Protecting
Texas
by
Reducing
and
Preventing
Pollution
2002­
0001­
0074
HRS
Documentation
Record
Gulfco
Marine
Maintenance
Site
Freeport,
Brazoria
County,
Texas
TXD055144539
REGION
VI
Prepared
in
cooperation
with
the
U.
S.
Environmental
Protection
Agency
February
2002
Final
HRS
Documentation
Record
Gulfco
Marine
Maintenance
Site
Freeport,
Brazoria
County,
Texas
TXD055144539
Prepared
in
cooperation
with
the
U.
S.
Environmental
Protection
Agency
Prepared
by
Texas
Natural
Resource
Conservation
Commission
Site
Assessment
&
Management
Section
Site
Discovery
and
Assessment
Program
Austin,
Texas
February
2002
The
preparation
of
this
report
was
financed
through
grants
from
the
U.
S.
Environmental
Protection
Agency
administered
through
the
Texas
Natural
Resource
Conservation
Commission
Site
Description
Summary
Gulfco
Marine
Maintenance
Freeport,
Brazoria
County,
Texas
TXD055144539
The
former
Gulfco
Marine
Maintenance,
Inc.,
(Gulfco)
facility
is
located
at
906
Marlin
Avenue,
Freeport,
Brazoria
County,
Texas
(Ref.
5,
p.
6).
The
property
consists
of
lots
21
through
25
and
lots
55
through
58
of
Brazos
Coast
Investment
Company,
Subdivision
Number
8.
Marlin
Avenue
separates
the
lots
55
through
58
on
the
north
from
lots
21
through
25
on
the
south.
Lots
21
through
25
are
approximately
four
acre
tracts
bordered
on
the
south
by
the
Intracoastal
Waterway.
Lots
55
through
58
are
approximately
five
acre
tracts.
The
entire
property
is
approximately
40
acres
in
size
(Ref.
5,
p.
6).

Gulfco
Marine
Maintenance,
Inc.,
operated
a
barge
cleaning
and
waste
disposal
facility
in
Freeport,
Texas
from
1971
through
1979
(Ref.
7,
p.
2;
Ref.
5,
p.
6).
Barges
brought
to
the
facility
were
cleaned
of
waste
oils,
caustics,
and
organic
chemicals,
and
the
wash
waters
generated
during
these
operations
were
reportedly
stored
in
three
surface
impoundments
located
on
Lot
56
on
the
north
side
of
Marlin
Avenue
(Figure
2)
(Ref.
7,
p.
2).
These
surface
impoundments
are
described
in
a
July
15,
1980
U.
S.
Environmental
Protection
Agency
Site
Inspection
Report
as
lined,
earthen
lagoons
(Ref.
25).

Fish
Engineering
and
Construction,
Incorporated,
(Fish
Engineering)
purchased
the
property
in
November
1979
from
Gulfco
Marine
Maintenance,
Inc.
(Ref.
15,
p.
17).
Fish
Engineering
also
utilized
the
facility
for
barge
servicing
and
cleaning.
In
1981,
Fish
Engineering
deactivated
the
surface
impoundments
and
began
closure
activities
(Ref.
24,
p.
1).
These
impoundments
were
reportedly
closed,
covered
with
a
hard
wearing
surface,
and
certified
as
closed
in
August
1982
(Ref.
31,
p.
1).
Four
monitor
wells
screened
between
38
to
48
feet
were
installed
during
closure
of
the
impoundments
and
sampled
at
least
four
times
from
July
1982
through
September
1982.
The
analyses
performed
were
benzene,
phenols,
chlorides,
conductivity,
pH
levels
and
total
organic
carbon
(TOC).
Total
organic
halogens
(TOX)
could
not
be
determined
due
to
high
interference
with
high
inorganic
chlorides.
The
analysis
revealed
concentrations
of
benzene
(1
to
8180
ppb),
inorganic
chlorides
(higher
than
15,
700
ppb),
phenols
(<
10
to
1092
ppb),
and
TOC
(60
to
290
ppb)
(Ref.
33,
pp.
1­
4;
Ref.
34,
pp.
3­
6;
Ref.
35,
pp.
2­
5;
Ref.
36.
pp.
3­
6;
Ref.
37
pp.
3­
6).
These
wells
were
reportedly
plugged
in
December
1983
(Ref.
7,
p.
7).

