SITE

PORT ARTHUR, TEXAS

July 2005 Project No. 37679261

URS Corporation

140 Cypress Station Drive, Suite 140

Houston, Texas 77090

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TABLE OF CONTENTS

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Section Executive Summary.................................................................................................... ES-1

1.0 Introduction....................................................................................................................1-1

1.1 Site Description....................................................................................... 1-1

1.2 Site History ............................................................................................. 1-1

1.3 Areas of Concern .................................................................................... 1-2

1.4 Summary of Previous Investigations and Activities................................ 1-3

1.5 Risk Assessment Findings....................................................................... 1-4

1.5.1 Baseline Human Health Risk Assessment................................... 1-4

1.5.2 Screening Ecological Risk Assessment....................................... 1-5

2.0 Remedial Action Objectives..........................................................................................2-1

2.1 Applicable or Relevant and Appropriate Requirements (ARARs).......... 2-1

3.0 General Response Actions ...........................................................................................3-1

3.1 No Action................................................................................................ 3-1

3.2 Institutional Controls............................................................................... 3-1

3.3 Containment............................................................................................ 3-1

3.4 Collection................................................................................................ 3-2

3.5 Treatment ................................................................................................ 3-2

3.6 Disposal................................................................................................... 3-2

3.7 Description of BLRA Response Areas.................................................... 3-2

3.8 Description of SLERA Response Areas.................................................. 3-3

3.9 Approximate Volume Requiring Remedial Action ................................. 3-5

4.0 Identified Remedial Technologies and Screening.......................................................4-1

4.1 No Action................................................................................................ 4-1

4.2 Institutional Controls............................................................................... 4-1

4.3 Containment............................................................................................ 4-1

4.3.1 Caps............................................................................................. 4-1

4.3.2 Vertical Barriers.......................................................................... 4-2

4.4 Excavation............................................................................................... 4-2

4.5 Treatment ................................................................................................ 4-3

4.5.1 Fixation/Immobilization.............................................................. 4-3

4.5.2 Chemical Oxidation..................................................................... 4-3

4.6 Disposal................................................................................................... 4-4

4.6.1 On-Site ........................................................................................ 4-4

4.6.2 Off-Site........................................................................................ 4-4

5.0 Evaluation of Process Options.....................................................................................5-1

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5.1 No Action................................................................................................ 5-1

5.2 Institutional Contols................................................................................ 5-1

5.2.1 Effectiveness............................................................................... 5-1

5.2.2 Implementability ......................................................................... 5-1

5.2.3 Cost ............................................................................................. 5-2

5.3 In-Place Soil Cover ................................................................................. 5-2

5.3.1 Effectiveness............................................................................... 5-2

5.3.2 Implementability ......................................................................... 5-2

5.3.3 Cost ............................................................................................. 5-2

5.4 Isolation Soil Cover................................................................................. 5-2

5.4.1 Effectiveness............................................................................... 5-3

5.4.2 Implementability ......................................................................... 5-3

5.4.3 Cost ............................................................................................. 5-3

5.5 Excavation............................................................................................... 5-3

5.5.1 Effectiveness............................................................................... 5-3

5.5.2 Implementability ......................................................................... 5-4

5.5.3 Cost ............................................................................................. 5-4

5.6 On-Site Disposal ..................................................................................... 5-4

5.6.1 Effectiveness............................................................................... 5-4

5.6.2 Implementability ......................................................................... 5-5

5.6.3 Cost ............................................................................................. 5-5

5.7 Off-Site Disposal..................................................................................... 5-5

5.7.1 Effectiveness............................................................................... 5-5

5.7.2 Implementability ......................................................................... 5-5

5.7.3 Cost ............................................................................................. 5-5

6.0 Alternatives Identified ...................................................................................................6-1

7.0 Screening of Alternatives..............................................................................................7-1

7.1 Common Components............................................................................. 7-1

7.2 Alternative 1 – No Action....................................................................... 7-2

7.3 Aternative 2 – ICs................................................................................... 7-2

7.3.1 Effectiveness............................................................................... 7-2

7.3.2 Implementability ......................................................................... 7-2

7.3.3 Cost ............................................................................................. 7-2

7.4 Alternative 3 – Excavation / On-site Disposal / Soil Cover / ICs............ 7-2

7.4.1 Effectiveness............................................................................... 7-3

7.4.2 Implementability ......................................................................... 7-4

7.4.3 Cost ............................................................................................. 7-4

7.5 Alternative 4 – Excavation / Off-site Disposal / ICs............................... 7-4

7.5.1 Effectiveness............................................................................... 7-5

7.5.2 Implementability ......................................................................... 7-5

7.5.3 Cost ............................................................................................. 7-5

7.6 Comparative Analysis............................................................................. 7-6

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List of Tables

Table 1-1 Soil Exceedances of Preliminary Remediation Goals (PRGs) for 10-6 to 10-4

Target Risk Levels

Table 2-1 Site Specific Constituents of Potential Concern (COPCs) and Target Cleanup

Levels

Table 3-1 Identification of Maximum Concentrations Following Implementation of Remedy

Table 3-2 Upper-end Risk Estimate Following Implementation of Remedy

Table 3-3 Detected COPC Concentrations Versus Safe Soil Levels and Summary of

Wildlife Risk – RI Dataset

Table 3-4 Detected COPC Concentrations Versus Safe Soil Levels and Summary of

Wildlife Risk – ESI Dataset

Table 7-1 Alternative 2 Cost Estimate

Table 7-2 Alternative 3 Cost Estimate

Table 7-3 Alternative 4 Cost Estimate

Table 7-4 Evaluation of Remedial Alternatives

Table 7-5 Remedial Alternative Rankings

List of Figures

Figure 1-1 Site Location Map

Figure 1-2 Location of AOCs

Figure 1-3 Conceptual Exposure Model – Human Health Risk Assessment

Figure 1-4 Conceptual Ecological Exposure Model for Terrestrial Receptors

Figure 1-5 Conceptual Ecological Exposure Model for Sabine Lake

Figure 3-1 Identified Response Areas for 10-4 Target Risk Levels

Figure 3-2 Identified Response Areas for 10-5 Target Risk Levels

Figure 3-3 Identified Response Areas – Areas of Potential Ecological Risk

Figure 7-1 Alternative 3 – Consolidation Area & Isolation Cover Detail

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Executive Summary

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EXECUTIVE SUMMARY

A Feasibility Study (FS) was completed for the Palmer Barge Line Superfund Site (Site) located

in Port Arthur, Texas. This FS was prepared on behalf of the Potentially Responsible Parties

(Ashland Inc., ChevronTexaco, DuPont, and Kirby) in accordance with an Administrative Order

of Consent to conduct the Remedial Investigation (RI/FS). In support of the RI/FS process, a

Baseline Human Health Risk Assessment (BLRA) and a Screening-Level Ecological Risk

Assessment (SLERA) were prepared to identify any existing or potential risks to human health

and the environment. The BLRA and SLERA provide the basis for the FS.

Based on the conclusions and recommendations of the BLRA and SLERA, the Remedial Action

Objectives for the Site were identified as follows:

• Prevent ingestion/inhalation or direct contact with surface soil containing elevated

concentrations of COPCs which may pose an unacceptable level of risk to human health, and

• Prevent direct contact with surface soil containing elevated concentrations of constituents of

potential concern (COPCs) which may pose an unacceptable level of risk to potential future

ecological receptors.

The BLRA identified three response areas with concentrations exceeding the 10-4 risk-based

preliminary remediation goals (PRGs) in surface soils. The SLERA screening using safe soil

concentrations for future potential ecological risk identified seven response areas. Preliminary

calculations indicate that approximately 1,061 cubic yards (yd3) of surficial soil will require

remedial action to achieve both BLRA and SLERA Remedial Action Objectives.

Several process options and technology types which could potentially apply to the Site were

evaluated based on findings from the RI, as well as on-site characteristics of facility operations.

During this step, entire process options and technology types were eliminated from further

consideration on the basis of technical implementability. Process options which were retained

were further evaluated on the basis of effectiveness, implementability, and cost. Subsequently,

process options evaluated were assembled into specific remedial alternatives for the response

areas identified. The alternatives were developed while taking into consideration site specific

conditions to ensure that an effective and implementable remedial strategy is developed. The

“No Action” alternative was retained to serve as a baseline for comparison. The alternatives

identified in this FS are as follows:

• Alternative 1 – No Action: Involves leaving the Site as is. No measures that prevent or

minimize exposure to site contaminants would be implemented;

• Alternative 2 -- Institutional Controls (ICs): Involves leaving the response areas at the Site as

they are; however, 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;

• Alternative 3 – Excavation / On-site Disposal / Isolation Soil Cover / ICs: Consists of the

excavation of impacted surface soils from each response area and relocation of the excavated

soils to a designated area on-site. The excavated soils would be consolidated and an

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Executive Summary

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isolation soil cover consisting of a geotextile and 24 inches of low permeability soil would be

placed over the consolidated soils. Proprietary institutional controls would be implemented

as part of this alternative; and

• Alternative 4 – Excavation / Off-site Disposal / ICs: Consists of the excavation of impacted

surface soils from each response area and off-site disposal of the excavated soils at a

permitted facility. Proprietary institutional controls would be implemented as part of this

alternative.

Alternatives 2 through 4 contain three common components, which include deed restrictions,

abandonment of five existing monitoring wells, and removal and off site disposal of waste

sludge materials still present in an above ground storage tank (AST). The AST will be

decontaminated and left on site for the owner to reuse as scrap metal.

The four identified alternatives were screened based on short- and long term aspects of three

broad criteria: (1) effectiveness, (2) implementability, and (3) cost. Based on the information

presented in the comparative analysis for the alternatives, the EPA will make the decision on

which alternative to select as the preferred alternative that is presented to the community. Based

on comments and input from the community during the public comment period, EPA, in

consultation with the Texas Commission on Environmental Quality (TCEQ) will make a final

selection on the remedy for the site.

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SECTION ONE Introduction

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1.0 Introduction

A Feasibility Study (FS) was completed for the Palmer Barge Line Superfund Site (Site) located

in Port Arthur, Texas. This FS was prepared on behalf of the Potentially Responsible Parties

(PRP) (Ashland Inc., ChevronTexaco, DuPont, and Kirby) in accordance with an Administrative

Order of Consent to conduct the Remedial Investigation (RI/FS). In support of the RI/FS

process, a Baseline Human Health Risk Assessment (BLRA) and a Screening-Level Ecological

Risk Assessment (SLERA) were prepared and submitted to U.S. EPA on March 4, 2005. The

purpose of the BLRA and SLERA was to identify any existing or potential risks to human health

and the environment. U.S. EPA provided comments on the BLRA and SLERA on

March 28, 2005. The PRP Group submitted responses on April 20, 2005 and May 16, 2005 and

U.S. EPA agreed to the proposed revisions. The BLRA and the SLERA were submitted as final

to U.S. EPA on June 10, 2005. The BLRA and SLERA provide the basis for this FS.

The purpose of this FS is to develop an appropriate range of remedial technologies and process

options that will be evaluated through a series of steps, with the objective of developing potential

remedial alternatives. Potential remedial alternatives are further evaluated with respect to nine

specific criteria to ultimately identify a preferred remedy for the Site. A draft FS was submitted

to U.S. EPA on June 10, 2005. U.S. EPA provided comments on the FS on June 29, 2005.

Comment responses were submitted to U.S. EPA on July 15, 2005. This revised FS, which was

prepared in accordance with the Guidance for Conducting Remedial Investigations and

Feasibility Studies under CERCLA (EPA, October 1988), incorporates changes requested by

U.S. EPA.

1.1 SITE DESCRIPTION

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

Sabine Lake, in Jefferson County, Texas. The site is located approximately 4.5 miles eastnortheast of the City of Port Arthur. A site location map is provided in Figure 1-1. The Palmer

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

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

Yacht Club Road, to the south by 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.

1.2 SITE HISTORY

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

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

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

contents are still present on the Site in the subsurface soils.

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

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

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

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

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

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

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

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

to construct marine equipment on the Site.

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

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

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

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

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

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

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

on-site to 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.

