first five-year review report for hart creosoting …

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FIRST FIVE-YEAR REVIEW REPORT FOR HART CREOSOTING COMPANY SUPERFUND SITE

JASPER COUNTY, TEXAS

August 2013

United States Environmental Protection Agency · Region 6 Dallas, Texas

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691999

First Five-Year Review Report Hart Creosoting Company

State Highway 96 Jasper, Jasper County, Texas

List of Acronyms......... :···········································································································.·······3 Executive Summary .......................................................................................................................5

1.0 Introduction ........................................................................................................................... 13

2.0 Site Chronology- .~................................................................................................................... 15

3.0 Background ............................................................................................................................ 16

3.1 PHYSICAL CHARACTERISTICS ......................................................................................... 16 3.2 LAND AND RESOURCE USE ....................................: .. ··············· ..·····································20 3.3 HISTORY OF CONTAMINATION ........................................................................................20 3.4 INITIAL RESPONSE ............................................................................... :..........................21 3.5· BASIS FOR TAKING ACTION ............................................................................................21

4.0 Remedial Actions ...................................................................................................................23

4.1 REMEDY SELECTION .......................................................................................................23 4.2 REMEDY IMPLEMENTATION ............................................................................................26 4.3 OPERATION AND MAINTENANCE (O&M) ................................. :.............., ......................28

5.0 Progress Since the Last Five-Year Review ..........................................................................33

6.0 Five-Year Review Process .....................................................................................................33

6.1 ADMINISTRATIVE COMPONENTS .................................................................................... .33 6.2 COMMUNITY INVOLVEMENT ........................................................................................... 33 6.3 DOCUMENT REVIEW ....................................................................................................... 33 6.4 DATA REVIEW .................. ~ ............................................................................................. 36 6.5 SITE INSPECTION .................................................. :..........................................................41 6.6 INTERVIEWS............... ·.....................................................................................................43

7.0 Technical Assessment ............................................................................................................46

7.1 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION

DOCUMENTS? .................................................................... :.........................•.................46 7.2 QUESTION B: ARE THE EXPOSURE A:SSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS AND

REMEDIAL ACTION OBJECTIVES (RAOs) USED AT THE TIME OF REMEDY SELECTION

STILL VALID? ................................................................................................................47 7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO

QUESTION THE PROTECTIVENESS OF THE REMEDY? ...................................................... .48 7.4 TECHNICAL ASSESSMENT SUMMARY .............................................................................48

8.0 Issues ..........................................................................................................................................50

9.0 Recommendations and Follow-up Actions .......................................................................... 51

10.0 Protectiveness Statements ................................................................................................... 53

11.0 Next Review ..........................................................................................................................50

Appendix A: List of Doctiments Reviewed ...................._...........................................................A-1

Appendix B: Press Notices ........................................................................................................8-1

Appendix C: Interview Forms ..................................................................................................C-1 Appendix· D: Site Inspection Cbecklis·t ....................................................................................0-1

Appendix E: Photographs from Site Inspection Visit ............................................................E-1

Appendix F: Toxicity Review Table ......................................................-.................................. F.:1

Appendix G: Institutional Control Documentation .•.••••••~.................................................... G-1

Appendix H: 2006 ROD Remedial Goals for Environmental Media .................................. H-1

Appendix I: Ground Water Monitoring Data ....................................................~····················I-1

Tables Table 1: Chronology of Site Events .............................................................................................. 15 Table 2: Ground Water Preliminary Remedial Goals ............. ; ..................................................... 24 Table 3: Annual LTRA and O&M Costs ..... : ...................................... : ............. ; ............................ 32 Table 4: Annual TCEQ O&M Costs ..............................................................................................32 Table 5: Current Site Issues .......... · ................................................................................................. 50 Table 6: Recommendations to Address Current Site Issues .......... , ............................................... 51

Figures Figure 1: Location Map for the. name Superfund Site .......... : ........................................................ 18 Figure 2: Detailed Map of the name Superfund Site ... ; ..................................................... '. ........... 19 Figure 3:_ Total PAH Concentrations in Ground Water, 2008-2011 ............................................. .40

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List of Acronyms

AOC ARAR AST BaP CERCLA CFR CIC coc DNAPL EA EE/CA EPA FYR GCL GPM HCC HDPE IC LTRA MCL µg/L NAPL NCP NPL O&M PAH PCP PMZ

.POTW PRG PRP PR/VSI RAO RCC RCRA RD ROD RPM svoc SWMU TBC TCEQ TDLR TIZ

Area of Concern Applicable or Relevant and Appropriate Requirement · Aboveground Storage Tank Benzo( a )pyrene Comprehensive Environmental Response, Compensation, and Liability Act Code of Federal Regulations Community Involvement Coordinator Chemical of Concern Dense Non-Aqueous Phase Liquid Exposure Area Engineering Evaluation and Cost Analysis United States Environmental Protection Agency Five-Year Review Geosynthetic Clay Liner Gallons per Minute Hart Creosoting Company High-Density Polyethylene Institutional Control Long-Term Remedial Action Maximum Contaminant Level Microgram per Liter Non-Aqueous Phase Liquid National Oil and Hazardous Substances Pollution Contingency Plan National Priorities List Operation and Maintenance Polycyclic Aromatic Hydrocarbon ·Pentachlorophenol Plume Management Zone Publicly Owned Treatment Works Preliminary Remediation Goal Potentially Responsible Party Preliminary ReviewNisual Site Inspection Remedial Action Objective Resource Conservation and Recovery Act Containment Cell Resource Conservation and Recovery Act Remedial Design Record of Decision Remedial Project Manager Semi-Volatile Organic Compound Solid Waste Management Unit To-Be-Considered Texas Commission on Environmental Quality Texas Department of Licensing and Regulation Technical Impracticality Zone ·

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TRRP .Texas Risk Reduction Program USACE U.S. Army Corps of Engineers voe Volatile Organic Compound

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Executive Summary

Introduction The Hart Creosoting Company (HCC) Superfund site (the Site) is the location of a former creosote-based wood treating facility. The 23.4-acre Site is located in a wooded industrial and commercial area about one mile south of downtown Jasper in east Texas. Wood treatment operations, which used a steam preconditioning and pressurized creosote process, began in 1958 and ended in May 1993. Other activities at the Site included a sawmill that operated between 1952 and 1958, a pole peeling plant that operated from 1968 to 1978, and a pipe threading shop that operated from 1982 until 1985.

Between 1958 and 1977, the wood treating facility managed creosote waste from treatment operations in six unlined surface ponds. Around 1977, the facility reconfigured these ponds into four ponds (Pond A, Pond B, Pond C and Pond DIE) and used them until November 1985. In 1988, under state oversight, HCC closed the four ponds. HCC then treated creosote wastes generated following pond closure in an on-site wastewater treatment system prior to discharge to a publicly owned treatment works (POTW). Potential contaminant sources at the Site following its abandonment in 1993 included a drip pad, deteriorating aboveground storage tanks, contaminated treatment cylinders, wastewater holding tanks, cooling towers, treated wood storage areas, and contaminated soil and ground water associated with spills and past waste management practices. The U.S. Environmental Protection Agency placed the Site on the National Priorities List (NPL) on July 22, 1999. Contaminants of concern (COCs) primarily include polycyclic aromatic hydrocarbons (P AHs ), a group of compounds present in creosote.

Environmental investigations at the Site led to a time-critical removal action in 1995 where the EPA drained the four ponds and stabilized sludge. The EPA consolidated sludge and visibly contaminated soil and placed the material in a natural ~lay-lined temporary waste cell on site. On September 21, 2006, the EPA selected the remedy for remaining site soil, sediment and surface water contamination in the Site's Record of Decision (ROD). The remedy included removing and treating contaminated surface water, excavating contaminated soil and sediment and disposing of the material in an on-site Resource Conservation and Recovery Act (RCRA) ~ontainment cell, and putting institutional controls in place to restrict the future use of the Site to commercial and industrial uses.

The remedy also included: • Installing a dense non-aqueous phase liquid (DNAPL) (creosote) recovery system to

remove free-phase and residual DNAPL from Zone P-2 (the saturated zone) to the extent practicable, and to reduce dissolved COC mass within the DNAPL source area to affect concentration reductions within the larger dissolved phase plume.

• Applying a technical impracticability waiver to waive the maximum contaminant levels (MCLs) and or ground water preliminary remediation goals (PRGs) and defining a

. Technical Impracticality Zone (TIZ) for the contaminated ground water. • Establishing a Plume Management Zone (PMZ) encompassing the TIZ to prevent ground

water development. • Putting institutional controls in place for the TIZ and PMZ to restrict future ground water

use.

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• Restricting ground water use in and next to the TIZ. • Implementing a ground water monitoring program to evaluate natural attenuation of the

COCs and to verify that the contaminated ground water is managed within the PMZ.

The remedy also called for a hydraulic containment system as necessary, to prevent plume. expansion and to protect Big Walnut Run Creek surface water. However, based upon subsequent study, the EPA determined that it would not need to implement this contingency remedy.

The EPA signed the Site's Preliminary Close-Out Report on September 12, 2008, documenting the completion of remedy construction.

The triggering action for this Five-Year Review (FYR) was the initiation of site remedial action on December 17, 2007.

Remedial Action Objectives As stated in the September 2006 ROD, the Site's remedial action objectives (RAOs) are:

• Prevent exposure to ground water containing COCs at concentrations exceeding the ground water PRGs, minimize dissolved phase plume expansion, and reduce the quantity of free phase and residual NAPL identified in the saturated zone to the extent practicable.

• Prevent leaching of COCs from contaminated soil into ground water resulting in ground water COCs at concentrations exceeding ground water PRGs.

•. Prevent direct contact of adolescent recreational users and/or ecological receptors with sediment containing COCs at concentrations exceeding the PRGs in the un-named tributary and Pond DIE.

• Prevent plume expansion and migration of COCs from ground water into Big Walnut Run Creek surface water and resulting in the surface water COC concentrations exceeding the surface water PRGs.

• Minimize the transport of remaining COCs from the un-named tributary into the downgradient surface water bodies (Big Walnut Run Creek and Neches River).

Technical Assessment The review of documents, applicable or relevant and appropriate requirements (ARARs), risk assumptions and the site inspection indicate that the remedy is mostly functioning as intended by the Site's decision documents. Remedial actions to address contaminated surface water, soil and sediment and placement of contaminated soil and sediment into the RCRA containment cell (RCC) have addressed current threats to human and ecological health from these. media.

In addition, the ground water ingestion pathway is incomplete. The establishment of the PMZ has prevented the operation or placement ofdrinking water weUs in areas near the ground water plume. Operation of the ground water extraction and treatment system has helped minimize plume expansion and contain the plume within the PMZ. If future ground water sampling suggests that the plume may be expanding beyond the TIZ, it may be necessary to establish ground water monitoring wells ou~side the.fMZ.

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Operational issues have hampered the performance of the ground water extraction and treatment system. Biofouling of the system's infiltration trenches resulted in the shutdown of the system . from October 2008 \intil December 2009. During this time, the EPA's contractor installed a series of infiltration wells and converted one monitoring well into an injection well. Due to the poor performance of the injection wells, a majority of the water from the water treatment plant following treatment (about 70 percent) was diverted to the top of the RCC for irrigation. Preliminary estimates indicated that the irrigation level (38 inches per year) may be greater than the water absorption rate of the current grass cover. If this is determined to be the case, then additional treated water discharge options will be identified, including discharging to the POTW. The EPA did not use the irrigation system in 2012 because the injection wells were able to infiltrate the water at the reduced pumping rates resulting from changes to the ground water extraction and treatment system.

One other issue that has hampered performance of the ground water extraction and treatment system was the entry of free-phase DNAPL into water treatment vessels. The preliminary design for the system called for an oil-water separator to provide for the separation and recovery of DNAPL from the combined DNAPL ground water influent stream. During a value engineering review conducted by the EPA and the U.S. Anny Corps of Engineers (USACE), it was decided to defer the procurement and installation of the oil-water separator until more definitive information on DNAPL recovery rates and recovery duration could be obtained.

In lieu of the oil-water separator, the EPA's contractor installed a third vessel filled with 3,000 pounds oforgano-clay as part of the water treatment plant design to provide for low-level oil filtration and removal prior to granulated activated carbon treatment and took additional related steps. After discovering DNAPL in the system in July 2011, the EPA kept the system offline or operating at a reduced rate while extraction wells were modified to include a second, DNAPLonly recovery pump placed in the bottom of each extraction well. The system has been operating continuously since January 2013. Additional sustained operation of the ground water extraction and treatment system and ground water sampling events will be needed before a full determination of the effectiveness of the treatment system can be made.

Overall, the RCC cap is in good condition. However, erosion is evident on sides of the cap where vegetation has not been established. Institutional controls are in place to restrict placement of drinking water wells within the PMZ. However, institutional controls are needed to address onsite and off-site surface and subsurface residual soil/sediment contamination and to limit the future use of the Site and contaminant-impacted off-site areas to commercial and industrial uses.

Federal MCLs were identified as ARARs but waived under a technical impracticability waiver. Some ofthe surface water standards on which surface water discharge goals were based have become more stringent since the signing of the Site's ROD. These standards applied to the temporary treatment and discharge of surface water from Pond DIE and affected storm water to the un-named tributary, which was completed in 2008. However, analytic results of effluent from the temporary water treatment system indicate effluent concentrations were below current, more stringent standards. Exposure assumptions· used in the risk assessment remain valid. Of the 23 COCs, 12 have inhalation toxicity values more stringent now than at the time of the Site's 2006 remedial investigation/feasibility study. Oral toxicity remains unchanged or lessened for all

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COCs. The EPA will consider whether the Site's cleanup goals are still valid, in light of these revised toxicity values.

While vapor intrusion is not currently a risk to on-site water treatment plant workers, it is uncertain if it could pose a human health risk in the future, if structures are built over the plume.

Conclusion The remedy for the Site currently protects hillnan health and the environment in the short term. Current exposure to contaminated media has been addressed through surface water, soil and sediment cleanup actions and is being addressed through operation of a ground water extraction and treatment system and restrictions qn drilling drinking water wells in the PMZ. For the remedy to be protective in the long term, the following actions need to be taken:

• .. Conduct follow-up analysis to verify whether the water absorption capacity of RCC cap soils and vegetation can· withstand current irrigation levels. Ifnot, take necessary steps to enable appropriate infiltration of treated ground water.

• Repair the eroded areas on the RCC cap and establish a suitable v_egetative cover. • Implement enforceable restrictions to prevent potential exposure to cqntaminated

material in the RCC and to restrict future land uses both on site and at off-site contaminant-impacted properties to commercial and industrial activities.

• Consider whether the Site's cleanup goals are still valid, in light of revised toxicity values.

, . • Determine if the potential exists for a future vapor intrusion exposure pathway. Ifso, determine whether it results in an unacceptable risk.

• Evaluate the ground water extraction and treatment system within three years to make sure ttiat recent system improvements are helping the Site achieve applicable RAOs and determine whether a hydraulic containment system is necessary.

Protectiveness Determination: , The remedy for the Site currently protects human health and the environment in the short-term. Current exposure to contaminated media has been addressed through surface water, soil and sediment cleanup actions and is being addressed through operation of a ground water extraction and treatment system and restrictions on drilling drinking water wells in the PMZ. For the remedy to be protective in the long term, the actions listed above in the Conclusion Section need to be taken.

Carl Edlund, Di ect r D;ie I Superfund Division U.S. EPA, Region 6

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Five-Year Review Summary Form

SITE IDENTIFICATION : ~ .~ ~~i . '

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NPL Status: Final

Multiple OUs? Has the site achieved construction completion? No Yes

REVIEW STATUS '

Lead agency: EPA If "Other Federal Agency" was selected above, enter Agency name: Click here to enter text.

Author name (Federal or State Project Manager): Bob Sullivan, with additional support provided by Eric Marsh and Melissa Oakley of Skeo Solutions

Author affiliation: U.S. EPA Region 6, with additional support provided by Skeo Solutions

Review period: 11/06/2012 - 06/30/2013

Date of site inspection: 01/15/2013 -

Type of review: Statutory

Review number: 1

Triggering action· date: 12/1712007

Due date (five years affer triggering action date): 12/1712012

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routing and Concurrence Slip . fBegin Routing Date:f061i8J2ofa Routing Status:I ~ormal q . · · ·

1- .....iTo: (Name, office symbol, route number, building, Agency/Post . Initialsj________J Date

1. cs 06/18/2013 ' Carlos Sanchez @ I I - . -':'.:~---.___,

. 2· Robert Sullivan RS 06/18/2013

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1 .- @ Stephanie Delgado . I:

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Tracking Category:! [ D Five-Year Review

Enforcement Confidential:!• Yes 0 No Email Subject:! Hart Creosoting First Five Year Review

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D Approval D File D Note and Return D AD Signature D As Requested D For Clearance 0 Per Conversation [g] DD/DOD Signature D Circulate 0 For Correction 0 Prepare Reply 0 RA Signature D Comment D For Your Information D Review [g] Concurrence D Investigation D See Me

-- - - - --- - - - - I Remarks: ---- - - - - -I

Hart Creosoting First Five Year Review i i

From: (Name, org, symbol, -Agency/Post) -I - -Room No:ieidg:I'._-6_-s-_F-_RA_--_---~ Carlos Sanchez I Phone Number:! 214.665.8507 i

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Choose EDIT document and turn on Track changes in WORD. I Remember to SAVE the Word Document before exiting Word.

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Then Ciiek on Save & Exit or Save and Route Next. Otherwise your changes will not be saved.

Inquiry/Supporting' - Documents:

Final Document(s):I - - - -- - - -

DO NOT ATTACH DOCUMENTS BELOW HERE! USE THE ATTACH DOCUMENT BUTTON!

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Five-Year Review Summary Form (continued)

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The table below is for the purpose of the summary form and associated data entry and does not replace the two tables required in Section VIII and IX by the FYR guidance. Instead, data entry in this section should match information in Section VII and IX of the FYR report.

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the F.ive-Year Review:

Click here to enter text.

Issues and Recommendations Identified in the Five-Year Review:

OU(s): 1 Issue Category: Remedy Performance

Issue: Treated ground water is now primarily used for irrigation of RCC cap vegetation. The irrigation level (38 inches per year) may be greater than the water absorption capacity of RCC cap soils and vegetation.

Recommendation: Conduct follow-up analysis to verify whether the water absorption capacity of RCC cap soils and vegetation can withstand current irrigation levels. If not, take necessary steps to enable appropriate infiltration of treated ground water (e.g., make arrangements to discharge to the POTW).

Affect Current Affect Future Implementing Oversight Milestone Date Protectiveness Protectiveness Party Party

No Yes EPA EPA 06/30/2014

OU(s): 1 Issue Category: Reme~y Performance

Issue: Erosion is evident on sides of the cap where grass has not been .fully established.

Recommendation: Repair the eroded areas on the RCC cap and establish a suitable vegetative cover.


No Yes State EPA 06/30/2014

OU(s): 1 Issue Category: Institutional Controls

Issue: Institutional controls are not in place to prevent potential exposure to contaminated material in the RCC or. to restrict future land uses on site and at contaminant-impacted off-site p~operties to commercial and industrial activities.

Recommendation: Implement enforceable restrictions to prevent potential exposure to contaminated material in the RCC and to restrict future land uses on site and at contaminant-impacted off-site properties to

.. commercial and industrial activities . 0

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No Yes EPA/State EPA 06/30/2014


Issue: Twelve COCs have inhalation toxicity values more stringent now than at the time of the 2006 Rl/FS.

Recommendation: Consider whether t.he Site's cleanup goals are still valid, in light of these revised toxicity values.



OU(s): 1 Issue Category: Monitoring

Issue: It is unclear at this time if vapor intrusion would pose a human threat if structures were built over the plume in the future.

Recommendation: Review available data and collect new data to determine if the potential exists for a future vapor intrusion exposure pathway, especially since inhalation toxicity values for many of the COCs have changed. If so, determine whether it results in an unacceptable risk.




Issue: Operation of the ground water extraction and treatment system has been impeded by biofouling and entry of DNAPL into the treatment system. Although corrective steps have been taken, the system should be reevaluated within three years to make sure that the system is achieving RAOs.

Recommendation: Conduct an evaluation of the ground water extraction and treatment system within three years to make sure that recent system improvements are helping the Site achieve applicable RAOs and determine whether a hydraulic containment system needs to be added to minimize the plume expansion and to prevent the migration of COCs from ground water to surface water.

Affect Current Affect Future Implementing Oversight Milestone Date Protectiveness Protectiveness Party . Party


Protectiveness Statement(s)

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Operable Unit: Protectiveness Determination: Addendum Due Date 1 Short-term Protective (if applicable):

1 Click here to enter date.

Protectiveness Statement: The remedy for the Site currently protects human health and the environment in the shortterm. Current exposure to contaminated media has been addressed through surface water, soil and sediment cleanup actions and is being addressed through operation of a ground water extraction and treatment system and restrictions on drilling drinking water wells in the PMZ. For the remedy to be protective in the long term, the following actions need to be taken: 1) Conduct follow-up analysis to verify whether the water absorption capacjty of RCC cap soils and vegetation can withstand current irrigation levels. If not, take necessary steps . to enable appropriate infiltration of treated ground water. 2) Repair the eroded areas on the RCC cap and establish a suitable vegetative cover. 3) Implement enforceable restrictions to prevent potential exposure to contaminated material in the RCC and to restrict future land uses both on site and at off-site contaminant-impacted properties to commercial and industrial activities. 4) Consider whether the Site's cleanup goals are still .valid, in light of revised toxicity values. 5) Determine if the potential exists for · a future vapor intrusion exposure pathway. If so, determine whether it results in an unacceptable risk. 6) Evaluate the ground water extraction and treatment system within three years to make sure that recent system improvements are helping the Site achieve applicable RAOs and determine whether a hydraulic containment system is necessary.

Sitewide Protectiveness Statement (if applicable)

For sites that have achieved construction completion, enter a sitewide protectiveness ·determination and statement.

Protectiveness Determination: Addendum Due Date (if applicable): Short-term Protective Click here to enter date.

Protectiveness Statement: The remedy for the Site currently protects human health and the environment in the shortterm. Current exposure to contaminated media has been addressed through surface water, soil and sediment cleanup actions and is being addressed through operation of a ground water extraction and treatment system and restrictions on drilling drinking water wells in the PMZ. For the remedy to be protective in the long term, the following actions need to be taken: 1) Conduct follow-up analysis to verify whether the water absorption capacity of RCC cap soils and vegetation can withstand current irrigation levels. If not, take necessary steps to enable appropriate infiltration of treated ground water. 2) Repair the eroded areas on the RCC cap and establish a suitable vegetative cover. 3) Implement enforceable restrictions to prevent potential exposure to contaminated material in the RCC and to restrict future land uses both on site and at off-site contaminant-impacted properties to commercial and industrial activities. 4) Consider whether the Site's cleanup goals are still valid, in light of revised toxicity values. 5) Determine if the potential exists for a future vapor. intrusion exposure pathway. If so, determine whether it results in an unacceptable risk. 6) Evaluate the ground water extraction and treatment system within three years to make sure that recent system improvements are helping the Site achieve applicable RAOs and determ.ine whether a hydraulic containment system is necessary.

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First Five-Year Review ·Report for

Hart Creosoting Company Superfund Site

1.0 Introduction

The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy in order to determine if the remedy will continue to be protective of human health and the environment. FYR reports document FYR methods, findings and conclusions. In addition, FYR reports identifyissues found during the review, if any, and document recommendations to address them.

The United States Environmental Protection Agency prepares FYRs pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section

•121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). · CERCLA Section 121 states:

"If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews."

The EPA interpreted this requirement further in the NCP; 40 Code ofFederal Regulations (CFR) Section 300.430(f)(4)(ii), which states:

"If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such actions no less often than every five years after the initiation of the selected remedial action."

Skeo Solutions, an EPA Region 6 contractor, conducted the FYR and prepared this report regarding the remedy implemented at the Hart Creosoting Company Superfund site (the Site) in Jasper, Jasper County, Texas. The EPA's contractor conducted this FYR from November 2012 to June 2013. The EPA is the lead agency for developing and implementing the remedy for the Superfund-financed cleanup at the Site. The Texas Commission on Environmental Quality (TCEQ), as the support agency representing the State of Texas, has reviewed all supporting documentation and provided input to the EPA during the FYR process.

This is the first FYR for the Site. The triggering action for this statutory review is the on-site construction start date of the remedial action. The FYR is required because hazardous

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substances, pollutants or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure. This FYR report addresses the entire Site.

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2.0 Site Chronology

Table 1 lists the dates of important events for the Site. Table 1: Chronology of Site Events

Event Wood treatment operations began Hart Creosoting Company (HCC) initiated program to assess impacts of previous waste operation practices on ground water Quality HCC performed hydrogeologic site investigation HCC performed expanded hydrogeologic site investigation The EPA conducted a preliminary review/visual site inspection to identify potential solid waste management units (SWMUs) and areas of concern (AOC) HCC discontinued wood treatment operations and abandoned the Site The EPA performed a site inspection The EPA initiated a time-critical removal action to drain four ponds, stabilize sludge, and remove wood treatment equipment and process buildings Time-critical removal action completed by the EPA The EPA listed the Site on the National Priorities List {NPL) The United States Army Corp. of Engineers (USACE) performed an engineering evaluation and cost analysis (EE/CA) The EPA initiated Site's remedial design The EPA completed Site's remedial design The EPA completed Site's remedial investigation (RI) and issued Record of Decision {ROD) The EPA initiated second remedial design (RD) The EPA completed secoi:id RD and approves remedial action The EPA initiates on-site remedial action The EPA issued Preliminary Close-Out Report documenting the completion ofremedy construction The EPA transferred operation and maintenance responsibility for the Resource Conservation and Recovery Act Containment Cell to the TCEQ The EPA completed remedial action and began long-term remedial action (LTRA) The EPA completed LTRA 2010 Annual Operations Report Creosote dense non-aqueous phase liquid (DNAPL) detected at the water treatment plant and recovery well R-2 The EPA shut down water treatment plant after detecting DNAPL at the plant and at recovery well R-2 The EPA restarted water treatment plant The EPA shut down water treatment plant after discovering DNAPL itt all four recovery wells The EPA conducted testing to evaluate the feasibility ofDNAPL recovery at the Site The EPA completed DNAPL recovery test results and recovery strategy evaluation The EPA completed L TRA 2011 Annual Operations Report The EPA completed retrofitting ofrecovery wells with a dual-phase pumping system and restarted water treatment plant The EPA completed LTRA 2012 Annual Operations Report

Date 1958

October 1984

July 1985 July 1986

1988

May 1993 June 14, 1994

July 24, 1995

October 5, 1995 July 22, 1999

February 2001

August 15, 2001 August 15, 2003

September 21, 2006

March 13, 2007 September 20, 2007 December 17, 2007

September 12, 2008

August 17, 2009

August 4, 2010

April 6, 2011 July 12, 2011

July 12, 2011

October 1, 2012

November 1, 2011

December 2011

February 22, 2012

April 6, 2012

November 2012

April 8, 2013

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3.0 Background

3.1 Physical Characteristics

The Site is the former location of a creosote-based wood treating facility located on 23.4 . acres. It is situated just west of State Highway 96, about 1 mile ~outh of Jasper in Jasper County, Texas (Figure 1). An un-named tributary flows along the Site's west-southwest boundary, converging with Big Walnut Run Creek about one mile south of the Site. Densely forested private property (Crown Pine Timber 3 LP) borders the Site to the south and west. Commercial property borders the Site to the north. State Highway 96 borders the Site to the east.

Major features of the Site included the former process area, wastewater treatment areas and surface impoundments (ponds), a temporary waste cell constructed during the 1995 removal action, and non-process areas. Current features at the Site include the water treatment plant, a Resourc.e Conservation and Recovery Act (RCRA) containment cell (RCC), site fencing, and ground water recovery and monitoring wells. The Site also includes an area to the east of the RCC and water treatment plant that was not subject to the remedial action. This area includes an abandoned office building, a shop building, the former pipe threading facility building, a single-family residence and a portion of the yard of another single-family residence. The Site is not located in or near any rare, threatened, or endangered species and critical habitats.

The EPA also established a Technical Impracticality Zone (TIZ) and a Plume Management Zone (PMZ) as part of the Site's selected remedy (Figure 2). The TIZ extends south from the southeast comer of the Site, covering the area directly above the contaminated ground water plume. In this.area, the restoration of ground water quality to drinking water standards is not required. Surrounding the TIZ is the PMZ, which creates a buffer zone around the TIZ. The purpose of the PMZ is to restrict ground water use within and adjacent to the TIZ by preventing the drilling of any water wells.