On
January
20,
1989,
Fish
Engineering
sold
the
majority
of
the
Gulfco
property
to
Hercules
Offshore
Corporation
(Hercules),
with
the
exception
of
Lot
56
on
the
north
side
of
Marlin
Avenue
(Ref.
71,
pp.
1­
8).
Lot
56
is
the
location
where
Gulfco
Marine
Maintenance
and
Fish
Engineering
operated
three
(3)
surface
impoundments.
Hercules
installed
three
monitor
wells
near
the
previous
surface
impoundments
in
January
1989
prior
to
their
purchase
of
the
property
from
Fish
Engineering
(Ref.
38,
pp.
2­
5).
Analysis
of
ground
water
samples
from
these
three
wells
indicated
detectable
concentrations
of
volatile
organic
compounds
and
pesticides.
Soil
samples
collected
during
the
construction
of
the
monitor
wells
indicated
elevated
levels
of
heavy
metals.
These
wells
remain
at
the
facility,
but
no
ground
water
samples
were
collected
by
the
TNRCC
during
the
January
2000
SSI
sampling
event
or
during
the
January
2001
ESI
sampling
event.
Hercules
conducted
barge
cleaning
and
refurbishing
operations
at
the
facility
until
May
1998,
when
the
company
declared
bankruptcy
(Ref.
40,
pp.
1­
2).
Three
additional
monitor
wells
are
located
on
the
southern
part
of
the
facility
south
of
Marlin
Avenue.
No
information
is
available
concerning
construction
of
these
wells
or
when
they
were
installed,
however,
total
depths
for
the
wells
range
from
about
15.2
feet
to
20.3
feet.
LT
Environmental,
Inc.
sampled
these
wells
on
March
18,
1999
and
analyzed
the
ground
water
samples
for
VOCs.
The
sample
results
indicated
no
VOCs
were
detected
(Ref.
5,
pp.
16
and
38).

The
original
Gulfco
property
is
currently
owned
by
two
entities.
LDL
Coastal,
Inc.
purchased
Lots
21
through
25
on
the
south
side
of
Marlin
Avenue
and
Lots
55,
57
and
58
on
the
north
side
of
Marlin
Avenue
through
the
Chapter
7
bankruptcy
court
in
mid­
1999
(Ref.
41,
pp.
1­
5).
This
is
the
portion
of
the
property
previously
owned
and
operated
by
Hercules.
KTI
Fish
(KTI
purchased
Fish
Engineering
forming
KTI
Fish)
sold
Lot
56
of
the
original
Gulfco
property
to
Messrs.
Jack
Palmer
and
Ron
Hudson
sometime
in
1999
(Ref.
42,
p.
1).