The Site was placed on the National Priorities List on July 27, 2000. 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. On

September 30, 2002, EPA Region VI issued an Administrative Order on Consent. Voluntary

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

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

1.3 AREAS OF CONCERN

As part of the ESI (Weston, 2000), a site reconnaissance was performed to identify Areas of

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

• Wastewater Aboveground Storage Tanks (ASTs);

• Boiler House ASTs;

• Open Top Slop tanks;

• Horizontal ASTs;

• 12 ASTs; and

• Flare.

Locations of these AOCs are shown in Figure 1-2. A description of each AOC is provided

below. At this time, all of the above-ground storage tanks have been removed except for a large

tank on the northern portion of the site that contains sludge. Current site operations have

resulted in demolition of these features. The majority of the facility consists of open areas

covered by grassy vegetation. Several of the concrete AST foundations remain along with gravel

throughout the Site.

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Wastewater ASTs: Four ASTs were located in the northeastern portion of the Site. The four

ASTs included one 25,000-gallon tank and three 5,000-gallon tanks. They were constructed of

steel and surrounded by an earthen berm. The tanks were used for bulk storage during barge

cleaning operations.

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

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

Three of the four boiler house ASTs were reportedly used to store diesel fuel for steam boilers

that were operated as part of the barge cleaning process. The fourth boiler house AST was used

to store fresh water. The ASTs were located on the ground surface and did not have containment

berms or dikes.

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

near the flare area. The tanks were constructed of steel and measured 8 feet by 5 feet by 4 feet.

The tanks were placed on the ground and did not have secondary containment.

Horizontal ASTs: The horizontal ASTs were located in the southeastern portion of the Site near

the Sabine Lake shoreline. The three ASTs had a capacity of 10,000 gallons each. A concrete

berm surrounded the three ASTs. The tanks were used as part of the barge cleaning and

degassing system.

Twelve ASTs: Twelve ASTs were located in the eastern portion of the Site near the shoreline of

Sabine Lake. Each tank was approximately 7,000 gallons in capacity. The tank farm is

surrounded by a concrete berm measuring 95 feet by 30 feet lateral dimension by 1 foot in

height. The tanks were likely used for liquid transfer and liquid separation activities during

cleaning operations.

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

gases produced during cleaning operations.

1.4 SUMMARY OF PREVIOUS INVESTIGATIONS AND ACTIVITIES

Previous investigations of the Site include the following:

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

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

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

determine the compliance status of the facility.

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

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

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

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

storage tanks, and stained soil near wastewater tanks. Results indicated the presence of

inorganic constituents such as metals, semi-volatile organic constituents (SVOCs), and

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pesticides in on-site soil. Metals and SVOCs were detected in offshore sediment adjacent

to the Site.

• July 1999: TNRCC Region 10 Field Office sampled aboveground storage tanks, roll offboxes and "slop" tanks to characterize materials stored.

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

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

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

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

polychlorinated biphenyls (PCBs), and metals.

• August 2000: USEPA Region VI conducted a Removal Action to remove material stored

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

sludge stabilization. Approximately 250,000 gallons of water was treated on site, 500 cubic

yards of sludge stabilized and 100,000 gallons of oil/styrene were separated and removed

from the site.

• Between the year 2000 and 2003, the Site was ranked and was placed on the National

Priority List (NPL). The Hazard Ranking concluded that constituents present in Sabine

Lake sediments adjacent to the Site were a potential threat to human health primarily via the

fish consumption exposure pathway (USEPA, 2000).

• 2003: URS Corporation (URS), on behalf of the PRPs, conducted a Remedial Investigation

(RI) at the Site in July 2003, which characterized the nature and extent of constituents

present in environmental media at the Site and in adjacent Sabine Lake surface water and

sediments (URS, 2004d). USEPA approved the RI Report in February 2005.

1.5 RISK ASSESSMENT FINDINGS

Based on data collected during previous investigations, a Baseline Human Health Risk

Assessment (BLRA) and a Screening Level Ecological Risk Assessment (SLERA) were

completed. The scope of both assessments was to provide technical documentation of the

magnitude of risk posed to receptors, both human and ecological. The purpose of the

assessments was to provide the basis for decision making with regard to the need for potential

remediation. The BLRA and the SLERA were submitted to U.S. EPA on March 4, 2005 and

finalized on June 10, 2005. A summary of the findings provided in the BLRA and SLERA is

presented in the following sections.

1.5.1 Baseline Human Health Risk Assessment

The primary sources of information used in the human health BLRA are the Expanded Site

Inspection Report (ESI) (Weston, 2000) and the Remedial Investigation Report for Palmer

Barge Line Superfund Site (URS, 2004d). The Site Conceptual Exposure Model for the risk

assessment indicates that the primary exposure scenarios of interest are on-site industrial worker

exposure to constituents present in surface soil and off-site exposure to a recreational fisherman

primarily via consumption of fish from Sabine Lake that may have accumulated site-related

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SECTION ONE Introduction

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constituents from surface water and sediment. A site conceptual exposure model for human

health is provided in Figure 1-3.

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

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

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

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

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

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

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

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

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

is slightly above the upper end of the target risk range. However, the weight of evidence

considered indicates that ultimately this result does not represent a threat to human health.

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

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

data that were not included in the baseline risk calculations would likely produce risk estimates

approximately an order of magnitude greater than the estimates developed based on the RI soil

data. Therefore, Site soil concentrations from both the historic and RI data were compared to

risk-based preliminary remediation goals (PRGs) that were developed for the range of applicable

target risk criteria (10-6 to 10-4). Table 1-1 presents a summary of Site soil data with COPCs

exceeding Medium Specific Screening Levels (MSSL) in comparison to each of the three PRG

levels.

Several surface soil sample locations with concentrations exceeding PRGs for the upper end of

the target risk range were identified as “hot spots” to be addressed in the FS. The BLRA

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.

1.5.2 Screening Ecological Risk Assessment

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

media were identified and screened against highly conservative Ecological Screening Levels

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

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

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

characterized using Hazard Quotients. Wildlife ingestion exposure pathways were evaluated for

bioaccumulative chemicals using dose modeling with the maximum concentrations and the

95%UCLs. Risks to wildlife were characterized using Hazard Quotients calculated for noobservable-adverse-effect-levels (NOAELs) and lowest-observed-adverse-effect-level (LOAEL)

endpoints. The site conceptual exposure models for on-site/off-site ecological receptors are

presented in Figures 1-4 and 1-5.

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.

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Therefore, the SLERA recommended allowing 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 this FS. A detailed discussion

of the development of potential response areas is presented in Section 3.8 of this FS.

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SECTION TWO Remedial Action Objectives

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2.0 Remedial Action Objectives

Remedial Action Objectives consist of medium-specific goals for protecting human health and

the environment. Based on the conclusions of the BLRA 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 elevated

concentrations of COPCs which may pose an unacceptable level of risk to human health;

• Prevent direct contact with surface soil containing elevated concentrations of COPCs which

may pose an unacceptable level of risk to potential future ecological receptors;

• Prevent surface runoff of site contaminants that could further accumulate in the Sabine Lake

Sediments; and

• Prevent potential future exposure to a sensitive ground feeding bird.

Since the Palmer Barge Site is currently occupied by a boat maintenance facility with

aboveground structures, there is little if any potential for subsurface excavation activities to

occur in the future. Therefore, the Remedial Action Objectives for soil will be applied only to

surficial soil that is defined spatially by the response areas identified in this FS. The depth

consideration for surficial soil exposure will be limited to areas that are not covered by existing

concrete structures and will extend only to a depth of two feet below ground surface.

Excavation to depth below two feet will encounter solid waste landfill material, which is not

considered as the Remedial Action Objectives of this FS. In addition to depth, the Remedial

Action Objectives for soil will be applied only to surficial soil that is exposed. There are several

areas on-Site that are covered by concrete pads from former ASTs or gravel roadways. The soil

beneath these areas will not be considered for remediation.

2.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)

Applicable or relevant and appropriate requirements (ARARs) for the Site include chemicalspecific ARARs. As part of the BLRA and SLERA, a list of site-specific COPCs was

developed. The list of site-specific COPCs is presented in Table 2-1. In addition, risk-based

PRGs were developed corresponding to the 10-4 target cancer risk criteria. 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, presented in Table 2-1, will be used to evaluate remedial

action performance. A detailed discussion of the development of safe soil concentrations for

addressing potential future ecological risk is presented in Section 3.8 of this FS.

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SECTION THREE General Response Actions

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3.0 General Response Actions

General response reactions describe those actions which may potentially satisfy Remedial Action

Objectives. General response actions identified for the Site include:

• No Action: consists of leaving the Site “as is” with no provisions being made for the cleanup

of contamination.

• Access Restrictions: consist of mechanisms for controlling or restricting property or

resource usage and development.

• Containment: involves the construction of physical barriers to reduce or eliminate exposure

to contamination or contaminated sources and physical restrictions on contaminant mobility.

• Collection: involves the direct physical collection of the contamination or contaminant

sources.

• Treatment: involves on-site and/or off-site measures to reduce toxicity, mobility, and/or

volume of the contaminated materials.

• Disposal: involves the physical off-site or on-site removal of the contamination or

contaminant media.

Each of these general response actions are described further in the following sections.

3.1 NO ACTION

No Action consists of leaving the Site “as is” with no provisions being made for the cleanup of

contamination. The “No Action” response is an important gauge for subjectively evaluating all

other technologies.

3.2 INSTITUTIONAL CONTROLS

Institutional controls are defined by U.S. EPA as non-engineered instruments, such as

administrative and/or legal controls that minimize the potential for human exposure to

contamination by limiting land or resource use. Although institutional controls are generally

used in conjunction with engineering controls, they can also be applied without implementation

of active remedial responses. Under these circumstances, institutional controls are considered

“limited action”, as opposed to “no action”, since it is part of the remedy selected to provide

protection to human health and the environment.

3.3 CONTAINMENT

Containment technologies involve the construction of physical barriers that reduce or eliminate

exposure pathways to surficial soil contamination or contaminated sources. Containment

response actions also place a physical restriction on contaminant mobility, both on-site and offsite. Potential containment technologies discussed in this FS include placement of soil covers

and vertical barriers.

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3.4 COLLECTION

Collection technologies involve the direct physical collection of the contamination or

contaminant sources. These remedial responses may also require treatment of the media prior to

disposal. A potential collection technology alternative discussed in this FS is soil excavation.

3.5 TREATMENT

Treatment involves on-site or off-site measures to reduce toxicity, mobility, and/or volume of the

contaminated materials. Treatment technologies that are available for implementation include

fixation/immobilization and chemical oxidation.

3.6 DISPOSAL

Disposal involves on-site or off-site remedial technologies to relocate impacted media in such a

way as to reduce their interaction with groundwater and soil at the Site.

On-site remedial technologies selected for soil disposal response actions are limited to

consolidation and replacement of surficial soils. Off-site remedial technologies selected for soil

and sludge disposal response actions are limited to transportation to a permitted landfill.

3.7 DESCRIPTION OF BLRA RESPONSE AREAS

The BLRA identified four “hot spots” exhibiting concentrations exceeding the 10-4 risk-based

PRGs. These “hot spots” consisted of four ESI soil sample locations:

• Locations ESI-003 (0 to 2 feet) and ESI-004 (2 to 4 feet), which are located immediately

south of the Wastewater ASTs;

• Location ESI-012 (0 to 2 feet), which is located in the Boiler House ASTs area; and

• Location ESI-015 (0 to 2 feet), which is located in the Open Top Slop Tanks area.

The BLRA identified potential risk to human health due to polycyclic aromatic hydrocarbons

(PAHs) in soil at the 2 to 4-foot interval at location ESI-004. As municipal waste is encountered

beneath the upper 2 feet of soil, remedial activities will not extend to the 2 to 4-foot interval to

prevent exposure of this waste. However, remedial alternatives identified will incorporate

institutional controls to ensure that exposure to the 2 to 4-foot interval does not occur in the

future. In addition, a conservative upper end assessment of cumulative “residual” risk to human

health following implementation of the proposed remedy for these locations is presented on

Tables 3-1 and 3-2. The results indicate that cumulative risks associated with concentrations

remaining in place following removal/control of the three locations identified are below the 10-4

target risk level.