Historical operations performed at the Site used coal tar creosote and pentachlorophenol (PCP) dissolved in diesel to treat railroad ties and utility poles. Wood treatment processes occurred at the Site between 1958 and 1993. Other site operations included a sawmill that operated between 1952 and 1958; a pole peeling plant that operated from 1968 to 1978 and a pipe threading shop that operated from 1982 until 1985. Improper waste management and disposal practices during wood treatment facility operations resulted in the release of creosote, a listed hazardous waste. Operators released creosote into soil, ground water, surface water and sediment at the Site and downgradient of the Site.

The principal threats posed by hazardous substances present at the Site included direct contact with contaminated soil and sediment, ingestion of contaminated ground water by future residents, and ecological receptor exposure to contaminated ground water that discharges to Big Walnut Run Creek.

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The Site's topography slopes from northeast to southwest, with the ground surface elevation descending from 200 feet mean sea level near the northern site property line to 189 feet mean sea level along the bank of the un-named tributary. The Site is located in the area where the Jasper Aquifer outcrops, or intersects, the ground surface.

The Site is underlain by alluvium composed of varying proportions of clay, silt and sand size material extending to depths up to 220 feet. The subsurface geology was grouped into three low-permeability and three permeable zones. The low-permeability zones consisting primarily of silt- to clay-size material are informally referred to as Zones 1-l, 1-3 and 1-5. Sandwiched between the low-permeability units are permeable Zones P-2, P4 and P-6, consisting primarily of sand-size material. Zones 1-1 and P-2 are the uppermost units at the Site and were the primary zones investigated during the remedial investigation (RI) and supplemental RI. Although there is some variability across the Site, Zone 1-1 generally occurs at depths between ground surface and 23 feet, and Zone P-2 at depths between 23 and 63 feet. Ground water in Zone P-2 flows in a southsoutheast direction at an estimated velocity of 52 feet per year. Zone P-2 ground water flows beneath the un-named tributary and does not discharge into the un-named tributary.

Water level data obtained from a multi-level monitoring well (MW-19) installed about 200 feet north of Big Walnut Run Creek indicates a neutral vertical gradient. Interpretation of the regional topographic and hydrogeologic setting suggests that Big Walnut Run Creek is a local ground water discharge zone for hydrostratigraphic Zone P-2 ground water flow.

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Figure 1: Site Location Map

0 0.1 0 .2 0.4 0 .6 Legend•--=::11--=:::::i••••====:J•Miles

() [=:J Site Boundary

Hart Creosoting Company Superfund Site Jasper, Jasper County, Texas NORTH

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding the EPA's response actions at the Site.

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Figure 2: Detailed Site Map

L~•nd

0 Site Boundary • •• • Estimated Boundary ofthe-NAPL Source Area 0 0.05 0 .1 0.2 A Singl• Compl•tion Monitor w.11 --reehnical lmprllClimllty Zon. (TIZI••-==:::i•••••Miles ffi CMT W•I c Plu""' M.,agemenl Zon• {PMZj

D Fonner HCC Facility Boundary L _IRCRAContlllnm.ntC.rl(RCCJ

0 Hart Creosoting Company Superfund Site Jasper, Jasper County, Texas

NORTH

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding the EPA's response actions at the Site.

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·· ..•.-·r: '•

3.2 Land and Resource Use

The Site is comprised primarily of the former HCC facility property. This property is vacant except for the water treatment plant. The EPA removed all process buildings and all of the wood treating equipment from this area during a 1995 removal action. The area · east of the Site not subject to the remedial action is in use for small-scale automotiverelated purposes and for residential uses. Portions of. the un-named tributary impacted by Site cleanup activities are located west and south of the Site on private property owned by a timber management company.

The EPA based the reasonable exposure assessment assumptions and risk characterization conc!usions discussed in the Site's Record of Decision (ROD) on past land uses at the Site and the City of Jasper's redevelopment plans for the area. The EPA considers the Site's remedy protective for industrial and commercial uses. The un-named tributary and Big Walnut Run Creek could be used for recreation.

The Site is located in an area where the Jasper Aquifer intersects the ground surface. The aquifer is the sole water supply for the cities of Jasper and Newton, Texas. A previous search ofTexas Water Development Board records indicated that there are no registered drinking water wells within a half-mile radius of the Site. The Upper Jasper County Water

. Authority's well #10, located 3,900 feet northwest (upgradient) is the nearest water supply well. Two public and 39 private wells are located within four miles of the Site. The two public water supply wells, used as sources of drinking water, serve about 12,000 users and are located about three miles north and upgradient of the Site at depths of 764 and 802 feet below ground level, respectively. The private wells are used for drinking water and irrigation purposes. They are not impacted by site-related contamination. · ·

A ground water beneficial use classification performed in conjilnction with preparation of the Site's Remedial Investigation/Feasibility Study (Rl/FS) Report conclu4ed that ground water Underlying and immediately downgradient of the Site is a Class IIB ground water resource. The Class IIB classification indicates that ground water is not currently in use but could be used in the future.

3.3 History of Contamination Wood treatment operations, which used a steam preconditioning and pressurized creosote process, began in 1958 and ended in May ,1993. Between 1958 and 1977, operators managed creosote waste from treatment operations in six unlined surface impoundments (ponds). Around 1977, HCC reconfigured these ponds into four ponds (Pond A, Pon~ B, Pond C, and Pond DIE), which it used until November 1985. In October 1984, in response to a compliance agreement with the Texas Department of Water Resources, HCC initiated a program to assess the impacts of past waste management practices on ground water quality. ·

Under Texas Water Commission oversight in 1988, HCCclosed the four ponds. HCC removed creosote waste from the four ponds and treated the waste in two biological treatment cells and an aeration pond, and then transferred it to a holding tank prior to

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discharge to City of Jasper's publicly owned treatment works (POTW). HCC treated creosote wastes generated following pond closure in an on-site wastewater treatment system prior to POTW discharge.

Potential contaminant sources at the Site following its abandonment in 1993 included the drip pad, deteriorating aboveground storage tanks, contaminated treatment cylinders, wastewater holding tanks, cooling towers, treated wood storage areas, and contaminated soil and ground water associated with historic spills and waste management practices.

Texas and federal regulatory agencies performed numerous soil~ ground water, surface water and sediment sampling events following the Site's closure in 1993. There are 16 different polycyclic aromatic hydrocarbon (P AH) compounds typically associated with creosote-based wood treating sites. Regulators identified elevated P AH concentrations in all environmental media sampled.

3.4 Initial Response In October 1984, in response to a compliance agreement with the Texas Department of Water Resources, HCC initiated a program to assess the impacts of past waste management practices on ground water quality.

In 1988, EPA contractor A.T. Kearney conducted a preliminary review - visual site inspection (PR/VSI) at the Site. The PR/VSI identified potential solid waste management units (SWMUs) and areas of concern (AOCs) that might have released hazardous constituents that could pose a threat to human health and the environment. The PR/VSI identified 27 SWMUs and seven AOCs at the Site. It recommended further investigation of 10 SWMUs and four AOCs.

1995 Removal Action In 1995, the EPA performed a time-critical removal action to drain the four ponds (Pond A to Pond DIE) and stabilize the remaining sludge. The EPA consolidated the sludge and visibly contaminated soil and placed the material in an on-site, natural clay-lined temporary waste cell (the temporary waste cell). 1 The EPA then plac;d a clay cover over the cell and seeded it with grass for erosion control.

The EPA listed the Site on the National Priorities List (NPL) on July 22, 1999.

3.5 Basis for Taking Action ·A U.S. Army Corps of Engineers (USACE) contractor conducted an engineering evaluation and cost analysis (EE/CA) from December 2000 to January 2001 under the EPA's removal program. The focus of the EE/CA field investigation was to determine the extent of contaminated soil remaining after the time-critical removal action in the former process area and the volume of contaminated soil placed in .the temporary waste cell. It also assessed the impact of historical releases on surface water and sediment downstream of the Site.

1 The EPA later replaced the temporary waste cell with the RCC as part of the remedial action.

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The EPA initiated an RI for the Site in 2004, followed by a supplemental RI in 2006, to further characterize the nature and extent of contamination originally documented by the earlier investigations and to provide data to support the completion ofhuman health and ecological risk assessments. The risk assessments provided the basis for taking action and identified the contaminants and exposure pathways that needed to be addressed by the remedial action. The risk assessment findings suggested there was a potential for receptors. to experience adverse effects from exposure to P AHs, metals, semi-volatile organic compounds (SVOCs) and benzene.

Final contaminants of concern (COCs) were identified as constituents with individual hazard quotients above 1.0, hazard indices above 1.0, or carcinogenic risks greater than one in one million (lxl0-6). There was no evidence of metals or bis(2ethylhexyl)phthalate being associated with any site-related activities or processes. Thus, for marginal risks from these constituents (that isi hazard quotients between 3 and iO), remedial actions were not considered necessary.

Specific conclusions included:

• The process and non-process areas presented risk to industrial workers from P AHs, but the risk was within the EPA acceptable risk range of 1x10-6 to 1x104

. There is a potential unacceptable risk at the non-process area if the future use of the non-process area will be changed from commercial/industrial uses to recreational use (e.g., a soccer venue).

• The sediments in Pond DIE presented risks to both human health and ecological receptors from P AHs, SVOCs and benzene. Amphibians exposed to surface water. may also be at risk, though the exact constituents of concern are Unknown.

• The un-named tributary presented risks to both human health and ecological receptors from P AHs in surface water and sediment.

• Big Walnut" Run Creek presented no risk to human health and ecological receptors. • Ground water presented risk to human health from P AHs (carcinogenic and

noncarcinogenic), SVOCs and benzene.

Overall, findings suggested that Big Walnut Run Creek presented no risk to human health and ecological receptors. However, there were risks to human health and ecological receptors in Pond DIE and the un-named tributary,as well as to human health in the process and non-process areas and in shallow ground water.

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4.0 Remedial Actions

In accordance with CERCLA and the NCP, the overriding goals for any remedial action are protection of human health and the environment and compliance· with applicable or relevant and appropriate requirements (ARARs). A number ofremedial alternatives were considered for the Site, and final selection was made based on an evaluation of each alte11_1ative against nine evaluation criteria that are specified in Section 300.430(e)(9)(iii) of the NCP. The nine crjteria include:

1. Overall Protectiveness of Human Health and the Environment 2. Compliance with ARARs 3. Long-Term Effectiveness and Permanence 4. Reduction of Toxicity, Mobility or Volume of Contaminants through Treatment 5. Short-term Effectiveness 6. Implementability 7. Cost 8. State Acceptance 9. Community Acceptance

4.1 Remedy Selection The EPA selected a final remedy in the Site's 2006 Record of Decision (ROD). Site remedial action objectives (RAOs) are:

• Prevent exposure to ground water containing COCs at concentrations exceeding the ground water preliminary remedial goals (PRGs), minimize dissolved phase plume expansion, and reduce the quantity of free phase and residual non-aqueous phase liquid (NAPL) identified in the saturated zone to the extent practicable.

• Prevent leaching ofCOCs from contaminated soil into ground water resulting in ground water COCs at concentrations exceeding ground water PRGs.

• Prevent direct contact of adolescent recreational users and/or ecological receptors with sediment containing COCs at concentrations exceeding the PRGs in the unnamed tributary and Pond DIE. .

• Prevent plume expansion and migration of COCs from ground water into Big Walnut Run Creek surface water resulting in the surface water COC concentrations exceeding the surface water PRGs.

• Minimize the transport of remaining COCs from the un-named tributary into the downgradient surface water bodies (Big Walnut Run Creek and Neches River).

Selected Remedy for Contaminated Soil and Sediment The selected remedy for contaminated soil and sediment included:

• Implementing a drainage ditch to replace the portion of un-named tributary that contains soil/sediment PRO exceedances.

• Removing and treating contaminated surface water in Pond DIE and the unnamed tributary:

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• Excavating soil and sediment containing COCs exceeding the human health and ecological PRGs in the temporary waste cell, former process area, the un-named tributary and Pond DIE. '

• Disposal of excavated soil/sediment into an RCC designed to meet RCRA subtitle C landfill requirements. 2

. ·

• Backfilling the excavations with clean soil or soil below the PRGs and revegetating the backfilled areas.

• Monitoring ground water for the effectiveness of the RCC. • Implementing institutional controls to maintain a future industrial or commercial

land use scenario for both on-site and off-site affected properties and to maintain the integrity and protectiveness of the RCC.

Appendix H shows the PRGs for contaminated site media as defined in the ROD.

Selected Remedy for Contaminated Ground Water The ground water remedy selected in the ROD included:

• Installing a DNAPL recovery system to remove the free phase and residual DNAPL from the saturated zone to the extent practicable.

• Applying a Technical Impracticality (TI) waiver to waive the maximum contaminant levels (MCLs) and or ground water PRGs and defining a TI zone for the contaminated ground water. ·

• Establishing a PMZ encompassing the TIZ to prevent ground water development. • · Restricting ground water use in and next to the TIZ. • Applying a technical impracticability waiver to waive drinking water ARARs. • Implementing institutional controls for a designated PMZ to restrict ground water

use. • Implementing a ground water monitoring program to evaluate natural attenuation

of the COCs and to verify that the contaminated ground water is managed within the PMZ. .

• Implementing a hydraulic containment system as necessary, to prevent plume expansion .and to protect Big Walnut Run Creek surface water.

Table 2 shows the PRGs for ground water and ground water to surface water protection as stated in the 2006 ROD.

Table 2: Ground Water Preliminary Remedial Goals

Ground Water PRG Ground Water to Surface coc fo~/L) Water Protection PRG (1uz/Ll

PAHs Acenaphthene 130 153 Acenaphthylene NA 153 Anthracene NA . 2 Benzo(a)anthracene 0.085 5.4

2 The RCC replaced the temporary waste cell on site.

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Ground Water PRG Ground Water to Surfacecoc lus!IL' Water Protection PRG (1111/L)

Benzo(a)pyrene 0.2* 0.093 Benzo(b )tlouranthene 0.052 0.093 Benzo(g,h, i)perylene NA 0.093 Benzo(k)flouranthene NA 0.093 Chrysene · 19 47 Dibenz( a,h )anthracene 0.0033 1.2 Fluoranthene NA 41 Fluorene 87 . 73. Indeno( 1,2,3-c,d)pyrene 0.052 0.093 Napthalene 100 1,667 Phenanthrene 130 200 Pyrene 5 707 Others 2,4-Dimethylphenol 250 700 2-Methvlnaphthalene 57 420 2-Methylphenol 660 7,467 3 &/or 4-Methvlphenol 660 7,467 Benzene 5* 707 Carbazole 43 379 Dibenzofuran 4.3 493 Notes: µg/L = microgram per Liter *:The PRG is the maximum contaminant level (MCL) NA: Not Applicable

The 2006 ROD adopted the PRGs listed in its RAOs and remedial goals section as the final remedial goals. The ROD refers to the values as PRGs throughout the document. Therefore, the final re.medial goals for ground water are presented as PRGs in this table and throu!iliout the FYR.

The EPA further clarified its approach to addressing contaminated ground water in its 2007 Final Design Criteria Report. First, the EPA noted that the contingency ground water containment remedy selected in the ROD would not be necessary. Laboratory analysis of a sample collected from new monitoring well (MW-19), installed along the projected point of ground water entry to Big Walnut Run Creek, did not detect P AHs or other SVOCs above the 0.1 microgram per Liter (µg/L) reporting limit. In addition, the report noted that evaluation of historical and recently acquired ground water analysis results indicated no apparent expansion of the plume within the area of investigation over the past three y.ears.

The report also clarified that the main cleanup alternative selected in the ROD included:

• A DNAPL recovery system to remove free-phase and residual creosote from Zone P-2 to the extent practicable, and to teduce dissolved COC mass within the DNAPL source area to affect concentration reductions within the larger dissolved phase plume.

• A TIZ to identify the area where restoration of ground water quality to PRGs will not be performed.

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• Institutional controls for a designated PMZ to restrict use of ground water within and adjacent to the TIZ.

• Long-term ground water monitoring to evaluate the effectiveness of the remedy ·and to verify that the contaminated ground water is managed within the PMZ.

4.2 Remedy Implementation

On September 20, 2007, the EPA approved the Site's remedial design and the remedial action work plan and started remedial action. EPA contractor CH2M HILL conducted remedial activities as planned. Remedial action activities included:

Surface Water Removal and Treatment • Removal of the surface water from Pond. DIE prior to excavation of sediment

PRO exceedance. • Pumping of pond water into a retention pond before treatment by a granular

activated carbon system. • Discharge of the treated water into the nearby creek after analysis showing

surface water PRO requirements were met.

Sediment Removal • Removal of the.sediment in Pond DIE containing COCs exceeding sediment

PROs. This included mixing the sediment with .contaminated soil, stockpiling it on site and later placing it in the RCC. CH2M HILL excavated about 930 cubic yards of sediment from.the pond and collected samples to ensure complete removal. of sediment with PRO exceedances.

• Removal of sediment in the un-named tributary. This included excavating sediment down to the ground water table and about 2 feet into the banks. CH2M HILL further excavated banks with visual contamination until there was no visual evidence of contamination. CH2M HILL excavated about 2,920 ctibic yards of sediment from the un-named tributary and collected samples from tributary banks and floor every 100 feet to document the levels of any remaining COCs. No additional excavation was conducted in the areas where samples showed PRO exceedances.

Soil Excavation • Removal of surface soil with PRO exceedances initially down to 2 feet below

ground surface. CH2M HILL collected confirmation samples from excavation walls and floors to determine if additional removal was needed. The contractor excavated a total of about 2, 160 cubic yards of Stµ"face soil and stockpiled the material on site before placing it in the on-site RCC.

• Removal of subsurface soil with PRO exceedances in the former process area and the temporary waste cell. CH2M HILL excavated the subsurface soil to an initial elevation of 1s·o feet above·mean sea level and collected confirmation samples from excavation floors and wans (one composite sample per 100 feet of side wall) to determine if additional excavation was required. No further excavation was conducted when the ground water table was reached if confirmation samples

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encountered PRO exceedance. The contractor excavated a total of about 38,070 cubic yards of soil from the subsurface excavations and 43, 100 cubic yards of soil from the temporary waste cell and stockpiled the material on site until its placement into the RCC.

· Backfill ofExcavation • Backfilling of surface and subsurface soil areas with clean soil from off-site

sources and from the RCC excavation. CH2M HILL conducted and tested backfill compaction to meet design specifications.

• Backfilling of the un-named tributary excavation was backfilled to the preexcavation level with clean fill material imported from off site.

RCC Construction • Construction of an RCC on site, which consisted of a multilayer liner, a leachate

collection system, a 2-foot protective soil cover and a multilayer cap .

. Installation ofRecovery Wells • Installation of three additional recovery (extraction) wells (R2, R3 and R4) along

the estimated boundary of the DNAPL source area. • Installation of a submersible well pump with an adjustable frequency drive at

each well as well as a well vault to house pump instrumentation and controls.

Construction ofGround Water Extraction and Treatment System • Construction of a water treatment plant southeast of the RCC. The building

includes a secondary containment enclosing equalization tank, filter tanks, injection/backwa5h tank and pumps. A continuous concrete curb cast integrally with monolithic slab forms the containment area.

• Construction of a ground water extraction and treatment system, which included two treatment trains. CH2M J-IILL designed the system for a maximum capacity of 125 gallons per minute. The two parallel treatment trains allow operational flexibility over a wide range of flow and reduce system down time during media change out. The contractor designed the system such that treated water would flow to the injection backwash tank with gravity drainage to the infiltration· trenches.

• Trenching and the installation of two infiltration high-density polyethylene (HDPE) conveyance pipes and associated fittings and cleanouts. CH2M HILL installed a perforated HDPE pipe near the bottom of the trench in a zone of granular backfill to aid infiltration.

• In addition to the treated water infiltration/injection trenches, CH2M HILL installed a surface water discharge pipe (an overflow pipe) to allow diversion of the overflow from the infiltration trenches through the surface water discharge pipe to the un-named tributary.

CH2M HILL designed the system to operate on a continuous basis without significant operation and maintenance (O&M) personnel present. A programmable logic controller can control operation of the ground water extraction wells automatically. Remote desktop

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software allows for remote monitoring and control of the treatment system. The programmable logic controller is designed to shut dowri the system in instances of equipment malfunction and notify the O&M operator.

The preliminary design for the treatment system called for an oil-water separator to provide for the separation and recovery of DNAPL from the combined DNAPL ground . \Yater influent stream. During a value engineering review conducted by the EPA and USACE, it was decided to defer the procurement and installation of the oil-water separator until more definitive information on DNAPL recovery rates and recovery duration could be obtained. ·

. In lieu of the oil-water separator, CH2M HILL installed a third vessel filled with 3,000 pounds of organo-clay'included as part of the water treatment plant design to provide for low-level oil filtration and removal prior to granular activated carbon treatment. Additionally, CH2M HILL set the well pumps about 25 feet above the well bottom to prevent inadvertent DNAPL entry into the pump intake in the event that increased hydraulic gradients resulting from ground water pumping mobilized DNAPL into the recovery wells.

The EPA and the TCEQ conducted a final site inspection on September 10, 2008, and determined that the contractor had constructed the remedy in accordance with remedial design plans and specifications. The EPA issued the Site's Preliminary Close-Out Report in September 2008.

A long-term ground water monitoring program has been implemented to evaluate the effectiveness of the remedy and to verify that contaminated ground water with COC concentrations greater than the remedial goals specified in the ROD is hydraulically contained within the PMZ.

Establishment ofthe TIZ, PMZ and Ground Water Institutional Controls

As required by the ROD, the EPA established a PMZ (Figure 2), which encompasses the TIZ, to ensure that future ground water pumping does not mobilize contaminants beyond the TIZ. The ROD also required institutional controls to prevent potential exposure to contaminated material placed in the RCC, to maintain the integrity of the RCC, and to restrict future land uses at the Site and at impacted off-site properties to commercial and industrial activities. See Section 6.3 for a discussion ofrelated institutional controls.

4.3 Operation and Maintenance (O&M) The ground water portion of the remedy is currently in the long-term remedial action (L TRA) phase. L TRA activities primarily include operation of the ground water extraction and tre.atment system and ground water monitoring. The contaminated soil/sediment remedy is in the O&M phase. O&M activities for contaminated soil/sediment include oversight of the RCC. Specific activities include RCC cap inspection, cap maintenance and mowing, leachate collection system and leachate . detection system inspections, and sampling of the leachate collected in the systems. The

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EPA oversees operations of the ground water extraction and treatment system and related O&M activities and ground water monitoring. The EPA transferred O&M responsibility for the RCC to the TCEQ in 2009.

Ground Water Extraction and Treatment LTRA Activities and Issues CH2M HILL started operation of the ground water extraction and treatment system on September 26, 2008. CH2M HILL shut the system down on October 2, 2008, because of the infiltration trenches' slow.infiltration rate. CH2M HILL conducted additional exploratory test pits 81\d infiltration tests in December 2009 along the north and east sides of the water treatment plant and-an injection test conducted at monitoring well MW-IA and recovery well R-1. Based on the test results, CH2M HILL proposed three new. injection wells and the conversion of well MW-IA to an injection well. Following design and installation of the injection wells and the injection.manifold, CH2M HILL restarted the system on December 9, 2009. The system ran continuously until July 2011, and then intermittently through December 2012. The system has run continuously since January 2013.

The ground water extraction and treatment system recovered about 1,400 pounds of dissolved-phase contaminant mass from 21.8 million gallons of treated ground water between December 2009 and December 2011. System pumping rates, which averaged about one-half the remedial design basis for the 2011 period, resulted in nominal P AH concentration declines near the recovery wells and within the upper portion ofZone P-2.

The four injection wells were unable to sustain long-term injection rates greater than 5 to 10 gallons per minute each, and required frequent rehabilitation to maintain this level of performance. Biofouling (sulfate and iron-reducing bacteria) was determined to be the primary cause of poor injection well performance. Subsequent biocide injections on the influent and effluent side of the water treatment plant and periodic disinfection of the injection Wells were unable to control biofouling. Due to the poor performance of the injection wells, a majority of the water from the water treatment plant (about 70 percent) following treatment was diverted to the top of the RCC for irrigation. Preliminary estimates indicated that the irrigation level (38 inches per year) may be greater than the water absorption rate of the current grass cover.

In addition to problems caused by biofouling, the sampler noticed free-phase DNAPL a.t several of the sampling port locations while conducting monthly water treatment plant sampling on July 12, 2011. Once samples were collected, CH2M HILL shut the system down to investigate the origin of the DNAPL. Inspection of the treatment plant's organoclay and granular activated carbon vessels confirmed that free-phase DNAPL had impacted the media. Samples collected at the wellhead of each of the extraction wells indicated free-phase creosote was being pumped from recovery well R-2 to the equalization tank. ·

After the impacted vessels and filter media replacement were cleaned, the treatment plant resumed operations on October 1, 2011. However, well R-2 remained offline to prevent free-phase DNAPL from entering the treatment vessels. On November 1, 2011, CH2M

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HILL gauged all of the recovery wells using an oil-water interface probe. The gauging efforts revealed that DNAPL was also present in recovery wells R-1, R-3 and R-4. DNAPL thickness in each of the four recovery wells measured 4.09 feet at well R-1, 7.52 feet at well R-2, 8.24 feet at well R-3 and 3.03 feet at well R-4. CH2M HiLL immediately stopped pumping operations from the recovery wells and shut down the treatment plant to prevent DNAPL from getting into the treatment plant vessels. Upon inspection of the equalization tank, CH2M HILL determined that DNAPL did not enter the system. The system remained offline until more detailed information on the presence of DNAPL in the extraction wells and a recovery/exclusion strategy could be developed.

CH2M HILL performed a DNAPL recovery pilot test to assess DNAPL recoverability in wells R-2 and R-4 in December 2011. As documented in the Hart Creosoting Company Superfund Site DNAPL Recovery Pilot Test Report, the pilot test results indicated that recoverable DNAPL was present in each of the four recovery wells. In addition, results suggested that DNAPL recovery rates could be enhanced through concurrent ground water pumping. Initial DNAPL recovery rates upwards of 1,000 gallons per month were determined to be possible. However, these were likely to drop off quickly if an aggressive program was put in place. The pilot test report also explained the RAOs specified in the Site's ROD require reducing the quantity of free-phase and residual DNAPL in the saturated zone to the extent practicable (RAO Nq. 1) and preventing the expansion of the dissolved-phase plume to preclude COC migration into Big. Walnut Run Creek surface water. The report added that by removing DNAPL and dissolved-phase contaminant mass from Zone P-2, it is expected that the boundary of the dissoived-phase ground water plume can be stabilized such that it remains within the PMZ.

Based on the results ofDNAPL recovery testing, in 2012 CH2M HILL placed an airoperated DNAPL-only recovery pump in the bottom of each recovery well. DNAPL is now pumped from the wells via an existing underground pipe to the treatment plant where water and DNAPL are separated in a decant tank. Any entrained water is separated in the decant tank and pumped to the water treatment plant equalization tank. Once sufficient DNAPL has accumulated, the material will be disposed of or recycled. In the event a high-level condition is reached, a level control in the decant tank can turn power off to the DNAPL pump controller.

The water treatment plant operated on a limited basis during the design and implementation of the DNAPL recovery system. The treatment system pumped and treated 4.2 million gallons ofground water in 2012. The treated ground water was infiltrated back to the formation through the Zone P-2 injection wells. The irrigation system was not used in 2012 because the injection wells were able to infiltrate the water at the reduced pumping rates of 10 to 20 gallons per minute.

The four recovery wells were pumped at reduced rates in 2012 to: 1) prevent DNAPL upwelling and entrainment in the ground water pump intake, 2) allow for SOI]le contaminated ground water treatment while the DNAPL pumping equipment was being

· installed and tested, and 3) maintain flow through the plant. The 4.2 million gallons pumped in 2012 is less than one-half the volume pumped in 2011 (10.l million gallons)

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and 2010 (11.2 million gallons). With pumping equipment now installed to control DNAPL upwelling in the recovery wells, the EPA expects higher pumping rates in 2013 ..