The
TNRCC
conducted
an
SSI
sampling
event
in
January
2000
and
an
ESI
sampling
event
in
January
2001.
Two
waste
source
areas
were
identified
during
these
investigations:
Source
No.
1,
Contaminated
Soil,
and
Source
No.
2,
Surface
Impoundments
(buried/
backfilled).
Analytical
results
for
soil,
sediment
and
ground
water
samples
collected
during
these
investigations
indicated
observed
releases
along
the
Surface
Water
Migration
Pathway.
Sediment
samples
collected
from
the
southern
boundary
of
the
former
Gulfco
property
along
the
Intracoastal
Waterway
indicated
that
hazardous
substances
have
migrated
from
the
facility
to
surface
water.
Four
(4)
semivolatile
organic,
two
(2)
pesticides,
and
two
(2)
inorganic
contaminants
were
detected
as
observed
releases
and
are
attributable
to
sources
at
the
facility
(Ref.
15;
Ref.
44).
i
CONTENTS
Page
HRS
Report
Review
Cover
Sheet
.................................................
1
Notes
to
Reader
..............................................................
2
HRS
Documentation
Record
...................................................
3
Worksheet
for
Computing
HRS
Site
Score
...........................................
6
Surface
Water
Pathway
Scoresheet
................................................
7
Reference
Listing
..............................................................
8
2.2
Source
Characterization
­
Source
1
..........................................
17
2.2.1
Source
Identification
.........................................
17
2.2.2
Hazardous
Substance
Associated
with
a
Source
.....................
23
2.2.3
Hazardous
Substance
Available
to
a
Pathway
.......................
34
2.3
Likelihood
of
Release
.........................................
35
2.4
Waste
Characterization
.......................................
36
2.4.1
Selection
of
Substance
Potentially
Posing
Greatest
Hazard
.............
36
2.4.2
Hazardous
Waste
Quantity
.....................................
36
2.4.2.1.1
Hazardous
Constituent
Quantity
.................................
36
2.4.2.1.2
Hazardous
Waste
Stream
Quantity
...............................
36
2.4.2.1.3
Volume
...................................................
36
2.4.2.1.4
Area
.....................................................
37
2.4.2.1.5
Hazardous
Waste
Quantity
Value
................................
41
2.2
Source
Characterization
­
Source
2
..........................................
42
2.2.1
Source
Identification
.........................................
42
2.2.2
Hazardous
Substance
Associated
with
a
Source
.....................
47
2.2.3
Hazardous
Substance
Available
to
a
Pathway
.......................
61
2.3
Likelihood
of
Release
.........................................
62
2.4
Waste
Characterization
.......................................
63
2.4.1
Selection
of
Substance
Potentially
Posing
Greatest
Hazard
.............
63
2.4.2
Hazardous
Waste
Quantity
.....................................
63
2.4.2.1.1
Hazardous
Constituent
Quantity
.................................
63
2.4.2.1.2
Hazardous
Waste
Stream
Quantity
...............................
63
2.4.2.1.3
Volume
...................................................
63
2.4.2.1.4
Area
.....................................................
64
2.4.2.1.5
Hazardous
Waste
Quantity
Value
................................
65
3.0
Ground
Water
Migration
Pathway
...........................................
67
ii
3.0.1
General
Considerations
.......................................
67
4.0
Surface
Water
Migration
Pathway
...........................................
68
4.1
Overland
Flood
Migration
Component
............................
68
4.1.1.1
Definition
of
Hazardous
Substance
Migration
Pathway
for
Overland/
Flood
Migration
Component
.....................................................
68
General
Considerations
.......................................
68
Definition
of
Overland
Segment
and
Probable
Point
of
Entry
............
69
Probable
Point
of
Entry
(PPE)
..................................
74
Definitions
of
In­
Water
Segments
................................
75
4.1.2
Drinking
Water
Threat
........................................
78
4.1.2.1
Likelihood
of
Release
..............................................
78
4.1.2.1.1
Observed
Release
...........................................
78
Chemical
Analysis
...........................................
78
Background
Concentrations
....................................
78
Contaminated
Samples
........................................
82
Attribution
.................................................
86
Hazardous
Substances
Released
................................
89
4.1.3
Human
Food
Chain
Threat
.....................................
90
4.1.3.1
Human
Food
Chain
Threat
­
Likelihood
of
Release
........................
90
4.1.3.2
Human
Food
Chain
Threat
­
Waste
Characteristics
........................
90
4.1.3.2.1
Toxicity/
Persistence/
Bioaccumulation
.............................
90
4.1.3.2.1.1
Toxicity
Factor
Value
.........................................
90
4.1.3.2.1.2
Persistence
Factor
Value
......................................
90
4.1.3.2.1.3
Bioaccumulation
Potential
Factor
Value
...........................
91
4.1.3.2.2
Hazardous
Waste
Quantity
.....................................
97
4.1.3.2.3
Waste
Characteristics
Factor
Category
Value
.......................
98
4.1.3.3
Human
Food
Chain
Threat
­
Targets
...................................
99
Actual
Human
Food
Chain
Contamination
.........................
99
Closed
Fisheries
............................................
99
Most
Distant
Level
II
Samples
..................................
99
Level
II
Fisheries
...........................................
100
4.1.3.3.1
Food
Chain
Individual
.......................................
100
4.1.3.3.2
Population
................................................
102
4.1.3.3.2.1
Level
I
Contamination
.......................................
102
4.1.3.3.2.2
Level
II
Contamination
.......................................
102
4.1.3.3.2.3
Potential
Human
Food
Chain
Contamination
.......................
103
4.1.3.3.2.4
Calculation
of
Population
Factor
Value
...........................
104
4.1.3.3.3
Calculation
of
HFC
Threat
­
Targets
Factor
Category
Value
...........
104
4.1.3.4
Calculation
of
Food
Chain
Threat
Score