Based on the data presented in the BLRA, three response areas were identified. The response

areas can be described as follows:

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• Response Area HR-1 (location ESI-015, 0 to 2 feet): approximately 953 ft2. COPCs in this

area include PAHs;

• Response Area HR-2 (location ESI-012, 0 to 2 feet): approximately 759 ft2. The only COPC

identified during the BLRA was lead; and

• Response Area HR-3 (location ESI-003, 0 to 2 feet): approximately 1,983 ft2. COPCs in this

area include heptachlor epoxide.

Response areas that will be considered to address BLRA exceedances are shown in Figure 3-1.

In order to make a risk management decision regarding the site cleanup levels, “hot spots”

exhibiting concentrations exceeding the 10-5 risk-based PRGs were evaluated. Results of the

BLRA indicated that to achieve the 10-5 cleanup levels, one additional response area would

require remedial action. RI sampling location SS-05 (0 to 1 foot) exhibited a concentration of

benzo(a)pyrene (3.3 mg/L), which exceeded the 10-5 PRG (2.3 mg/L). The response area at this

location is approximately 1,932 ft2. The response areas identified to achieve 10-5 cleanup levels

are presented in Figure 3-2.

3.8 DESCRIPTION OF SLERA RESPONSE AREAS

As previously noted, the SLERA recommended that remedial action be completed to mitigate

potential future ecological risks at the Site. To facilitate development of the FS, analysis of onsite areas needing soil remediation to protect ecological resources were performed by calculation

of safe soil concentrations for the worst case exposure to a sensitive ground feeding bird, the

American robin. Response areas were then developed based on the locations where soil

concentrations exceeded the safe values.

Safe soil concentrations for the American robin were back-calculated for all COPCs whose 95%

UCL concentration resulted in a dose that exceeded a LOAEL value in the supplemental

evaluation of bioaccumulative risks (See SLERA Section 2.2.4). Safe soil concentrations were

back-calculated by iteratively entering soil concentrations into the dose rate model until the

exposure point concentration resulted in a dose equivalent to the toxicity reference values,

TRVLOAEL (i.e., a LOAEL-based HQ = 1.0). The calculated safe soil concentrations were then

compared to detected concentrations in each sample from the RI and ESI datasets to identify

sampling locations where there is a potential for adverse effects to American robin.

Comparisons of safe soil concentrations to detected concentrations are presented in Table 3-1 for

the RI dataset and Table 3-2 for the ESI dataset.

Lead was the only metal that had a 95% UCL concentration that exceeded the TRVLOAEL in the

supplemental evaluation. Back calculation from the TRVLOAEL resulted in a safe soil

concentration of 497 mg/kg in surface soil. Comparisons of the safe soil concentration to

detected concentrations indicate that two samples in the RI dataset (Table 3-3) and four samples

in the ESI dataset (Table 3-4) have detected concentrations that exceed the safe soil

concentration for American robin. These locations included RI sampling locations HA-7 and

HA-8 and ESI sampling locations ESI-008, 012, 013, and 026.

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The evaluation of pesticides indicated that the 95% UCL concentrations of methoxychlor and

DDT exceeded LOAEL doses for American robin. Detected concentrations of these pesticides

exceeded calculated safe soil concentrations at two RI sampling locations and at four ESI

locations (Tables 3-3 and 3-4). In four of the six locations, detected concentrations were less

than 2.5 times the calculated safe soil concentrations (i.e., HQ < 2.5) and appear to represent

small isolated areas. Given that the safe soil calculations were based on a moderate level of

conservatism, a resulting HQ of 2.5 does not appear to represent an unacceptable risk that

warrants soil remediation. At RI sampling location HA-07 the exceedance of 4,4’-DDD is colocated with an exceedance of lead and will be identified for soil remediation to address both

COPCs. At the final location (ESI-003), concentrations of all pesticides were substantially

greater than calculated safe soil concentrations. This location represents an unacceptable risk to

wildlife from exposure to pesticides in soil and warrants soil remediation.

The infrequent and low level exceedances of the “safe levels” for phthalates encountered in

isolated on-site soil samples do not pose an ecological risk of sufficient magnitude to warrant the

delineation of these areas for soil remediation. These phthalates are common plasticizers with

frequent low-level occurrence in industrial areas. The identification of phthalates as COPCs was

based on conservative toxicity endpoints. Some phthalates are used an insect repellents with

minimal dermal toxicity. Their potential for food chain bioaccumulation is low and their

persistence in the environment is short. Bis(2-ethylhexyl)phthalate (BEHP) for example,

undergoes biodegradation and has a half-life of about 10 to 20 days in the soil (RAIS BEHP

Toxicity Profile - http://risk.lsd.ornl.gov/tox/profiles/bis_2-ethylhexyl_phthalate_f_V1.shtml).

No specific areas are identified for remediation of these COPCs. The proposed soil remediation

for other constituents appears adequate to simultaneously address phthalates.

Based on the data presented in the SLERA, seven response areas were identified. The response

areas can be described as follows:

• ECO Area 1 (locations ESI-008, ESI-012, ESI-13, 0 to 2 feet): approximately 1,764 ft2.

COPCs in this area include lead and butyl benzyl phthalate;

• ECOArea 2 (location ESI-028, 0 to 2 feet): approximately 513 ft2. COPCs in this area

include 4,4’-DDD;

• ECO Area 3 (location ESI-002, 0 to 2 feet): approximately 1,527 ft2. COPCs in this area

include 4,4’-DDD and 4,4’-DDE;

• ECO Area 4 (location ESI-005, 0 to 2 feet): approximately 1,647 ft2. COPCs in this area

include 4,4’-DDD and 4,4’-DDE;

• ECO Area 5 (location ESI-003 and RI location HA-09, 0 to 2 feet): approximately 2,419 ft2.

COPCs identified included 4,4’-DDD, 4,4’-DDE, 4,4’-DDT, and methoxychlor;

• ECO Area 6 (location ESI-026, 0 to 2 feet): approximately 806 ft2. COPCs in this area

include lead; and

• ECO Area 7 (location HA-07, 0-2 feet): approximately 4,869 ft2. COPCs in this area include

4,4’-DDE and lead.

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It must be noted that ECO Area 1 overlaps with HR Area 2, and ECO Area 2 overlaps with HR

Area 3. Identified response areas based on safe soil concentrations for the worst case exposure

to potential future ecological receptors are presented in Figure 3-3.

3.9 APPROXIMATE VOLUME REQUIRING REMEDIAL ACTION

Preliminary calculations indicate that the total volume of impacted surficial soil contained within

the identified response areas is approximately 1,061 yd3, considering a maximum depth of two

feet. This FS will focus on evaluating remedial technologies and process options that will

address the response areas identified and achieve Remedial Action Objectives. In addition to the

response areas, approximately 233 yd3of sludge contained within the Wastewater AST will be

removed and disposed of off-site.

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4.0 Identified Remedial Technologies and Screening

This section presents process options and technology types which could potentially apply to the

Site. This section uses the findings from the ESI and RI, as well as on-site characteristics of

facility operations to screen out technologies and process options that cannot be effectively

implemented at the Site for remediation of surficial soil. During this step, entire process options

and technology types are eliminated from further consideration on the basis of technical

implementability.

4.1 NO ACTION

As previously noted, No Action consists of leaving the Site “as is,” with no provisions being

made for the cleanup of contamination. The “No Action” response is easily implemented at the

Site and will be retained for further evaluation, as it is an important gauge for subjectively

evaluating all other technologies.

4.2 INSTITUTIONAL CONTROLS

Potential institutional controls considered for soil remedial response include land and resource

use restrictions, such as easements, covenants, zoning restrictions, and special building permit

requirements. Institutional controls can be classified as follows:

• Active/Passive Controls: Active controls include human responsibilities for controlling

access to a disposal site (e.g., guards), controlling or cleaning up releases, and monitoring of

parameters related to disposal system performance. Passive controls rely on methods of

preserving knowledge about the Site (e.g., public records and archives);

• Proprietary/Government Controls: Include zoning restrictions, ordinances, statutes, building

permits, deed restrictions, or other provisions that restrict land or resource use at a site; and

• Structural/Non-Structural Controls: Structural controls include physical barriers (e.g., gates,

fences, and natural barriers) to keep trespassers away, signs warning of danger, and

engineered barriers. Non-structural Controls are all other limitations on land use that do not

require physical means of exposure prevention.

Institutional controls can ensure that access restriction is maintained and are effective in

protecting human health and the environment. Institutional controls will be adopted by default

for retention as part of the final remedy.

4.3 CONTAINMENT

4.3.1 Caps

Capping is the most common form of soil and waste containment remediation to limit exposure

or reduce infiltration. It is generally less expensive than other technologies and effectively

manages the human and ecological risks associated with a waste management site.

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The design of caps is site specific and depends on the intended functions of the system. Caps

can range from RCRA Subtitle C caps for hazardous wastes, RCRA Subtitle D for nonhazardous wastes, soil and gravel covers, asphalt or concrete covers, and vegetative covers.

Vegetative covers reduce soil moisture via plant uptake and evapotranspiration, limit soil

erosion, and can reduce recharge to groundwater.

The material used in the construction of caps includes low-permeability and high-permeability

soils and low-permeability geosynthetic products. The low-permeability materials divert water

and prevent its passage into the waste. The high permeability materials carry water away that

percolates into the cap. Other materials may be used to increase slope stability. Caps are

generally the least expensive way to manage the human health and ecological risks effectively.

This remedial technology could be easily implemented at the Site, provided it is used in

conjunction with other remedial technologies. The Site is currently active and thus, spatial

limitations and structural impediments would be encountered during implementation at each of

the response areas. However, this technology will be retained for further evaluation in

conjunction with other remedial technology types.

4.3.2 Vertical Barriers

Vertical barriers, such as slurry walls, plastic sheet walls, and sheetpile walls, are typically used

to restrict or contain lateral migration of COPCs. Some vertically-installed physical barrier

approaches include an impermeable surface cap or cover to prevent percolation of precipitation

into the containment cell.

Although physical barriers are an effective means of containing COPCs, several factors limit the

implementability of this technology. The response areas identified consist of shallow depths (2

feet maximum), relatively small volume, and are located within an active facility. Installation of

a vertical barrier would require that the barrier be keyed into a low permeability zone. As

described in the RI Report, shallow soils at the Site (below 2 feet) are underlain by soils

interspersed with municipal waste. Therefore, implementation of this technology would require

disturbance and exposure of soils containing municipal waste. In addition, constructability

issues would be encountered due to spatial limitations and structural impediments, such as

buildings, facility roads, ASTs, etc. Thus, physical barriers are rejected as an implementable

technology for shallow soils at the Site.

4.4 EXCAVATION

Soil excavation involves the removal of soils with COPCs with concentrations exceeding riskbased levels. This option is effective in reducing exposure to all potential receptor populations

by removing the source of the unacceptable risk. Excavation and off-site disposal or on-site

disposal is a relatively simple process, with proven procedures. As the volume of surficial soils

from depths of 0 to 2 feet is expected to be relatively small, this technology could be

implemented quickly and effectively. This technology will be retained for further evaluation.

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4.5 TREATMENT

4.5.1 Fixation/Immobilization

Fixation/immobilization reduces the mobility of hazardous substances and contaminants in the

environment through both physical and chemical means. In this technology, contaminants are

physically bound or enclosed within a stabilized mass (solidification), or chemical reactions are

induced between the stabilizing agent and contaminants to reduce their mobility (stabilization).

It can be applied both in-situ and ex-situ. Ex-situ fixation/immobilization, however, typically

requires disposal of the resultant materials. The target contaminant group for ex situ

fixation/immobilization is inorganics, including radionuclides. Most fixation/immobilization

technologies have limited effectiveness against organics and pesticides. However,

fixation/immobilization can be effective for organic constituents if the correct mix design is

selected and complete mixing is achieved.

There are several distinct innovative processes or agents that are readily employed to stabilize

contaminated materials. These include (1) bituminization, (2) emulsified asphalt, (3) modified

sulfur cement, (4) polyethylene extrusion, (5) pozzolan/Portland cement, (6) sludge stabilization,

and (7) soluble phosphates. The process is completed using an auger/caisson system. Costs for

auger/caisson systems range from moderate for the shallow applications to high for the deeper

applications.

Mitigating factors that may limit the applicability, implementability, and effectiveness of

fixation/immobilization include:

• Future usage of the Site may "weather" the materials and affect ability to maintain

immobilization of contaminants;

• The volume of the treated soil may significantly expand in response to the treatment; and

• Fixation/immobilization has limited effectiveness treating organic compounds and pesticides.