In addition to reduced pumping rates, the ground water treatment system was offline for over 25 percent of the time in 2012. One reason was related to unauthorized attempts to remotely login to the systems' computer work station in February. In response, CH2M HILL added a more aggressive security feature for remote access. A second issue centered on a chemical compatibility issue with the diaphragm material instailed on the four new DNAPL pumps. As a result, the manufacturer replaced the diaphragms on each of the pumps. CH2M HILL installed the new pumps in early November. A third issue then resulted from the accumulation of condensate in the air supply line and at the pumps. The DNAPL recovery system has a compressed air dryer installed at the control box; however, the humidity at the Site was higher than what the manufacturer anticipated and thus condensate accumulated in the lines between the air dryer and the wellhead, adversely affeeting DNAPL recovery pump performance. The manufacturer then rebuilt the pumps and inspected the air dryer for defects. ·

CH2M HILL conducted ground water sampling twice in 2008, and once in 2009, 2010 and 2011. The Site's monito~ing well network includes 52 sampling ports at 12 locations. The network includes three single completion wells installed in 1983 during the RCRA facility investigation, six single-completion and multi-level well nests installed during the 2004 to 2006 Rl/FS, and three single-completion and multi-level well nests installed during the 2008 to 2009 remedial action construction phase. All sampling ports except one (MW-17-7) are screened in Zone P-2. Multi-level well MW-17-7 has a screen port open to Zone I-3. Several monitoring wells were plugged and abandoned in 2008 during RCC construction, including MW-2/2A, MW-8, MW-9, MW-IOA/IOB, MW-1 lA/1 lB, MW-12A/12B and MW-13A/13B.

According to the 2012 Annual Operations Report, more detailed plume stabilization criteria will be developed as additional remedy performance monitoring data are collected over the next two to three years. These criteria will guide recovery welf · operations, help define COC natural attenuation rates and help determine when recovery well operations can be scale~ back and eventually discontinued. ·

RCC O&MActivities and Issues Since 2010, the TCEQ has inspected and maintained the RCC cap, controlled the vegetation on and around the cap area, and inspected and sampled the leachate systems on a semi-annual basis. Inspection of the leachate system found that a large volume of leachate has accumulated in the leachate system. However, since the leachate volume ha.s not increased over time, the TCEQ believes that the leachate system is not leaking and is functioning as designed. According to the TCEQ's O&M contractor, the leachate accumulated during construction of the cell. Chemical analysis of the leachate samples verify it is composed primarily of water. The TCEQ is in the process of revising the August 2011 O&M Plan and Sampling and Analysis Plan. The TCEQ is also in the process of removing and disposing of the leachate. Periodic inspection of the RCC indicates that the grass and surface water runoff control measures are functioning

31

adequately during most periods. However, the banks of the RCC are still susceptible to erosion during heavy·rainfall events. Grass hydroseed applications have not taken on the banks of the RCC and testing has shown that the soil is nutrient poor.

O&MCosts The 2006 ROD estimated annual LTRA costs at $401,803. The EPA completed the operational and functional period for the water treatment plant in September 2009. The Site will be in LTRA until September 2019. After LTRA is complete, annual O&M costs are estimated at $92,189.The higher LTRA costs (Table 3) in comparison with the ROD L TRA estimates are likely attributable to the problems encountered in 2010, 2011 and 2012 and modifications to the ground water extraction and treatment system. In 2010, modifications to the system included installation of the irrigation system and installation of the chemical feed system. In 2011, modifications to the system included installation of a new irrigation system to better distribute water across the top of the RCC. In 2012, modifications to the system included installation of the DNAPL recovery system and subsequent repairs.

Table 3: Annual L TRA and O&M Costs

Year Total LTRA Cost (rounded to the

nearest $1,000) 2012 . $413,000

2011 $485,000

2010 $686,000

Estimated annual O&M costs in the Site's ROD for the annual inspection and maintenance of the RCC are $31,392. Table 4. shows annual O&M costs incurred by the TCEQ over the last two years.

Table 4: Annual TCEQ O&M Costs

Year Total O&M Cost ·2012 $11,900 2011 $24,000

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5.0 Progress Since the Last Five-Year Review

This is the Site's first FYR.

6.0 Five-Year Review Process

6.1 Administrative Components

EPA Region 6 initiated the FYRin December 2012 and scheduled its completion for June 2013. EPA Remedial Project Manager (RPM) Robert Sullivan led the EPA site review team, which also included contractor support provided to the EPA by Skeo Solutions. In November 2012, the EPA held a scoping call with the review team to discuss the Site and items of interest as they related to the protectiveness of the remedy currently in place .. The review schedule established consisted of the following activities:

• Community notification. • Document review. • Data collection and review. • Site inspection. • Local interviews. • EYR Report development and review.

6.2 Community Involvement

In January 2013, the EPA published a public notice in the Jasper Newsboy newspaper announcing the commencement of the FYR process for the Site, providing contact · informatfon for EPA RPM Bob Sullivan and Community Involvement Coordinator (CIC) Donn Walters and inviting community participation. The press notice is available in Appendix B. No one contacted the EPA as a result of the advertisement.

The EPA will make the final FYR Report available to the public. The EPA will place copies of the document in the designated site repository: Jasper Public Library, located at 175 East Water Street in Jasper, Texas. Upon completion of the FYR, the EPA will place a public notice in the Jasper Newsboy newspaper to announce the availability of the final FYR Report in the Site's document repository.

6.3 Document Review

This FYR included a review of relevant, site-related documents including the ROD, Remedial Action Report and recent monitoring data. A complete list of the documents reviewed can be found in Appendix A. ·

ARARs Review

CERCLA Section 12l(d)(l) requires that Superfund remedial actions attain "a degree of cleanup of hazardous substance, pollutants, and contaminants released into the

33

environment and ofcontrol of further release at a minimwn which assures protection of hwnan health and the environment." The remedial action must achieve a level of cleanup that at least attains those requirements that are legally applicable or relevant and appropriate. Applicable requirements are those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under federal environmental or state environmental or facility siting laws that specifically address a hazardous substance, remedial action, location, or other circwnstance found at a CERCLA site. Relevant and appropriate requirements are those standards that, while not "applicable," address problems or situations sufficiently similar to those encountered at · the CERCLA site that their use is well suited to the particular site. Only those state standards more stringent than federal requirements may be applicable or relevant and appropriate. To-Be-Considered (TBC) criteria are non-promulgated advisories and guidance that are not legally binding, but should be considered in determining the necessary remedial action. For example, TBCs may be particularly useful in determining health-based levels where no ARARs 'exist or in developing the appropriate method for conducting a remedial action.

Chemical-specific ARARs are health- or risk-based nwnerical values or methodologies which, when applied to site-specific conditions, result in the establishment of nwnerical values. These values establish an acceptable amount or concentration of a chemical that may remain in, or be discharged to, the ambient environment. Examples of chemicalspecific ARARs include maximwn contaminant levels (MCLs) under the federal Safe . Drinking Water Act and ambient water quality criteria enwnerated under the federal Clean Water Act.

Action-specific ARA.Rs are technology- or activity-based requirements or limits on actions taken with respect to a particular hazardous substance. These requirements are triggered by a particular remedial activity, such as discharge of contaminated ground water or in-situ remediation.

Location-specific ARARs are restrictions on hazardous substances or the conduct of the response activities solely based on their location in a special geographic area. Examples include restrictions on activities in wetlands, sensitive habitats and historic places.

Remedial actions are required to comply with the chemical-specific ARARs identified in the ROD. In performing the FYR for compliance with ARARs, only those ARARs that · address the protectiveness of the remedy .are reviewed.

Ground Water ARARs As stated in the 2006 ROD, it is technically impracticable to restore the ground water quality to meet the MCLs and the risk-based ground water cleanup levels, due to the presence of P AHs and free phase and residual DNAPL in the subsurface. Therefore, those ARARs were waived ..

Soil/Sediment ARARs

34

The soil/sediment ARARs.specified in the 2006 ROD were relevant during the remedy's construction, but are not relevant to the remedy's continued protectiveness. Cleanup goals ~or soil COCs were calculated based on protection of ground water. Cleanup goals for sediment COCs were calculated to protect human health, ecological receptors and ground water. See Section 7 .2 for a discussion of soil and sediment cleanup goals.

Surface Water Standards According to the 2006 ROD, cleanup goals for surface water COCs were developed to protect human health and ecological receptors. The lower of two surface water screening values (human health and ecological) was selected as the cleanup goal. Human health values were selected using the following hierarchy: Texas Surface Water Quality Standards (30 TAC §307), National Recommended Ambient Water Quality Criteria, and calculated according to the TCEQ guidance document Determining Protective Concentration Levels for Surface Water and S~diment. Ecological screening values were obtained from the TCEQ's Guidance for Conducting Ecological Risk Assessments at Remediation Sites in Texas (2006 revision) or were developed according to the method provided in the guidance. These standards applied to the temporary treatment and discharge of surface water from Pond DIE and affected storm water to the un-named tributary, which was completed in 2008. These standards no longer apply to the remedy. Some of the surface water standards on which the surface water discharge goals were based haye become more stringent since the signing of the Site's ROD. However, analytic results of effluent from the temporary water treatment system indicate effluent concentrations were below current, more stringent standards.

Institutional Control Review

Due to the presence of PAHs and free phase and residual NAPL in multi lithology zones, including permeable and less permeable zones (e.g., Zones 1-1, P-2, 1-3, and possibly P4), the EPA deemed it technically impracticable to restore ground water quality to meet the drinking water standards within a reasonable time frame. The Site's ROD established a TIZ for ground water at the Site. The 13-acre TIZ is defined by the zone of ground water containing naphthalene at concentrations greater than the 100 µg/L PRG. The TIZ is defined depth wise as the ground water present in Zones P-2 and P-4 at depths between 10 and 200 feet below ground surface.

As required by the Site's ROD, the EPA established a PMZ (Figure 2), which encloses the TIZ, to ensure that future ground water pumping does not mobilize contaminants beyond the TIZ.

The ROD also required PMZ institutional controls, including enforceable deed notices or restrictive covenants, to eliminate the potential exposure pathway by preventing water supply wells within the PMZ. The objective of the institutional controls is to prevent ingestion of contaminated ground water in the P-2 and P-4 zones. The EPA submitted a PMZ/TIZ registration letter to the City of Jasper, the Texas Department of Licensing and Regulation (TDLR) and the Southeast Texas Ground Water Conservation District (Appendix G- Exhibit 1). As part of the letter, the EPA also included a surveyed map

(

35

and legal description of the PMZ (Appendix G - Exhibit 2). Jasper Code of Ordinances, Chapter 26, Subsection 51 also includes restrictions for wells, whether inside or within one mile of the City, previously drilled or which may have been abandoned, to be plugged or sealed, as appropriate, to protect the public water supply (Appendix G- Exhibit 3).

The ROD also required institutional controls, including access restrictions and land use restrictions, to prevent breaching of the RCC cover and to preclude development of the Site for residential use. The objective of the institutional controls is to allow for future industrial and commercial land uses both on site and at the off-site affected properties and to maintain the integrity and protectivt?ness of the RCC. According to the ROD, institutional controls will potentially be implemented through a government ordinance, an enforceable restrictive covenant or a deed notice with both on-site and off-site property owners. At the time of the 2013 FYR site inspection, these institutional.controls were not

· yet in place.

The EPA attempted to contact on-site and off-site property owners regarding the need to implement these institutional controls. The EPA sent institutional control packages to applicable parties on July 27, 2012, to establish deed restrictions for the affected properties. However, the property owners did not agree to sign the necessary agreements. Ifproperty owners fail to agree to the institutional controls, the EPA will request that the State of Texas issue deed notices for the property. The institutional control package is included in Appendix G- Exhibit 4.

6.4 Data Review

Surface Water The EPA's contractor CH2M HILL removed surface water from Pond DIE prior to excavation of sediment PRO exceedances. CH2M HILL then discharged the treated water into the nearby creek after it was analyzed and met the surface water PRO requirements.

Soil/Sediment CH2M HILL removed all near-surface_contaminated soil, and sediment exceeding the ROD's specified remedial goals and consolidated the material in the RCC in 2008.

Ground Water Efforts to achieve the RA Os for ground water are ongoing. The ROD identified P AHs as the Site's primary COCs. The PAHs are ass~ciated with residual wood treating solutions released to soil and ground water at the Site. Sixteen different P AH comP.ounds are typically associated with creosote wood treating sites.

Operation ofthe Ground Water Extraction and Treatment System Analytical results show that the treatment system met ground water PROs for SVOCs and low-level PAHs for most parameters while the system was operational between 2010 and 2012. In 2010, CH2M HILL detected naphthalene at concentrations above the 100 µg/L ground water PRO in samples collected during August, September and October 2010 on Treatment Train 1. In addition, the .contractor detected an exceedance of naphthalene

36

above the PRG on Treatment Train 2 in October 2010. As a result of these detections, CH2M HILL performed backwashing of the organo-clay and granular activated carbon vessel to clean and restratify the filter media. Since naphthalene concentrations on Treatment Train 1 did not improve following the backwashing event, CH2MHILL replaced the organo-clay and granular activated carbon media.

In 2011, CH2M HILL detected naphthalene, acenaphthene and dibenzofuran at concentrations above their respective PRGs in samples collected on the final effluent port during the April 2011 sampling event for Treatment Train 1. As a result of these detections, CH2M HILL increased the backwashing frequency of the organo-clay and granular activated carbon vessel to clean and restratify the filter media. Following the backwashing events, naphthalene, acenaphthene and dibenzofuran concentrations decreased on Treatment Train 1 and remained below their respective remedial goals.

Samples collected from water treatment plant sampling ports on July 12, 2011- the day that CH2M HILL detected the entry of free-phase DNAPL into the system - indicated a higher than usual concentration of SVOCs, low and high molecular weight PAHs, due to the presence ofDNAPL in the water stream. CH2M HILL detected several high molecular weight P AH constituents above their PRGs in the final effluent. The system was either shut down or operated on a limited basis from July 2011 through December 2012 while CH2M HILL evaluated the DNAPL issue, retrofitted the recovery wells with dual-phase extraction pumps to capture the DNAPL, and made subsequent modifications and repairs to the new pumps.

In 2012, CH2M HILL detected high molecular weight P AHs, including benzo( a)anthracene, benzo( a)pyrene, benzo(b )fluoranthene, benzo(k)fluoranthene, benzo(g,h,i)perylene, indeno(l,2,3-c,d)pyrene; and dibenz(a,h)anthracene, at concentrations above their respective ground water or surface water discharge PRGs in samples collected on the final effluent port during the May 2012 sampling event on Treatment Train 2 and benzo(g,h,i)perylene and dibenz(a,h)anthracene at concentrations above their respective PRGs during the August 2012 sampling event, also on Treatment Train 2. As a result of these detections, CH2M HILL increased the backwash frequency for the organoclay and granular activated carbon vessel to flush and homogenize the filter · media. Following the increased backwashing frequency modification, the contaminant concentrations in the Treatment Train 2 effluent decreased and remained below their respective remedial goals for the remainder of 2012.

Ground Water Sampling Results Routine semi-annual ground water sampling that began in 2008 Wa$ limited to one event in 2009, 2010 and 2011. During 2010, CH2M HILL performed monitoring under the response action task order under operational and functional activities where the semiannual ground water sampling requirement was not as rigorous. The spring 2012 event was eliminated to free-up financial resources to purchase and install the DNAPL recovery equipment. The EPA cancelled the fall 2012 event due to the Hurricane Sandy storm event. Due to the presence ofDNAPL and limited ground water extraction

37

operations conducted in 2012, ground water quality conditions for the 2012 reporting period are estimated to be comparable to those present in 2011, as reported in the 2011 annual operations report.

Laboratory analysis results for all monitoring wells-between 2008 and 2011 are presented by individual well location in Appendix I. Rather than discuss each P AH compound individually, total PAH and total PAH concentrations expressed in benzo(a)pyrene (BaP) equivalents were calculated. The total P AH concentration provides an indicator of overall contaminant distribution in ground water and is used to determine whether the plume boundary is changing within the PMZ. Total PAH concentrations in ground water between 2008 and 2011 are presented below in Figure 3.

Since 2008, total P AH concentrations have increased at several locations, with the most recent notable increase taking place at monitoring well MW-18. For example; total PAH concentrations at MW-18 port 3 (MW-18-3) increased from 4,570 µg/L to 10,000 Jig/L between 2008 and 2011. The highest total P AH concentration in the monitoring wells located near the RCC perimeter and upgradient of the TIZ was 26 µg/L in June 2010 (MW- I). The highest total P AH concentrations in the monitoring wells located inside the PMZ, but just outside the TIZ, were 18.9 µg/L (MW-15-5) in June 2010 and 20.4 µg/L (MW-16-2) in June 2011. The highest concentratio.n in MW-19, located outside the TIZ

·in the far southern portion of the PMZ, was 18.1 µg/L (MW-19-3 and MW-19-4) in June 2011. The highest concentrations for all wells were at MW-20, MW-22 an4 MW-18, located in the center of the TIZ.running north to south. According to the 2011 Annual Operations Report, the presence ofDNAPL in the area directly upgradient of these wells is a significant source of the dissolved-phase contaminants. Reducing these concentrations will require DNAPL recovery and aggressive ground water pumping.

Overall, data suggests that the plume has not stabilized; concentrations for individual · wells and individual well ports have fluctuated from year-to-year sampling events. For example, total PAH concentrations for MW-14A, a single completion-well in the northern portion of the TIZ, increased from 723 µg/L to 1, 160 µg/L between December 2008 and June 2009, declined to 8.68 µg/L in June 2010, and then increased to 26.8 µg/Lin June 2011. Total PAH concentrations in MW-18, a multi-level well port in the center of the plume, also varied considerably from year to year and across its ports. For instance, concentrations in port 4 ofM·W-18 increased from 2,030 µg/L to 3,110 µg/L between June 2009 and June 2010, but declined to 1,530 µg/L in June 2011. Although there have been slight increases in total P AH concentrations in PMZ wells outside the TIZ, the plume appears to be well within the PMZ. According to the 2011 Annual Operations Report, the core region of the plume is advancing downgradient toward and beyond MW18. However, the larger diffuse portion of the plume, as defined by the 100 µg/L naphthalene concentration boundary, remains within the TIZ.

If the plume migrates beyond the PMZ, the remedy will no longer be considered protective. In the future, additional data may be needed to determine if this is the case.

38

In addition to reviewing total P AH concentrations site wide, this data review also examined individual COC concentrations at MW-19. MW-19 is located along the projected point of ground water entry to Big Walnut Run Creek. Comparison of ground water monitoring results collected between June 2008 and July 2011 with the ground water to surface water PRGs indicates there have been some COC detections, including acenaphthene and naphthalene, in MW-19 ground water samples, but at concentrations well below the ground water to surface water PRGs. Sampling data for MW-19 is included in Appendix I.

Owing to the presence of free-phase and residual DNAPL in permeable and less permeable zones, the ROD stated that restoring ground water quality to drinking water standards within a reasonable timeframe was technically impracticable. Therefore,

_ restoration of ground water quality to drinking water standards within the TIZ is not required under the ROD.

39

648 )(XX)

14.7

Woll Jun.OS

361J

1250 3450

3610

Image Source: 2011 Annual Operations Report, Version 1.0 for the Hart Creosoting Company Superfund Site

LEGEND

Single Completion " Monitor Well

• Recovery Well

• CMT Monitor Well

~ Injection Well

--Water Body

- Site Boundary

~ PMZ Boundary

-·- TIZ Boundary Estimated TPAH Plume Boundary

1. Aifri~ Phocoeraph ~ten In Dec. 2008. l. RCC! RCRA C.Onta nment ce1 3. WTP:. Water TrNtment P11nt Bu lcfi,.. 4. TPAH : Total PAH Conuntt1tion (uc/l)

Total PAH Distribution in Groundwater Hort Creosoting Company

Superfund Site Jasper, Texas

1. This figure only does not include results for all sampling wells or for all sampling ports for 2008 to 2011. To see the complete set of data, see Appendix I. 2. The June 2009 values presented in the figure for MW-I and MW-6 inadvertently list the June 2008 values. The correct values for the June 2009 sampling event for MW-1 and MW-6 should be 1.13 µg/L and 0.969 µg/L, respectively. See Appendix I for the complete data set.

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6.5 Site Inspection

A site inspection was conducted on January 15, 2013. The participants included EPA Region 6 RPM Bob Sullivan; Patrick Appel, CH2M HILL; Lam Tran, the TCEQ's representative for TCEQ Project Manager Andy Bajwa; and Eric Marsh and Melissa Oakley from EPA contractor Skeo Solutions. ·

The RPM, EPA contractor, TCEQ representative and Skeo Solutions staff met at Jasper City Hall at 9:00 a.m. and conducted local government interviews with Jasper City Manager Tommy Boykin and Jasper Public Works Director Greg Kelley. Site inspection participants then interviewed Kari Ellis, Executive Director of the Jasper Economic Development Corporation, at the corporation's offices. Site inspection participants then interviewed John Martin, General Manager of the Southeast Texas Groundwater Conservation District, at the Conservation District Office.

Following the interviews, site inspection participants met at the Site and began the inspection at the facility entrance. Participants toured the inside of the on-site water treatment plant. A tall, lo.cking fence, clearly marked with signs surrounds the plant. Plant operator Trey Pumphrey assisted with the tour. The treatment system appeared to be in good condition and was operational at the time of the inspection. The treatment system consists of two treatment trains, which include a large equalization tank, clay filter tanks,

, granular activated carbon tanks and a brown tank used to store recovered creosote. The entire system is contained within concrete secondary containment. All tanks are clearly marked. The plant control room contains all system breakers, an automated system that monitors and controls plant operations and all site-related health and safety plans, O&M plans and regulatory documentation.

Site participants then walked from the treatment plant to the RCC. A fence, marked clearly with signs, surrounds the entire RCC. The fence appeared to be in good condition. Participants walked the perimeter of the RCC. The RPM pointed out the vegetated areas on the top of the cap as well as the sides of the cap where vegetation has been difficult to · establish. The RPM identified let-down ditches and interception berms built in 2010 to channel storm water off the cap. The RPM also pointed out the sprinkler irrigation system that uses treated effluent from the treatment plant to irrigate cap vegetation. While vegetation on the landfill cap appeared to be healthy, there were a few areas of standing water and a few areas void of vegetation. Various points along the cap's edge, particularly on the western edge of the RCC, exhibited signs oferosion. There was no evidence of burrowing or settlement.

The RPM identified the leachate collection area on the southern edge of the cap, which consists of open-air leachate pipes where the TCEQ can access and pump RCC leachate. The TCEQ has not yet pumped leachate from the underground leachate storage tank but is preparing to do so.

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The RPM identified the location ofthe four extraction and recovery wells, all contained within locked white enclosure's. All extraction and recovery wells appeared to be in good condition. The RPM also identified ground ~ater monitoring wells, which were locked and in good condition.

· After the site inspection, site inspection participants drove to the southern edge of the site property and identified the point-of-compliance monitoring well located on the southern edge of the PMZ, a few hundred feet northwest of Big Walnut Run Creek.

Appendix E includes photographs taken during the site inspection. Appendix D includes a complete Site Inspection Checklist.

At 3:00 p.m., inspection participants then conducted an interview with Jasper Col;lllty. Judge Mark Allen at the county courthouse. · ·

During the site inspection, Skeo Solutions staff members visited the Site's local information repository, located at the Jasper Public Library on 175 East Water Street in Jasper. The repository contained a few site-related documents, including the HRS Document Record (1997), the Final EE/CA (2001 ), the Public Health Assessment (2000), the Proposed Plan (2000), the Administrative Record for the 1996 Removal Action and the Site's Community Relations Plan (2000). The Site's 2006 ROD and the 2008 , Preliminary Close-Out Report were not included in the information repository records.

I .

On January 16, 2013, the EPA RPM, CH2M Hill's representative, and a Skeo Solutions staff member met at Crown Pine Timber's offices in Jasper and conducted an interview with Keith Stephens. Mr. Stephens is a forester with Crown Pine Timber, the company that owns property adjacent to the Bite.

A Skeo Solutions staff member visited the Jasper County Tax Appraisal District Office located at 137 North Main Street in Jasper. The Skeo staff member collected parcel boundary information for parcels within arid near the Site. The staff member then · researched parcel ownership information. ·

. 42

6.6 Interviews

The FYR process included interviews with parties impacted by the Site, including the current landowners and regulatory agencies involved in site activities or aware of the . Site. The purpose was to document the perceived status of the Site and any perceived problems or successes with the phases of the rem~dy implemented to date. The report summarizes the interviews below. Appendix C provides the complete interviews.

Bob Sullivan: Bob Sullivan is the EPA RPM for the Site. Mr. Sullivan submitted his interview question responses via email on January 23, 2013. Overall, Mr. Sullivan has a positive impression of the project. The EPA believes that the selected remedy is currently protective of human health and the environm.ent and allows for appropriate reuse and that the remedy is performing as designed. The EPA acknowledges that institutional controls for the RCRA Subtitle C landfill are needed. The EPA mailed.a deed notice to the heir of the site property owner, Mr. James Day, on July 27, 2012. No response was received. The EPA plans to mail another deed notice by certified mail. Ifno response is received, the EPA will seek a deed notice through the State of Texas.

Pat Appel: Pat Appel is the representative from CH2M Hill, the EPA's O&M contractor for the Site. Mr. Appel submitted his interview responses via email on January 24, 2013. Mr. Appel explained that encountering free phase DNAPL ~t the Site has impacted the overall operations strategy and continuous operations of the water treatment plant. However, he added that performance observations, supported by a DNAPL recovery pilot test, have established the efficacy of the recovery ~nd injection well system and the water treatment plant, to mobilize and recover a significant long-term ground water contaminant source. The recommended solution to recover DNAPL included retrofitting the recovery wells with a dual-phase pumping system that was installed and operational in November 2012. Other challenges have been the ability of the injection wells to accept treated water, which has declined since system startup, and biofouling.

To address infiltration issues, the treatment system was modified to include piping modifications to the adjacent landfill cap surface that allows treated effluent to be reused for irrigation of the landfill cap vegetative cover. To address biofouling; the system was modified to include installation of metered pumps that disperse iron sequestering and biocide agents. These agents have helped reduce backwashing frequency and have

.increased the treatability of the filtration media. In general, Mr. Appel noted that the ground water remedy has contained the dissolved-phase plume within the PMZ, reduced or stabilized COC concentrations in portions of the plume, and recovered a portion of the DNAPL mass th~t acts as a source for the dissolved-phase plume.

Chuck Neeley: Chuck Neeley is the representative from URS Corporation (URS), the TCEQ's O&M contractor. Mr. Neeley submitted his interview responses via email on January 23, 2013. Mr. Neeley explained that the RCC is functioning as expected but needs repair in areas to replace top soil and vegetation. In addition, Mr. Neeley identified several issues to be addressed: tree removal from the RCC's side slopes; repair of cap

43

erosion areas, and replacement of top soil and vegetation in some cap locations. Leachate from the leachate collection and detection systems needs to be removed. This accumulated during construction of the cell. URS performs semi·annual leachate measurements, leachate analysis, RCC cap inspections and periodic mowing. Leachate levels have remained. constant and analytical results have remained the same since URS began performing O&M activities at the Site in 2011. ·

Andy Bajwa: Andy Bajwa is the TCEQ's Project Manager for the Site. Mr. Bajwa submitted his interview questions via email on January 22, 2013. Overall, Mr. Bajwa believes that there are no major issues or concerns at the Site. Mr. Bajwa has only been involved with O&M activities for the RCC to date. In 2008, the TCEQ inspected and sampled the leachate detection and collection systems. Since 2010, on a semi·annual basis, the TCEQ has inspected and maintained the RCC cap, controlled the vegetation on and around the cap area, and inspected and sampled the leachate systems. Overall, he stated that the remedy is effective and protective. Operational issues with the ground water extraction system are of a temporary nature, as expected. Operational issues have included loss of infiltration trench capacity, fouling of the injection wells screens, and free product entering the treatment system. These issues have been partially resolved and the system is operational, although at a lower capacity. Mr. Bajwa also explained that, in the current fiscal year, the TCEQ is planning to address minor issues with the cap, including repairing the side slope, adding nutrients to the soil, resodding t~e slope and reconfiguring the sprinkler system to irrigate this area.

The TCEQ is not completely comfortable with the status of the institutional controls at the Site. With the EPA's "tiered approach" to institutional controls, the "Ground Water Contamination and Restricted Water Well Drilling Area at the Hart Creosoting Superfund Site" letter, dated July 23, 2012, provides only one tier. While the EPA may consider the TDLR restrictions and the city ordinances as institutional controls, these instruments do not meet the TCEQ's Texas Risk Reduction Program institutional control requirements.

John Martin: John Martin is the General Manager of the Southeast Texas Groundwater Conservation District. Mr. Martin's interview took place at the Southeast Texas Water Conservation District Office on January 15, 2013. He is aware of the former environmental issues at the Site and the cleanup activities that have taken place to date and feels well informed regarding the Site's status and remedial progress. Mr. Martin indicated that it would be very helpful if the EPA could send institutional control documentation directly to the local well drillers. Direct communication might help reinforce the importance, purpose and details of the well drilling restrictions. Mr. Martin also indicated that due to the lack of an established land use zoning/classification program in the area, it may be challenging to implement institutional controls. restricting land use.