...............................
104
4.1.4
Environmental
Threat
........................................
105
4.1.4.1
Environmental
Threat
­
Likelihood
of
Release
...........................
105
4.1.4.2
Environmental
Threat
­
Waste
Characteristics
...........................
105
iii
4.1.4.2.1
Ecosystem
Toxicity/
Persistence/
Bioaccumulation
...................
105
4.1.4.2.1.1
Ecosystem
Toxicity
.........................................
105
4.1.4.2.1.2
Persistence
...............................................
105
4.1.4.2.1.3
Ecosystem
Bioaccumulation
...................................
105
4.1.4.2.2
Hazardous
Waste
Quantity
....................................
111
4.1.4.2.3
Waste
Characteristics
Factor
Category
Value
......................
112
4.1.4.3
Environmental
Threat
­
Targets
......................................
113
4.1.4.3.1
Sensitive
Environments
.......................................
113
4.1.4.3.1.1
Level
I
Concentrations
.......................................
113
4.1.4.3.1.2
Level
II
Concentrations
......................................
113
Sensitive
Environments
.......................................
113
Wetlands
.................................................
113
4.1.4.3.1.3
Potential
Contamination
......................................
114
Sensitive
Environments
.......................................
114
Wetlands
.................................................
115
4.1.4.3.1.4
Calculation
of
Environmental
Threat
­
Targets
Factor
Category
Value
............................................
117
4.1.4.4
Calculation
of
Environmental
Threat
Score
for
a
Watershed
.................
117
4.1.5
Calculation
of
Overland/
Flood
Migration
Score
for
a
Watershed
..............................................
117
4.1.6
Calculation
of
Overland/
Flood
Migration
Score
....................
117
4.2
Ground
Water
to
Surface
Water
Migration
Component
..............
118
4.3
Calculation
of
Surface
Water
Migration
Pathway
Score
..............
118
5.0
Soil
Exposure
Pathway
..................................................
119
5.0.1
General
Considerations
......................................
119
6.0
Air
Migration
Pathway
..................................................
120
6.0.1
Observed
Release
..........................................
120
iv
TABLES
Table
1
Barge
Cargoes
Brought
to
the
Gulfco
Marine
Maintenance
Facility
by
Fish
Engineering,
Period
from
June
1980
­
August
1981
...............
18
Table
2
Ground
Water
Samples
Used
to
Characterize
Source
No.
1
....................
25
Table
3
Source
Characterization
­
Source
No.
1
...................................
26
Table
4
Background
Sample
Locations
for
Source
No.
1
............................
29
Table
5
Background
Sample
Data
for
Source
No.
1
................................
31
Table
6
Soil
Samples
Used
to
Characterize
Source
No.
2
............................
50
Table
7
Source
Characterization
­
Source
No.
2
...................................
51
Table
8
Background
Sample
Locations
for
Source
No.
2
............................
55
Table
9
Background
Sample
Data
for
Source
No.
2
................................
57
Table
10
Site
Summary
of
Source
Descriptions
.....................................
66
Table
11
Background
Sediment
Sample
Locations
in
Intracoastal
Waterway
...............
79
Table
12
Summary
of
Highest
Constituents
Detected
in
Background
Sediment
Samples
Collected
From
the
Intracoastal
Waterway
.........................................
81
Table
13
Contaminated
Sediment
Samples
from
Intracoastal
Waterway
..................
82
Table
14
Contaminated
Sediment
Samples
........................................
83
Table
15
Data
Usability
for
Release
Sediment
Samples
...............................
85
Table
16
Human
Food
Chain
Threat
­
Toxicity/
Persistence/
Bioaccumulation
Factor
Values
......................................................
92
Table
17
Human
Food
Chain
Threat
­
Hazardous
Waste
Quantity
.......................
97
Table
18
Extent
of
Level
II
Fishery
.............................................
100
Table
19
Human
Food
Chain
Organism
­
Estimated
Annual
Production
..................
102
Table
20
Potential
Human
Food
Chain
Contamination
...............................
103
Table
21
Environmental
Threat
­
Ecosystem
Toxicity/
Persistence/
Bioaccumulation
....................................................
106
Table
22
Environmental
Threat
­
Hazardous
Waste
Quantity
..........................
111
Table
23
Sensitive
Environments
...............................................
115
Table
24
Wetlands
Frontage
..................................................
116
v
FIGURES
Figure
1
Facility
Location
Map
................................................
4
Figure
2
Facility
Features
Map
................................................
5
Figure
3
Source
No.
1,
Contaminated
Soil,
Sample
Location
Map
.....................
24
Figure
4
Background
Soil
Samples
for
Source
No.
1
...............................
30
Figure
5
Area
of
Observed
Contamination
­
Source
No.
1
..........................
40
Figure
6
Source
No.
2,
Surface
Impoundments,
Sample
Location
Map
.................
49
Figure
7
Background
Ground
Water
Samples
for
Source
No.
2
.......................
56
Figure
8
Surface
Water
Pathway
15­
Mile
In­
Water
Segment
.........................
71
Figure
9
Drainage
for
the
Southern
Part
of
the
Gulfco
Facility
.........................
72
Figure
10
Drainage
for
the
Northern
Part
of
the
Gulfco
Facility
........................
73
Figure
11
PPE
Sediment
Sample
Location
Map
...................................
77
Figure
12
Off­
site
Sediment
Sample
Location
Map
.................................
80
APPENDICES
Appendix
A
­
Analytical
Data
Assessment,
Gulfco
Marine
Maintenance
Expanded
Site
Inspection
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
1
HRS
DOCUMENTATION
RECORD
REVIEW
COVER
SHEET
NAME
OF
SITE:
Gulfco
Marine
Maintenance
CONTACT
PERSON:
Brenda
Cook,
USEPA
(214)
665­
8372
Region
6
NPL
Coordinator
PATHWAYS,
COMPONENTS
OR
THREATS
NOT
EVALUATED
Ground
Water
Pathway
Although
an
observed
release
to
the
ground
water
has
been
documented
to
the
shallow
aquifer
beneath
the
site,
the
Ground
Water
Pathway
was
not
scored
since
inclusion
of
this
pathway
would
not
significantly
affect
the
site
score
(Ref.
15,
p.
55).