As COPCs identified during the BLRA include PAHs and pesticides, it is unlikely that this

fixation/immobilization would achieve Remedial Action Objectives. Fixation/immobilization is

rejected as an implementable technology for the Site.

4.5.2 Chemical Oxidation

In situ chemical oxidation is a relatively new remediation technology that is still considered an

“innovative” technology. However, in situ oxidation has been increasingly used in recent years,

and several specialty contractors have emerged offering variations on oxidation technology. In

situ oxidation involves delivery of chemical oxidizing agents to the contaminated media and is

designed to destroy organic compounds by complete oxidation to carbon dioxide and water

(chloride, fluoride, and bromide ions are also released by oxidation of chlorinated, fluorinated,

or brominated compounds). The most common oxidizing agent is some form of peroxide (e.g.,

hydrogen peroxide, calcium peroxide, magnesium peroxide) usually coupled with an iron

catalyst. When iron is used with peroxides, the reagent is called Fenton’s reagent (for hydrogen

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peroxide), or Fenton-like reagents (for other peroxide salts). Peroxides in the presence of iron

salts or iron oxides form hydroxyl radicals which have a relatively high oxidation potential

compared to hydroxyl ions. Hydroxyl radicals react with organic chemicals, cleaving the

chlorine-carbon and carbon-carbon bonds. Potassium permanganate and sodium permanganate

are also used; the permanganate ion has only a slightly lower oxidation potential then hydroxyl

radicals, and is easier to handle than most peroxide reagents. Gaseous ozone is also used.

In-situ chemical oxidation is appropriate for source area mass reduction. Successful

implementation of chemical oxidation depends on the ability to achieve sufficient intimate

contact of a suitable oxidant with the target COPCs. Applicable contaminants include

chlorinated solvents, PAHs, and petroleum products, although each oxidant chemical is effective

for different contaminants.

Although PAHs and pesticides could be treated to some degree using in-situ chemical oxidation,

lead is not an applicable contaminant for this technology. Lead concentrations exceeded

acceptable risk levels in Response Area 3. In-situ chemical oxidation would not achieve

Remedial Action Objectives, as the risk to human health due to soils containing high

concentrations of lead would remain. In addition, in-situ chemical oxidation has the potential to

mobilize metals, which would cause contamination over a greater area. Thus, chemical

oxidation is rejected as an implementable technology for the Site.

4.6 DISPOSAL

4.6.1 On-Site

On-site disposal involves the relocation and consolidation of soils containing COPCs to a

designated on-site location, thereby reducing the potential for human exposure and direct contact

with impacted soils. This option can be implemented at the Site, as the volume of impacted soils

is relatively small. Effectiveness requires that a secure area is designated for stockpiling and that

this option is used in conjunction with other remedial technologies, such as capping and

institutional controls. This option will be retained for further evaluation.

4.6.2 Off-Site

Off-site disposal involves the complete removal of impacted soils and sludge from the Site and

transportation off site for disposal. This option can be implemented at the Site. During the

remedial design, characterization samples will have to be collected from the soil and sludge and

a waste profile will need to be established. The soil and sludge will be disposed of at either a

non-hazardous landfill or a permitted hazardous waste disposal facility, whichever is appropriate

depending on the waste profile. This option would achieve the Remedial Action Objectives

through the removal of risk associated with the impacted soils. This option will be retained for

further evaluation.

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5.0 Evaluation of Process Options

This section provides an evaluation of the process options retained following the screening

conducted in Section 4.0. In this section, process options are evaluated on the basis of

effectiveness, implementability, and cost. Evaluation of effectiveness will focus on the

following:

• Effectiveness of each option in handling estimated volume/area of media and meeting

remediation objectives;

• Potential impacts to human health and the environment during construction and

implementation phase; and

• How proven and reliable the process is with respect to the contaminants and conditions at the

Site.

Evaluation of implementability will focus on technical and administrative feasibility. In

addition, relative capital and operation and maintenance (O&M) costs will be provided for each

process option. Process options will be evaluate as to whether costs are low, medium, or high.

5.1 NO ACTION

This option involves leaving the response areas as they are. No active remedy would be

implemented at the Site. This option is unacceptable; however, it will be retained to serve as a

basis for comparison of other options.

5.2 INSTITUTIONAL CONTOLS

This option involves leaving the response areas as they are, though monitoring of COPCs may be

included. Structural and proprietary institutional controls would be implemented to restrict

access to the response areas identified and restrictions would be placed to restrict future land use

to industrial purposes.

5.2.1 Effectiveness

This option would involve leaving the response areas as they are, and therefore, this option does

not achieve remedial objectives. This option does not effectively address the volume/area of soil

at the Site, as the COPC soil mass would remain as is. Potential impacts to human health and

potential future ecological receptors include continued exposure to COPC concentrations

exceeding acceptable risk levels.

5.2.2 Implementability

This option is easily implemented, as there are no technical or administrative constraints.

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5.2.3 Cost

No action would result in low capital and low O&M costs, even if periodic monitoring is

required.

5.3 IN-PLACE SOIL COVER

This process option involves placing a 24-inch soil cover over each response area. The purpose

of the cover would be to protect human health by reducing exposure to surficial soils containing

COPCs exceeding acceptable risk levels.

5.3.1 Effectiveness

Soil covers have been employed at several Superfund sites to mitigate exposure to surface soils.

Soil covers may be susceptible to cracking; however, this option has self-healing properties.

This option meets remedial objectives by preventing ingestion/inhalation or direct contact with

impacted surface soils. In-place soil covers would be placed at each response area, for a

combined area of 14,301 ft2. This option could effectively handle the estimated area. During

construction, it is likely that field personnel would be exposed to soils exceeding acceptable risk

values. However, adequate health and safety measures, such as proper PPE, can be employed to

minimize contact with impacted soils. This option is reliable with respect to site-specific COPCs

and Site conditions, as it reduces human and ecological exposure to soils containing COPCs

exceeding acceptable risk levels. In addition, since the impacted soils would not be exposed, this

option would prevent surface runoff of site COPCs, which could potentially accumulate in the

Sabine Lake sediments. In-place soil covers would also prevent potential exposure to a sensitive

ground feeding bird. This option does not reduce COPC concentrations.

5.3.2 Implementability

This option may be difficult to implement at each response area. The Site is an active facility

and surface impediments (buildings, roads, AST foundations) would result in constructability

issues. The degree of success of this option would depend on adequate, regular maintenance of

the cover to prevent erosion, cracking, etc. This option would require placing restrictions on

future land use in addition to structural controls prohibiting excavation in these areas.

5.3.3 Cost

Placement of an in-place soil cover over each response area would result in low capital and low

O&M costs.

5.4 ISOLATION SOIL COVER

This process option involves placing an isolation soil cover over impacted soils that have been

excavated and consolidated in a dedicated area of the Site. The isolation cover would consist of

a synthetic root penetration barrier and 24 inches of clean low permeability soil, including 3 to 4

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inches of topsoil suitable for vegetation growth. The purpose of the cover would be to protect

human health and ecological receptors by isolating soils containing COPCs exceeding acceptable

risk levels.

5.4.1 Effectiveness

Soil covers have been employed at several Superfund sites to mitigate exposure to surface soils.

Soil covers may be susceptible to cracking; however, this option has self-healing properties.

This option meets remedial objectives by preventing ingestion/inhalation or direct contact with

impacted surface soils. The total volume of the identified response areas is approximately 1,061

yd3. This option could effectively handle the estimated volume. During construction, it is likely

that field personnel would be exposed to soils exceeding acceptable risk values. However,

adequate health and safety measures, such as proper PPE, can be employed to minimize contact

with impacted soils. This option is reliable with respect to site-specific COPCs and Site

conditions, as it reduces human and ecological receptor exposure to soils containing COPCs

exceeding acceptable risk levels. This option does not reduce COPC concentrations.

5.4.2 Implementability

This option is easily implemented at the Site. As the total volume to be covered is approximately

1,061 yd3, the approximate area necessary for the construction of the isolation cover is

approximately 14,301 ft2, or a 120 ft by 120 ft cell. This amount of land is readily available onsite. The degree of success of this option would depend on adequate, regular maintenance of the

isolation cover to prevent erosion, cracking, etc. This option would require placing restrictions

on future land use in addition to structural controls prohibiting excavation in these areas.

5.4.3 Cost

Placement of an isolation soil cover over consolidated impacted soils would result in moderate

capital and moderate O&M costs.

5.5 EXCAVATION

This option consists of the excavation of impacted soil from the response areas, on-site or offsite disposal, and backfill of the excavated areas.

5.5.1 Effectiveness

Excavation of impacted soils is an effective means for removing potential risks to human health

and potential future ecological receptors, thereby meeting Remedial Action Objectives. The

depth of excavation would extend to two feet below ground surface (bgs). The approximate total

volume that would be excavated is 1,061 yd3. The estimated volume can be handled effectively

using this option. Areas excavated would need to be backfilled to restore access for facility

operations. This option includes confirmation sampling after all impacted soils are removed.

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Potential impacts to human health during implementation include the exposure of field personnel

to impacted soils. However, adequate health and safety measures, such as proper PPE, can be

employed to reduce risk. This option is reliable with respect to COPCs and Site conditions, as

the soils containing COPCs exceeding acceptable risk levels would be removed from the

response areas, thereby eliminating human and ecological receptor population exposure. This

option does not reduce COPC concentrations.

5.5.2 Implementability

Some degree of soil excavation is usually readily implemented. Excavated soil would be

disposed of either on-site or off-site at a permitted facility. Factors limiting effective

implementation of an excavation approach to source elimination may include:

• Aboveground and underground structural impediments to excavation such as buildings,

utilities, and subsurface rock features;

• Fugitive vapor emissions from disturbed soils;

• Rain during excavation; and

• Spatial limitations.

5.5.3 Cost

This option would result in low capital cost due to the small volume of impacted soils. No O&M

is required for excavation.

5.6 ON-SITE DISPOSAL

On-site disposal involves the relocation of impacted soils to a designated area on-site.

5.6.1 Effectiveness

This option is effective in handling the estimated volume of impacted soils. As previously noted,

the estimated volume of impacted soils is 1,061 yd3. However, this option by itself does not

achieve Remedial Action Objectives. Consolidating the impacted soils in a designated area

within the facility would not reduce risk to human health. This option used in conjunction with a

soil cover would be protective of human health and the environment by eliminating the exposure

to impacted soils. Additionally, structural institutional controls (e.g., “no trespassing” signs,

fencing, etc.) could be employed to restrict access to the area designated for relocation of

impacted soils, thereby reducing human and ecological receptor population exposure. Areas

excavated would need to be backfilled to restore access for facility operations. Potential impacts

to human health during implementation include temporary exposure to impacted soils. However,

adequate health and safety measures, such as proper PPE, can be employed to reduce risk. This

process is reliable with respect to COPCs and Site conditions, provided it is implemented in

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conjunction with other options, as previously described. This option does not reduce COPC

concentrations.

5.6.2 Implementability

This option can be easily implemented at the Site. The Site contains sufficient area to relocate

impacted soils. Factors limiting effective implementation of on-site disposal may include:

• Fugitive vapor emissions from disturbed soils; and

• Rain during relocation and stockpiling.

5.6.3 Cost

This option would result in low capital and low O&M costs.

5.7 OFF-SITE DISPOSAL

Off-site disposal involves the complete removal of impacted soils and transportation to a

permitted hazardous or non-hazardous disposal facility, depending on the results of the waste

characterization and profiling.

5.7.1 Effectiveness

Off-site disposal achieves Remedial Action Objectives by removing the potential risk to human

health and potential future ecological receptors due to concentrations of COPCs exceeding

acceptable risk levels. This option is effective in handling the estimated 1,061 yd3 of impacted

soils. This volume is easily transported to a permitted landfill. Potential impacts to human

health during implementation include temporary exposure to impacted soils. However, adequate

health and safety measures, such as proper PPE, can be employed to reduce risk. Off-site

disposal is a reliable process with respect to COPCs and Site conditions in that it removes COPC

mass from the Site; however this option does not reduce COPC concentrations.

5.7.2 Implementability

Off-site disposal is easily implemented at the Site. One factor which may limit the

implementability of this option is that transportation to a permitted disposal facility is required.