Tommy Boykin and Greg Kelley: Tommy Boykin is the Jasper City Manager. Greg Kelley is the Jasper City Director of Public Works. Both individuals were interviewed at the same time at Jasper City Hall on January 15, 2013. They are aware of the former environmental issues at the Site and the cleanup activities that have taken place to date

44

·and feel well informed regarfling the Site's status and remedial progress. Concerning the Site's institutional controls, they expressed the need to work more closely with the local Ground Water Conservation District to prevent the drilling of wells in areas where drilling is not permitted. They would like more help to ensure the enforcement of the ordinance preventing well drilling and plan to discuss the issue with the District in the near future.

Kari Ellis: Kari Ellis is the Executive Director of the Jasper Economic Development Corporation. The EPA interviewed Ms. Ellis at the Jasper Economic Development Corporation's offices on January 15, 2013;. Ms. Ellis is aware of the former environmental issues at the Site and the cleanup activities that have taken place to date and feels well informed regarding the Site's status and remedial progress. No official commercial, residential or industrial designation exists for local properties. Ms. Ellis is not aware of any changes concerning changes in projected land use at the Site.

Mark Allen: Mr. Allen is a judge in Jasper County. The EPA interviewed Mr. Allen at the Jasper County Courthouse on January 15, 2013. He is aware of the former environmental issues at the Site and the cleanup activities that have taken place to date and feels well informed regarding the Site's status and remedial progress. Mr. Allen is not aware of any ch~ges to state laws or local regulations that might affect the protectiveness of the Site's remedy, or of any problems with unusual or unexpected activities at the Site. Mr. Allen feels that the EPA keeps involved parties and surrounding neighbors informed of activities at the Site, and that the EPA should continue with its current methods of keeping people informed.

Keith Stephens: Mr. Stephens is a Forester with Crown Pine Timber, which owns property adjacent to the Site. The EPA interviewed Mr. Stephens at the company's offices in Jasper on January 16, 2013. The representative is aware of the former environmental issues at the Site and has no concerns regarding the cleanup activities. He also feels well informed regarding the Site's status and remedial progress and has no suggestions as far as keeping residents or other businesses informed.

45

7.0 Technical Assessment

7.1 Question A: Is the remedy functioning as intended by the decision documents?

The review of documents, ARARs, risk assajnptions and the site inspection indicate that the remedy is mostly functioning as intended by the site decision documents. Remedial actions to address contaminated surface water, soil and sediment and placement of contaminated soil and sediment into the RCC have addressed current threats to human and ecological health from these media. In addition, the ground water ingestion pathway is incomplete. The establishment of the PMZ has prevented the operation or placement of drinking water wells in areas near the ground water plume and the nearest public water supply well is located.3,900 feet to the northwest and upgradient of the Site.

The ground water extraction and treatment system is withdrawing and treating contaminants in ground water to levels below PRGs. The system is also extracting freephase DNAPL. Although ground water monitoring data suggests that the plume has not fully stabilized, with contaminant concentrations increasing at some well locations and depths and decreasing in others, operation of the system appears to have helped minimize plume expansion and contain it within the PMZ. If future ground water sampling suggests that the plume may be expanding beyond the TIZ, it may be necessary to establish ground water monitoring wells outside the PMZ.

Operational issues have hampered the performance of the Site's ground water extraction and treatment system. Biofouling of the ground water extraction and treatment system's treated water infiltration trenches resulted in the shutdown of the system from October 2008 until December 2009. During this time, CH2M HILL installed a series of infiltration wells and converted one monitoring well into an injection well. Due to the poor performance of the injection wells, a majority of the water from the yvater treatment plant following treatment (about 70 percent) was diverted to the top of the RCC for irrigation. Preliminary estimates indicate that the irrigation level (38 inches per year) may be greater. than the water absorption rate of the current grass cover. If this is determined to be the case, then additional treated water discharge options will be identified, including discharging to the POTW. The EPA did not use the irrigation system in 2012 because the injection wells were able to infiltrate the water at the reduced pumping rates resulting from changes to the ground water extraction and treatment system. ·

One other issue that has hampered performance of the ground water extraction and treatment system was the entry of free~phase DNAPL into water treatment vessels. The preliminary design for the system called for an oil-water separator to provide for the separation and recovery ofDNAPL from the combined DNAPL ground water influent stream. During a value engineering review conducted by the EPA and USA CE, it was decided to defer the procurement and installation of the oil-water separator until more definitive information on DNAPL recovery rates and recovery duration could be obtained. In lieu of the oil-water separator, CH2M HILL installed a third vessel filled with 3,000 pounds oforgano-clay as part of the water treatment plant design to provide for low-level oil filtration and removal prior to granular activated carbon treatment and took additional

46

related steps. In July,2011, treatment plant operators discovered free-phase DNAPL in water treatment vessels. After discovering DNAPL in the system in July 2011, the EPA kept the system offline or operating at a reduced rate while extraction wells were modified to include a second, DNAPL-only recovery pump in the bottom of each well. The system has operated continuously since January 2013. Additional sustained operation of the ground water extraction and treatment system and ground water monitoring will be needed before a full determination of the effectiveness of the system can be made.

The TCEQ oversees and maintains the RCC cap while the EPA oversees the operation of the extraction and treatment system and the ground water monitoring program. Both the water treatment plant and RCC are enclosed within properly maintained fencing. A sign near the entrance to the Site is clearly marked to inform passersby and discourage trespassing. All monitoring and extraction wells are operational, in good condition and were locked at the time of th~ inspection.

Overall, the RCC cap is in good condition. However, erosion is evident on sides of the cap where grass has not been fully established. The TCEQ is aware of this issue and plans to address it.

Institutional controls are in place to restrict placement of drinking water wells within the PMZ. However, institutional controls need to be put in place to address on-site and offsite surface and subsurface residual soil/sediment contamination and limit the future use of the Site and contaminant-impacted off-site areas to commercial and industrial uses.

7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives (RAOs) used at the time of remedy selection still valid?

The federal MCLs were identified as ARARs, but were waived under a technical impracticability waiver.

Some of the surface water standards on which the surface water discharge goals were based have become more stringent since the signing of the Site's ROD. These standards applied to the temporafy treatment and discharge of surface water from Pond DIE and affected storm water to the un-named tributary, which was completed in 2008. These standards no longer apply to the remedy. However, analytic results of effluent from the temporary water treatment system indicate effluent concentrations were below current, more stringent standards.

The-baseline risk assessment determined that Big Walnut Run Creek did not present a risk to human health and ecological receptors. However, human and ecological risks were identified in Pond DIE and the un-named tributary. Human health risks were identified in the process and non-process areas and in shallow ground water. Exposure assumptions in the risk assessment remain valid.

The 2006 ROD based some of the Site's cleanup goals on site-specific risk. To help determine whether these cleanup goals are still valid, this FYR compared the toxicity

47

values in the 2006 Rl/FS against the current toxicity values. Appendix F presents this comparison. Of the 23 COCs, 12 have inhalation toxicity values more stringent now than at the time of the 2006 RI/FS. Oral toxicity remains unchanged or is less stringent for all COCs. The EPA will consider whether the Site's cleanup goals are still valid, in light of these revised toxicity values.

Contaminants that may result in vapor intrusion include volatile organic compounds (VOCs) and other vapor-forming chemicals, such as some SVOCs. Ground water COCs for the Site include both VOCs and SVOCs. The 2006 ROD did not identify vapor intrusion as a site risk. No occupied structures are located above the contaminated ground water plume, but the construction of structures for industrial, commercial or residential use over the plume is possible. The EPA currently recommends the use of multiple lines of evidence to adequately evaluate the vapor intrusion pathway and the associated potential risks to human health. Therefore, the collection and review ofnew data is recommended to determine if the potential exists for a future vapor intrusion exposure pathway, especially since inhalation toxicity values for many of the COCs have changed. If so, the next step would be to determine whether it results in an unacceptable risk.

There have been no changes in standardized risk assessment methodologies that could affect the protectiveness of the remedy ..

7.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

There are no new or previously unidentified risks and there are no impacts from natural disasters that could affect the performance or protectiveness.of the remedy. No other information has come to light that could call into question the protectiveness of the remedy. '

.. 7.4 Technical Assessment Summary

The review of documents, ARARs, risk assumptions and the site inspection indicate that the remedy is mostly functioning as iiitended by site decision documents. Remedial actions to address contaminated surface water, soil and sediment and placement of contaminated soil and sediment into the RCC have addressed current threats to human and ecological health from these media. In addition, the ground water ingestion pathway is incomplete. The establishment of the PMZ has prevented the operation or placement of drinking water wells in areas near the ground water plume. Operation of the ground water extraction and treatment system has helped minimize plume expansion and contain the plume within the PMZ. If future ground water sampling suggests that the plume may be expanding beyond the TIZ, it may be necessary to establish ground water monitoring . wells outside the PMZ.

Operational issues have hampered the performance of the Site's ground water extraction and treatment system. Biofouling of the system's infiltration trenches resulted in the shutdown of the system from October 2008 until December 2009. During this time, the

48

EPA's contractor installed a series of infiltration wells and converted one monitoring well into an injection well. Due to the poor performance of the injection wells, a majority of the water from the water treatment plant following treatment (about 70 percent) was diverted to the top of the RCC for irrigation. Preliminary estimates indicated that the irrigation level (38 inches per year) may be greater than the water absorption rate of the current grass cover. If this is determined to be the case, then additional treated water discharge options will be identified, including discharging to the POTW. The EPA did not use the irrigation system in 2012 because the injection wells were able to infiltrate the water at the reduced pumping rates resulting from changes to the ground water extraction and treatment system.

One other issue that has hampered performance of the ground water e":traction and treatment system was the entry of free-phase DNAPL into water treatment vessels. The preliminary design for the system called for an oil-water separator to provide for the separation and recovery ofDNAPL from the combined DNAPL ground water influent stream. During a value engineering review conducted by the EPA and USA CE, it was decided to defer the procurement and installation of the oil-water separator until more definitive information on DNAPL recovery rates and recovery duration could be obtained.

In lieu of the oil-water separator, the EPA's contractor installed a third vessel filled with 3,000 pounds of organo-clay as part of the water treatment plant design to provide for low-level oil filtration and removal prior to granular activated carbon treatment and took additional related steps. After discovering DNAPL in the system in July 2011, the EPA kept the system offline or operating at a reduced rate while extraction wells were modified to include a second, DNAPL-only recovery pump in the bottom of each extraction well. The system has been operating continuously since January 2013. Additional sustained operation of the ground water extraction and treatment system and ground water sampling events will be needed before a full determination of the effectiveness of the treatment system can be made.

Overall, the RCC cap is in good condition. However, erosion is evident on sides of the cap where vegetation has not been established. Institutional controls are in place to restrict placement of drinking water wells in the PMZ. However, institutional controls are needed to address on-site and off-site surface and subsurface residual soil/sediment contamination and to limit the future use of the Site and contaminant-impacted off-site areas to commercial and industrial uses.

Federal MCLs were identified as ARARs, but waived under a technical impracticability waiver. Some of the surface water standards on which surface water discharge goals were based have become more stringent since the signing of the Site's ROD. These standards applied to the temporary treatment and discharge of surface water from Pond DIE and affected storm water to the un-named tributary, which was completed in 2008. However, analytic results of effluent from the temporary water treatment system indicate effluent concentrations were below current, more stringent standards. Exposure assumptions used in the risk assessment remain valid. Of the 23 COCs, 12 have inhalation toxicity values more stringent now than at the time of the Site's 2006 RI/FS. Oral toxicity remains·

49

(

unchanged or lessened for all COCs. The EPA will consider whether the Site's cleanup goals are still valid, in light of these revised toxicity values. ·

While vapor in,trusion is not currently a risk to on-site water treatment plant workers, it is uncertain if it could pose a human health risk in the future, if structures are built over the plume.

8.0 ISsues

Table 5 summarizes the current site issues.

Table 5: Current Site Issues

Affects Current Affects Future Issue Protectiveness Protectiveness

(Yes or No) (Yes or No) Treated ground water is now primarily used for irrigation of RCC cap vegetation. The irrigation level (38 inches per year) may be greater than the water

No Yes ,_

absorotion caoacitv of RCC cap soils and vegetation. Erosion is evident on sides of the RCC cap where grass has not been fully established.

No Yes

Institutional controls are not in place to prevent potential exposure to contaminated material in the RCC or to restrict future land uses on site and at No Yes contaminant-imp~cted off-site properties to commercial and industrial activities. • Twelve COCs have inhalation toxicity values more stringent now than at the time of the 2006 RI/FS.

No Yes

It is unclear at this time if vapor intrusion would pose a human threat if structures were built over the plume No Yes in the future. Operation of the ground water extraction and treatment system has been impeded by biofouling and

·entry of DNAPL into the treatment system. Although corrective steps have been taken, the system should be

No Yes

reevaluated within three years to make sure that the system is achieving RAOs.

50

9.0 Recommendations and Follow-up Actions

Table 6 provides recommendations to address. the current site issues.

Table 6: Recommendations to Address Current Site Issues

Affects

Issue Recommendations I Follow-Up Actions

Party Responsible

Oversight Agency

Milestone Date

Protectiveness? (Yes or No)

Current Future Treated ground water Conduct follow-up is now primarily used analysis to verify for irrigation of RCC whether the water cap vegetation. The absorption capacity of irrigation level (38 RCC cap soils and inches per year) may vegetation can be greater than the withstand ctlrrent water absorption irrigation levels. Ifnot, EPA EPA 06/30/2014 No Yes capacity of RCC cap take necessary steps to soils and vegetation. enable appropriate

infiltration of treated ground water (e.g., make arrangements to discharge to the . POTW).

Erosion is evident on Repair the eroded areas sides of the cap on the RCC cap and where grass has not establish a suitable State EPA 06/30/2014 No Yes been fully vegetative cover. established. Institutional controls Implement enforceable are not in place to restrictions to prevent prevent potential potential exposure to exposure to contaminated material contaminated in the RCC and to material in the RCC restrict future land uses or to restrict future on site and at EPA/State EPA 06/30/2014 No Yes land uses on site and contaminant-impacted at contaminant off-site properties to impacted off-site commercial and properties to industrial activities. commercial and industrial activities. Twelve COCs have Consider whether the inhalation toxicity Site's cleanup goals are values more stringent still valid, in light of EPA EPA 06/30/2014 No Yes now than at the time these revised toxicity of the 2006 Rl/FS. values. It is unclear at this Review available data time if vapor and collect new data to intrusion would pose a human threat if

determine ifthe potential exists for a

EPA EPA 06/30/2015 No Yes

structures were built future vapor intrusion over the plume in the exposure pathway,

51

" Recommendations I

Issue Follow-Up Actions

future. especially since inhalation toxicity values for many of the COCs have changed. If so, determine whether it results in an unacceptable risk.

Operation of the Conduct an evaluation ground water of the ground water extraction and extraction and treatment treatment system has system within three been impeded by years to make sure that biofouling and entry recent system ofDNAPL into the improvements are treatment system. helping the Site achieve Although corrective applicable RAOs and steps have been determine whether a taken, the system hydraulic containment should be reevaluated system needs to be within three years to added to minimize the ·make sure that the plume expansion and to system is achieving prevent the migration of RA Os. COCs from ground

water to surface water.

: Affects Party Oversight Mil(lstone Protectiveness?

. Responsible Agency Date (Yes or No) Current Future

.

'.

EPA EPA 06/30/2016 No Yes

"

The following additional items, though not expeeted to affect protectiveness, warrant additional follow up:

• Verify that site information is properly maintained and accessible in the information repository.

52

10.0 Protectiveness Statements

The remedy for the Site currently protects human health and the environment in the short-term. Current exposure to contaminated media has been addressed through surface water, soil and sediment cleanup actions atid is being addressed through operation of a ground water extraction and treatment system and restrictions on drilling drinking water wells in the PMZ. For the remedy to be protective in the long term, the following actions need to be taken:

• Conduct follow-up analysis to verify whether the water absorption capacity of RCC cap soils and vegetation can withstand current irrigation levels. Ifnot, take necessary steps to enable appropriate infiltration of treated ground water. ·

• Repair the eroded areas on the RCC cap and establish a suitable vegetative cover. • Implement enforceable restrictions to prevent potential exposure to contaminated

material in the RCC and to restrict future land uses both on site and at 0ff-site contaminant-impacted properties to commercial and industrial activities.

• Consider whether the Site's cleanup goals are still valid, in light ofrevised toxicity values.

• Determine if the potential exists for a future vapor intrusion exposure pathway. If so, determine whether it results in an unacceptable risk.

• Evaluate the ground water extraction and treatment system within three years to make sure that recent system improvements are helping the Site achieve applicable RAOs and determine whether a hydraulic containment system is necessary.

11.0 Next Review

The next FYR will be due within five years of the signature/approval date of this FYR.

53

Appendix A: List of Documents Reviewed

CERCLA Information System Site Information accessed from website http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0601975. Accessed December 2012January 2013.

Dense Nonaqueous Phase Liquid Recovery Test Results and Recovery Strategy Evaluation. Prepared for United States Environmental Protection Agency Region 6 by CH2M HILL. February 22, 2012.

Final Design Criteria Report. Hart Creosoting Company Superfund Site. Prepared for United States Environmental Protection Agency Region by CH2M HILL. December 2007.

Final Interi!ll Groundwater Remedial Action Completion.Report, Hart Creosoting Company Superfund Site. Prepared for United States Environmental Protection Agency Region by CH2M HILL. July 2010.

Preliminary Close Out Report, Hart Creosoting-Company, Inc. Superfund Site, Jasper, Jasper County, Texas. United States Environmental Protection ~gency Region 6. September 12, 2008.

Record of Decision, Hart Creosoting Company, Inc. Superfund Site, Jasper, Jasper County, Texas. United States Environmental Protection Agency Region 6. September 21~ 2006.

Remedial Investigation and Feasibility Study Report, Hart Creosoting Company, Volume 1. Prepared for United States Environmental Protection Agency Region 6 by CH2M HILL. Septem~er 2006.

Year 2010 Annual Operations Report, Hart Creosoting Company Superfund Site. Prepared for United States Environmental Protection Agency Region by CH2M HILL. April 2011 ..

Year 2011 Annual Operations Report, Hart Creosoting Company Superfund Site. Prepared for United States Environmental Protection Agency Region 6 by ~H2M HILL. April 2012.

Year 2012 Annual Operations Report, Hart Creosoting Company Superfund Site. Prepared for United States Environmental Protection Agency Region 6 by CH2M HILL. April 2013.

A-1

Appendix B: Press Notices

Thr U.S. Endronmmtal Prottttion Agency, Rrgion 6 · Announces Fh-e-Year !Ulit'lTS for the

Jmiprr CTt'osoting Company and Hart CrfOsoting Company Suprrfund Sitrs, 1

Jasprr, Jasprr County, Trxas January 2013

Purpose/Objttrin: The U.S. Emiromnental Protection Agency (EPA) is conducting Fin-Year Re\-iews ofthe remedies for the Jasper Creosoting Company and Hart Creosoting Company Superfund Sites in I asper, T nas. lhe purpose of these Fi1;e-Year Re\-iews is to make sure the sel.eded cleanup actions effectively protect human health md the en\iromnent.

.Site Bmrkgrouads: Jasper Creosoting Company The Jasper Creosoting Company Site is the location of a fonner wood treating facility in Jasper, Te."'t:ls. The 11.3-acre sne i.S located one mile aorthHst of doWDtown Jasper at 601 N. McQueen StreeL Put acti,.;ties at the site used coal tar aeosote and pentach.lorophenol (PCP) dissoh·ed in diesel to treat railroad ties and utility poles between 1946 and 1986. EPA placed the site on. the NatiOJLal Priorities List (NPL) on July 28, 1998. Primary contamjnagts of concem are P AHs, PCP and dioxiasffurans.

Hart Creosoting Comuanv The Hart Creosotillg Company Site is the. location of a fonner wood treating facility that perf011Ded wood treatlllent, pole peeling and pipe threading openti!lll:i. The 23.4-acre site is located about one mile south of downtown Jasper on Wheeler Street (Highway 96). Past acti-..-ities at the site used coal tar creo:ote dissolved in diesel to treat railroad ties and utility poles between 1952 and 1978. EPA placed the site on the NPL ou July 22, 1999. PAHs are the primary contam;nants of ccmcem..

Cleanup Actions: Jasper Creosoting Company On September 20, 2006, EPA .selected the remedy for remai!li!lg site soil and sediment contamination ill the site's Record ofDecision (ROD). It incladed excn'3ting contaminated soil and sediment and disposing of the material in an oa~ite R.CRA contaillmeat cell; installing a !>)"stem to reco\·er cont>mniagt; such as creosote from ground water in the source arH and to c:311t1ue the ground water collt.amination; identifying a technical ~ticality zone (IlZ) where restor.iltion ofground water quality to drinking water standards is

Bob Sullivan, EPA Remedial .Project Manager Phone: (214) 66S"22.J3 Email:: sulli\'311.tobert1iteva.gov

not required and re~s ground water use in the TIZ; and long-term grcnmd water monitoring. EPA began operating the groU11d water recot-ery md containment systems in 2008. Effom to address contaminated ground water continue.

Ha.rt Creosoting Compmy On September21, 2006, EPA selected the remedy for remaining site soil, sediment and surface water contaminaticm in the site's ROD. It includedremo-..-ing and treating «illtaminated surface water, md excavating contaminated soil and sediment and disposing of the material in an on-site RCR.A cont3inment ctil; installing a system to recover contimina!lb such as creosote from grouad water in the soUIN area and to capture the ground water contamination; identifying a TIZ where restoration of ground water quality to drinking water standards is not required and restricts ground water use in the TlZ; and long-term ground wate:r monitoring. EPA began operating the ground · water recO\·ery and conta.iument systems in 2008. Efforts to address contammated groU!ld water continue.

Fin-l'ear Renew s~hedule: The National Contingency Plan requires re\;ew ofremedial actions diat result in my hazardous substances, pollutants or CO!ltamllunb remaining at a site above le\-els that allow mr ~ted use and unrestricted exposure e\"ery fh-e yaars to ensure the protection oflmmm health and the en\-iromaent. EPA i:; scheduled to complete the fust Fi,-e-Year Rn-ie\\'S for the Jasper Creosoting Company and Hart Creosoting Campany sites by Jmie 2013.

EPA In-rit11s Community Participation in the FinYear Ren11w Pro<~n: EPA is conducting these Fil-eyear R.ni.nn to e\"aluate the effecti"t'l!Jll!ss of the site remedies and to make :ruJ-e the remedies remain protective ofhuman health and the l!ll\;ionment. As part of the Fil-e-Year R.ei.-iew proces:i, EPA staff members are a,·ailable to answer any que:>tions about the sites. Community m.e.mbel5 who hai.-e questions about either site or the Fn-e-Year R.e~-iew process, or. \\-ho would like to participate in a community inten-iew, are asked to contact:

Donn Waltets, EPA Public Liaison Phone: (214) 665-6483 Email: walte1~.doDDli"i1epa.goy

MDling Address: U.S. EPA Region 6, 1445 R.oss A,·enue, Suite 1200, Dallas, Texas 75202

.Adtltrional .site irifonnarion i:s available at the sites· local docrrmmt repositozy, locared at Jasper Public Library. 175 East Water Slr66t, Jasp6T, T6Xtu 75951or011-linB at htm·l6tww mg gqy!rnriqu616sf!&f_q htm

B-1

Appendix C: Interview Forms

Jasper Creosoting Company Five-Year Review Interview Form Superfund Site

Site Name: Hart Creosoting Company EPA ID No.: TXD050299577 Interviewer Name: Email-based Affiliation: Skeo Solutions Subject Name: Chuck Neeley Affiliation: URS Corporation Subject Conta'ct Information: phone: (512) 4i9-5834 Time: Date: Interview Location:

1/7/2013

Interview Format (circle one): In Person

Interview Category: O&M Contractor3

Phone Mail Other: Email

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?

Response: The RCC cell is functioning as expected but improvements are needed. Cap needs repair_ in areas to replace top soil and vegetation. Trees need to be removed from the side slopes, erosion areas repaired, and top soil/vegetation replaced in some locations. Leachate from the leachate collection system needs to be removed. This accumulated during construction of the cell.

2. What is your assessment of the current performance of the remedy in place at the Site?

Response: RCRA cap is functioning well but repairs are needed as mentioned in question #1.

3. What are the findings from the monitoring data? What are the key trends in contaminant levels that are being documented over time at the Site?

Response: Leachate levels have remained constant and analytical results have remained the same since URS began performing O&M activities at the Site in 2011.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities. Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if there is not a continuous on-site O&M presence.

Response: URS performs semi-annual leachate measurements, analytical, RCC cap inspections and periodic_ mowing.

3 l,JRS Corporation is the TCEQ's contractor for performing O&M activities at the landfill at the Site.

C-1

5. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling routines since start-up or in the last five years? Ifso, do they affect the protectiveness or effectiveness of the remedy? Please describe changes and impacts.

Response: No. However, URS did not begin O&M activities until 2011.

6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? Ifso, please provide details'.

Response: Only items identified in response to question #1.

7. Have there been'opportunities to optimize O&M activities or sampling efforts? Please describe changes and any resulting or desired cost savings or improved efficiencies.

Response: No.

8. Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at the Site?

Response: Only ~hose items listed in response to question #1.

C-2


Site Name: Hart Creosoting Company EPA ID No.: TXD050299577 Interviewer Name: Eric Marsh Affiliation: Skeo Solutions Subject Name: Tommy Boykin and Affiliation: Jasper City Manager

Greg Kelley Affiliation: · Jasper City Director of · Public Works

Subject Contact Information: Tommy Boykin -(409) 384-4651 Email: [email protected] Greg Kelley - ( 409) 383-7039 Email: [email protected]

Time: 9:00 a.m. Date: 1115/2013 Interview Location: Jasper City Hall

Note: These two individuals were interviewed at the same time.

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Local Government

1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place to date?

Response: Yes.

2. Do you feel well informed regarding the Site's activities and remedial progress? Ifnot, how might the EPA convey site-related information in the future?

Response: Yes.

3. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism or trespassing?

Response: No.

4. Are you aware of any changes to state laws or local regulations that might affect the protectiveness of the Site's remedy?

Response: No.

5. Are you aware of any changes in projected land use(s) at the Site?

Response: No.

6. What is your understanding of the institutional controls required as part of the site's remedy? Do you expect they will be effective?

C-3

Response: The City needs to work more closely with the local Ground Water Conservation District to prevent the drilling of wells in areas where drilling is not permitted. The City would like more help ensuring that the ordinance that prevents well drilling is enforced, and plans on discussing the issue with the District in the near future. ·

7. Has the EPA kept involved parties and surrounding neighbors informed of activities at.the Site? How can the EPA best provide site-related information in the future?

Response: Yes. The EPA can best provide site-related information in the future through · email and phone calls. The on-site O&M contractor is also very helpful in providing siterelated information.

8. Do you have any comments, suggestions or recommendations regarding the project? Response: No.

C-4


Site Name: Hart Creosoting Company EPA ID No.: TXD050299577 Interviewer Name: . Eric Marsh Affiliation: Skeo Solutions Subject Name: Kari Ellis. Affiliation: Executive Director of the

Jasper Economic Development Corporation

Subject Contact Information: Phone: (409) 383-6120, Email: [email protected] Time: 10:00 a.m. Date: 1115/2013 Interview Location: Jasper Economic Development Corporation office


~nterview Category: Local Government

1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place to date?

Response: Yes. ·

2. Do you feel well informed regarding the Site's activities and remedial progress? Ifnot, how might the EPA convey site-related information. in the future?

Response: Yes.

3. Have there been any problems with unusual or unexpected activities at the Site, such as e~ergency response, vandalism or trespassing?

Response: No.

4. · Are you aware of any changes to state laws or local regulations that might affect the protectiveness of the Site's remedy?

Response: No. However, it should be noted that there is no zoning program in place for the City of Jasper. There are no official commercial, residential or industriaf designations for local properties.

· 5. Are you aware of any changes in projected land use(s) at the Site?

Response: No. .

6. What is your understanding of the institutional controls required as part of the site's remedy? Do you expect they will be effective?

Response: Yes.

C-5

7. Has the EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can the EPA best provide site-related information in the future?

Response: Yes. The EPA can.best provide site-related information in the future through email and phone calls.

8. Do you have any comments, suggestions or recommendations regarding the project?

Response: No.