Ground
Water
to
Surface
Water
Migration
Component
The
Ground
Water
to
Surface
Water
Migration
Component
was
not
scored
since
the
Surface
Water
Pathway/
Overland
Flood
Migration
Pathway
was
evaluated.
Inclusion
of
this
component
would
not
significantly
affect
the
site
score.

Soil
Exposure
Pathway
The
Soil
Exposure
Pathway
was
not
scored
due
to
the
lack
of
residential
targets
and
inclusion
of
this
pathway
would
not
significantly
affect
the
site
score.

Air
Migration
Pathway
The
Air
Pathway
was
not
scored
due
to
the
lack
of
an
observed
release
to
the
pathway
and
inclusion
of
the
pathway
would
not
significantly
affect
the
site
score.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
2
NOTES
TO
THE
READER
The
following
rules
were
used
when
citing
references
in
this
Screening
Site
Inspection
Report:

1.
Each
reference
cited
in
the
report
has
been
assigned
a
designated
tracking
number.
The
reference
and
the
assigned
tracking
number
are
cited
in
the
body
of
this
report.

2.
If
the
reference
cited
is
for
analytical
data
found
within
a
table,
the
sample
ID
is
used
to
locate
that
reference.

3.
The
State
predecessor
agencies:
Texas
Water
Quality
Board
(TWQB),
Texas
Department
of
Water
Resources
(TDWR),
Texas
Water
Commission
(TWC),
and
Texas
Air
Control
Board
(TACB),
referred
to
throughout
this
report
are
now
known
as
the
Texas
Natural
Resource
Conservation
Commission
(TNRCC).
The
new
agency,
TNRCC,
became
effective
September
1,
1993,
as
mandated
under
State
Senate
Bill
2
of
the
73
rd
Regular
Legislative
Session.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
3
Final
HRS
Documentation
Record
Name
of
Site:
Gulfco
Marine
Maintenance
Date
Prepared:
12/
01
CERCLIS
Site
ID
Number:
TXD055144539
Site
Specific
Identifier:
06JZ
Street
Address
of
Site:
906
Marlin
Avenue
City,
County,
State:
Freeport,
Brazoria
County,
Texas
General
Location
in
the
State:
The
former
Gulfco
Marine
Maintenance,
Inc.
(Gulfco)
facility
is
located
at
906
Marlin
Avenue,
Freeport,
Brazoria
County,
Texas
(Ref.
5,
p.
6)
(Figure
1).
The
property
consists
of
lots
21
through
25
of
the
Brazos
Coast
Investment
Company
Subdivision,
Division
No.
8
on
the
south
side
of
Marlin
Avenue
(main
facility),
and
lots
55
through
58
of
the
Brazos
Coast
Investment
Company
Subdivision,
Division
No.
8
on
the
north
side
of
Marlin
Avenue.
Lots
21
through
25
are
four
acre
tracts
bordered
on
the
south
by
the
Intercoastal
Waterway.
Lots
55
through
58
are
five
acre
tracts.
The
entire
property
is
approximately
40
acres
in
size
(Ref.
5,
pp.
6).

Topographic
Map:
U.
S.
Geological
Survey
7.5
Minute
Topographic
Quadrangle,
Freeport,
Texas
Latitude:
28°
58'
00.65"
N
Longitude:
95°
17'
22.76"
W
EPA
Region
6
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
4
Figure
1
Facility
location
map
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
5
Figure
2
­
Facility
Features
Map
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
6
WORKSHEET
FOR
COMPUTING
HRS
SITE
SCORE
S
S²

1.
Ground
Water
Migration
Pathway
Score
(Sgw)
NS
NS
(from
Table
3­
1,
line
13)

2a.
Surface
Water
Overland/
Flood
Migration
100
10,000
Component
(from
Table
4­
1,
line
30)

2b.
Ground
Water
to
Surface
Water
Migration
NS
Component
(from
Table
4­
25,
line
28)

2c.
Surface
Water
Migration
Pathway
Score
(Ssw)
100
10,000
Enter
the
larger
of
lines
2a
and
2b
as
the
pathway
score.

3.
Soil
Exposure
Pathway
Score
(Ss)
NS
(from
Table
5­
1,
line
22)

4.
Air
Migration
Pathway
Score
(Sa)
NS
(from
Table
6­
1,
line
12)

5.
Total
of
Sgw
2
+
Ssw
2
+
Ss
2
+
Sa
2
10,000
6.
HRS
Site
Score
Divide
the
value
on
line
5
by
4
and
take
the
square
root.
50.00
NS
=
Not
Scored
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
7
SURFACE
WATER
OVERLAND/
FLOOD
MIGRATION
COMPONENT
SCORESHEET
Factor
Categories
and
Factors
Maximum
Value
Value
Assigned
DRINKING
WATER
THREAT
Drinking
Water
Threat
Score
1.
Observed
Release
550
550
2.
Potential
to
Release
by
Overland
Flow:

2a.
Containment
10
NS
2b.
Runoff
25
NS
2c.
Distance
to
Surface
Water
25
NS
2d.
Potential
to
Release
by
Overland
Flow
(Lines
2a
x
(2b
+
2c))
500
NS
3.
Potential
to
Release
by
Flood:

3a.
Containment
(Flood)
10
NS
3b.
Flood
Frequency
50
NS
3c.
Potential
to
Release
by
Flood
(Lines
3a
x
3b)
500
NS
4.
Potential
to
Release
(Lines
2d
+
3c,
subject
to
a
maximum
of
500)
Contamination
500
NS
5.
Likelihood
to
Release
(Higher
of
Lines
1
and
4)
550
550
Waste
Characteristics
6.
Toxicity/
Persistence
*
NS
7.
Hazardous
Waste
Quantity
*
NS
8.
Waste
Characteristics
100
NS
Targets
9.
Nearest
Intake
50
NS
10.
Population:

10a.
Level
I
Concentrations
**
NS
10b.
Level
II
Concentrations
**
NS
10c.
Potential
Contamination
**
NS
10d.
Population
(Lines
10a
+
10b
+
10c)
**
NS
11.
Resources
5
NS
12.
Targets
(Lines
9
+
10d
+
11)
**
NS
*
=
Maximum
value
applies
to
waste
characteristics
category
**
=
Maximum
value
not
applicable
NS
=
Not
Scored
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
8
SURFACE
WATER
OVERLAND/
FLOOD
MIGRATION
COMPONENT
SCORESHEET
Factor
Categories
and
Factors
Maximum
Value
Value
Assigned
DRINKING
WATER
THREAT
(Concluded)

Drinking
Water
Threat
Score
13.
Drinking
Water
Threat
Score
((
Lines
5
x
8
x
12)/
82,500,
subject
to
a
maximum
of
100)
100
NS
HUMAN
FOOD
CHAIN
THREAT
Likelihood
of
Release
14.
Likelihood
of
Release
(Same
value
as
Line
5)
550
550
Waste
Characteristics
15.
Toxicity/
Persistence/
Bioaccumulation
*
5x10
8
16.
Hazardous
Waste
Quantity
*
10,000
17.
Waste
Characteristics
1,000
1,000
Targets
18.
Food
Chain
Individual
50
45
19.
Population:

19a.
Level
I
Concentrations
**
0
19b.
Level
II
Concentration
**
0.03
19c.
Potential
Human
Food
Chain
Contamination
**
0.0000003
19d.
Population
(Lines
19a
+
19b
+
19c)
**
0.0300003
20.
Targets
(Value
from
Lines
18
+
19d)
**
45.0300003
Human
Food
Chain
Threat
Score
21.
Human
Food
Chain
Threat
Score
((
Lines
14
x
17
x
20)/
82,500
subject
to
a
maximum
of
100)
100
100
*
=
Maximum
value
applies
to
waste
characteristics
category
**
=
Maximum
value
not
applicable
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
9
SURFACE
WATER
OVERLAND/
FLOOD
MIGRATION
COMPONENT
SCORESHEET
Factor
Categories
and
Factors
Maximum
Value
Value
Assigned
ENVIRONMENTAL
THREAT
Likelihood
of
Release
22.
Likelihood
of
Release
(Same
Value
as
Line
5)
550
550
Waste
Characteristics
23.
Ecosystem
Toxicity/
Persistence/
Bioaccumulation
*
5x10
8
24.
Hazardous
Waste
Quantity
*
10,000
25.
Waste
Characteristics
1,000
1,000
Targets
26.
Sensitive
Environment:

26a.
Level
I
Concentrations
**
0
26b.
Level
II
Concentrations
**
0
26c.
Potential
Contamination
**
0.00825
26d.
Sensitive
Environments
0.00825
(Lines
26a
+
26b
+
26c)
**
0.00825
27.
Targets
(Value
from
Line
26d)
**
0.00825
Environmental
Threat
Score
28.
Environmental
Threat
Score
((
Lines
22
x
25
x
27)/
82,500,
subject
to
a
maximum
of
60)
60
0.055
SURFACE
WATER
OVERLAND/
FLOOD
MIGRATION
COMPONENT
SCORE
FOR
A
WATERSHED
29.
WATERSHED
SCORE***

(Lines
13
+
21
+
28,
subject
to
a
maximum
of
100)
100
100
SURFACE
WATER
OVERLAND/
FLOOD
MIGRATION
COMPONENT
SCORE
30.
Component
Score
(S
of
)***
(Highest
score
from
Line
29
for
all
watersheds
evaluated,
subject
to
a
maximum
of
100)
100
100
*
=
Maximum
value
applies
to
waste
characteristics
category
**
=
Maximum
value
not
applicable
***
=
Do
not
round
to
the
nearest
integer
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
10
REFERENCE
LISTING
Reference
Number
Description
of
the
Reference
1.
U.
S.
Environmental
Protection
Agency.
Federal
Register
­
40
CFR
Part
300;
Hazard
Ranking
System;
Final
Rule,
Volume
55,
No.
241,
December
14,
1990.

2.
U.
S.
Environmental
Protection
Agency.
1996
Superfund
Chemical
Data
Matrix
(SCDM).
June
1996.

3.
U.
S.
Environmental
Protection
Agency.
Hazard
Ranking
System
Guidance
Manual,
EPA
540­
R­
92­
026,
OSWER
Directive
9345.1­
07,
November
1992.

4.
U.
S.
Geological
Survey,
Freeport
Quadrangle,
Texas,
7.5
Minute
Series.
Topographic
Map.
1964,
Photorevised
1974.
Base
Map
for
Figures
1,
9
and
12.
1
page.

5.
LT
Environmental,
Inc.
Site
Characterization
Report,
Hercules
Marine
Service
Site,
Freeport,
Brazoria
County,
Texas.
57
pages.
June
1999.