Solidification of the soil on site with Portland cement or other suitable reagent may be necessary

prior to transportation off site, such that the material will meet TCLP requirements for

acceptance at a non-hazardous landfill.

5.7.3 Cost

Off-site disposal would most likely result in moderate capital cost, due to transportation. There

are no O&M costs associated with this option. However, the cost of disposal can vary

003939
SECTION FIVE Evaluation of Process Options

S:\Groups\URS\WP\Palmer Barge\Feasibility Study\FS Report text.doc\22-JUL-05\\SOL 5-6

considerably, depending on the results of the waste characterization. If the waste must be

disposed of as hazardous waste (in particular if incineration is required to meet land ban

restrictions for pesticides) the disposal cost could increase by more than an order of magnitude

over the cost for disposal at a non-hazardous landfill, upon which the cost estimate is based.

003940
SECTION SIX Alternatives Identified

S:\Groups\URS\WP\Palmer Barge\Feasibility Study\FS Report text.doc\22-JUL-05\\SOL 6-1

6.0 Alternatives Identified

In this section, process options evaluated in Section 4 have been assembled into specific

remedial alternatives for the response areas identified at the Site. The alternatives were

developed while taking into consideration site specific conditions to ensure that an effective and

implementable remedial strategy is developed. The “No Action” alternative has been retained to

serve as a baseline for comparison. The alternatives identified in this FS are as follows:

• No Action

• ICs

• Excavation / On-site Disposal / Isolation Soil Cover / ICs

• Excavation / Off-site Disposal / ICs

Definition and screening of the alternatives identified are presented in the following section.

003941
SECTION SEVEN Screening of Alternatives

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7.0 Screening of Alternatives

This section presents the screening process for each alternative presented in Section 6.0. The

objective of the screening is to provide sufficient information for each alternative so that the

most effective, implementable and cost-effective remedy can be selected. Alternatives are

screened based on short- and long term aspects of three broad criteria: (1) effectiveness, (2)

implementability, and (3) cost. Based on these three broad criteria, nine specific criteria were

developed. The nine specific criteria, which are described in the USEPA Guidance for

Conducting Feasibility Studies, are as follows:

• Overall protection of human health and the environment;

• Compliance with ARARs;

• Short-term effectiveness;

• Reductions in toxicity, mobility, and volume;

• Long-term effectiveness and permanence;

• Implementability;

• Cost;

• State acceptance; and

• Agency acceptance.

The implementability evaluation will focus on technical and administrative feasibility aspects.

The cost evaluation will focus on capital and O&M costs. Costs are based on generic unit costs,

vendor information, and prior similar estimates which have been modified based on site-specific

information.

7.1 COMMON COMPONENTS

Alternative 2, 3, and 4 have three components in common:

• 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 BLRA determined that groundwater at

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

Site will be abandoned; and

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

AST will be removed and disposed of off-site. The tank will be cleaned, demolished, and

reused as scrap metal by the property owner.

Descriptions of these components will not be repeated in the discussions for each alternative;

however, the cost of these components has been incorporated in the cost evaluation for each

alternative.

003942
SECTION SEVEN Screening of Alternatives

S:\Groups\URS\WP\Palmer Barge\Feasibility Study\FS Report text.doc\22-JUL-05\\SOL 7-2

7.2 ALTERNATIVE 1 – NO ACTION

Alternative 1 involves leaving the response areas at the Site as they are. No remedy would be

applied to impacted soils.

7.3 ATERNATIVE 2 – ICs

Alternative 2 involves leaving the response areas at the Site as they are. However, 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.

7.3.1 Effectiveness

Alternative 2 provides no reduction in risk to human health. As no action would be taken, this

alternative would not comply with any applicable or relevant and appropriate requirements, such

as PRGs developed during the BLRA or safe soil concentrations developed based on the

SLERA. There would be no reduction in mobility, toxicity, and volume of the impacted soils.

The potential for sediment runoff from the Site that may contain COPCs and exposure to a

sensitive ground feeding bird would not be eliminated. No additional impact to workers, the

community, or the environment would result from this alternative, as no action would be taken.

Alternative 2 does not reduce the toxicity, mobility, or volume of the waste. All current and

potential future risks would remain. This alternative has a low likelihood of agency and

community acceptance.

7.3.2 Implementability

There are no implementability issues associated with this alternative. Structural controls could

be easily implemented at the Site.

7.3.3 Cost

The 30-year present worth cost of this alternative is estimated to be $141,205, with a capital cost

of $135,500 and an annual O&M cost of $500. Costs associated with this alternative include the

common components described in Section 7.1, as well as structural controls. Additional

construction costs required to complete the Remedial Design/Remedial Action activities were

estimated to be $70,000. The items considered for the purpose of preliminary cost estimation for

the implementation of Alternative 2 are presented in Table 7-1.

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

Alternative 3 includes the following activities:

• Excavation of approximately 1,061 yd3 consisting of the upper two feet of soil at each of the

response areas;

003943
SECTION SEVEN Screening of Alternatives

S:\Groups\URS\WP\Palmer Barge\Feasibility Study\FS Report text.doc\22-JUL-05\\SOL 7-3

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

required for consolidation encompasses approximately 14,324 ft2. The location in which

excavated soils will be placed is presented in Figure 7-1;

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

collected from sidewalls of the excavated areas. A minimum of three samples will be

collected from each response area. Samples will be analyzed for COPCs specific to each

response area (Table 2-1).

• Backfilling of the response areas with clean soil; and

• 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

• Implementation of proprietary controls to restrict future land use to industrial purposes only.

The specific objective of this alternative is to protect human health by isolating the source of the

risk. The time frame in which isolation can be achieved is approximately two months.

7.4.1 Effectiveness

Placement of an isolation soil cover over surface soils reduces risk to human health and the

environment by eliminating potential pathways. Potential pathways identified in the BLRA

included ingestion, dermal contact, and inhalation of dust/vapors. As Alternative 3 does not

involve treatment of the impacted soils, this option does not provide any reduction in the toxicity

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.

As part of Alternative 3, 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 will

be eliminated. Also, the soil cover over the consolidation area would reduce the potential for

runoff. Placement of a soil cover would eliminate potential exposures to a sensitive ground

feeding bird.

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 institutional controls to reduce

potential for future exposure. Additionally, as a result of leaving the impacted soils on-site, a

review of the effectiveness of the remedy would need to be completed every five years to ensure

that the remedy continues to be protective of human health and the environment, in accordance

with CERCLA 121(c). This alternative has a low to moderate likelihood of agency and

community acceptance.

003944
SECTION SEVEN Screening of Alternatives

S:\Groups\URS\WP\Palmer Barge\Feasibility Study\FS Report text.doc\22-JUL-05\\SOL 7-4

7.4.2 Implementability

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

implement this Alternative. As the total volume to be covered is approximately 1,061 yd3, the

approximate area necessary for the construction of the isolation cover is approximately 14, 301

ft2, or a 120 ft by 120 ft cell. This amount of land is readily available on-site. The location in

which soils will be consolidated is presented in Figure 7-1. The cover soil, which will consist of

24 inches of low permeability soil, is readily available, as is the synthetic root penetration

barrier. It is estimated that 1,061 yd3 of low permeability soil would be required for the

construction of the isolation soil cover. The low permeability soil and topsoil required for

construction is available locally. A detail of the isolation soil cover is also presented in

Figure 7-1.

7.4.3 Cost

The 30-year present worth cost of this alternative is estimated to be $458,371. Capital cost and

annual O&M costs were estimated to be $295,303 and $93,068, respectively. Additional

construction costs required to complete the Remedial Design/Remedial Action activities were

estimated to be $70,000. The capital cost is primarily for the installation of the isolation soil

cover, while O&M cost is primarily for the maintenance of the cover. Costs associated with this

alternative include common components described in Section 7.1. The items considered for the

purpose of preliminary cost estimation for the implementation of Alternative 3 are presented in

Table 7-2.

7.5 ALTERNATIVE 4 – EXCAVATION / OFF-SITE DISPOSAL / ICs

Alternative 4 consists of the following activities:

• Excavation of approximately 1,061 yd3 consisting of the upper two feet of soil at each of the

response areas;

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

collected from the sidewalls of the excavated areas. A minimum of three samples will be

collected from each response area. Samples will be analyzed for COPCs specific to each

response area (Table 2-1).

• 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 sole objective of this alternative is to protect human health and the environment by

removing the source of the risk from the Site. The time frame in which removal can be achieved

is approximately two weeks. Pending results of waste characterization, it could be necessary to

dispose of the excavated materials at a hazardous waste landfill.

003945
SECTION SEVEN Screening of Alternatives

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7.5.1 Effectiveness

Alternative 4 is protective of human health and the environment by removing the source of the

risk at the Site. The sole objective of this alternative is to protect human health and the

environment by removing the source of the risk from the Site. As Alternative 4 does not involve

treatment of the impacted soils, this option does not provide any reduction in the toxicity or

volume of impacted soil.

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 each response area would be excavated and backfilled with clean

soil or gravel. Therefore, risk to human health, the potential for sediment runoff from the site

that may contain COPCs, and the potential exposure to a sensitive ground feeding bird would be

eliminated.

Alternative 4 ensures long-term effectiveness and permanence by removing the source of the risk

from the Site. This alternative has a moderate to high likelihood of agency and community

acceptance.

7.5.2 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 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. If the impacted soils are determined not to be hazardous waste, 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.

7.5.3 Cost

The 30-year present worth cost of this alternative is estimated to be $418,307. Capital costs and

annual O&M costs were estimated to be $342,103 and $500. Additional construction costs

required to complete the Remedial Design / Remedial Action activities were estimated to be

$70,000. The capital cost is primarily for the transportation and disposal of the impacted soils.

Costs associated with this alternative include common components described in Section 7.1.

003946
SECTION SEVEN Screening of Alternatives

S:\Groups\URS\WP\Palmer Barge\Feasibility Study\FS Report text.doc\22-JUL-05\\SOL 7-6

The items considered for the purpose of preliminary cost estimation for the implementation of

Alternative 4 are presented in Table 7-3.

7.6 COMPARATIVE ANALYSIS

As part of the evaluation of the four identified alternatives, a comparative analysis was

completed. The four alternatives were ranked utilizing a basic grading scale. Each alternative

was graded based on its ability to meet the nine evaluation criteria outlined in Section 7.0. A

summary of the evaluation is presented in Table 7-4. Results of the ranking are presented in

Table 7-5.

As shown in Table 7-2, the remedial alternative which received the highest ranking for the Site

was Alternative 4. As previously discussed, this alternative consists of the excavation of

impacted soils and disposal at an off-site permitted facility. Alternative 4 received the highestranking score on the based on the following:

• Alternative 4 achieves Remedial Action Objectives and does so within a reasonable

timeframe;

• 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 eliminated potential exposure of COPCs to a sensitive ground feeding bird

and sediment runoff that may contain COPCs from entering Sabine Lake.

• Alternative 4 is easily implemented and of moderate cost.

Alternative 3 received a slightly lower ranking due to the long-term monitoring that must be

completed to ensure long-term effectiveness. Alternatives 3 and 4 also received a negative score

for the ability to reduce the toxicity or volume of the waste. Alternatives 1 and 2 received the

lowest scores, as these alternatives do not achieve Remedial Action Objectives and thus are not

protective of human health and the environment.

Based on the information presented in the comparative analysis, the U.S. EPA will make the

decision on which alternative to select as the preferred alternative that is presented to the

community. Based on comments and input from the community during the public comment

period, U.S. EPA, in consultation with the Texas Commission on Environmental Quality

(TCEQ) will make a final selection on the remedy for the site.

003947
Table 1-1

Soil Exceedences of Preliminary Remediation Goals (PRGs) for 10-6 to 10-4 Target Risk Levels

Palmer Barge Line, Port Arthur, Texas

Conc 1 x 10-6 PRG (a) Exceeds 1 x 10-5 PRG (b) Exceeds 1 x 10-4 PRG Exceeds

AOC Area Name Sample ID (f) Constituent mg/kg mg/kg PRG? mg/kg PRG? mg/kg PRG?