C-6

Jasper Creosoting Company ·Five-Year Review Interview Form Superfund Site

Site Name: Hart Creosoting Company EPA ID No.: TXD050299577 Interviewer Name: Eric Marsh Affiliation: Skeo Solutions Subject Name: John Martin Affiliation.: General Manager of the

Southeast Texas Groundwater Conservation District·

Subject Contact Information: Phone: (409) 383-1577, Email: [email protected] Time: 10:30 a.m. Date: 1115/2013 Interview Location: Southeast Texas Groundwater Conservation District office

Interview Format (~ircle one): In Person. Phone Mail Other:


.1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place to date?

Response: Yes.

2. Do you feel well informed regarding the Site's activities and remedial progress? Ifnot, how might the EPA convey site-related infon;nation in the future?

Response: Yes.


Response: No.

4. Are you aware of any·changes to state laws or local regulations that might affect the protectiveness of the Site's remedy?

Response: No.


Response: No.

6. What is your understanding of the institutional controls required as part of the Site's remedy? Do you expect they will be effective?

Response: Yes. It would be very helpful if the EPA could send institutional control documentation directly to the local well drillers. That direct communication might help reinforce the importance, purpose and details of the well drilling restrictions.

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7. Has the EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can the EPA best provide site-related information in the future?

Response: Yes, as far as I know.


Response: The fact there is no land use zoning/classification program in place for the area may make the implementation of certain institutional controls challenging. Again, that is why it would be helpful if the EPA could send institutional control-related documentation (example: detailed PMZ maps with well drilling restriction information) directly to the local well drillers.

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Site Name: Hart Creosoting Company EPA ID No.: TXD050299577 Interviewer Name: Eric Marsh Affiliation: Skeo Solutions Subject Name: Honorable Mark Allen Afftliation: Jasper County Judge Subject Contact Information: -Phone: (409) 384-2612 Time: 3:00 p.m. Date: 1115/2013 Interview Location: Jasper County Courthouse



l. Are you aware ofthe former environmental issues at the Site and the cleanup activities that have taken place to date?

,.

Response: Yes.

2. Do you feel well informed regarding the Site's activities and remedial progress? Ifnot, how might the EPA convey site-related information in the future?

Response: Yes. The EPA keeps me well informed about site activities.


Response: No. ·

4. Are you aware of any changes to state laws or local regulations thatmightaffect the protectiveness of the Site's remedy? ·

Response: No.

5. Are you aware of ~y changes in projected land use(s) at the Site?

Response: No.

6. What is your understanding of the institutional controls required as part of the Site's remedy? Do you expect they will be effective?

Response: Yes.

7. Has the EPA kept inYolved parties and surrounding neighbors informed of activities at the ,site? How can the EPA best provide site-related information in the future? ·

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Response: Yes. The EPA should continue with its current methods ofkeeping involved parties and the community well informed about site activities.


Response: No.

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.Hart Creosoting Company Five-Year Review Interview Form Superfund Site

Site Name: Hart Creosoting·company EPA ID No.: EPA ID: TXD050299577 . Interviewer Name: Eric Marsh Affiliation: Skeo Solutions Subject Name: Representative for Affiliation: Crown Pine Timber/

Crown Pine Campbell Timber Management

Subject Contact Information: Time: 9:00 a.m. Date: 1/16/2013 . Interview Location: Crown Pine Timber/Campbell Timber Management - Jasper Office

Interview Format (circle one): In Person Phone . Mail . Other:

Interview Category: Residents and Nearby Business Owners

I. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place to date?

Response: Yes.

2. \\'.}lat is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?

Response: No concerns whatsoever.

3. What have been the effects of the Site on the surrounding community, if any?

Response: They removed some timber but that did not affect us. ·

4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism ·or trespassing?

Response: Saw a lid on one of the wells open when we were putting in a new gate in the area. EPA contractors may have been working on it.

5. Has the EPA kept involved parties and surrounding neighbors inform!!d of activities at the Site? How can the EPA best provide site-related information in the future?

Response: We have everything we need.

6.. Do you own a private well in addition to or instead of accessing city/municipal water supplies? If so, for what purpose(s) is your private well used?

Response: No private well.

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7. Do you have any comments, suggestions or recommendations regarding any aspects of the project? ·

Response: No concerns or questions.

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Site Name: Hart Creosoting Company EPA ID No.: TXD050299577 Interviewer Name: Email-based Affiliation: Skeo Solutions Subject Name: Andy Bajwa Affiliation: TCEQ/SPM Subject Contact Information: Phone: 713-422-8926, Email: [email protected] Time: Date: _...1::.:../1=8:;,:.;/2=0~1=3_____ Interview Location: Houston Regional Office .

Interview Format (circle one): In Person Phone Mail Other: Email

Interview Category: State Agency

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?

Response: As the TCEQ project manager for the Site, I have only been involved with O&M activities for the RCC cap inspection, leachate collection system and leachate detection system inspection, and sampling of the leachate collected in the systems. Since 2010, the TCEQ has on a semi-annual basis inspected and maintained the RCC cap, controlled the vegetation on and around the cap area, and inspected and sampled the leachate systems. Inspection of the leachate system has found that a large volume of leachate has been

· accumulated in the leachate system. Since the leachate volume has not increased over time, the TCEQ believes that the leachate system is not leaking and functioning as designed. The TCEQ also believes the collected leachate is from the placement of wet waste in the RCC during the hurricane. Chemical analysis of the leachate samples taken from the leachate collection system show it is mostly water. The TCEQ is in the process of revising the O&M Plan and Sampling and Analysis Plan to properly remove and dispose of the leachate from leachate collection ~d d~tection systems.

An EPA.institutional control is in place to prevent potential exposure to the contaminated material in the RCC and to restrict site's future use to commercial and ~ndustrial uses only.

The EPA is operating the ground water extraction and treatment system under the L TRA. The system has pumped and treated 21.8 million gallons of contaminated ground water and has removed 1,400 pounds of dissolved phase contaminated mass at the end ofNovember 2011. There have been operational issues with the system due to loss of infiltration trench capacity, fouling of the injection wells screens, and free product entering the treatment system. However, these issues have been partially resolved. The system is operational although at a lower capacity.

I am not aware of any specific effort by the EPA regarding a Ready for Anticipated Reuse designation. With the EPA's institutional control finalized, the Site should qualify as Ready for Reuse. The Site and RCC are fenced. Access to the Site is controlled by a locked gate to

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prevent entry for the general public. My overall impression is that there are no major issues or concerns at the Site.


Response: Contaminated soils have been excavated and consolidated in the RCC; therefore, this material no longer poses any threat to human health or ecological risk. The RCC cap and slopes are well vegetated and regularly inspected to insure that the integrity of the cap and the slopes is sufficient to prevent any leaching of the chemical of ~oncerns from the RCC. The southwest side slope of the RCC cap has partially lost vegetation due to severe drought. The slope also has some washout areas. The TCEQ is planning in the current fiscal year to repair the side slope, add nutrients to the soil, re-sod the slope, and reconfigure the sprinkler system to irrigate this area.

An EPA institutional control is in place to prevent potential exposure to the contaminated material in the RCC and to restrict the Site's future use to commercial and industrial uses only.

The ground water remedy includes extraction wells, a water treatment plant and a treated water discharge system, which consists of injection wells, infiltration trenches and an RCC irrigation sprinkler system. The water treatment system is designed to operate on a continuous basis without significant human operation or maintenance personnel present. The remedy operated for 21 months, until December 2011, treating 21.8 million gallons of contaminated'water and recovering 1,400 pounds of contaminant mass. A network of monitoring wells are periodically sampled to evaluate the effectiveness of ground water remedy and to verify the ground water plume is managed within the PMZ.

The system's pumping has averaged about one-half of the remedial design capacity for the 2011 period, and has resulted in noininal P AH decline near recovery wells and in the upper portion ofhydrostatic zone P-2. Ground water monitoring well sampling results from the June 2011 sampling event indicates that the core region of the plurhe is advancing down gradient towards and beyond MW-18, but the plume remains well within the TIZ. This was expected as there have been operational issues with the water treatment system due to loss of infiltration trenches capacity, fouling of the injection wells screens and free product entering the treatment system. However, these issues have been partially resolved. The system is operational although at a lower capacity.

Overall, the remedy is effective and protective and the operational issues with the system are ofa temporary nature, as expected.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial activities from residents or businesses in the past five years?

Response: The Site is located in the TCEQ's Region 9, Beaumont Field Office. An email request was sent to the region to check its database to see if site-related inquiries or

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complaints had been received in the past five years. Region 9 confirmed that no site-related inquiries have been received.

The Kelly-Hart law firm, representing the timber company located adjacent to the Site, has requested copies of TCEQ inspection and sampling reports, as they are generated as well as other documents regarding the remedial action at the Site.

4. Has your office conducted any site-related activities or communications in the past five years? Yes. If so, please describe the purpose and results of these activities. List the activities and/or communications here. Include the following at a minimum:

Response: The TCEQ has visited the site several times in the past five years for: a. Site visits for ground water treatment optimization in fiscal year 2010. b. O&M inspections of the RCC and leachate sampling visit in August 2011; c. O&M inspections of the RCC and leachate sampling visit in February 2012. d. O&M inspections of the RCC and leachate sampling visit in July 2012. e. O&M inspections of the RCC and leachate sampling visit in January 2013. f. Site visits to discuss leachate removal and disposal in January 2013

5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy?.

' '

Response: There have been no changes to state laws that might affect the protectiveness of the remedy from the 81st and 82nd legislative sessions (2009 and 2011 respectively). However, one of the biggest issues of the 83rd legislative session (convening January 8, 2013) will be water, so there is the potential for changes regarding,protectiveness.

6. Are you comfortable with the status of the institutional controls (ICs) at the Site?

Response: Not completely. Ifnot, what are the associated outstanding issues?

Response: With the EPA's "tiered approach" to institutional controls, the "Ground Water Contamination and Restricted Water Well Drilling Area at the Hart Creosoting Superfund Site" letter, dated July 23, 2012, provides one tier. A TCEQ review of the EPA institutional controls in accordance with the Texas Risk Reduction Program rules resulted in the following comments:

a. While EPA may consider the TDLR restrictions and the city ordinances as institutional controls, these instruments do not meet TCEQ T~xas Risk Reduction Program (TRRP) IC requirements.

b. The TCEQ will need to pursue institutional controls that meet our TRRP requirements in the form of restrictive covenants or deed notices if restrictive covenants cannot be obtained.

c. In accordance with TRRP, a separate survey map and metes and bounds is required for each individual legal property affected.

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Response: I am not aware of any projected land use changes for the Site.

8. Do you have any coinments, suggestions or recommendations regarding the management or operation of the Site's remedy?

Response: The RCC is in excellent condition and routinely inspected to verify the in~egrity of the cap. The leachate collection and det~ction systems are routine insp~cted and sampled. The liquid collected in the leachate is in the process of being removed and disposed of. The ground water extraction and treatment system is fully functional and its operations are constantly monitored and as necessary adjusted and repaired. I do not have any comments, suggestions or recommendations regarding the management or operation of the Site·'s remedy.

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Site Name: Hart Creosoting Company EPA ID No.: TXD050299577 Interviewer Name: Email-based Affiliation: Skeo Solutions Subject Name: Patrick Appel Affiliation: L TRA Project Manager,

CH2M HILL Subject Contact Information: Phone: (409) 384-2612, Email: [email protected] Time: 9:00 a.m. Date: 1121/201 Interview Location: Dallas, TX


Interview Category: O&M Contractor4

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?·

Response: Encountering free phase DNAPL at the Site has impacted the overall operations strategy and continuous operations of the water treatment system. However, performance observations, supported by a DNAPL recovery pilot test, have established the efficacy of the recovery and injection well system, and the water treatment system, to mobilize and recovery a significant long-term ground water contaminant source. The project team continues to iden.tify potential operational modifications to accelerate cleanup progress while maintaining the remedy's overall protectiveness. Ground water and water treatment system performance monitoring indicates that the ground water extraction wells are drawing large amounts of contaminant mass from the subsurface. CH2M HILL noted the potential for DNAPL mobilization and recovery in the predesign report. However, installation of an oil-water separator within the .water treatment system was eliminated by an external value engineering team.


Response: In general, the ground water remedy has contained the dissolved phase plume within the PMZ, reduced or stabilized COC concentrations in portions of the plume, and recovered a portion of the DNAPL mass that acts as a source for the dissolved phase plume. These accomplishments are consistent with the remedy performance expectations outlined in the ROD. Additional information on remedy performance with respect to both short-term and .long-te.rm objectives is detailed in the Site's 2010 and 2011 Annual O&M reports.

3. What are the findings froin the monitoring data? What are the key trends in contaminant . levels that are being documented over time at the Site?

Response: COC concentrations are trending down or have stabilized at many ground water monitoring well locations. However, further concentration reductions are not anticipated until

4 CH2M HILL manages the L TRA at the Site for the EPA.

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the fraction of recoverable DNAPL present at the Site is removed. Additional data analysis and evaluation for the semiannual ground water and treatment system monitoring are detailed in the Site's 2010 and 2011 Annual O&M reports.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities. Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if there is not a continuous on-site O&M l'resence.

Response: There is a local O&M operator that provides continuous on-site O&M for about 20 hours per week. A staff engineer travels to the Site once per month to perform routine system sampling and inspect the system.

5. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling routines since start-up or in the last five years? Ifso, do they affect the protectiveness or effectiveness of the remedy? Please describe changes and impacts.

Response: There have been no significant changes. However, routine semi-annual ground water sampling was limited to one event in 2010 and one event in 2011. During 2010, O&M activities were performed under the response action task order under operational and functional activities where the semiannual ground water sampling requirement was not as rigorous. In 2011, it was determined that perforniing a semiannual ground water sampling event would not provide value due to the limited water treatment system operations. The system was mostly shut down between July 12 and December 31, 2012, due to the presence of DNAPL in the recovery well ground water stream.

6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If so, please provide details.

Response: The ability of the injection wells to accept treated water has declined since system startup.·Discharge options were required to continue operations at the optimal flow rates. The treatment system was modified to include piping modifications to the adjacent landfill cap surface that allows treated effluent to be reused for irrigation of the landfill cap vegetative cover. This option was installed at minimal cost and future cost savings will be realized due to lower injection well rehabilitation frequency requirements.

Biofouling has impacted treatment system operations and impacted the treatability of the filtration media. To control biofouling, the system was modified to include installation of metered pumps that disperse iron sequestering and biocide agents. These agents have helped reduce backwashing frequency and have increased the treatability of the filtration media.

In July 2011, DNAPL was observed in the water treatment system and in each of the four recovery wells. As a result, the system was shut down, the media required disposal and replacement with new fresh media, and the system required complete cleaning. A subsequent DNAPL recovery test was performed and the results were issued in the Hart Creosoting · Company Superfund Site Long-term Remedial Action Dense Nonaqueous Phase Liquid Recovery Test Results and Recovery Strategy Evaluation Technical Memorandum on

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~- . -..

February 22, 2012. The recommended solution to recovery DNAPL included retrofitting the recovery wells will a dual-phase pumping system which was installed and operational in November 2012.

Additional details regarding O&M of the water treatment system are included in Site's 2010 and 2011 Annual O&M reports.

7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes and any resulting or desired cost savings or improved efficiencies.

Response: The system modifications noted in question #7 were implemented for optimization purposes and are documented in detail in the Site's 2010 and 2011 Annual O&M reports.

8. Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at the Site?

Response: The current long-term operations strategy is to recover DNAPL as aggressively as possible and to the extent practical. Once DNAPL recovery rates slow or reach an asymptotic level, recovery well pumping rates will be incrementally increased to a rate that is sustainable on both the extraction and injection/.irrigation reuse sides such that plume contraction is ' accelerated. Additional recommendations are detailed in the Site's 2010 and 201'1 Annual O&M reports.

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Site Name: Hart Creosoting Company EPA ID No.: TXD050299577 Interviewer Name: Email-based Affiliation: Skeo Solutions Subject Name: Robert Sullivan Affiliation: EPA Project Manager Subject Contact Information: Phone: 214-665-2223, Email: [email protected] _....................,___Time: Date: 01/23/13 Interview Location:


Interview Category: EPA Remedial Project Manager

I. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?

Response: The EPA excavated soil and sediments meeting the PR Gs and constructed a RCRA Subtitle C landfill. The EPA is extracting DNAPL to the extent practicable from dedicated pumps in recovery wells. The.EPA has constructed a recovery well network and water treatment plant to pump and treat contaminated ground water.

2. What have been the effects of the Site on the surrounding community, if any?

Response: The EPA remedial action is currently protective of human health and the environment and allows for appropriate reuse.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial activities since the implementation of the cleanup?

Response: No knowledge of any complaints.


Response: The remedy is performing as designed.

5. Are you comfortable with the status of the institutional controls at the Site? Ifnot, what are the associated outstanding issues? .

Response: The EPA established a PMZ at the Site. The institutional control for ground water is a City of Jasper drilling ordinance and an EPA notification to the TDLR and the Southeast Texas Groundwater Conservation District restricting any drilling activity in the PMZ. An institutional control for the RCRA Subtitle C landfill is needed. The EPA mailed a deed notice to the heir of the property owner, Mr. James Day, on July 27, 2012. No response was received. The EPA plans to mail another deed notice by certified mail. Ifno response is received, the EPA will seek a deed notice through the State of Texas.

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6. Are you aware of any ,community concerns regarding the Site or the operation ~d management of its remedy? If so, please provide details.

Response: No knowledge of any concerns.

7. Do you have any comments, suggestions or recommendations regarding the management or operation of the Site's remedy? ·

Response: The EPA (LTRA) and the TCEQ (O&M) continue to manage the Site jointly.

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Appendix D:· Site Inspection Checklist

Site Inspection Checklist

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Jasper Creosoting Company

Location and Region: Jasper, TX/Region 6

Agency, Office or Company Leading the Five-Year Review: EPA Region 6

Remedy Includes: (Check all that apply) ~ Landfill cover/containment ~ Access controls ~Institutional controls ~ Ground water pump and treatment D Surface water collection and treatment OOther:_·_

Attachments: ~ Inspection team roster attached

Date of Inspection: January 15, 2013

EPA ID: TXD008096240

Weatherffemperature: Raining and 40°F

D Monitored natural attenuation ~ Ground water containment D Vertical barrier walls

D Site map attached

II. INTERVIEWS (check all that apply)

l. O&M Site Manager Patrick Appel Project Manager, CH2M HILL l/23/2013 Name Title Date

Interviewed D at site D at office D by phone Phone: 972-663-2394 Problems, suggestions D Report attached: Interview responses submitted via email. Interview guestions and resnonses can be found in Annendix C. CH2M HILL is manai!:inl! the Site's lonl!-term resnonse action.

2. O&M Staff Chuck Neeley State Contractor for Landfill O&M 1/7/2013 Name Title Date

Interviewed D at site D at office D by phone Phone: Problems/suggestions D Report attached: Interview responses submitted via email. Interview guestions and

resnonses can be found in Annendix C.

D-1

3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency response office, police department, office of public health or environmen~I health, zoning office, recorder ofdeeds, or other city and county offices). Fill in all that apply.

Agency Texas Commission on Environmental Quali!)'. Contact And)'. Bajwa Project 1122/2013 (713) 422-8926

Name Manager, Date Phone No. Remediation Division Title

Problems/suggestions 0 Report attached: Interview guesti~ns and reponses can ·be found in Appendix C.

Agency Southeast Texas Groundwater Conservation District Contact John MartinName General 01/15/2013 (409) 3 83-1577

Manager Date Phone No. Title

Problems/suggestions 0 Report attached: Interview guestions and responses can be found in AppendixC.

Agency Ci!)'. of Jasper Contact Tomm)'. Bo:tkin Ci!)'. Manager 01115/2013 (409) 384-4651

Name Title Date Phone No. Problems/suggestions O Report attached: Interview guestions and responses can be found in Appendix C.

Agency Jasper Economic Development Corporation Contact Kari Ellis Executive 01/15/2013 (409) 383-6120

Name Director Date Phone No. Title

Problems/suggestions O Report attached: Interview guestions and responses can be found in AppendixC.

Agency Ci!)'. of Jasper Contact Greg Kelle)'. Public Works 01/15/2013 (409) 383-7039

Name Director Date Phone No. Title

Problems/suggestions 0 Report attached: Interview guestions and responses can be found in Annendix C.

4. Other Interviews (optional) 1:8:1 Report attached: Interview guestions and responses can be found in Appendix C.

Bob Sullivan, EPA Region 6 Site l_lPM; Jasper County Judge, Honorable Mark Allen;

Crown Pine Timber, Keith Stephens

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

l. O&M Documents ,,

1:8:1 O&M manual 1:8:1 Readily available 1:8:1 Up to date "ON/A "~

~ As-built drawings ~ Readily available ~Up to date ON/A

~ Maintenance logs ~ Readily available ~Up to date ON/A

Remarks: O&M documents are stored onbsite in the water treatment plant operations room.

D-2

2. Site-Specific Health and Safety Plan 1:8:1 Readily available 1:8:1 Up to date ON/A

181 Contingency plan/emergency response plan 1:8:1 Readily available 1:8:1 Up to date ON/A

Remarks: Site health and safetx Qian is keQt in the water treatment Qiant OQerations room.

3. O&M and OSHA Training Records 1:8:1 Readily available 1:8:1 Up to date ON/A

Remarks: O&M and OSHA training records are stored online in CH2M HILL's database. Training records for all site contractors can be accessed at anx time.

4. Permits and Service Agreements

0 Air discharge permit 0 Readily available 0 Up to date 1:8:1 N/A

0 Effluent discharge 0 Readily available 0 Up to date ~NIA

0 Waste disposal, POTW 1:8:1 Readily available 1:8:1 Up to date ~NIA

0 Other permits: __ 0 Readily available 0 Up to date ON/A

Remarks: Treated ground water is infiltrated through four injection wells, two infiltration trenches, and an RCC irrigation SQrinkler arrax.

5. Gas Generation Records

Remarks: - 6. Settlement Monument Records

Remarks: - 7. Ground Water Monitoring Records

Remarks: - 8. Leachate Extraction Records

Remarks: - 9. Discharge Compliance Records

0Air 0 Readily available

0 Water (effluent) 0 Readily available

Remarks: - 10. Daily Access/Security Logs

Remarks: -

0 Readily available

0 Readily available

Readily available 1:8:1 .

0 Readily available

0 Up ~o date

0 Up to date

0 Readily available

IV. O&M COSTS

l. O&M Organization

0 State in-house ~ Contractor for state

0 PRP in-house 0 Contractor for PRP

0 Up to date ~NIA

0 Up to date ~NIA

1:8:1 Up to date . ON/A

0 Up to date ~NIA

~NIA

~NIA

0 Up to date ~NIA

. 0 Federal facility in-house 0 Contractor for Federal facility.

181 LTRA costs are submitted in annual OQerations reQorts QreQared bx CH2M Hill.The TCEQ 1;ontracts O&M work for the RCC to URS.

D-3

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--

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2. O&M Cost Records

1:8:1 Readily available 1:8:1 Up to date

0 Funding mechanism/agreement in place 0 Unavailable

Original O&M cost estimate: $401.803 (for L TRA .costs only) 0 Breakdown attached

Total annual cost by year for review period if available

From: 01/01/2011

Date

From: 01/01/2010

Date

From: mm/dd/vvyy

Date

From: mm/dd/vvyy

Date

From: mm/dd/yvvy

Date

To: 12/31/2011

Date

To: 12/31/2010

Date

To: mm/dd/vvyy

Date

To: mm/dd/vvyy

Date

To: mm/dd/vvyy

bate

~484,866

Total cost

~686,187

Total cost

Total cost

Total cost

Total cost

0 Breakdown attached . 0 Breakdown attached

0 Breakdown attached

0 Breakd'own attached

0 Breakdown attached

3. Unanticipated or Unusually High O&M Costs during Review Period

Describe costs and reasons: ffwo signifi.carit 12roblems were encountered and addressed in 2010: thd ~remature blinding of cartridge filters as a result of biomass accumulation and the loss of treated wateil dis12osal ca12aci!Y because of injection well biofouling. One significant 12roblem was encountered and ~ddressed in 2011: free-12hase creosote entered the water treatment system's treatment 12rocess yessel~ Cluring normal 12um12ing 012eration from well R-2. The subseguent identification ofDNAPL was alsd bresent in recoveo: wells R-1 1 R-3 and R-4J .

V. ACCESS AND INSTITUTIONAL CONTROLS ~Applicable ON/A

A. Fencing

1. Fencing Damaged 0. Location shown on site map ~ Gates secured ON/A

Remarks: All site fencing a1212eared to be in good condition.

B. Other Access Restrictions

l. Signs and Other Security Measures 0 Location shown on site map ON/A

Remarks: All signs were clearly 12osted on site fencing.

C. Institutional Controls (ICs)

D-4

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1. Implementation and Enforcement

Site conditions imply ICs not properly implemented [gJ Yes D No ON/A

Site conditions imply ICs not being fully enforced [gJ Yes 0 No ON/A

Type of monitoring (e.g., self-reporting, drive by): __

Frequency: __

Responsible party/agency: EPA Region 6

.Contact Bob Sullivan Site RPM 01/15/2013 (214} 6652223

Name Title Date Phone no.

Reporting is up to date 0Yes 0No [gJ NIA

Reports are verified by the lead agency 0Yes· 0No [gJ NIA

Specific requirements in deed or decision documents have been met 0Yes [gJ No ON/A

Violations have been reported 0Yes 0No [gJ NIA

Other problems or suggestions: 0 Report attached

2. Adequacy 0 ICs are adequate [gJ ICs are inadequate ON/A • - . -· . . ·:--:-;-i

Remarks: ffhe 2006 ROD calls for the imnlementation of institutional controls to orevent ootential exoosure to the PRG exceedances disoosed·of in the RCC. Controls are not vet in olace. The 2006 ROD also calls for thd 1molementation of institutional controls to nrevent the notential exoosure to ITT"ound water within the TIZ. Thd EPA has established a PMZ that contains the TIZ. A local ordinance nrevents the drillin11: of trround water wells iri

-· - - ·- ··- ~reas of the citv without a nermit.I

D. General

1. Vandalism/Trespassing 0 Location shown on site map [gJ No vandalism evident

Remarks: - 2. Land Use Changes On Site ON/A

Remarks: The Citr of Jasger recent!~ gurchased groge!!Y that gartiall~ falls within the PMZ.

3. Land Use Changes Off Site [gJ N/A

Remarks:

VI. GENERAL SITE CONDITIONS

A. Roads [gJ Applicable ON/A

1. Roads Damaged 0 Location shown on site map [gJ Roads adequate ON/A

Remarks:

B. Other Site Conditions

Remarks: - VII. LANDFILL COVERS [gJ Applicable ON/A

A. Landfill Surface

D-5

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--

--

I. Settlement (low spots)

Arial extent: - Remarks: -

2. Cracks

Lengths: __

Remarks:

3. Erosion

Arial extent: - Remarks:

4. Holes

Arial extent: - Remarks:

5. Vegetative Cover

D No signs of stress·

D Location shown on site map


' Widths: -


· D Location shown on site map

[81 Grass

181 Settlement not evident

Depth: __

[81 Cracking not evident

Depths: __

[81 Erosion not evident

Depth: __

181 Holes not evident

Depth: __

D Cover properly established

[81 Trees/shrubs (indicate size and locations on a diagram)

Remarks: A few areas on the can are barren. Vegetation is not well established on the slones of the can. A few small trees are growing on the slones of the can.

6. Alternative Cover (e.g., armored rock, concrete) 181 N/A '

Remarks: - 7. Bulges D Location shown on site map [81 Bulges not evident

Arial extent: -- Height: __

Remarks: - 8. Wet Areas/Water Damage 0 Wet areas/water damage not evident

D Wet areas 0 Location shown on site map Arial extent: -- ..

[81 Ponding 0 Location shown on site map Arial extent: - -0 Seeps 0 Location shown on site map Arial extent: - D Soft subgrade 0 Location shown on site map Arial extent: - Remarks: There are a few areas where stormwater accumulates on the ton of the can during hean rain events.

9. Slope Instability 0 Slides D Location shown on site map

D No evidence of slope instability

Arial extent:

Remarks: There are some signs of erosion along the slones of the can, narticularl)'. on the southwestern side of the can.