6.
Walker,
H.
M.,
Ph.
D.,
Environmental
Consultant.
Application
for
a
TNRCC
Construction
Permit
For
Hercules
Marine
Services
Corporation
of
Freeport,
Texas.
May
3,
1994.
46
pages.

7.
Guevara,
Jairo,
FIT
Chemical
Engineer,
Ecology
and
Environment,
Inc.
Screening
Site
Inspection
of
Fish
Engineering
and
Construction,
Inc.
(TXD980626121).
13
pages.
Undated.

8.
Ecology
and
Environment,
Inc.
Environmental
Priority
Initiative
(EPI)
Preliminary
Assessment
of
Fish
Engineering
Construction,
Inc.
(Marine
Operations)
(Presently
Hercules
Off­
Shore
Drilling
Company),
Freeport,
Brazoria
County,
Texas
(TXD980626121).
Memorandum,
From:
Jairo
Guevara,
FIT
Chemical
Engineer,
Thru:
K.
H.
Malone,
Jr.
FITOM,
To:
Ed
Sierra,
Region
VI
RPO.
13
pages.
August
2,
1989.

9.
Texas
Water
Commission.
Solid
Waste
Compliance
Monitoring
Inspection
Report,
Fish
Engineering
&
Construction
(Marine
Operations),
EPA
I.
D.
No.
TXD980626121.
February
27,
1986.
19
pages.

10.
Gill,
G.
J.,
Fish
Engineering
&
Construction,
Inc,
to
Jeff
Webb,
Texas
Department
of
Water
Resources,
Solid
Waste
Section.
Letter.
January
26,
1982.
2
pages.

11.
Guevara,
Jairo,
FIT
Chemical
Engineer,
Ecology
and
Environment,
Inc.
Screening
Site
Inspection
of
Hercules
Offshore
Corporation
(TXD980626121).
15
pages.
Undated.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
11
12.
Guidry,
Darrell,
Project
Manager,
Hercules
Offshore
Corporation,
to
Texas
Air
Control
Board,
Attention
Exemption
Status
Board.
Letter.
December
11,
1991.
2
pages.

13.
Gill,
G.
J.,
Senior
Vice
President,
Fish
Engineering
&
Construction,
Inc.,
to
Bill
Stewart,
P.
E.,
Executive
Director,
Texas
Air
Control
Board.
Letter.
April
14,
1982.
38
pages.

14.
Texas
Natural
Resource
Conservation
Commission.
TNRCC
Investigation/
Violation
Form.
Hercules
Marine
Services,
Annual
Inspection.
March
18,
1997.
54
pages.

15.
Texas
Natural
Resource
Conservation
Commission.
Screening
Site
Inspection
Report
Gulfco
Marine
Maintenance,
Inc.
Site,
Freeport,
Brazoria
County,
Texas.
July
2000.
122
pages.

16.
Kennedy,
Johnny
W.,
Site
Investigation
Manager,
Texas
Natural
Resource
Conservation
Commission.
Screening
Site
Inspection
Field
Logbook.
Gulfco
Marine
Maintenance,
Inc.
Site,
Freeport,
Brazoria
County,
Texas.
CERCLIS
No.
TXD055144539.
January
24
through
January
27,
2000.
79
pages.

17.
Texas
Natural
Resource
Conservation
Commission.
Quality
Assurance
Project
Plan
for
Texas
Natural
Resource
Conservation
Commission
Preliminary
Assessment/
Site
Inspection
Program
(FY
2000­
2001).
October
1999.
134
pages.

18.
Kennedy,
Johnny
W.,
Site
Investigation
Manager,
Texas
Natural
Resource
Conservation
Commission.
Screening
Site
Inspection
Photographs.
Gulfco
Marine
Maintenance,
Inc.
Site,
Freeport,
Brazoria
County,
Texas.
CERCLIS
No.
TXD055144539.
January
24
through
January
27,
2000.
36
pages.

19.
United
States
Environmental
Protection
Agency,
Region
VI,
Houston
Branch.
Case
Number
27763,
Sample
Designation
Group
Number
(SDG#)
FGK18,
Contract
Laboratory
Program
Data
Review.
From
Marvelyn
Humphrey,
Alternate
ESAT
RPO,
6MD­
HC,
to
B.
Rhotenberry,
6SF­
RA.
March
8,
2000.
104
pages.

20.
United
States
Environmental
Protection
Agency,
Region
VI,
Houston
Branch.
Case
Number
27763,
Sample
Designation
Group
Number
(SDG#)
MFJQ24
Contract
Laboratory
Program
Data
Review.
From
Marvelyn
Humphrey,
Alternate
ESAT
RPO,
6MD­
HC,
to
B.
Rhotenberry,
6SF­
RA.
March
6,
2000.
35
pages.

21.
United
States
Environmental
Protection
Agency,
Region
VI,
Houston
Branch.
Case
Number
27763,
Sample
Designation
Group
Number
(SDG#)
FGK08,
Contract
Laboratory
Program
Data
Review.
From
Marvelyn
Humphrey,
Alternate
ESAT
RPO,
6MD­
HC,
to
B.
Rhotenberry,
6SF­
RA.
March
15,
2000.
189
pages.