1 Wastewater ASTs

003 (0-2) 4,4'-DDE 12 7.8 a 78 780

003 (0-2) 4,4'-DDT 11 7.8 a 78 474 (e)

003 (0-2) Aldrin 9.2 0.11 a 1.1 a 11

003 (0-2) Dieldrin 4.4 0.12 a 1.2 a 12

003 (0-2) Heptachlor 1 0.43 a 4.3 43

003 (0-2) Heptachlor epoxide 9.5 0.21 a 2.1 a 8.9 (e) a

003 (0-2) Pentrachlorophenol 200 10 a 100 a 1000

003 (2-4) Aldrin 0.4 0.11 a 1.1 11

003 (2-4) Pentrachlorophenol 570 10 a 100 a 1000

004 (0-2) Benzo(a)pyrene 0.38 0.23 a 2.3 23

004 (2-4) Benzo(a)anthracene 280 2.3 a 23 a 230 a

004 (2-4) Benzo(a)pyrene 240 0.23 a 2.3 a 23 a

004 (2-4) Benzo(b)fluoranthene 220 2.3 a 23 a 230

004 (2-4) Benzo(k)fluoranthene 190 23 a 230 2300

004 (2-4) Dibenzo(a,h)anthracene 110 0.23 a 2.3 a 23 a

004 (2-4) Indeno(1,2,3-cd)pyrene 280 2.3 a 23 a 230 a

004 (2-4) Pentrachlorophenol 140 10 a 100 a 1000

006 (0-2) Benzo(a)pyrene 0.25 0.23 a 2.3 23

PBL-S-HA-03(0-2) Benzo(a)pyrene 1.57 0.23 a 2.3 23

PBL-S-HA-03(0-2) Benzo(a)pyrene 1.46 0.23 a 2.3 23

PBL-S-HA-03(0-2) Benzo(b)fluoranthene 2.73 2.3 a 23 230

PBL-S-HA-10(0-2) Benzo(a)pyrene 0.277 0.23 a 2.3 23

PBL-S-HA-9(0-2) Dieldrin 0.153 0.12 a 1.2 12

PBL-S-HA-9(2-4) Benzo(a)pyrene 0.235 0.23 a 2.3 23

PBL-S-HA-9(2-4) Dieldrin 0.136 0.12 a 1.2 12

PBL-S-SS-01(0-1) Benzo(a)pyrene 1.3 0.23 a 2.3 23

PBL-S-SS-01(0-1)D Benzo(a)pyrene 1.5 0.23 a 2.3 23

PBL-S-SS-05(0-1) Benzo(a)pyrene 3.3 0.23 a 2.3 a 23

PBL-S-SS-05(0-1) Dibenz(a,h)anthracene 0.55 0.23 a 2.3 23

PBL-S-TP-03(2-4) Arsenic 8 1.8 a 18 180

PBL-S-TP-04(0-2) Arsenic 8.6 1.8 a 18 180

PBL-S-TP-04(2-4) Arsenic 10.8 1.8 a 18 180

PBL-S-TP-04(2-4) Dieldrin 0.4 0.12 a 1.2 12

PBL-S-TP-04(2-4) Pentachlorophenol 150 10 a 100 a 1000

2 Boiler House

008 (0-2) Arsenic 11.7 1.8 a 18 180

009 (0-2) Arsenic 8.9 1.8 a 18 180

012 (0-2) Aroclor-1254 1.2 0.83 a 8.3 11.8 (e)

012 (0-2) Arsenic 86.5 1.8 a 18 a 180

012 (0-2) Benzo(a)pyrene 0.53 0.23 a 2.3 23

012 (0-2) Lead 5050 800 (d) a 800 (d) a 800 (d) a

012 (2-4) Arsenic 43 1.8 a 18 a 180

012 (2-4) Benzo(a)anthracene 14 2.3 a 23 230

012 (2-4) Benzo(a)pyrene 4.2 0.23 a 2.3 a 23

012 (2-4) Benzo(b)fluoranthene 14 2.3 a 23 230

012 (2-4) Dibenz(a,h)anthracene 1.9 0.23 a 2.3 23

013 (0-2) Aroclor-1260 0.85 0.83 a 8.3 83

013 (0-2) Arsenic 12.7 1.8 a 18 180

013 (2-4) Benzo(a)pyrene 0.28 0.23 a 2.3 23

PBL-S-HA-11(0-2 Arsenic 9.53 1.8 a 18 180

PBL-S-HA-14(0-2 Arsenic 8.1 1.8 a 18 180

PBL-S-SS-03(0-1) Benzo(a)pyrene 0.35 0.23 a 2.3 23

PBL-S-TP-05(0-2) Arsenic 11.9 1.8 a 18 180

PBL-S-TP-06(2-4) Benzo(a)pyrene 0.28 0.23 a 2.3 23

3 Former Slop Tanks

014 (0-2) Benzene 1.7 1.6 a 16 160

014 (0-2) Benzo(a)pyrene 1.4 0.23 a 2.3 23

014 (0-2) Benzo(a)anthracene 4 2.3 a 23 230

015 (0-2) Benzene 3.1 1.6 a 16 160

015 (0-2) Benzo(a)pyrene 40 0.23 a 2.3 a 23 a

015 (0-2) Benzo(a)anthracene 88 2.3 a 23 a 230

015 (0-2) Napthalene 370 210 a 210 (c) a 210 (c) a

4 Horizontal ASTs

PBL-S-HA-07(0-2 Benzene 2.02 1.6 a 16 160

5 12 ASTs

PBL-S-TP-11(0-2) Benzo(a)pyrene 0.27 0.23 a 2.3 23

PBL-S-TP-11(2-4)D Arsenic 120 1.8 a 18 a 180

6 Flare

PBL-S-HA-8(2-4) Aroclor-1254 4.18 0.83 a 8.3 11.8 (e)

PBL-S-TP-12(2-4) Arsenic 11.9 1.8 a 18 180

Notes

a Region 6 MSSLs. 1E-6 only applies to MSSLs based on carcinogenic effects per MSSL tables. Others based on noncancer HI = 1.0

b PRGs calculated using 10X MSSLs for COCs with MSSLs based on carcinogenic effects unless noncancer HI = 1 criteria is lower, then PRG is based on noncancer HI = 1.

c Noncancer-based criteria from MSSLs

d MSSL for Lead used for all risk ranges. ESI012 (0-2) is the sitewide soil maximum. Identified as an exceedence due to elevated concentration level.

e Calculated PRG based on noncancer HI = 1 < than cancinogenic risk criteria.

f Sample list comprised of locations exceeding Region 6 MSSLs. Source data for ESI was RI Work Plan summary tables.

003948
Table 2-1

Site Specific Constituents of Potential Concern (COPCs)

and Target Cleanup Levels

Palmer Barge Liner, Port Arthur, Texas

COPC Target Cleanup Levels

(mg/kg)

BLRA Values

Heptachlor epoxide 8.9

Benzo(a)pyrene 23

Naphthalene 210

Lead 800

SLERA Safe Soil Concentrations

Butyl benzyl phthalate 5.37

4,4-DDD 0.0864

4,4-DDE 0.0864

4,4-DDT 0.0865

Methoxychlor 0.09

Lead 497

003949
Table 3-1

Identification of Maximum Concentrations Following Implementation of Remedy

Palmer Barge Line, Port Arthur, Texas

Conc

AOC Area Name Sample ID (b) Constituent mg/kg

1 Wastewater ASTs 003 (0-2) 4,4'-DDE Targeted for Remedy

1 Wastewater ASTs 003 (0-2) 4,4'-DDT Targeted for Remedy

1 Wastewater ASTs 003 (0-2) Aldrin Targeted for Remedy

1 Wastewater ASTs 003 (0-2) Dieldrin Targeted for Remedy

1 Wastewater ASTs 003 (0-2) Heptachlor Targeted for Remedy

1 Wastewater ASTs 003 (0-2) Heptachlor epoxide Targeted for Remedy

1 Wastewater ASTs 003 (0-2) Pentrachlorophenol Targeted for Remedy

1 Wastewater ASTs PBL-S-TP-04(0-2) Arsenic Targeted for Remedy (a)

2 Boiler House 012 (0-2) Aroclor-1254 Targeted for Remedy

2 Boiler House 012 (0-2) Arsenic Targeted for Remedy

2 Boiler House 012 (0-2) Benzo(a)pyrene Targeted for Remedy

2 Boiler House 012 (0-2) Lead Targeted for Remedy

3 Former Slop Tanks 015 (0-2) Benzene Targeted for Remedy

3 Former Slop Tanks 015 (0-2) Benzo(a)anthracene Targeted for Remedy

3 Former Slop Tanks 015 (0-2) Benzo(a)pyrene Targeted for Remedy

3 Former Slop Tanks 015 (0-2) Napthalene Targeted for Remedy

1 Wastewater ASTs 003 (2-4) Aldrin (b)

1 Wastewater ASTs 003 (2-4) Pentrachlorophenol (b)

1 Wastewater ASTs 004 (2-4) Benzo(a)anthracene (b)

1 Wastewater ASTs 004 (2-4) Benzo(a)pyrene (b)

1 Wastewater ASTs 004 (2-4) Benzo(b)fluoranthene (b)

1 Wastewater ASTs 004 (2-4) Benzo(k)fluoranthene (b)

1 Wastewater ASTs 004 (2-4) Dibenz(a,h)anthracene (b)

1 Wastewater ASTs 004 (2-4) Indeno(1,2,3-cd)pyrene (b)

1 Wastewater ASTs 004 (2-4) Pentrachlorophenol (b)

1 Wastewater ASTs PBL-S-HA-9(2-4) Benzo(a)pyrene (b)

1 Wastewater ASTs PBL-S-HA-9(2-4) Dieldrin (b)

1 Wastewater ASTs PBL-S-TP-03(2-4) Arsenic (b)

1 Wastewater ASTs PBL-S-TP-04(2-4) Arsenic (b)

1 Wastewater ASTs PBL-S-TP-04(2-4) Dieldrin (b)

1 Wastewater ASTs PBL-S-TP-04(2-4) Pentachlorophenol (b)

2 Boiler House 012 (2-4) Arsenic (b)

2 Boiler House 012 (2-4) Benzo(a)anthracene (b)

2 Boiler House 012 (2-4) Benzo(a)pyrene (b)

2 Boiler House 012 (2-4) Benzo(b)fluoranthene (b)

2 Boiler House 012 (2-4) Dibenz(a,h)anthracene (b)

2 Boiler House 013 (2-4) Benzo(a)pyrene (b)

2 Boiler House PBL-S-TP-06(2-4) Benzo(a)pyrene (b)

5 12 ASTs PBL-S-TP-11(2-4)D Arsenic (b)

6 Flare PBL-S-HA-8(2-4) Aroclor-1254 (b)

6 Flare PBL-S-TP-12(2-4) Arsenic (b)

2 Boiler House 013 (0-2) Aroclor-1260 0.85

2 Boiler House PBL-S-HA-14(0-2 Arsenic 8.1

2 Boiler House 009 (0-2) Arsenic 8.9

2 Boiler House PBL-S-HA-11(0-2 Arsenic 9.53

2 Boiler House 008 (0-2) Arsenic 11.7

2 Boiler House PBL-S-TP-05(0-2) Arsenic 11.9

2 Boiler House 013 (0-2) Arsenic 12.7

3 Former Slop Tanks 014 (0-2) Benzene 1.7

4 Horizontal ASTs PBL-S-HA-07(0-2 Benzene 2.02

3 Former Slop Tanks 014 (0-2) Benzo(a)anthracene 4

1 Wastewater ASTs 006 (0-2) Benzo(a)pyrene 0.25

5 12 ASTs PBL-S-TP-11(0-2) Benzo(a)pyrene 0.27

1 Wastewater ASTs PBL-S-HA-10(0-2) Benzo(a)pyrene 0.277

2 Boiler House PBL-S-SS-03(0-1) Benzo(a)pyrene 0.35

1 Wastewater ASTs 004 (0-2) Benzo(a)pyrene 0.38

1 Wastewater ASTs PBL-S-SS-01(0-1) Benzo(a)pyrene 1.3

3 Former Slop Tanks 014 (0-2) Benzo(a)pyrene 1.4

1 Wastewater ASTs PBL-S-HA-03(0-2) Benzo(a)pyrene 1.46

1 Wastewater ASTs PBL-S-SS-01(0-1)D Benzo(a)pyrene 1.5

1 Wastewater ASTs PBL-S-HA-03(0-2) Benzo(a)pyrene 1.57

1 Wastewater ASTs PBL-S-SS-05(0-1) Benzo(a)pyrene 3.3

1 Wastewater ASTs PBL-S-HA-03(0-2) Benzo(b)fluoranthene 2.73

1 Wastewater ASTs PBL-S-SS-05(0-1) Dibenz(a,h)anthracene 0.55

1 Wastewater ASTs PBL-S-HA-9(0-2) Dieldrin 0.153

Notes:

Sample list comprised of results exceeding Region 6 MSSLs. 