B. Benches D Applicable 181 NIA

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

D-6

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--

--

1. Flows Bypass Bench 0 Location shown on site map IZI N/A or okay

Remarks: - 2. Bench Breached 0 Location shown on site map IZI N/A or okay

Remarks: - 3. Bench Overtopped 0 Location shown on site map IZI NIA or okay

Remarks: - c. Letdown Channels IZI Applicable ON/A

(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

1. Settlement (Low spots) 0 Location shown on site map IZI No evidence of settlement

Arial extent: -- Depth: __

Remarks: - 2. Material Degradation 0 Location sho~n on site map IZI No evidence ofdegradation

Material type: __ Arial extent: - Remarks: -

3. Erosion 0 Location shown on site map IZI No evidence oferosion

Arial extent: Depth: __

Remarks:

4. Undercutting 0 Location shown on site map IZI No evidence of undercutting

Arial extent: -- Depth: __

Remarks: -

5. Obstructions Type: __ IZI No obstructions

0 Location shown on site map Arial extent: -

Size: - Remarks: -

6. Excessive Vegetative Growth Type: __

IZI No evidence ofexcessive growth

O Vegetation in channels does not obstruct flow

0 Location shown on site map Arial extent:

Remarks:

D. Cover Penetrations IZI Applicable ON/A

D-7

--

--

--

--

--

--

I. Gas Vents O Active 0 Passive

0 Properly secured/locked 0 Functioning 0 Routinely sampled 0 Good condition

0 Evidence ofleakage atpenetration · 0 Needs maintenance ON/A

Remarks:

2. Gas Monitoring Probes


-0 Evidence of leakage at penetration 0 Needs maintenance ON/A

Remarks:

3. Monitoring Wells (within surface area of landfill)


0 Evidence of leakage at penetration 0 Needs maintenance ON/A

Remarks:

4. Extraction Wells Leachate

0 Properly secured/locked 0 Functioning 1:8:1 Routinely sampled 1:8:1 Good condition

0 Evidence of leakage at penetration 0 Needs maintenance ON/A

Remarks:

. 5. Settlement Monuments 0 Located 0 Routinely surveyed ON/AI

Remarks:

E. Gas Collection and Treatment 0 Applicable 1:8:1 N/A

I. Gas Treatment Facilities

'0 Flaring 0 Thennal destruction 0 Collection for reuse

0 Good condition 0 Needs maintenance

Remarks: - 2. Gas Collection Wells, Manifolds and Piping

D Good condition 0 Needs maintenance

Remarks: - 3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

0 Good condition 0 Needs maintenance ON/A

Remarks: - F. Cover Drainage Layer 1:8:1 Applicable ON/A

I. Outlet Pipes Inspected 1:8:1 Functioning ON/A

Remarks:

2. Outlet Rock Inspected 1:8:1 Functioning ON/A

Remarks: - G. Detention/Sedimentation Ponds 0 Applicable 1:8:1 N/A

D-8

--

--

--

--

--

--

--

I. Siltation Area extent: -- Depth: __ ON/A

. 0 Siltation not evident

Remarks:

2.' Erosion Area extent: -- Depth: __

0 Erosion not evident

Remarks: - 3. Outlet Works 0 Functioning ON/A

Remarks:

4. Dam 0 Functioning ON/A

Remarks: - H. Retaining Walls 0 Applicable ~NIA

I. Deformations 0 Location shown on site map 0 Deformation not evident

Horizontal displacement: __ Vertical displacement: __

Rotational displacement: __

Remarks:

2. Degradation 0 Location shown on site map 0 Degradation not evident

Remarks:

I. Perimeter Ditches/Off-Site Discharge 0 Applicable ~N/A.

I. Siltation 0 Location shown on site map 0 Siltation not evident

Area extent: -- Depth:_·_

Remarks: - 2. Vegetative Growth 0 Location shown on site map ~NIA

0 Vegetation does not impede flow

Area extent: -- Type: __

.Remarks:

3. Erosion 0 Location shown on site map ~ Erosion not evident

Area extent: -- Depth: __

Remarks:

4.. Discharge Structure 0 Functioning ~NIA

Remarks: - _,, VIII. VERTICAL BARRIER WALLS 0 Applicable ~NIA

I. Settlement 0 Location shown on site map 0 Settlement not evident

Area extent: -- Depth: __· r-

Remarks:

D-9

--

2. Performance Monitoring Type of monitoring:_._

0 Perfonnance not monitored

Frequency: __ 0 Evidence of breaching ~

Head differential: '

Remarks: - IX. GROUND WATER/SURFACE WATER REMEDIES 181 Applicable D NIA

A. Ground.Water Extraction Wells, Pumps and Pipelines 181 Applicable .ON/A

I. Pumps, Wellhead Plumbing and Electrical

181 Good condition 181 All required wells properly operating 0 Needs maintenance ON/A

Remarks: - 2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances


Remarks: - 3. Spare Parts and Equipment

[8J Readily available [8J Good condition 0 Requires upgrade 0 Need; to be provided

Remarks: - B. Surface Water Collection Structures, Pumps and Pipelines D Applicable [8J N/A

1. Collection Structures, Pumps and Electrical

0 Good condition D Needs maintenance

Remarks: - ·2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances


Remarks: - 3. Spare Parts and Equipment ,,

0 Readily available 0 Good condition 0 Requires upgrade 0 Needs to be provided

Remarks: - C. Treatment System 181 Applicable ON/A

D-10

I. Treatment Train (check components that apply) \

0 Metals removal 0 Oil/water separation 0 Bioremediation

D Air stripping D Carbon adsorbers

[8J Filters: The sxstem includes clax and granular activalted carbon filters.

[8J Additive (e.g., chelation agent, flocculent): Sxstem additives include biocide and an iron seguestrant.

OOthers: __

[8J Good condition 0 Needs maintenance

[8J Sampling ports properly marked and functional

[8J Sampling/maintenance Jog displayed and up to date

[8J Equipment properly identified

[8J Quantity of ground water treated annually: 10.1 million gallons of ground water were treated in 2011.

0 QuantitY of surface water treated annually: __·

Remarks: Annual amounts of treated ground water can be found-in annual O&M regorts.

2. Electrical Enclosures and Panels (properly rated and functional)

ON/A [8J Good condition D Needs maintenance

Remarks: - 3. Tanks, Vaults, Storage Vessels

) ) ON/A [8J Good condition [8J Proper secondary containment 0 Needs maintenance

Remarks: - '

4. Discharge Structure and Appurtenances

ON/A [8J Good condition 0 Needs maintenance

Remarks: - 5. Treatment Building(s)

ON/A ·[8J Good condition (esp. roof and doorways) 0 Needs repair ()

[8J Chemicals and equipment properly stored

Remarks: - 6. Monitoring Wells (pump and treatment remedy)

[8J Properly secured/locked [8J Functioning [8J Routinely sampled [8J Good condition

[8J All required wells located 0 Needs maintenance ON/A

Remarks: - D. Monitoring Data

I. Monitoring Data

[8] Is routinely submitted on time [8] Is of acceptable quality

2. Monitoring Data Suggests:

[8J Ground water plume is effectively contained D Contaminant concentrations are declining

E. Monitored Natural Attenuation I. Monitoring Wells (natural attenuation remedy)

D Properly secured/locked 0 Functioning 0 Routinely sampled

0 All required wells located 0 Needs maintenance

0 Good condition

181 N/A

Remarks: - X. OTHER REMEDIES

If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An-example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions). tfiie remed)'. was designed to grevent direct contact with contaminated soil and sediment, ingestion of bontaminated ground water b)'. gotential future residents, and contaminated ground water migration aqil ~n!n:'. to surface water. Remedial actions tQ address conmminated surface water, soil and sediment an~ placement of contaminated soil and sediment in the RCC have addressed current threats to human and eco)og:ical health from these media. The PMZ restricts g:round water use within and adiacent to the TiiJ frhe water treatment nlant annears to be controlling: eimansion of the nlume. However there have heed boerational difficulties with the oneration of the treatment svstem <see C. below). In addition the 2006 ROD called for imnlementing: institutional controls to maintain a future industrial or commercial land use scenario for both on-site and off-site affected nronerties. These controls have not vet been imnlementedJ

B. Adequacy of O&M Describe issues and observations related to the implementation and scope ofO&M procedures. In ~articular, discuss their relationship to the current and long-term protectiveness of the remed_~------, O&M efforts are underwa)'. for both the ogeration of the ground water treatment S)'.Stem and maintenance bfthe RCC can. The O&M for these activities annears adeauate althou!!h there have been som~ bnerational issues. See C below .I

c. Early Indicators of Potential Remedv Problems Describe issues and observations such as unexpected changes in the cost or scope ofO&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. In 2011, treatment S)'.Stem ogeri}tors identifed fuat free-ghase DNAPL entered the water treatment giant's treatment grocess vessels during normal gumging ogeration from well R-2. It was later discovered tha1 DNAPL was also oresent in recoverv wells R-1. R-3 and R-4. To address this nroblem the recoverv weITS ~ere retrofitted with a dual-ohase numnine svstem. Collected DNAPL is now conveved to the DNAPU tank within the water treatment giant that is segarate from the ground water treatment S)'.Stem used to treat ~issolved ghase contaminant mass . The dual-ghase s~stem is successfull)'. keeging DNAPL from entering i . the ground water treatment s~stem.I

One other issue has been infiltration cagaci!)'. of the injection wells. The main cause ofgoor injection berformance was biofouJing:. Biocide iniection on the influent side of the water treatment nlant has beert lmable to control injection well biofouling. To i}llow for some limited ogeration of the recovery wells1 ~ bortion of the treated water was diverted to the RCC for irrigation of the f?TaSS cover. To maintaiJ. individual well numning: rates close to 15 g:allons ner.minute. and to nrovide relief to the iniectio~ wells ~ tiiore robust irrig:ation svstem <snrinkler svstem) was nlaced on ton of the RCCJ

D. Opportunities for Optimization Describe possible.opportunities for optimization in monitoring tasks or the operation of the remedy. RCC irrigation max be exceeding agronomic rates, and it might be necessID to connect the water treatment giant to the Ci!)'. of Jasger's POTW.

Site Inspection Participants:

D-12

Eric Marsh, Skeo Solutions Melissa Oakley, Skeo Solutions Bob Sullivan, EPA Region 6 Pat Appel, CH2M HILL Lam Tran, TCEQ

D-13

Appendix E: Photographs from Site Inspection Visit

View of the water treatment plant from the Site's front entrance.

Water enters the treatment plant here along the building's southern exterior wall. The RCC is shown in the background.

E-1

The treatment system consists of an equalization tank, clay filters, granular activated carbon filters, a backwash tank and a large creosote collection tank.

DNAPL (creosote) holding tank. Dedicated DNAPL pumps convey the DNAPL directly to the tank, bypassing the treatment trains.

E-2

Breaker boxes in the treatment plant control room.

d '.>It <1,. ....l.Y,.,.

t J h•Y<. f.t

" I li•I

The status of the automated treatment system can be viewed on this screen in the control room and accessed remotely.

E-3

Site O&M plans, health and safety plans, and regulatory documentation are stored in the control room.

The RCC cap is mostly vegetated.

E-4

Sprinkler system used to irrigate cap vegetation. Treated water from the effluent plant is used as the water source.

Leachate collection system on the southern edge of the RCC cap.

E-5

Let-down channels help to direct stormwater off of the RCC cap.

The establishment of a vegetative cover on portions of RCC cap slopes has been difficult. Various slope segments, as shown here, have erosion problems as well as unwanted tree

growth.

E-6

The treatment system's recovery wells are located south of the RCC.

Recovery wells were locked and secured.

E-7

•

Interior view of recovery well enclosure. In November 2012, the recovery wells were retrofitted with a dual-phase pumping system to recover DNAPL.

Point-of-compliance well located toward the southern end of the PMZ just north of Big Walnut Run Creek. The compliance well was locked and secured.

E-8

.._...-. ~ . : :: ·.j • ' •••

.... - ...

Appendix F: Toxicity Review Table

cart1nogenlc toxtclty changes Non·carctnoa:enk toxicity changes Orel cancer Slope Factor Inhalation Unit Risk (IUR) Orel Reference Dose (RID) Inhalation Reference concenuauon (RIC)

2013 2006 Rl/FS 2013

2006Rl/FS Oral Inhalation Inhalation 2006 Rl/FS Oral canrer cancer Slope Unit Risk UnllRl>I< Orel RID 2013 Orel 2006Rl/FS 2013 lnhalatlon

Slope Factor Factor Chanse In Value Value Cha~ie irl\). Value RID Value Chanae In Inhalation RIC RfCValue. Chanse In Contaminant (molka-d...1·• lm11/l111-dayr' OrelCSF !ualm'r' (ualm'r' IUR (mlllkR·dl Ilmlllka-dl Orel RID Value (molm'J (mlllm'l Inhalation RIC

,2,4-Dtmethvlnhenol N/A N/A nochant:e N/A N/A nod'lanae 2.0E-02 2.0E·02 nod\anCH1 N/A N/A nochana:e 2·Methvlnaohthalene N/A N/A nochan.lle N/A N/A nochanae 4.0E-03 4.0E-03 nochans:e N/A N/A no change 2·Methylphenol N/A N/A no change N/A N/A nochana:e 5.0E-02 5.0E·02 no change N/A 6.0E·Ol more strinaent 3 &/or4-Methvtphenol N/A N/A nochansce N/A N/A no cham1e 5.0E-02 5.0E-02 no change N/A 6.0E-01 morestrln1ent

Acenaphthene • N/A N/A nochanae N/A N/A no change 6.0E-02 6.0E-02 no thanae N/A N/A nochanae Acenaohthvlene N/A N/A nochan1te N/A N/A 6.0E-02 N/A less striruzent N/A N/A nochan2e Anthracene N/A N/A no change N/A N/A nochana:e 3.0E-01 3.0E-01 no change N/A N/A Benzo(a)anthracene 7.3E·Ol 7.3E·Ol nothanae N/A 1.lE-04 more stringent N/A N/A nochanae N/A N/A noch8nae Benzo(aloVTene 7.3E-t00 7.3E«JO no chanee N/A 1.lE-03 more strlna:ent N/A N/A nochanae N/A N/A nochan2e 1Ben:rolblfluoranthene 7.3E·Ol 7.3E-Ol no chan•e N/A J.lE-04 more strinRent N/A N/A nothanae N/A N/A nothamze Benzol..h,iloervlene N/A N/A no chan•e N/A N/A no chanae 3.0E-02 N/A N/A N/A no mange Benzo(k)fluoranthene 7.3E-02 7.3E-02 no thange N/A 1.lE-04 more strinllent N/A N/A no change N/A N/A •nochanae carbazole 2.0E-02 N/A less stnnaent N/A N/A no change N/A N/A N/A N/A _ no change

!Chrvsene 7.3E-03 7.3E-03 nochant:e N/A 1.lE.OS more stringent N/A N/A nochanae N/A N/A noctianae '01benzta,hlanthracene 7.3E-+00 7.3E«JO no change N/A t.2E-03 more strinaent N/A N/A nochanae N/A N/A nodianae Dlbenzofuran N/A N/A no change N/A N/A no chan•e 2.0E-03 LOE-03 more strlfuz:ent N/A N/A no change Fluoranthene N/A N/A nochanae N/A N/A no chanoe 4.0E-02 4.0E-02 no change N/A N/A no than.Re Fluorene N/A N/A nochana.e N/A N/A nothan•e 4.0E-02 4.0E-02 no chanae N/A N/A nochanae lndenoll.2.3-all-ovrene 7.3E-01 7.3E·01 nochan1e N/A l.lE-04 more stringent N/A N/A no thanae N/A N/A notharuze

iNachthalene N/A N/A nochanae N/A 3.4E-OS more strinaent 2.0E-02 2.0E-02 no chan11e 3.0E-03 3.0E-03 no change i Phenanthrene N/A N/A no change N/A N/A no chanoe 3.0E-02 N/A less stnnoent N/A N/A nochan1e l!Pvrene N/A N/A nochanae N/A N/A no change 3.0E·02 . 3.0E-02 no change N/A N/A nochanae Benzene 5.SE-02 5.5E·02 nochanRe N/A 7.8E-o& more strinRent 4.0E-03 4.0E-03 nochanae N/A 3.0E-02 more strinRent

F-1

Appendix G: Institutional Control Documentation

Exhibit 1: PMZ Registration Letter

UNJTED STATES ENVIRONMENTALPROTECTION AGENCY REGION6

1445ROSSAVENUE,SUl'TE 12CO DAU.AS TX75202·2733

·JUL S 3 !Off Lee Parham! Mana.gel

~ · Texas Department ofLicensing and Regulation Water Well Driller/Pump Installer Section Compliance Division P.O. Box 12157 Austin, Texas 78711

Subject: OtoUnd Water ContamiDlltion and Restricted Water Well Drilling Area at the Han Creosoting Superfund Site, Jaspec, Jasper County, Texas

Dear Mr. Parham:

·.The United States Environmental Protection Agency (EPA) Region 6 is provi~ this letter to tho Texas Department of Licensing and Regulation (f'DLR) as notification of the ptcSence of ground water contarni~tion associated with the Hart Creosoting Company Superfund .Site

· located in Jasper, Jasper County, Texas. EPA has conducted ground water sampling and analysis in the affected area.( as indicated on the attached map), which detectal elevated concentratiom of constituents from historical wood Jireserving operations.. 11le following is lhe list ofground.water contaminants of concern (COCs) provided ~the Record of Decision (ROD) for the Hart Creosoting SupCrfund Site. .

2,4-DimcthylPJtenol · 2·Methylnaphlhalene 2-Methylphenol

. 3 &/or4-Methylphenol Acenaphthene Acenaphthylenc Anthrac:ene ~enzo(a)anthracene Bcn:zo(a)pyrene Benzo(b)fluoranthene

Benzo(g,hJ)perylene

Bemo(k)tluomnthene

Chrysene

Dibem.(a,h)anthracene

Indeno(l ,2;3--<:,d)pyrene Naphthalene Phenanthrene Carbazole Chrysene Dibcnz(a.h)anthmcenc · Dibenzofunm Fluonmthcne Fl\IOl'elW Indeno(l~2,3-cd)-pyrene

Naphthalerie

Phenanthrene

Pyrene

Bemenc

The known ground water aontaminant.plume and KStricted drilling area are located wi1hin the south portion of Grid 61·08-6 ofth.Q Texas Water Well Numbering System. Due to known levels ofco.ntmn.inants in the ground watei, the ROD established a Plume ~ement Zone (PMZ) where the iastall8tion of new water supply wells is restricted. Abendonri:tent and plugging of

G-1

I

. ·1\ . . . ' l

.., . I 'j

r

II

)

I I

! '

' l I

i I II , i

..}"... .•;

. ·~. ·. .. .

existing water Welts ~y also be required in -thlB area ror grQund M~r protectio~ The attadi~d . . map shows .the boundary of the PMZ and le8al descfiption as defined by Mark Birdwell 8111'."eying on December 21, 2010 (enclosed). ·

. -Jf you have any questions or require additiorutl information concerning this notification, please · · contact Robert Sullivan, ReinedialProject Manager~ at (214) 665-2223.. ·

,.

Sincerely, . .

-~'.··.· .Remedial Prciject Manager · EPA Regioi;i 6

_Enclosures

Cc: Alan (Buddy) Henderson· TCEQ .

Andy Bajwa . TCEQ

John Martin; General Man$ger · SETGCD .

Tammy Boykin, City Maoaier City ofJasper

.Hrinotable Mark:W; Allen · · Jasper County Judge_

G-2

Exhibit 2: PMZ Survey and Legal Description

Mark Birdwell Surveying PO Box J 142

I 121 .Market Street Hemphill, TX 75948

Phone 1409) 787-2722 Fax (409) 787-9986

James Conn Survey A-8 Robert Conn Survey A-9 State ofTexas

County ofJao;per

Lcgnl Description Toa

79.24 t Tract (Plume Munag<!ment Zone)

Bci11g a lcgnl description to n 79.141 acre tract (Plume Management Zone) in the Jame~ Corm Sun•ey A-8, and the Robert Conn Survey, A-8. Louted in fa!per County, Texas being part of a cnlled 253.024 ncrc tract owned by Crown ·Pine Timber 3, LP, nnd is further described by metes nnd bounds as follows to-wit:

BEGINNING: Al a point S 52° 22' 59" W 632.68' from 11 concrete monum(mt with bras.!! disk (Stampi:d "J 362'/, with n coordinate value of I0.346, 188,83. N aru:l 4,284.215.47 E (Texas State Plane Coordinates), provided lo me. Wm Mark

Birdwell RPLS #51411, by L & L Engineers lllld Planner.>, Inc., being the Northeast comer ofn called 8.83 owned by E.T.M.S."Inc. recorded in Volume 460 Page 405 of the. Deed Records ofsnid County;

THJ:.'NCE: Along the boundary ot' a 79.241 acre tract as follows:

I. S 05°41 '49" E 3568.90' ton point~

2. S 86°13'29" W 3'7.92' to a point:

3. S 51°13'57" W 51.43' to a point;

4. S 00"45'45" E 80. Hi' ton point;

s. S 12°44'53'' E 81.05' ton point;

6. S 33°31'13" E 135.88' ton point;

7. S 35°16'47" E76.60' to ti point;

8. S 06°30'06" E 44.29' lo a point;

9. S ·11°44'55" W 39.34' to a point;

·10. S 48°04'02" \V 37.51' too poim:

11. S 67"47'23" W 59.96' to a point;

12. S 42°57'37" W 49.18' to a point;

13. S 34°53'04" W 67.45' lo a point;

G-3

14. S 11 "44'55" W 39.36' to a point:

l:i. S 41"38'55" E 24.02' to a point;

16. S 29"20' I 0" E 53.71' \o a point;

17. S 01"29'05" E S2.71' to a point:

18. S 24°07' 19" W 4C.52' lo apoint;

19. S 39"29'20" W 4<;.18' to a point;

20. S 18"50'40" W 54. 77' io a point;

21. S 06"03'08" W 6<;,37• to a point;

22. N 28°55'13" W 1259.62' to a point;

23. N 11°25'21" W 33Kl.03' to a point;

24. N 86° IJ'2R" E 713.64' 10 a point:

25. N 84°57'05" E 349.14' to the point of begitu1ing containing approximately 79.241 at:l't!s ofland; '

-*NOTE*

L I. Wm Mark Birdwell RPLS 115148, did nut perrorm a Survey on the ground.

2. Surveyor did nut Abmact for title and did not locate any utlliti~s ..

3. All bearing, distances, and coordinates herein recited Rll: from information pro\•idcd by L & L Engineers and Planners, Inc.

4. All Deed infomui.tion herein was provided by L &. L Engineers and Planners., Inc.

5. Above acreage calculated from infonnation provided by L &· L Engineers and Plruuiers, Inc

6. Sur"eyor does not guarantee acreage or accuracy of this legal document.

7. Abo"e Legal description does not meet ihe minimum standards set by the Texas Board of Professional Land Surveying aJld are meant for dcscripti\•e purposes only.

Surveyed by;

Wm. M1uk llirdwi:ll R.P.L.S. #5148

Dccember21~ 2010 Job #PWME·Drawing #PLUME

If this document is not signed and sealed in red, it is deemed void by the above signed.

G-4

---

SURVEY PLAT 1t!A

79.241 ACRE P~IJME MANAGEMENT ZONE '~ •aNd,..dRfu.nl4. ..... pnlrlt•

.-...~ ........ 11'"!118

COUNTY OF JASPl!R. TEXASL~#!l..,..~~~-!!"111'~~

t,AI ......................................_ l'ra........._...,9fiA1.~.m1;aml-... ...

1.,o1lbir'"2h1k...._ Ndl•1111 p-~\'L•L ,~ ... hmrn.

,,Amltll~hnllllnld•nnul• LA.L elllftm et'~"

&-Ci&rwf6t ............ llnllt..MC'ft0f1Chpk.

DETAIL t'A" NOTTO SCALE

_,

79.241 ACRES MANAGEMENT ZON. ·--~-·-··

AlD111Dl.llJfnnsD

ID"'Mm•JJ.nli.rt ~IQ.tltftt.I ~~n'1'n

..M"i"lfftl ,~..,.Pl~

ac.tc: Nit.

G-5

Exhibit 3: Jasper Code of Ordinances: Contaminated Wells

Municode Page 1 of3

Jasper, Texas, Code of Ordinances» PART II - CODE OF ORDINANCES» Chgmer 26 -WELLS» ARTICLE II. - WAJFB WEI I S » DMSION 3 - CONIAM!NAJFQ Wfl I S >>

DIVISION 3. - CONTAMINATED WELLS

srs 26-.51 - Spgpg· spmpljansft

S..c. 26-52. - Pluppinp required when e<1ntaminated water encountered.

Sec. 26-53. - Procedure when well greater than eighty ~t deep is contaminated.

Sec. 26-55. - Filling and pfuggina w~ defect uncorrectable.

Seq 26.fift fjlibq fit.:Jt:ment pf Qpmffitign pf dgfgst:;a

Secs. 26-67~26-73. - Reserved.

Sec. 26-51. - Scope; compliance.

The provi~ions o~this division shall apply to all wells, whether inside or within one (1) mile of the city, heretofore drilled or which may have been abandoned, and upon proper notice, as called for being given to the owner, agent of the owner or lessee of the property on which any such wen is situated. such well shall be plugged or sealed as called for herein.

(Ord. No. 11-96-2, 11-4-96)

Sec. 26-52. - Plugging required when contaminated water encountered.

If a stratum of contaminated water or water having a high mineral content Is encountered In the test hole below the water bearing strata from which the water supply of the city is taken or drawn, such contaminated or highly mineralized stratum shall be plugged or closed off from the · remainder of the well. This shall be accomplished by pumping through a pipe extending to the bottom of the test hole a plastic or aqueous mixture of quick-setting cement of sufficient quantity to completely plug or extend entirely through the contaminated or mineralized stratum and well up into the first impervious or nonwater bearing stratum above. The test hole ·shall then be allowed to .remain undisturbed for a period of at least seventy-two (72) hours In order that the cement plug become thoroughly set or hardened.

(Ord. No.. 11-96-2, 11-4-96)

Sec. 26-53. - Procedure when well greater than eighty feet deep is contaminated.

In order to prevent contaminated, polluted, highly mineralized or otherwise objectionable water encountered in any stratum above those from which the water supply of the city is taken or drawn, from entering or mixing with the water bearing strata from which the city supply is taken or drawn; and to prevent the entrance of surface water to such water bearing strata, in each case of a well drilled over eighty (80) feet and in penetrating the water bearing strata from Which the city supply is taken or drawn, the following procedure shall be followed:

(1)

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MUDlCOOC r.ige L. OI .3

The test hole shall be reamed out to the desired diameter of the finished well down to the first impervious or nonwater bearing stratum above the strata from which the water supply of the city is taken or drawn.

(2) The casing shall then be set down to the aforesaid point or depth and upon a nonwater bearing.or impervious stratum.

(3) The annular space between the outside of the casing and the bore hole or natural formations shall then be completely filled with a plastic or aqueous mixture of quicksetting cement which shall be pumped into the well under pressure through a pipe or conduit extending to the bottom or the casing as set, such cement entering the annular space between the outside or the casing and the bore hole at the bottom or such casing, and filling such annular space by flowing upward to the top of the well or surface of the ground. Evidence of such annular space being completely filled shall be by the plastic or aqueous cement mixture returning to and llowing from the annular space at the surface of the ground.

1(Ord. No. 11·!iJ6·2, 11-4-96)

Sec. 26·54. ·Defective wells declared nuisance; correction of defect.

(a) Every well which for any reason does not completely prevent the mixing of water or other liquid from above and below the source of the city's water supply with the water in the source of the city's water supply, or which for any reason would tend to pollute or contaminate the water in the course of the city's water supply shall be considered a defective well. Defective wells are hereby declared to constitute a nuisance, and the city manager on his~ initiative or upon information or complaint from any source shall make an examination of any well suspected of being defective, and shall issue written instructions to the owner or his agent in •

·charge of such well or the property upon which it is situated, for correcting the defects and complying with provisions of this artide. The city manager shall prescribe a time which, in his judgment, under all the circumstances. is reasonable and within Which the instructions shall be complied with. It shall be unlawfUI for the owners or operators of a defectiVe well to fail to comply with the city manager's instructions and abate the nuisance within the time limit prescribed. If the instructions are not complied with, the nuisance may be abated by the city as provided in this section. · ·

(bl If the owner, agent of owner or lessee fails to comply with the city manager's instructions, the city manager may apply to the city council for permission to plug, seal or case the defective well and thereby abate the nuisance, and place a lien on the property and a personal charge against the owner to cover the costs of sealing the defective welt. The manager shall set forth in his application the location of the well, the name of the record owners of the property and the manner in which the well is defective. Notice of the filing of such application to plug, case or seal the well and place a lien on the property and personally charge the owner to cover the costs [of) sealing the defective well, shall be published once in the official newspaper of the city not more than five (5) days prior to any regular meeting of the city

council. (c) The city council may hear the application, and if it determines by resolution that the well is

defective and thereby constitutes a nuisance, it shall be resolution order the city manager to proceed with the plugging, casing or sealing or the well and to file upon completion of the work, with the city secretary, a sworn statement setting forth the expenses incurred in plugging, sealing or casing the well. Upon filing of such statement, the mayor shall incorporate the statement in a notice to be executed and acknowledged by him and filed with the county derk, setting forth the claim or the city for expenses incurred in plugging, sealing

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Municode Page3 of3

or casing the well; and upon the filing of the notice, it shall constitute a lien against the property on which the well is located, and a personal charge against the owner. A suit may be thereon, and the lien foreclosed as provided by law for the foreclosure of other liens. Notice shall be given to any person in possession of the property on which the defective well is located'by mailing a copy of the published notice to·the person.