Source data for ESI was RI Work Plan summary tables.

Maximum Concentrations identified based on assumption that remedy performed for three identified locations.

 indicates maximum concentration following implementation of remedy option.

(a) location in proximity with ESI-003 which is targeted in remedy.

(b) location is below 0-2' zoned defined as surface soil in the FS and may be associated with landfill operations

rather than Palmer Barge site operations. Therefore, this result not included in

post-remedy cumulative risk evaluation.

003950
Table 3-2

Upperend Risk Estimate Following Implementation of Remedy

Maximum Sitewide

Soil Concentration (f)

Following Assumed Remedy Soil Conc for HI = 1.0 (b) Soil Conc for TR = 1x10-6 (c)

Constituents (a) (mg/kg) (mg/kg) (mg/kg) Hazard Quotient (d) Cancer Risk (e)

Aroclor 1260 0.85 -- 8.30E-01 -- 1.02E-06

Arsenic 12.7 2.84E+02 1.80E+00 4.47E-02 7.15E-06

Benzene 2.02 1.83E+02 1.60E+00 1.10E-02 1.26E-06

Benzo(a)anthracene 4 -- 2.30E+00 -- 1.74E-06

Benzo(a)pyrene 3.3 -- 2.30E-01 -- 1.43E-05

Benzo(b)fluoranthene 2.73 -- 2.30E+00 -- 1.19E-06

Dibenzo(a,h)anthracene 0.55 -- 2.30E-01 -- 2.39E-06

Dieldrin 0.153 3.42E+01 1.20E-01 4.47E-03 1.28E-06

Cumulative 6.0E-02 3.0E-05

Notes:

a - Constituents with detected concentrations in 0-2' soil exceeding Region 6 MSSLs for industrial outdoor worker

 Assumes locations ESI 003, ESI 012, and ESI 015 are remedied. See Table 1.

b - Derived by ratios from baseline risk calculations

c - Region 6 MSSLs

d - Derived by Max Soil Concentration / Soil Conc for HI 1.0.

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

f - Assumes locations ESI 003, ESI012, and ESI015 are remedied. Maximum concentrations for COCs with concentrations exceeding MSSLs in 0-2' horizon. See Table 1.

003951
Table 3-3

Detected COPC Concentrations Versus Safe Soil Levels and Summary of Wildlife Risk

RI Dataset

Palmer Barge Superfund Site

Port Arthur, Texas

Sample ID

Lead4,4'-DDD4,4'-DDETotal PCBsbis(2-ethylhexyl)phthalate (BEHP)

Safe Robin Concentration (mg/kg): 497 0.0864 0.0864 4.28 5.37

PBL-S-TP-01(0-2) 7/14/2003 4.1

PBL-S-TP-02(0-2) 7/14/2003 14.2

PBL-S-TP-03(0-2) 7/14/2003 70.5 0.049 0.78

PBL-S-TP-04(0-2) 7/14/2003 83.4 0.02 0.0095 0.46

PBL-S-TP-05(0-2) 7/15/2003 306 0.0034 0.18 0.057

PBL-S-TP-06(0-2) 7/15/2003 13 0.029 0.91

PBL-S-TP-07(0-2) 7/15/2003 24 0.19

PBL-S-TP-08(0-2) 7/15/2003 41.9 0.51

PBL-S-TP-09(0-2) 7/15/2003 35.6

PBL-S-TP-10(0-2) 7/14/2003 170 0.0085 0.01 0.67

PBL-S-TP-11(0-2) 7/15/2003 119 0.006

PBL-S-TP-12(0-2) 7/15/2003 38.1

PBL-S-SS-01(0-1) 7/15/2003 28.7 0.87

PBL-S-SS-02(0-1) 7/15/2003 43.5 18

PBL-S-SS-03(0-1) 7/15/2003 117 0.021 1.2

PBL-S-SS-04(0-1) 7/15/2003 72 0.034 7.7

PBL-S-SS-05(0-1) 7/15/2003 47.3 0.94

PBL-S-HA-01(0-2) 2/26/2004 9.67

PBL-S-HA-01(0-2) 2/26/2004

PBL-S-HA-02(0-2) 2/26/2004 14.8

PBL-S-HA-02(0-2) 2/26/2004

PBL-S-HA-03(0-2) 2/26/2004 7.57

PBL-S-HA-03(0-2) 2/26/2004

PBL-S-HA-4(0-2) 2/25/2004 13.9

PBL-S-HA-05(0-2) 2/27/2004 16 0.145

PBL-S-HA-05(0-2)

PBL-S-HA-05(0-2)

PBL-S-HA-6(0-2) 2/25/2004 23.6

w:/eco/projects/2003/palmer barge/fs/FS Table 3-3 and 3-4.xls

003952
Table 3-3

Detected COPC Concentrations Versus Safe Soil Levels and Summary of Wildlife Risk

RI Dataset

Palmer Barge Superfund Site

Port Arthur, Texas

Sample ID

Lead4,4'-DDD4,4'-DDETotal PCBsbis(2-ethylhexyl)phthalate (BEHP)

Safe Robin Concentration (mg/kg): 497 0.0864 0.0864 4.28 5.37

PBL-S-HA-07(0-2) 2/27/2004 1080 0.306

PBL-S-HA-07(0-2)

PBL-S-HA-8(0-2) 2/25/2004 161 0.0403 0.0212 0.562 0.45

PBL-S-HA-9(0-2) 2/25/2004 181 0.194 0.537

PBL-S-HA-10(0-2) 2/25/2004 29.9

PBL-S-HA-10(0-2)

PBL-S-HA-11(0-2) 2/25/2004 478 0.358

PBL-S-HA-11(0-2) 0.431

PBL-S-HA-12(0-2) 2/25/2004 583 0.288

PBL-S-HA-12(0-2) 0.271

PBL-S-HA-13(0-2) 2/25/2004 328 0.0155 0.119 0.272

PBL-S-HA-14(0-2) 2/25/2004 348

Notes:

Shaded cells indicate detected concentration exceeds calculated safe soil concentrations.

w:/eco/projects/2003/palmer barge/fs/FS Table 3-3 and 3-4.xls

003953
Table 3-4

Detected COPC Concentrations Versus Safe Soil Levels and Summary of Wildlife Risk

ESI Dataset

Palmer Barge Superfund Site

Port Arthur, Texas

Sample ID

Lead4,4'-DDD4,4'-DDE4,4'-DDTMethoxychlorTotal PCBsbis(2-ethylhexyl)phthalate (BEHP)Butyl benzyl phthalateDi-n-butylphthalateDi-n-octylphthalate

Safe Robin Concentration (mg/kg): 497 0.0864 0.0864 0.0865 0.0864 4.28 5.37 5.37 5.37 5.37

99ESI-001-21-1

99ESI-001-21-1R 0.002

99ESI-001-51-1 48.8 0.0041 0.19 0.042

99ESI-002-51-1 327 0.11 0.13 0.032 0.047 0.24

99ESI-002-51-1D 0.09 0.14

99ESI-003-51-1 425 12 11

99ESI-003-51-1D 51 26 4.7

99ESI-004-51-1 40 0.0051

99ESI-005-51-1 15.1 0.061 0.071 0.0061

99ESI-005-51-1D 0.1 0.13

99ESI-006-51-1 10.6

99ESI-006-51-1R 0.041

99ESI-008-51-1 427 0.015 0.012 5.8 0.065 0.38

99ESI-008-51-1D 4.8

99ESI-008-52-1 756 0.39 0.05

99ESI-009-51-1 412 0.0035 0.0035 0.0035 0.018 0.281 0.081 0.35

99ESI-010-51-1 72.7 0.38 0.33

99ESI-011-51-1 172 0.0049 0.13 0.35

99ESI-012-51-1 5050 0.024 0.084 1.2 0.4 24 0.047

99ESI-012-51-1D 1.8 15

99ESI-013-51-1 282 0.013 0.018 0.886 0.5 0.043 0.35

99ESI-013-51-1D 1.1

99ESI-013-51-1R 0.57 0.12 0.049

99ESI-013-52-1 1110 0.15 0.41

99ESI-013-52-1D

99ESI-014-51-1 21.6

99ESI-014-51-1D

99ESI-014-52-1 40.4

99ESI-014-52-1D

99ESI-015-51-1 133 0.017

99ESI-015-51-1D

99ESI-016-51-1 29.5

99ESI-017-51-1 39.9 0.044

99ESI-017-51-1D

99ESI-018-51-1 57.1 0.011 0.052

99ESI-018-51-1D

99ESI-019-51-1 15.1 0.02 74

99ESI-019-51-1D

99ESI-020-51-1 20.8 0.14

99ESI-021-51-1 232

99ESI-022-51-1 58.5

99ESI-023-51-1 24.8 0.018 0.043 0.15

w:/eco/projects/2003/palmer barge/fs/FS Table 3-3 and 3-4.xls

003954
Table 3-4

Detected COPC Concentrations Versus Safe Soil Levels and Summary of Wildlife Risk

ESI Dataset

Palmer Barge Superfund Site

Port Arthur, Texas

Sample ID

Lead4,4'-DDD4,4'-DDE4,4'-DDTMethoxychlorTotal PCBsbis(2-ethylhexyl)phthalate (BEHP)Butyl benzyl phthalateDi-n-butylphthalateDi-n-octylphthalate

Safe Robin Concentration (mg/kg): 497 0.0864 0.0864 0.0865 0.0864 4.28 5.37 5.37 5.37 5.37

99ESI-023-51-1R 0.071

99ESI-024-21-1 1 0.00014 0.002

99ESI-024-21-1R 0.003

99ESI-024-22-1 0.22 0.002

99ESI-024-22-1R 0.002 0.006

99ESI-024-51-1 32.2

99ESI-025-51-1 77.5 0.013 0.0091 0.0037 0.15 0.27

99ESI-025-51-1D 0.38

99ESI-026-51-1 3450 0.015 0.017

99ESI-026-51-1R 0.059

99ESI-027-51-1 160

99ESI-027-51-1R

99ESI-028-51-1 133 0.0036 0.003 0.0036 0.036 0.098

99ESI-028-52-1 34.8 0.12 0.059 0.047 0.031 0.64 0.062

99ESI-029-51-1 51.7 0.0038 0.0038 0.0038 0.02 0.45

99ESI-030-51-1 319 0.19

99ESI-031-51-1 30.6 0.0059 0.071

Notes:

Shaded cells indicate detected concentration exceeds calculated safe soil concentrations.

w:/eco/projects/2003/palmer barge/fs/FS Table 3-3 and 3-4.xls

003955
Item 

No. Description Unit1

Estimated 

Quantity Unit Cost ($) Total

1 Implementation of ICs ls 1 $ 10,000 $ 10,000

2 Abandonment of Existing Monitoring Wells ea 5 $ 5,000 $ 25,000

3 Wastewater AST Demolition & Sludge Removal ls 1 $ 100,000 $ 100,000

$ 135,000

Design and Procurement Services $ 30,000 $ 30,000

Construction Oversight $ 20,000 $ 20,000

Reporting $ 20,000 $ 20,000

Total Additional Construction Cost: $ 70,000

4 Maintenance of ICs $ 500 $ 500

$ 500

30 Years O&M Net Present Value Years 30 7.0% $ 6,205

$ 141,205

1) Guide to abbreviations:

ls = lump sum

ea = each

2) ICs may include deed restrictions, signs, fencing.

3) Cost of sludge removal may vary depending on volume and characterization of the sludge.