(Ord. No. 11-96-2, 114-96}

Sec. 26-55. - Filling and plugging when defect uncorrectable.

Any well or other opening now constructed penetrating the underground water supply, and which pollutes or contaminates, or tends in the judgment of the city manager to Pollute or contaminate the city's water supply, and Which cannot be corrected in the judgment of the city manager, is hereby declared a nuisance. On notice to the owner of the well or opening, or to his agent in charge of it or of the property on which it is situated, issued by the city manager the nuisance shall be abated by the owner within sixtY (60) days from date of the notice by filling and plugging the well or opening in the manner provided for in this article for abandoned wells. If the owner shall fail to abate the nuisance within the sixty (60) days, or if after exercising reasonable diligence, the city manager is unable to locate the owner or his agent, the city manager shall go onto the land or property upon which the well is situated, and abate the nuisance in the manner above provided; and the owner of the well shall be liable to the city for the cost of the work.

(Ord. No. 11-96-2, 11-4-96)

Sec. 26-56. - Filing statement of correction of defects.

Upon completion of the work correcting the defects of any well, and before putting it into operation, the owner of the well shall file with the city manager a sworn statement that all defects have been corrected to comply with this article in accordance with instructions issued by the city manager and failure to file such a statement within thirty (30) days after completion of corr:ection of the defects shall be deemed a violation of this article.

(Ord. No. 11-96-2, 11-4-96)

Secs. 26-57-26-73. - Reserved.

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Exhibit. 4: Institutional Control Package

Institutional Control Area - HARTCreosotirig Site long~Term Remedial Action Jasper, Tex:as

.. ",; . \

BURIED CONTAMINANTS: STOP BEFORE YOU O!G

le. ~h;Jil be Ynl~'llrli.!! for Q:!!.y p~rs.<>.t11 Qt p~~QIU .tQ drmt n~ Wlf!i!!% Wietlti'! ~c. Pl1,1me M.:tll>l!S~ll'!Cnt ZQ~ ~l"l~;I~ \ltC Mart Su~mmd .¥tc. It !:i; the '!i'.!:n1fowncr':S< tes111onsibi!~ty to rni!1n,til;n tho int~t'f il!nd 11.~iibl!itr of the m~~tini~I~ !«<Iced r:m tt1!1't P!'~perty. bc;t~tion. far tt<:?!' bu!rd~~ ~li!~J! •be llm.~ to iim: fti_al'! l I~.y~~ prfQ~ EPA or TC:EQ. wti'!Ur.i ar;ipro-~1 ~~imed, The RCC i'n tM tr1idd'ft of~ piropgey shr:;u;itd .be ctt limits eo anv ii> • • wltQ m dtrNttm the int :: of ttm R-OC,.

lnstltutf()~I control f P'A !llill TX!H1Ml299!>17 tJ;in111~sl~~ t>!mlct a L'\ll~p(ri:!!~~~

ti~ ~PA Ri!BMoMi!<ilS $YJ!IXlrt 111ra;e flam G~.Xptorcr CIG!»f?OU l~'l'IXIO

Ai ri:atnfod :in deed rite numt111r V>lllumc _______~·~-

flied IAJr r'.!ll:o1lll In 11'1e Jasper C<l1;111ty,'Te.0s Oler~~ O~lc...' ------

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. ;t.':."· ' r \ ~ _.,. • ; ' l

.

State of Texas, County of Jasper_________

This instrument was acknowledged before me on this date· 2012 by:._______________

Notary Public's SignatureCam.mission Expires:___________

As a representative of the U.S. Environmental Protection Agency, I he<lrby affirm that the facts and information contained herein are truthful and accurate to the best of my knoWledge, and that the filing of this notice is required byUSEPA, '

Robert Sullivan, Remedial Project Man111:er

G-10

Appendix H: 2006 ROD Remedial Goals for Environmental Media

TABLE 1-2

Summary of Remedial Goals for Contaminated Media Hart Cteosoting Company SUpertund Site

Jasper Texas

Ground Water PRG Surface Water PRG Sediment PRG COCs (llgll) Soil GW-PRG (mg/kg) (pg/L) (mg/kg)

2,4-0lme111y1pneno1 250 3.2 105 NA

2-Metllylnaplltll31ene 57 25 63 0.54·

2-Metnylpllenol 660 7.1 1,120 NA

3 &/or 4-Mellly!phenol 660 6 1,120 NA

Acenaphtnene 130 52 23 0.121'

Acenaphtnylene NA NA 23 1.22·

Antnracene NA NA 0.3 0.57'

BenzO(a)anlhracene 0.085 3 0.81 1.17

Benzo(a)pyrene 0.2 19 0.014 0.789

Benzo(b)lluorantnene 0.052 6.3 0.014 0.976

BenzO(g,h,i)perytene NA NA 0.014 0.28'

Benzo(k)Duorantnene NA NA 0.014 0.833

Car1lazole 43 10.6 56.8 NA

Chrysene 19 587 7 2.02'

Oibenz(a.h)antnracene 0.0033 0.63 0.18 0.131

Olbenzofuran 5 4.3 74 0.912'

Fluoranthene NA NA 6.16 2.9•

Fluorene 87 66 11 1.07'

lndeno(1.2,3-cd}-pyrene 0.052 18 0.014 0.304

Naphtnalene 100 15.6 250 0.1

Phenantllrene 130 184 30 3.4·

Pyrene NA NA 7 1.97'

Benzene 5 0.039 106 NA

Notes:

COC: contaminant of concern GW: Groundwater

mg/kg: mHligrams per kilogram

NA: Not Applicable (not a COC for the medium)

PRG: Proposed remedial goal

•: PRGs for protection of ecolOgical receptors only.

11gll: micrograms per liter

HCC_YEAl\...2011...ANNlJAl.J!B'_TABLE 1-2 E&:ll211Z2242400FW

Ground Water to Surface Water PRG

(pg/L)

700 • 420

7,467

7,467

153

153

5.4

0.093

0.093

0.093

0.093

379

47

1.2

493

41

73

0.093

1,667

200

47

707

H-1

2

Appendix I: Ground Water Monitoring Data

Hart Creosoting Company Superfund Site: Total PAH Concentrations, 2008-2011

Well ID Approximate

Location Jun-08 Dec-08 Jun-09 Jun-10 Jun-11

MW-J RCC 1.23 0.893 1.13 26

MW1A RCC 0.951 1.52

MW-6 RCC 2.67 0.85 0.969 11.7

MW-14A TIZ 510 723 1160 8.67 26.8

MW-14B* TIZ. 1370 1380 1250 409

MW-15-1 PMZ-East 0.923 1.23 0.943 9.33

MW-15-2 PMZ-East 0.97 1.04 0.876 6.7

MW-15-3 PMZ-East 0.91 1.17 0.916 6.93 18.1

MW-15-4 PMZ-East 0.96 1.07 0.907 4.45

MW-15-5 PMZ-East 0.91 1.18 0.91 18.9 18.2

MW-15-6 PMZ-East 0.91 1.24 1.01 7.35

MW-15-7 PMZ-East 0.88 1.16 1.12 6.69 16.1

MW-16-1 PMZ-West 0.87 1.19 0.879 14.1

MW-16-2 PMZ-West 0.8 1.14 1.1 6.69' 20.4

MW-16-3 PMZ-West 0.8 I.I 0.892 8.37

MW-16-4 PMZ-West 0.8 1.35 0.982 7.38 18.2

MW-16-7 PMZ-West 0.799 1.07 0.962 7.24

MW-17-1 TIZ-West 3.03 1.38 2.59 5.73

MW-17-2 TIZ-West 2.05 2.95 2.51 10.6

MW-17-3 TIZ-West 1.34 2·.15 2.64 14

MW-17-4 TIZ-West 1.29 5.75 2.76 13.1 67.6

MW-17-5 TIZ-West 848 1070 1490 2620 1970

MW-17-6 TIZ-West 3000 4580 6570 6530 5540

MW-17-7 TIZ-West 14.7 '35.2 54.5 54.1 NS

MW-18-1 TIZ-Center 2950 3450 3690 4450 2740

MW-18-2 TIZ-Center 5690 8220 8470 6690 10400

MW-18-3 TIZ-Center 4570 7420 8590 6790 10000

MW-18-4 TIZ-Center 3470 4720 2030 3110 1530

MW-18-5 TIZ-Center 1540 6280 6620 5750 1140

MW-18-7 TIZ-Center 331 68.6 87 442 509

MW-19-1 PMZ-South 0.8 1.18 1.23 11.7

MW-19-2 PMZ-South 0.8 1.21 0.806 9.89

MW-19-3 PMZ-South 0.8 2.45 0.869 4.65 18. 1

MW-19-4 PMZ-South 0.927 1.47 0.895 6.47 18.1

MW-19-5 PMZ-South 0.978 0.8 1.21 8.06

MW-19-6 PMZ-South 0.8 2.45 0.771 4.65

I- 1

Well ID Approximate Location Jun-08 Dec-08 Jun-09 Jun-IO Jun-11

MW-19-7 PMZ-South 1.86 1.32 0.878 9.09

MW-20-1 TIZ-Center 1910 6240 5970 532 2280

MW-20-2 TIZ-Center 5540 8460 8380 116 90.9

MW-20-3 TIZ-Center 6270 7080 8020 4380 3770

MW-20-4 TIZ-Center 6890 7300 7600 5960 7830

MW-20-5 TIZ~Center 5660 5450 5230 7710 ·8480

MW-20-6 TIZ-Center 6200 6320 6190 7200 8430

MW-20-7 TIZ-Center 6140 5580 6000 5520 . 8100

MW-21 RCC 1.96 1.15 4.72 9 20.4

MW-22-1 TIZ-Center 361 863 3110 5460 2140

MW-22-2 TIZ-Center 1250 3290 4910 6360 4260

MW-22-3 TIZ-Center 3450 6920 6050 6380 6450

MW-22-4 TIZ-Center 3610 7720 7510 7850 6590

MW-22-5 TIZ-Center 3330 5260 6900 5260 6990

MW-22-6 TIZ-Center 3430 7150 5570 2450 7540

MW-22-7 TIZ-Center 3920 4860 7030 5340 7140 Note: Blank cells indicate that no sampling occurred. *No value is listed for MW-14B for the June 2011 sampling event in the data included in the 2011 Annual Operations Report. However, a value of 2,300 for this period is shown in the figure excerpted from the 2011 Annual Operations Report (see Figure 3 in the FYR).

1-2

Sampling Data for MW-19: 2008-201 TAB!£A-1-l'/B.lll\'#.19

- - CroundwalBr Analysis ResultsHart Creosollng Company S14Jsfund SIU! ll!snor, Tl!taS

WeUID: w 11"' Effluent laOam MW-19-1 MW-19-1 MW-19-1 UW-19-1 UW-19-2 -~-19-2 --e1tJ-.i£ MW-19_,, location ID : HCC-61W19-01 HCC-MW19-01-1208 HCC-MW19.01--0609 HCC-MW19-01-0610 HCC-llW19.02 HCC-MW19.02-1208 HCUDOl-0609 HCC-61W19-02.0609

CH211 Sample ID : Aquifer 5urface Waler CLP Sample ID : Injection DillCbarge F2lM8 F2XMO F38118 F3J31 F2TM9 F2XMI F38K5 F38119 Dale Collected : 613/0B 0:00 12/BI08 11 :07 6'7/09 16-'03 6191'1015:20 6l3f08 0:00 12mloa 11:08 617!09 16-114 617/09 16:1).4

SampleTvpe: N N N ti N N FD II Parameta I Unit Result I Qual Resutt I Qual R011ult IOU.I Resutt I Qua! Result I Qua! R011ult I Qual Result I Qual Resutt I Qua!

SVOC-Total PAH and CPAH - TEQ Tollllt'Alis ~LI I I O.BI U I 1.181 • I 1.231 • I 11-11 - 0.61 U I 1.211 • I 1.na1 . I OJl061 Benm(a)Pyrelle TOllicity ~..;,,.,.,,..~ ~LI I I 01 U I UI u I o- = I 0 u 01 U I 01 U I OClll J I u.~ J

SVOC-t.ow Molecular W . 1PAHs N0~1halene •m 100 250 1 Naplrthalene, low l"""' .. 100 250 0.1 UJ 0.43 B 0.21 - 0.1 u 0.46 B 0.18 . 0.11 ... 23

=

lowLewi •m 23 0.1 u 0.1 u 0.1 u 0.5 u 0.1 u 0.1 u 0.1 u 0.1 u un 130 23 0.31 u

low level .. 130 23 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.019 . 0,1 u u 81 11 un"'""' •

Nucrene, low l...el u 8r 11 0.1 u 0.1 u U.1 u 0.1 u 0.1 u 0.1 u 0.1 u An!hracene low le.el 0.3 0.1 UJ 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u' A'aeum 1due11e .. 130 . 30 Pl"eiPibi 1ltbetie, Low Leva 130 30 11.1 u 0.1 u 0.1 u 0.5 u 0. 1 u 0.1 u 0.1 u 0.1 u Fluonmthene ... 6.1t> F._.,,thene low Lewi 6.16 0.1 u 0.1 u 0.1 u 0.5 u 0.1 u 0.1 u 0.1 u 0.1 u ~ un

·~ 1

~.LJ'JWLevel 1 u. u 0.1 u 0.1 u 0.5 u u.1 u u. u u.I u 0.1 u"" 1•V0<:-0ther Creosote Related 2 one 57 I 63 I I I I I I I 0.831 LJ I I I I I I 2 ene. Lowlevet

~· I 57 63 I 0.1 u 0.1 u 0.072• = 0.11 u I 0.09 J 0.0791 . I o.oa.. .

~ uoJL I 43 I 56.8 I 51 UJ I 51 u I s1 u I SI u 51 u I SI u I 51 u I u Ulbenzolunln • ,. I "1 w I ,. u I ,. u I ,. u 51 u I •I u I •I u I "' •I u

SVOC_...irrn Molecular Weioht PAHa .-n?l'lllo nmnracene Low Level •m 0.085 0.81 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u '-"""""" 19 0.27 LJun

~.l.owleve:i 19 0.1 u 0.1 u 0.1 u 0.5 u 0.1 u 0.1 u 0.1 u"' aen.LLllO)pyr'ene. Low Levei 02 0.014 0.1 u 0.1 u ..~. u 0.1 u 0.1 u 0.1 u 0.1 u u"·""' L-level 0.052 0.014 0.1 u 0.1 u 0.0 u- 0.1 u 0.1 u 0.1 u 0.1 u 0.018 u __.., muormrthene Low Lewi " 0.014 0.1 u 0.1 u 0.01 u 0.1 u 0. 1 u 0.1 u 0.1 u 0.016 u Benm(g,ll,1)per)1ene u D.014 Berml(g,hJ)pecytene, low level u 0.1114 0.1 u 0.1 u u.11 . 0.5 u 0.1 u 0.1 u u.v.. . .

·~ 1-1_2-3-c..d- Lcwlevel .. 0.052 0.014 0.1 u 0.1 u 0.1 . 0.1 u 0.1 u 0.1 u 0.1 u 0.1 UJ Dmenzla low level om O.D033 0.1 u 0.1 u 0.1 = 0.1 u D.1 u 0.1 u 0.1 u 0.1 u

SVU\-~

1.2.4. •m u s u 5 u s u u s u s u•"" 2.Z-0'""""'1-dllao~ •m UJ 5 u 5 u s u 5 u u s u u 2.34 un 5 UJ 5 u 5 u 5 u 5 u s u 5 u s u 2.4,5-Trichlarophenol s UJ 5 u u s u 5 u s u 5 u i u 2,4,t>-T. ! UJ s u u s u 5 u 5 u 5 u i u"' 2 •m ! UJ 5 u 5 u 5 u 5 u 5 u s u i u 2 250 105 ! u 5 u 5 u 5 u s u 5 u s i u.. "'

10 u 10 u 10 u 10 u ID u 10 u 10 u u 10 u ~ llQll ! w 5 u u s u : w : u 5 u u

PlllL w u ' u : u w : u u ' ua 2 E

""" s UJ s • u ' u s u s u s u • 5 u ' u

HCC._YEAA..201~_lABl.EA-1.V'5U.MW-t9

ES03221m424QDFW !OF~

l-1

TABLE A-1 - WB.U!W-19 Monitor Well Grwrlhratl!r Analysls Resulls Hart Oeosoling Company~ Sile 1-,Tl!Jll5

WelllD: WTP Elffuen1 Goab MW-19-1 MW-19-1 MW-19-1 MW-19-1 MW-19-2 llW-19-2 llW-19-2 MW-19-2 Location ID : HCC-MW19.()1 HCC-MW19-01-1208 HCC-MW19.()1.()609 HCC-MW19.()1.()610 HCC-MW19.()2 HCC-MW19.()2-1208 HCC-fll03-0609 HCC-MWf9.()2.()609

CH2M sample ID : Aquifer Surface Water CLP Sample ID : Injection OisdM!Tge F2TM8 F2XMO Fl8M8 f3J31 F2TM9 F2XM1 f38K5 F38M9 Date Collected : 6l3I08 0:00 12!8!08 11 :OT 617/09 16..-03 619110 15:20 613108 0:00 1218/0811:08 611/09 16,114 6/T/09 16..114

sample Type: ll ll N ll ll ll FD ll Parameur I Unit Resun Qual Result Qual Result Qual Result Qwll Result Qua! Result Qual Result Qual Result Qua!

2-Chkntl~~ ·~· 5 u 5 u s u 5 u 5 u 5 u 5 u 5 u 2-Meu~nol (o-Cresol) pgll 660 1120 5 u 5 u 5 u s u s u 5 u 5 u 5 u 2-Nltn>nniline Ug/l 10 u 10 u 10 u 10 u 10 u 10 u 10 u 10 u 2 ,,_, 5 UJ 5 u 5 u 5 u 5 u 5 u 5 u 5 u 3.3'-0ichlorobenzidine ua.1. 5 u 5 u s u 5 u 5 u 5 u 5 u 5 u 3-Nitroaniline "9fl. 10 u 10 u 10 u 10 u 10 u 10 u 10 u 10 u 4,6-Dinitro-2-meth)'lphenol l>g/L 10 u 1~ u ID u 10 u 10 u 10 u 10 u 10 u 4-6m"""""""" Phel1\'I el!ler unn 5 UJ 5 u ! u 5 u 5 u 5 u 5 u 5 u 4-Ch """ 5 UJ 5 u 5 u 5 u 5 u 5 u 5 u 5 u 4-Chloroaniline 4-Chlorophen)'I phenyl ether 4-Ni1l'Oanlline

•~n

llg/l llg/l

5 5

10

u UJ u

5 5

10

u u u

s , 10

u u u

s s

1c

u u u

s 5

10

u u u

5 u • u

10 u

s s

10

u u u

5 10

u u u

4-Nl~~not '~" 10 u 10 u 10 u 10 u 10 u 10 u 10 u 10 u Acetoohenone Atrazine Benzllldehyde Ben~~~ n~mate

""" µg/l l>g/L

"""

5 s !

5

UJ u UJ u

5 , 5 5

u u u u

s u u

• u 5 u

5 5 5 5

u u u u

5 5 5 5

UJ u UJ u

5

5 5

u u u u

5 5 5

0.24

u u u w

5 5 5 5

u u u u

bi...._nul fdtDhenun """ 5 u s u 5 u 5 u s u s u s u 5 u Bill(2-ChloroelhoxyJ methane ugll ' UJ 5 u 5 u u 5 u 5 u ! u 5 u bis(l-Cldoroelhyl) ether (2-Chlo~~ ether). llg/L 5 UJ 5 u 5 u 5 u 5 u 5 u ! u 5 u ht.:.M-Eth.,...,,....... \ Dhthalate """ 5 u 5 u 5 u 5 u 5 u 5 u 5 u s u taDrOISctam """ 5 u 5 u 5 u 5 u 5 u 5 u 5 u 5 u cresot&, m & P Oietnvlphllmlale '-.....,,, nhthalate o;.,,..,,."'" o11111a1a1e

. l>g/L l>g/L un

""

660 1120 5

5 5

u u u u

5 5 5 s

u u u u

5 5 5 5

u u u u

s ! s 5

u u u u

5 5 5 5

u u u u

5 5 5 5

u u u u

5 u • u 5 u 5 u

5 5 5 5

u u u u

O' Hexachlarobenzene

"" 11! 'L

5 5

u u

5 5

u u

s 5

u u

s s

u u

5 5

u u

5 5

u u

5 5

u u . 5

5 u u

nemchklrobulodiene ~ 5 UJ 5 u 5 u s u 5 u 5 u 5 u 5 u Hem e om 5 u s u 5 u s u 5 u 5 u 5 u 5 u Hexochlaroelhane lsophorone llitrobennme

ow

~

~

5 5 5

UJ UJ

UJ

5 u 5 u • u

5 u - u 5 u

5 u • u 5 u

5 5 5

UJ u UJ

5 u • u 5 u

5 5 5

u u u

5 5 5

u u u

n-Nitrusocf "" 5 UJ 5 u 5 u 5 u 5 UJ 5 u 5 u 5 u n-l\lllmSOdiphenylamine µglL 5 UJ 5 u 5 u u 5 UJ 5 u 5 u 5 u

-·=~

, wwLevet -~ -· u.

: UJ

"" v~ u

• u v• u

• u v~ u

• u "·" "

u UJ

v~ u

• u u u

• u u

• u

1-1

TABlf A-I -WEl.1 MW-19 Monitor Well GrlllnlVlaler Analys6 Results Han CreosoUng Company~ Siie JS<DA', Teias

WelllD: .. ' ... Effluent Goals MW-19-2 MW-19-3 MW-19-3 MW-19-3 MW-19-3 mn-19-3 MW-19-4 Location ID : HCC-MW1~2-0610 HCC-MW1~ HCC-MW1~1208 HCC-MW1~609 HCC-MW19-03-0610 HCC-MW! 9-3-4611 HCC-MW19-04

CH2M Sampie ID: Aquifer Surface Water HCC-llW19-3-0611 CLP Sample ID : Injection Discllorge F3J32 F2TNO · F2XM2 F38NO F3J33 F4JLO F2TN1 Date Collected : 6./9110 14:20 613108 0:00 121810811:07 617109 16:05 619110 14:30 612811115:50 6.14/08 0:00

Sample Type : N N N N N N N Parameter I Unit Resun I QuaJ Re&utt I Qual Result I Quol Result I Oual Result I QUBI Result I QuaI Resun I Qual

SVOC-Tolal PAH and CPAH - TEQ TotalPAHs llg/L I I I 9.891 = 0.81 u I 2.461 .J I 0.8691 = I 4.651 - I 18.11 J 0.9271 = ""'121J(Q)Pyrene To-.. ~~·-·~ llg/L I I I UI u UI U I UI U I u.11171 ~ I UI U I 01. u 01 u

SVOC-l.ow Molecular Weiallt PAHs UOIL 100 250 1c J

Naphlhalene, Low Level Ace A ne Lowlevel

IJ!l/L UQ/L

·~

100 250 23 23

1.4 =

• u 0.1 w

0.1 u 0.1 u

D.18 =

0.1 u

1.1 =

0.2 u

0., UM

• u 0.22 =

0.1 u ua 130 23 0.24 u 5 u 0.17 u . ,..

A Low level om 130 23 0.1 u 0.1 u 0.1 u 0.1 u ..' ·~ Auorene U< 81 11 = u u ~1uorene Low Lewi ~ 87 11 0. u 0.1 u 0.1 u 0.2 u 0.1 u An!hracene Low Level uaJl 0.3 0.1 u 0.1 w 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u Phenanlhrene "" 130 30 ~ u 5 u nienanthrene. Low .......... Fluamnlhene

iJglL

IJ!l/L "'" 30 6.16

0.1 u 0.1 u 0.1 u o.• u 5 u

O.uu~ - '. :~. Auorenlhene Low leYel .,.,._ uaJl ..... 6.16

7 o~ u 0.1 u 0.1 u 0.1 u 0.2 u

5 u 0.1 u '~ -;...

.-y1ene, Low Level IJ9IL 1 0.2 u 0.1 u 0.1 u 0.1 u 02 u 0.1 u SVOC-Other Creosote~

2-Meth ·~· 57 63 0.4'. u 0.34 LJ ~ u __, 2-Meth~m~tene. Low level ,..,n 57 63 0.1 u O.~ u 0.061 = 0.027 -Cmbazole ~~•uran

SVOC-Hi11h Molecular Weillht PAHe

ua/L U1IJI.

43 56.8 5 14

5 u • u

5 u • u

5 u 5 u

5 u 5 u

5 u 5 u

5 u - • u

5 UJ 5 UJ

ttemnrol3nthnlcene Law Level unn O.D85 0.81 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u Cl!~ ,mn 19 5 u ~U'lf:llCllm::::~ _n.J ~~ =· 19 o~ u 0.1 u 0.1 u 0.1 u 0 u 0.1 u ~a)pyTene, Low Level IJ9IL 0.2 0.014 0.1 u 0.1 u 0.1 u 0.01l u 0. u 0.1 u 0.1 u

Low Level unn O.D52 0.014 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u Low level ..~. 0.014 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u ,,·

llenzu{g,h,i oerytene ug/L 0.014 5 w ~nunrt,1~.Low- pg/L 0.014 D. u 0.1 u 0.1 u O.u.u = 0.2 u u.I u lndenoll ~ '-'"A~ Lowlevef · ""n 0.052 0.014 0.1 u 0.1 u 0.1 u 0.1 w 0.1 u 0.1 u 0.1 u o;~~a Low level """ 0.0033 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u

SVOC-Other 1,2,4,S-lelrachlorobenzene iJglL 5 u 5 u 5 u 5 u 5 u 5 u 5 u 2 2'~1-dlloro~ >mH - 5 u 5 u ! u 5 u 5 u 5 u 5 u 2 3 4 6-letrm:hloro ·~· s u 5 u ! u 5 u 5 u ! u 5 u 2,4 5-Trichlarophenol 2.4,5-Trid1larophenol 2•

'""' iJglL >mH

5 u 5 u 5 u

5 u • u 5 u

5 u 5 u 5 u

~ u ! u 5 u

5 u 5 u 5 u

5 u 5 u 5 u

5 u 5 u 5 u

2· ·~" 250 105 5 u 5 u 5 u s u 5 u ~ u 5 ·u 2.4-0inltrmll ....... Uftll 10 u 10 u 10 u 10 u 10 u 10 u 10 u 2,llLllir irrnm mene ;,,c

2

iJglL iJglL

·~"

5 u • u s u

5 u • u 5 u

5 u 5 u 5 u

5 u 5 u 5 u

= u • u 5 u

! u u u

0 u 5 u 5 u

30fll)

1-2

TABLE A-1 - WEil MW-1 ~ Monitor Well GroundWater AnaJysls Results Han Creosoling Company~ Sile Ja""". Texas

Well ID: WTP Effluent Goals MW-19-2 MW-19-3 MW-19-3 MW-19-3 MW-1B-3 MW-19-3 MW-19-4 Location ID : HCC-MW19-02--0610 HCC-MW19-03 HCC-MW19-03-1208 HCC-MW19--03--0609 HCC-MW19-03--0610 HCC-MW19-3--0611 HCC-MW19--04

CH2M Sample ID : Aquifer Surface Woter HCC-MW19-3--0611 CLP Sample ID : Injection Discllaf'ge F3J32 F2TNO F2XM2 F38NO F3J33 F4JLO F21H1 Date Collected : 619110 14:20 613108 0:00 12/8f0811:07 61710916:05 619110 14:30 6128111 15:50 6/4/08 0:00

Sample Type : N " tl N tl N N Parameter I Unit Result Qual Result Qual Result Qua! Result Qual Result QuaI Result QuaI Result Qual

2-Chkm>Dhenol """ s u 5 u 5 u 5 u s u 5 u 5 u 2""""""""phenol (o-Cresol) 11¢. 660 1120 s u 5 u 5 u 5 u s u 5 U· 5 u 2-Nilrooniline 11¢. 10 u 10 u 10 u 10 u 10 u 10 u 10 u 2-Nlln>llhenol -•m" s u 5 u ! u 5 u s u 5 u 5 u 3 3'-Dichlorobenzidine unll s u 5 u 5 u 5 u s u 5 u s u 3-Nitrooniline 11¢. 10 u 10 u 10 u 10 u 10 u 10 u 10 u 4,6-0initro-2-methylphenol 11¢. 10 u 10 u 10 u 10 u 10 u 10 u 10 u ~nnenv1 nnPnvl ether '""' s u s u 5 u 5 u s u 5 u 5 w 4-0!loro-:Hne~enol omn 5 u 5 u 5 u 5 u s u 5 u 5 u 4-Cl1loroonUine """ 5 u 5 u 5 u 5 u 5 u 5 u 5 u 4-0tlorophenyl phenyl ether pg/L 5 u 5 u 5 u 5 u 5 u 5 u 5 w 4-Nltroanillne pg/L 10 u 10 u 10 u 10 u 10 u 10 u 10 u 4-Nilroonenol ·~" 10 u 10 u 10 u 10 u 10 u 10 u 10 u n~none unit 0.73 u 5 u 5 u 5 u 5 u 5 u 5 u Atrazine pg/L s u 5 u 5 u 5 u 5 u 5 u 5 u Benzald~··~ pg/L 0.66 u 5 w 5 u s u s u 5 u 5 u Ben..-;! DUN! Dh1halale """ ! u 5 u 5 u 0.68 u s u u 5 w ..m ~ (djnnanu11 uall 5 u 5 u 5 u 5 u s u 5 u 5 UJ Bis 2-Chloroethoxy) melh3ne 11¢. 5 u 5 u 5 u 5 u 5 u 5 u 5 u bis ..... -Chlornethyl) ether (2-Chloroedtyl ether)

<·~-~•phthalate 11¢. unit

5 5

u u

5 5

u u

5 5

u u

5 5

u u

5 5

u u

s 5

u u

s 5

u UJ

cnnm1actam """ 5 u 5 u 5 u 5 u 5 u 5 u 5 UJ cresols, m & p IJ9IL 660 1120 5 u 5 u 5 u 5 u 5 u 5 u 5 u Diethyl phthalate IJ9IL 5 u 5 u 5 u 5 u : u 5 u 5 UJ nimPthvt Dmnnlnte ·~· 5 u 5 u 5 u 5 u 5 u s u 5 w ~~~~-te unn 5 u 5 u 5 u 5 u 5 u 5 u 5 UJ

ate ·~ ! u 5 u 5 u 5 u 5 u 5 u 5 w Hel<OCldotobenzen llg/L ! u 5 u 5 u 5 u 5 u s u 5 u Hexachlorobut3diene IJll/L 5 u 5 u 5 u 5 u 5 u 5 u 5 u

ntadiene ·~· 5 u 5 u 5 u 5 u 5 u 5 u 5 u Hexoddon>e1hane """ 5 u 5 u 5 u 5 u 5 u 5 u 5 u laopharone llg/L s u 5 u 5 u 5 u 5 u 5 u 5 u Nitroben?ene IJ9IL 5 u 5 u 5 u 5 u s u 5 u s u n-Nilmsod ne OmH 5 u 5 u 5 u 5 u 5 u 5 u 5 u n-N!lrosodiphenyl3mine pglL u : u 5 u 5 u : u 5 u s u r-c11.......... uorop1re1Hn~ LOW' Lf:Nel l'!l'L LI. u u w U. u U- u U. u u u !Ll w

"""""' ~L ~ u 0 U.J - u " u 0 u 0 u " u

1-3

TABLE.\-1-WB.l.MW-19

llm1!tor Well Groundwater Analysls ResuDs Han C1eOSOUng Cmnpany ~ SAi! JaSDef. Teias

WeDID: WTP Effluent Goals MW-19-4 MW-19-4 MW-19-4 MW-19-4 MW-19-5 MW-194 MW-19-5 Location ID : HCC.UW19-M-1208 HCC-MW19-04-0609 HCC.UW19-44-4610 HCC-MW19-4-0611 HCC.UW19.05 HCC.UW19.05-1208 HCC-MW19.o5-0609

CH2M Sample ID : Aquifer Smface Water HCC.MW19-4-0611 CLP Sample ID : Injection Dlsdlarge F2XM3 F38H1 F3J34 F4JL1 F2TN2 F2XM4 F38H2 Date Colleded : · 1218108 11 :08 617109 16:06 619/10 14:40 6128111 15:45 6(4/080:00 1218108 16:48 617109 16:07

SampleT""": Parameter I Unit Result" I Quot

N Result I Qual " Result I Qual "Resu11 I Oual " Result I Qual

N Result IQual

N Result I Qual

SVOC-TolAI PAH and CPAH • TEQ Total PAHa 1J91L I I I 1A71 - I o.ll!!!>I = I 6.471 = I 18.11 J 0.9181 J I 0.81 u I 1.211 = =-01~~ toxicity Equivalents •mu I I I OI u I 01 u I 01 u I 01 u 01 U I 01 u 0 u

SVOC-Low Molecular W""""' PAHs Nn~otene uoll 100 250 Naph1halene, Low Lewi Uft/l 100 250 0.72 B 0.21 = 0.61 = 0.1 UM 0.078 u 0.1 u 0.48 . AcenaDIYITIVlene •mil 23 ! u Acena~- Lowlewl "" 23 0.1 u 0.1 u 0.1 u 0.12 u 0.1 u 0.1 u Ac:enaohthene "" 130 23 0..1 u 0.21 LJ A LowL"""I •m 130 23 0.1 u 0.017 = 0.12 u 0.1 u 0.054 = Fluorene •m 87 11 s u s u Fluorene, Low LeYel Ardltracene Low Level

"" ,.. 87 11 0.3

u.1 u 0.1 u

0.1 u 0.1 u 0.1 u 0.1 u

0.12 u 0.12 u

0.1 u 0.1 u

U.1 u 0.1 u

Phenontluene ,., 130 30 : u 5 u Phenanltuene, Low~ Ftuoran111ene

•m ... 131) 30 6.16

0.1 u 0.1 u s u

0.12 u 0. u 0.1 u

Fluorartthene Low Level "" 6.16 0.1 u 0.1 u 0.1 u 0.12 u 0.1 u 0.1 u ,..,,,,,.,., ,., 7 5 u Pyrene, Low Le.et IJg/L 7 0.1 u 0.1 u 0.1 u 0.12 u 0.1 u 0.1 u

s~,. -Other o-eoso1e ~-2 lene ·-• I 57 63 I I I 51 u 51 u I I I I I 2 ene Low Lewi unn I 57 63 I 0.131 = I o.on = I I 0.121 U I 0.11 u I 0.131 = carbazole DibenZOfumn

'"'" I lllllL I

43 56.S5 74

I

I SI u 51 u

I

I 5 u s u

51 u 51 u

51 u 51 u

61 UJ 61 UJ

I I

51 u ,. u I I

51 u ~I u

SVDC-Hiah Molecular Weiohl PAHs Benzolo.........__e LowLe...i ·- unn

'"'" 0.085 0.81

19 0.1 u 0.1 u 0.1 u D.I u

s u 0.12 u 0.1 u 0.1 u

~n- 1111:,lnw.~ '"'" 19 u.1 u 0.1 u 0.1 u 0.12 u 0.1 u 0.1 u ~ O)pyrene, low Level IJWL 02 u.014 0.1 u 0.1 u u.1 u 0.1 u 0.12 u 0.1 u u.1 u

Low level '""' 0.052 D.014 0.1 u 0.1 u 0.1 u 0.1 u 0.12 u 0.1 u 0.1 u Benzo UCll'lllllhene low Level ··~· 0.014 0.1 u 0.1 u 0.1 u 0.1 u 0.12 u 0.1 u 0.1 u ~ ,h,in~rVll'!ne

Benm(a ·~>~.Low -maenor1 .2 ,_,. . LowLevel

ua/L Ug/L

unn

0.014 U.u•~

0.052 0.014 u.1 u 0.1 u

u_,. = 0.1 UJ

0.1 u 0.1 u

5 UJ

0.1 u u.12 u 0.12 u

0.1 u 0.1 u

~~- . 0.1 UJ

,w...~a LOO&' level un/l 0.0033 0.1 u 0.1 u 0.1 u 0.1 u 0.12 u 0.1 u 0.1 u svoc~~r

1.2,4,~ ""'' : u 5 u : u 5 u 6 u 5 u 5 u 2.Z...uxv!:ld.11-chlorotmll'ITC'ITll'! •mn 5 u 5 u 5 u 5 u 6 u 5 u 5 u 2 3 4 6-tetr •mu 5 u 5 u 5 u 5 u 6 u 5 u 5 u 2,4,!;.Ttidllorophenal 2,4,6-Tn 2.·

IJ9IL ~

•m

5 u 5 u 5 u

5 u , u 5 u

5 u , u s u

5 u 5 u 5 u

6 u • u 6 u

5 u 5 u 5 u

5 u • u 5 u

24-0ime~ , 2,4 2,~lrrn!t'HI~

2~ ~~nhlhalene

•m .. u• ~

ua/L

250 1115 ! u 10 u

' u

' u 5 u

5 u 10 u. 5 u

• u 5 u

! u 10 u • u • u 5 u

5 u 10 u • u 5 u 5 u

6 u 12 .u 6 UJ 6 UJ

6 UJ

5 u 10 u : u : u 5 u

5 u 10 u : u 5 u 5 UJ

HCC_Y".JJUOll~?ORT_TAlll.EA-,_,,./Bl lll\l-19 ESllJ2212224240 50F ID

1-4

TABlE A-1-WEU MW-19

Monitor Well Groundwater Analysis Results Han creosoting Company~ Sile .Jasoer. Teias

WeUID: WTP Eflluenl Goals MW-19-4 MW-19-4 MW-19-4 MW-19-4 MW-19-5 MW-19-5 MW-1,,_,. location ID : HCC-MW19-04-1208 HCC-MW19-04-0609 HCC-MW19-04-ll610 HCC-MW19-4-4611 HCC-MW19-05 HCC-MW19-05-1208 lfCC-MW19-05-0009

CH2M Sample ID : Aqllifer Surface Water HCC-MWfS-4-0611 CLP Sample ID : Injection Discharge F2XM3 F38N1 F3J34 F4Jl1 F2TN2 f2XM4 F38N2 Date Collected : 1218/0S 11:08 611109 16--06 619110 14:40 6128111 15:45 614/08 0:00 12l8!0816:48 617109 16:07 .

Sample Type : N N N N N ti N Parameter I Unit Result Oual Result Qual Result Oual Result Qual Result Oual Result Oual Result Qua!

2-Cldo~enot ·~" : u 5 u ! u 5 u 6 u 5 u 5 u 2-Melhylphenol (o-<:resol) 11!11' 660 1120 u 5 u ' u 5 u 6 u 5 u : u 2-Mroonlline 11!11' 10 u 10 u 10 u 10 u 12 u 10 u 10 u 2-N"""""""" unn 5 u 5 u 5 u 5 u 6 u 5 u 5 u 3 3'-0idllorobenzidine ,_,, 5 u 5 u 5 u 5 u 6 u 5 u 5 u ~ unit 10 u 10 u 10 u 10 u 12 u 10 u 10 u 4,6-0initn>-2 llg/l 10 u 10 u 10 u 10 u 12 u 10 u 10 u 4-&omnnh"""' ether ·~" 5 u 5 u 5 u 5 u 6 UJ 5 u 5 u 4-ClttoR>-~ al ,_,, ! u 5 u 5 u 5 u 6 u 5 u 5 u 4-0llotonniline '"'" ! u 5 u 5 u 5 u 6 u 5 u 5 u 4-ChloropherM phenyl ether 11!1/l 5 u 5 u 5 u 5 u 6 UJ 5 u 5 u 4-Nitro3niline ~ 10 u 10 u 10 u 10 u 12 u 10 u 10 u 4-N•~• · 10 u 10 u ID u 10 u 12 u 10 u 10 u A...mnhenone un 5 u 5 u 5 u 5 u 6 UJ 5 u 5 u Atrazine UOll u 5 u 5 u 5 u 5 u 6 UJ 5 u 5 u Benmldehytle ~~N- Dh1halate

ll!lll ·~·

5 u u

5 5

u u

5 u u

5 5

u u

6 6

u UJ

5 5

u u

5 0.59

u LJ

_......., (cfltlhenvn '"'" 5 u 5 u 5 u 5 u 6 UJ 5 u 5 u Bis(2-Chloroelhoxy) methane ll!lll 5 u 5 u 5 u 5 u 6 u 5 u 5 u bls(2-Chlotoelhyl) ether (2.Chlo~~ elher) ll!lll 5 u 5 u 5 u 5 u 6 u 5 u 5 u biS(2->crnvm'"""' nhlh!ll.11e unn,_. !

! u u

5 5

u u

! 5

u u

5 5

u u

6 6

UJ UJ

5 5

u u

0.84 5

u u

crerols, m & p llg/l 660 1120 u 5 u u 5 u 6 u 5 u 5 u Diethyl phtholate llg/l 5 u 5 u 5 u 5 u 6 UJ 5 u 5 u Dimethyl nntnal:lle unn 5 u 5 u 5 u 5 u 6 UJ 5 u 5 u Oi-n-buM Dllthalate ·~· 5 u 5 u 5 u 5 u 6 UJ 5 u 5 u ni...ft.__rw.nnftft1halete Uftn 5 u 5 u 5 u 5 u 6 UJ 5 u 5 u Hexachlorobenzene HeX3Chlorabuladiene

He:<adtloR> ene Hexadllomelhane lsophorone NllrobenZene n-Nitmsodi...l\J'Vnmnamine n-Nimlsodiphenylamine t'en , LnWL.eVe1

··~·-

11!1/l ll!lll ,_,,

·-· 11!11'11!11',_. IJg/l IJQIL

.-~

5 u • u ! u : u : u 5 u 5 u • u

02 u

• u

5 5 5 5 5 5 5 5

u.z •

u u u u u u u u u u

' u 5 u 5 u

u

' u 5 u 5 u 5 u

U.4 u 0 u

5 5 5 5 5 5 5 5

U-"

•

u u u u u u u u u

u

6 6 6 6 6 6 6 6

v~•

"

UJ u u UJ u UJ UJ UJ UJ

u

s 5 5 5

: 5 :

u~

•

u u u u u u u u u u

5 u ~ u 5 u 5 u • u 5 u 5 u : u

u u

• u

1-5

,,

TABlf A-l-WEU.MW-19 Monitor Well Groundwater Analysis Resulls Han Creosallng Company Sl4Jelfllld Slle Jasner, TelllS

WeUID: WTt' dfluent GoalB MW-t9-5 MW-t9-6 MW-t,,_.. MW-t9-6 MW-t9-6 MW-19-7 MW-tll-7 Location ID : HCC-MWt&-05-0610 HCC-MW19-06 HCcawt~-1208 HCC-¥Wt9-06-0609 HCcaw19-06-0610 HCC-MWt9-07 HCC-MWt~7-1208

CH2M Sample ID : Aquifer Surface Water CLP SallllllelD: Injection Discharge F3J35 F2TN3 F2XM5 F38N3 F3J36 F21N4 F2XM6 Date Collected : 61911014:t0 614/08 0:00 1218/0811:12 617109 16:08 619/tO 14:50 614/0B 0:00 t218/08 t1:12

Sample Type : N N N N ti N N Parameter IUnft Result I Qual Resuh I Qual Result IQual Resutt I Qual Result I Qual Resuh IQual Resuh I Qual

SVOC-Total PAH and CPAH - TEQ T~PAHs ~LI I I 8.o.,. = 0.61 u I 2.451 J I o.n11 = I 4=• = 1.861 = I 1.321 = Benza(a)Pyrene IOuciov t::lluivalen!D unu I I I UI u 01 u I UI U I 0.0181 J I UI u 01 U I 01 u

SVOC-Low Molecular Wei<lllt PAHa NaDhtha!ene · 100 250 1.7 J Naphthalene, L- Le...,1 "" 100 250 3.3 = 0.1 UJ 0.11 = t.t = t.t J 0.58 B Acenaphll1ylene ~ 23

Low Level ·~ 23 0.5 u 0.1 u 0.1 u O.t u 0.2 u 0.1 u 0.1 u A-~ne ·~ 130 23 0.4t u s u Acenarm:mene Law Level ,., 130 23 0.1 u 0.1 u 0.016 = 0.063 = 0.039 J ., Fluorene ·~ 87 11 u Ruorene,LowLevel "" 87 11 0.1 u 0.1 u 0.1 ·U 0,2 u 0.1 u 0.1 u Anthmcene Low Le-.el ·~ 0.3 0.1 u 0.1 UJ 0.1 u 0.1 u 0. 1 u 0.1 u 0.1 u Phenan!h"""' · 130 30 Phenanthrene, Low Level ~ 130 30 o.S u 0.1 u 0.1 u 0.1 u 0.1 u u.1 u U.1 u Fluoranthene om 6.16 Fl-.nthene Low Level ·~ 6.16 0.5 u 0.1 u 0.1 u 0.1 u 0.2 u 0.1 u 0.1 u ~ un 7 Pyrene, Low ~I unu 7 a u 0.1 u 0.1 u 0.1 u 0.2 u 0.1 u D.1 u

svoc~ "-Creosote w-~~ 2 ene 2-"'111 LowL.....,,

·-" I Uft/L I

57 63 57 63

0.581 u I . I

0.11 U I I

I 051 u

I I

I 0.0511 =

I I

0.311 u I

1. 0.161 =

I I

I 0.0981 J

ea. mn I 43 56.8 SI u 51 UJ I SI u I 51 u I SI u SI UJ I 51 u '~"I 5 74 51 u 51 UJ I 51 u I 51 u I 51 u 51 UJ I 51 u

SVOC-tliah Molecular Weiam PAiis .-n7n1Blmrthmcene. LOW Level ,_.. o.oes 0.81 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u n~ .~.. 19

wuysene, Low Level UQIL 1~ 0.5 u 0.1 u 0.1 u 0.1 u 0.2 u 0.1 u 0.1 u llenzD(alPYJene, """ ~ ll!IA ""' u.014 0.1 u 0.1 u 0.1 u 0.1 u 11.1 u 11.1 u 0.1 u

Low Level ·~" O.D52 0.014 0.1 u 0.1 u D.1 u 0.1 u D.1 u 0.1 u 0.1 u thene Low Level """ OD14 0.1 u 0.1 u 0.1 u D.1 u 0.1 u 0.1 u 0.1 u

Benza(g,h,i)perylene ~g/L 0.014 ~~u.h)J~~ne, Low Level pg/L 0.014 "·" u 0.1 u 0.1 u u.u27 = u. u u.1 u 0.1 u ~1.23-<:d~ LowLevel •mn 0.052 0.014 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u 0.1 u o;--a Low Level """ OD033 0.1 u 0.1 u 0.1 u G.018 u Ill u 0.1 u 0.1 u

SwuL~u~

1 ,2,4 S-tetrnchlorobelaene 2.2'· ......... ,-~-2.3.4 &-lelmchion:J

~

··• u s u 5 u

5 u 5 u 5 u

5 u 5 u 5 u

5 u s UJ 5 u

s u 5 u s u

5 u ~ u ~ u

5 u s u s u

2.4.>Trtchkllaphenol 2.4.6-Tn 2.U

.... P<I

·~

5 u 5 u s u

5 u 5 u 5 u

5 u 5 u 5 u

5 u 5 u 5 u

5 u s u 5 u

·5 u

' u ! u

s u • u s u

2• nal .., 250 105 5 u 5 u s u 5 u s u 5 u 5 u 2 4-0ini = ~ m 10 u 10 u 10 u 10 u 10 u 10 u 10 u .. m : u 5 u ' u 5 UJ ' u ' u u 2.6-0in ~ ••ene · : u 5 u ' u 5 UJ ' u ' u : u 2-Chlo om ! u 5 u s u 5 u 5 u ~ u s u

1-6

TABlEA-1-WB.LMW-19

Mooitor Well Groundllater Analysis Resulls Halt craosollng Company Sl4Jelfund Site Jastll!f, 1exas

WeDIO: WTP Effluent Goals MW-19-5 MW-19-6 MW-19-6 MW-19~ MW-19~ MW-19-7 mn-19-7 Location ID : HCC-MW19~5-0610 HCC-MW19~6 HCC-MW19-06-12()8 HCC-MW19~609 HCC-MW19-06~10 HCC-MW19-47 HCC-MW19-47-1208

CH2M Sample ID : Aquifer Surface Water CLP Sample 10 : Injection Discharge F3J35 F2TN3 F2XM5 f38N3 F3J36 f2TN4 F2XM6 Dote Collected : 619110 14:10 614/08 0:00 121810811:12 6'11119 16:08 619110 14:50 614/08 0:00 1218/0811:12 -

Sample Type : N N H N N N N ParameteT I Unit Result QuaJ Result Qual ReBUll QU31 Result Qual Result Oual Result Qual Result Ollal

2-Cllloro"""nol 2-Metllylphenol ( o-<.reD01) 2~ilroanum..

Uftl<

ll!llL µglL

660 1120 5 5

10

u u u

5 s

10

u u u

5 5

10

u u u

5 UJ

• u 10 u

5 5

10

u u u

5 5

10

u u u

5 u • u

10 u 2 UlllL 5 u 5 u 5 u 5 u 5 u 5 u s u 3.3'-DichlorobeRZicline ·~" 5 u 5 u 5 u 5 u 5 u 5 u 5 u 3-Nltroaniline µglL 10 u 10 u 10 u 10 u 10 u 10 u 10 u 4,6-Diniln>-2-melhytphenol µglL 10 u 10 u 10 u 10 u 10 u 10 u 10 u 4-Bromo~ DherM ether '"'" 5 u 5 UJ 5 u 5 u 5 u 5 UJ 5 u 4-Chlon>-4 unJL 5 u 5 u 5 u 5 u 5 u 5 u 5 u 4-Chloroaniline '"'" ! u 5 u 5 u s u 5 u 5 u 5 u 4-Clllomphenyt phenyl ~~ 11911. u UJ 5 u 5 u 5 u 5 UJ 5 u 4-Nllrnariiline uatL 10 u 10 u 10 u 10 u 10 u 10 u 10 u 4-N..........,enol m 10 u IO u 10 u 10 u 10 u 10 UJ 10 u Acelonhenone UQ 0.61 LJ 5 u 5 u 5 UJ 5 u 5 u 5 u AIJazine Benzaldehyde Be~ ~ °"" Dhlhalale

m

µglL

'"'"

5 0.38

5

u LJ u

5 5 5

u u UJ

5 5 5

u u u

5 , 0.63

u UJ LJ

5 5 5

u u u

5 5 5

u u UJ

5 5 5

u u u

b"'"""~ !di!lllenV11 '"' : u 5 UJ 5 u 5 u 5 u 5 UJ 5 u Bis(2-Chk>roelhoxy) methane "" 5 u 5 u 5 u 5 UJ 5 u 5 u 5 u bis(2-Clllorcelhyl) ether ,~ hloroell!yl ether) = : u 5 u 5 u 5 UJ 5 u 5 u 5 u Mt?-EfftV!Ntwt 1 nmnala.1:e rn~aclllm

"" ... 5 5

u u

5 5

UJ UJ

5 5

u u

5 5

u u

5 5

u u

5 5

UJ UJ

5 5

u u

cresolo, m & p uieuM Dlltnatate

Oi-n-buM --~alale

11911. 1'!111. mn

'"'"

660 1120 5 5 ! 5

u u u u

5 5 5 5

u UJ UJ UJ

5 5 5 5

u u u u

5 , 5 5

u u u u

5 5 s. 5

u u u u

5 5 5 5

u UJ UJ UJ

5 5 5 5

u u u u

alate Hexachlonlbenzene HexachlotObuUldiene

ene

'"'" IJ9IL µglL,.,n

5 5 5 5

u u u u

5 s 5 5

UJ u u u

5 5 5 5

u u u u

5 5 s 5

u u u u

5 5 5 5

u u u u

5 UJ

• u 5 UJ 5 u

5 5 5 5

u u u u

Hexachlonlelhane '"'" ! u 5 u 5 u s UJ 5 u 5 u s u lsophorone Ilg/I. : u 5 u 5 u 5 u 5 u 5 u 5 u Nilrobename Ilg/I. 5 u 5 u 5 u 5 UJ 5 u 5 u 5 u n Bmine '"'" 5 u 5 u 5 u 5 UJ 5 u 5 u 5 u ~e ll!llL 5 u 5 u 5 u 5 UJ 5 u 5 u 5 u

, LOW Level .....L u.i u U • .l UJ u.i u o.i u 0.2 u ~~ "" U--< u

-·~- -· , u ~ u , u , UJ , u , u , u

1-7

Tl'SlEA-1-YltllM'#-lll Mc!morwell ~ Ana!ym Results Hitt CrelJsolilg ~Sqler.u!ld ~ JD21!!1'. fell!S

welllu: Wll' 1;;n1Ucnt Go1119 "'".,~., .......:;.., ,,.w.111-1 Loeallon ID : HCC-MWf9.07.otiD9 HCC.FDGl-06111 HCC-MW19..07.otl10

CHZM 5ainp1e ID: Aquifer SurfacewatN CLP S..mplc ID : Injection Dia.charge FUll4 ruoo F3J37 Date COiiected : 61710916:09 61!1/'IO 15!00 &'!l!tO 15:00 ~T-: ti FD N

Parameter I 111111 Rcavlt 1aua1 II- I ouot I Clual !IVOC-TotalPAH.tndCPAH-TEO "-

ICllal t'Alt:I =•I I I ~•a• • I • I 9..... . ~· -n-ai~-Toxk:Uy~~ts •~• I I I DI UI 01 u I DI U

!lvoc.t.ow llall!cular Wermn PAHs t- aml\. 100 250 ~.LDowLe,;et 100 2Sll 0.15 O.M 0.99 ~" """

~·- z:s L<rlflC.CI 23 0.1 u Q,, u 0.1 u"" 130 2l 5 u u

Lawl..e'<cl ·~ 130 23 0.1 u ·~

..,.,._ UQI\. l!T 11 5 u s u

... ucnne towl.e'od 111 11 D,1 u"" An111mCC'1C. l""' Le.,.t 0.3 0.1 u 0.1 u 0.1 u Prienamlllene

-~ 130 30 ·s u ~ u·~

!'!let1ill11ll'lnme, LOWlCVCI = uu J.u u. u FluorDinlllelle UOIL 6.16 ALIOrlln!hene. LO•~ ~.. 6.t6 0.1 u 0.1 u 0.1 u

·~· ~tj2.LOWUM!I 1

I u.1 u D..1 u 0.1 u .. creosote ..ei~

2 uall. 57 63 0.21 u 0.29 u z.uem . Lo.llU!W!J ·~· 57 63 0.059 ~

~ ....... 43 56.8 5 u s u ! u Dllleroclurnn UQI\. 5 74 ~ u s u =

u SVOC~ M<JleculM Weloh1 PAHs

Ben..-olal~ l.<Nr l.cvd · ·~· ·-· 0-035 19

0.81 0.1 u Q.1 u 0.1 u

~.~L~ ·~· ·~ u.1 u u. u u.1 u llenm(o ll1lfllfll!, LOW LIM!! UOIL 0.2 0.014 0.1 u 0.1 u 0.1 u ~nl!llJomnlllen.e. U. Level ·~· !Ul52 0.01' 0.1 u 0.1 u 0.1 u 8e"-•-•tnnthlone L""' l.evel · 0014 0.1 u 0.1 u 0.1 u BerunfQ.hJJpery1eoo tll!rt3XC,h,1·frworv.--. LO&t

UOIL 0.014 0.Ul4 ...... .. II. u . D.1 u

~12.3-c.d~ l-L..,..,i ·~ o.l'.62 0.014 0.1 u Q.1 u 0.1 u Olben~• hl311111rOC@M low Lewi ·-~ 0.003.3 0.1 u 0.1 u 0.1 u

1.2.4.,,...,....cn-lmlfle llQI\. 5 u 5 u ! u 2.2'.0~ 1-dllOl'C -~~n& ·~· 5 u s u ~ u 2 3 "' ~d'ltal'DDherml ·-· s u 5 u 5 u 2.4,S.Tn~ llQI\. 5 u s u u :L4,~1n ~L : u u ! u 2 4-0ic;Noro~!IOI ·~· 5 u s u u 2.4.Dm~Ml

2 ..

' ...,,t. ~~

2511 105 ~

Ill u u

5 ID

u u

. ID

u u

2.~cne

' 2 l"1lene

llQI\. ~L

·~·

!

5

u u u

s " 5

u u u

~ u • u s u

HCC_~,,~~-fQE ...,_\'EU._19 ESOmlZ!24

1-8