Remedial Alternative Total:

Capital Costs:

SUBTOTAL CAPITAL COST:

Average Annual Operation & Maintenance Costs:

SUBTOTAL AVERAGE ANNUAL O&M COSTS:

Additional Construction Costs:

PROJECT: Palmer Barge Line Superfund Site - Port Arthur, Texas

Table 7-1

Cost Estimate

Alternative 2 - No Action / ICs

W:\AshlandChem\2008200\Tri-Alliance Project Mgmt\Glenrose\CMS\Tables\FS Table 7-1 thru 7-3.xls\Table 7-1

003956
Item 

No. Description Unit1 Estimated Quantity Unit Cost ($) Total

1 Mobilization ls 1 $ 50,000 $ 50,000

2 Site Preparation/Erosion Control ls 1 $ 15,000 $ 15,000

3 Excavation and Consolidation of Impacted Soil cy 770 $ 8.00 $ 6,160

4 Confirmation Sampling Activities ls 1 $ 35,000 $ 35,000

5 Backfill/Grading Excavated Areas cy 770 $ 12.50 $ 9,625

6 Geotextile sf 10,395 $ 0.12 $ 1,247

7 24-inch Soil Cover (Offsite source) cy 770 $ 15.00 $ 11,550

8 Vegetative Soil Amendment cy 96 $ 8.50 $ 818

9 Erosion Monitoring Plates ea 1 $ 250 $ 250

10 Drainage Features ls 1 $ 10,000 $ 10,000

11 Seeding and Mulching of Soil Cover ac 0.24 $ 1,350 $ 322

12 Demobilization ls 1 $ 10,000 $ 10,000

13 Implementation of ICs ls 1 $ 20,000 $ 20,000

14 Abandonment of Existing Monitoring Wells ea 5 $ 5,000 $ 25,000

15 Wastewater AST Demolition & Sludge Removal ls 1 $ 100,000 $ 100,000

$ 294,973

Design and Procurement Services $ 30,000 $ 30,000

Construction Oversight $ 20,000 $ 20,000

Reporting $ 20,000 $ 20,000

Total Additional Construction Cost: $ 70,000

16 Soil Cover Maintenance $ 5,000 $ 5,000

17 Inspections $ 2,500 $ 2,500

18 Maintenance of ICs $ 500 $ 2,500

$ 10,000

30 Years O&M Net Present Value Years 30 7.0% $ 124,090

$ 489,063

1) Guide to abbreviations: ea = each

cy = cubic yards

ls = lump sum

sf = square feet

ac = acre

2)

3) ICs may include deed restrictions, signs, fencing.

4) Cost of sludge removal may vary depending on volume and characterization of the sludge.

Design assumes that all soils for backfill and cover are not available on-site. 

Average Annual Operation & Maintenance Costs:

SUBTOTAL AVERAGE ANNUAL O&M COSTS:

Remedial Alternative Total:

Additional Construction Costs:

Table 7-2

Cost Estimate

Alternative 3 - Excavation / On-site Disposal / Isolation Soil Cover / ICs

PROJECT: Palmer Barge Line Superfund Site - Port Arthur, Texas

Capital Costs:

SUBTOTAL CAPITAL COST:

W:\AshlandChem\2008200\Tri-Alliance Project Mgmt\Glenrose\CMS\Tables\FS Table 7-1 thru 7-3.xls\Table 7-2

003957
Item 

No. Description Unit1

Estimated 

Quantity Unit Cost ($) Total

1 Mobilization ls 1 $ 50,000.00 $ 50,000

2 Site Preparation/Erosion Control ls 1 $ 10,000.00 $ 10,000

3 TCLP Testing ls 1 $ 10,000.00 $ 10,000

4 Excavation cy 770 $ 6.30 $ 4,851

5 Transportation and Handling ton 1,309 $ 8.30 $ 10,865

6 Disposal (Non-Haz) ton 1,309 $ 50.00 $ 65,450

7 Backfilling cy 770 $ 12.50 $ 9,625

8 Site Restoration & Demobilization ls 1 $ 10,000.00 $ 10,000

9 Implementation of ICs ls 1 $ 5,000.00 $ 5,000

10 Abandonment of Existing Monitoring Wells ea 5 $ 5,000 $ 25,000

11 Wastewater AST Demolition & Sludge Removal ls 1 $ 100,000 $ 100,000

$ 300,791

Design and Procurement Services $ 30,000 $ 30,000

Construction Oversight $ 20,000 $ 20,000

Reporting $ 20,000 $ 20,000

Total Additional Construction Cost: $ 70,000

12 Maintenance of ICs $ 500 $ 500

$ 500

30 Years O&M Net Present Value Years 30 7.0% $ 6,205

$ 376,995

1) Guide to abbreviations: ea = each

lf = linear feet

ls = lump sum

2)

3) Assumes waste in non-hazardous. Hazardous waste transportation and disposal cost is approximately $800 per ton (includes incineration).

4) ICs may include deed restrictions and signs.

5) Cost of sludge removal may vary depending on volume and characterization of the sludge.

PROJECT: Palmer Barge Line Superfund Site - Port Arthur, Texas

Table 7-3

Cost Estimate

Alternative 4 - Excavation / Off-site Disposal / ICs

Capital Costs:

SUBTOTAL CAPITAL COST:

Average Annual Operation & Maintenance Costs:

SUBTOTAL AVERAGE ANNUAL O&M COSTS:

Remedial Alternative Total:

Design assumes that all soils for backfill cover are not available on-site. 

Additional Construction Costs:

W:\AshlandChem\2008200\Tri-Alliance Project Mgmt\Glenrose\CMS\Tables\FS Table 7-1 thru 7-3.xls\Table 7-3

003958
Table 7-4

Evaluation of Remedial Alternatives

Palmer Barge Line Superfund Site Feasibility Study

U:\Groups\URS\WP\Palmer Barge\Feasibility Study\FS Table 7-4.doc 07/22/05 2:31 PM

Alternative

No. Description Advantages Disadvantages

1 No Action 1. Low Cost

2. Easily Implemented

1. Does Not Meet Remedial Action Objectives

2. Not Protective of Human Health and the Environment

3. Does not comply with ARARs

4. Does Not Reduce Mobility, Toxicity, or Volume of Waste

5. Low Probability of Agency and Community Acceptance

6. Does not Provide Short-Term Effectiveness

7. Does Not Address Long-Term Effectiveness (Wastes

Remain)

2 ICs 1. Low Cost

2. Easily Implemented

1. Does Not Meet Remedial Action Objectives

2. Not Protective of Human Health and the Environment

3. Does not comply with ARARs

4. Does Not Reduce Mobility, Toxicity, or Volume of Waste

5. Low Probability of Agency and Community Acceptance

6. Does not Provide Short-Term Effectiveness

7. Does Not Address Long-Term Effectiveness (Wastes

Remain)

3 Excavation / OnSite Disposal /

Isolation Soil

Cover/ ICs

1. Meets Remedial Action Objectives

2. Easily Implemented

3. Protective of Human Health and the Environment

4. Moderate Cost

1. Does Not Reduce Toxicity or Volume of Waste

2. Low to Moderate Probability of Community or Agency

Acceptance

3. Health and Safety Measures Required During

Implementation

4. Long-Term O&M Required for Long-Term Effectiveness

5. Review of Remedy Every 5 Years per CERCLA 121(c)

4 Excavation / OffSite Disposal/

ICs

1. Meets Remedial Action Objectives

2. Protective of Human Health and the Environment

3. Achieves Long-Term Effectiveness and Permanence

(Risk Removed)

4. Easily Implemented

5. Moderate to High Likelihood of Agency and

Community Acceptance

6. No Long-Term Activities

7. Moderate Cost

1. Does Not Reduce Toxicity or Volume of Waste

2. Health and Safety Measures Required During

Implementation

003959
Table 7-5

Remedial Alternatives Rankings

Palmer Barge Line Superfund Site Feasibility Study

U:\Groups\URS\WP\Palmer Barge\Feasibility Study\FS Table 7-5.doc

Alternative

Protective of

Human Health &

Environment

Compliance

with ARARs

Short-term

Effectiveness

Minimize

Toxicity,

Mobility, &

Volume of

Waste

Long-term

Effectiveness/

Permanence

Implementability CostEffectiveness

Probability of

Community/

Agency

Acceptance

Score

1 – No Action / ICs — — — — — + + — -4

2 – ICs — — — — — + + — -4

3 – Excavation / OnSite Disposal /

Isolation Soil Cover/

ICs

+ + + — — + 0 0 +2

4 – Excavation /

Off-Site Disposal /

ICs

+ + + — + + 0 + +5

Notes: 

Ranking Score

+ = Positive or High

0 = Moderate or Neutral

- = Negative or Low

003960
003961

9801 Westheimer Suite 500

Houston, Texas 77042Ph: (713) 914-6699Fax: (713) 914-8404

Pa

HuPaPo

Con

Primary Release Environmental Release Environmental Indirect Facilit

Source Mechanism Media Mechanism Media Exposure Ing. D

X 

LEGEND

X Potentially complete pathway Notes: Ing. In

Incomplete pathway Der. D

Inh. In

Releases 

and Spills 

from Barge 

Cleaning

Infiltration Seepage

Surface Runoff

Shallow WaterBearing Zone

Sediment

Surface 

Water

Fish

Direct Contact

Particulate 

Emissions

Surficial 

Soils

Volatilization

Ambient

Air

Subsurface

Soils

003963
FIGURE 1-4 CONCEPTUAL ECOLOGICAL EXPOSURE MODEL FOR TERRESTRIAL RECEPTORS -- PAL

Lower Trophic Level Terrestrial Organisms

PRIMARY SOURCE

Former Barge Cleaning 

Operations

TERTIARY SOURCE

Shallow Groundwater

PRIMARY RECEPTOR

Earthworms, Insects, Other 

Soil-Dwelling Invertebrates

PRIMARY RECEPTOR

Terrestrial Plants

SECONDARY SOURCE

Surface Soils

overland transport

percolation

Potentially Significant TransportMechanism

Direct Contact/Absorption

Potentially Significant Dietary

Ingestion Pathway

Incidental Ingestion

K

E

Y

M

E

ASU

R

ES O

F

E

F

F

E

C

T

PH

YS

I

CA

L

MED

IA

B

I

O

L

O

GI

CA

L

MED

IA (Potential Recep

Upper Tro

Terrestrial organisms vulnerable to direct exposure to surface soil were evaluated using ef

(ESLs) for soil.

Terrestrial wildlife vulnerable to indirect exposures via ingestion of soil and food/prey we

doses to toxicity reference values (TRVs).

P

RIM

A

R

Y

R

E

C

E

P

T

O

R

Soil Microorganisms and

Microbial Processes

Insignificant Dietary IngestionPathway

spills

leaching

003964
FIGURE 1-5 CONCEPTUAL ECOLOGICAL EXPOSURE MODEL FOR SABINE LAKE -- PALMER B

Incidental Sediment Ingestion

Lower Trop

hic Level Aquatic Organisms

PRIM

A

R

Y SO

U

R

C

E

Former Barge Cleaning

Operations

T

E

R

TIA

R

Y SO

U

R

C

E

Sabine Lake Sediments

PRIM

A

R

Y

R

E

C

EPT

O

R

Benthic Macroinvertebrates

PRIM

A

R

Y

R

E

C

EPT

O

R

Fish, Aquatic Plants, Other

Water-Column Animals

SE

C

O

N

D

A

R

Y SO

U

R

C

E

Sabine Lake Surface Water surface runoff

sorption,

deposition

suspension,

desorption

Potentially Significant TransportMechanism

Direct Contact (absorption via

integument, gills)

Potentially Significant Dietary

Ingestion Pathway

Incidental Ingestion

K

E

Y

SE

C

O

N

D

A

R

O

m

(mallar

(os

M

E

ASU

R

ES O

F

E

F

F

E

C

T

PH

YSICA

L

MEDIA

BIO

L

O

GICA

L

MEDIA (Potential Receptors)

Upper Trop

hic Le

Aquatic organisms vulnerable to direct exposures to surface water and sediments were evaluat

ecotoxicological screening levels (ESLs; e.g., ambient water quality criteria, sediment quality 

Wildlife vulnerable to indirect exposures via ingestion of sediment/water and food/prey were e

daily doses to toxicity reference values (TRVs).

PRIM

A

R

Y

R

E

C

EPT

O

R

Reptiles and A

mphibians

Insignificant Dietary Ingestion

Pathway

groundwater infiltration

Insignificant Transport Mechanism

003965