22.
United
States
Environmental
Protection
Agency,
Region
VI,
Houston
Branch.
Case
Number
27763,
Sample
Designation
Group
Number
(SDG#)
MFJQ44,
Contract
Laboratory
Program
Data
Review.
From
Marvelyn
Humphrey,
Alternate
ESAT
RPO,
6MD­
HC,
to
B.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
12
Rhotenberry,
6SF­
RA.
March
6,
2000.
19
pages.

23.
Texas
Natural
Resource
Conservation
Commission,
GIS
Section.
Digital
Ortho
Quarter
Quad,
Freeport
Quadrangle,
Northeast
Quarter.
Base
Map
used
in
Figures
3
­
8,
and
11.
2
pages.

24.
Gill,
G.
J.,
Senior
Vice­
President,
Fish
Engineering
&
Construction,
Inc.,
to
Jay
Snow,
Texas
Department
of
Water
Resources,
Solid
Waste
Section.
Letter.
November
17,
1981.
3
pages.

25.
U.
S.
Environmental
Protection
Agency.
Potential
Hazardous
Waste
Site,
Site
Inspection
Report.
Gulfco
(TX06432).
July
15,
1980.
7
pages.

26.
Gill,
G.
J.,
Senior
Vice­
President,
Fish
Engineering
&
Construction,
Inc.,
to
Jay
Snow,
Texas
Department
of
Water
Resources,
Solid
Waste
Section.
Letter.
April
29,
1982.
10
pages.

27.
Gruenwald,
Rodger
K.,
Insurance
Manager,
Fish
Engineering
&
Construction,
Inc.,
to
Mr.
J.
Snow,
Texas
Department
of
Water
Resources.
Letter.
May
14,
1981.
2
pages.

28.
Snow,
Jay,
P.
E.,
Chief,
Solid
Waste
Section,
Texas
Department
of
Water
Resources,
to
Mr.
Rodger
K.
Gruenwald,
Fish
Engineering
&
Construction,
Inc.
Letter.
June
29,
1981.
2
pages.

29.
Davis,
Harvey,
Executive
Director,
Texas
Department
of
Water
Resources,
to
G.
J.
Gill,
Senior
Vice­
President,
Fish
Engineering
&
Construction,
Inc.
Letter.
May
21,
1982.
2
pages.

30.
Texas
Secretary
of
State.
Texas
Administrative
Code,
Title
30,
Part
1,
Chapter
335,
Subchapter
R,
Rule
§§
335.503
­
335.507.
Internet
URL:
http://
info.
sos.
state.
tx.
us/
pub/
plsql/
readtac$
ext.
TacPage?
sl=
R&
app=
9&
p_
dir=&
p_
rloc=
&p_
tloc=&
p_
ploc=&
pg=
1&
p_
tac=&
ti=
30&
pt=
1&
ch=
335&
rl=
503.
10
pages.

31.
Carden,
Clair
A.,
P.
E.,
Consulting
Engineer,
to
Mr.
Glen
J.
Gill,
Senior
Vice­
President,
Fish
Engineering
&
Construction,
Inc.
Letter.
August
18,
1982.
1
page.

32.
Gill,
G.
J.,
Senior
Vice
President,
Fish
Engineering
&
Construction,
Inc.,
to
Mr.
Harvey
Davis,
Executive
Director,
Texas
Department
of
Water
Resources.
Letter.
May
26,
1982.
2
pages.

33.
State
of
Texas.
Water
Well
Reports
for
Test
Wells
Fish
Engineering
&
Construction.
4
pages.
Undated.
34.
Gill,
G.
J.,
Senior
Vice
President,
Fish
Engineering
&
Construction,
Incorporated,
to
Jay
Snow,
Texas
Department
of
Water
Resources,
Solid
Waste
Section.
Letter.
August
4,
1982.
6
pages.

35.
Nicholson,
J.
R.,
Vice
President,
Construction,
Fish
Engineering
&
Construction,
Incorporated,
to
Gay
Snow,
Texas
Department
of
Water
Resources,
Solid
Waste
Section.
Letter.
August
31,
1982.
5
pages.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
13
36.
Nicholson,
J.
R.,
Vice
President,
Construction,
Fish
Engineering
&
Construction,
Incorporated,
to
Jay
Snow,
Texas
Department
of
Water
Resources,
Solid
Waste
Section.
Letter.
October
4,
1982.
7
pages.

37.
Nicholson,
J.
R.,
Vice
President,
Construction,
Fish
Engineering
&
Construction,
Incorporated,
to
Jay
Snow,
Texas
Department
of
Water
Resources,
Solid
Waste
Section.
Letter.
October
26,
1982.
7
pages.

38.
Ellison,
Raymond
H.,
Jr.,
President,
Hercules
Offshore
Corporation,
to
Jairo
A.
Guevara,
Ecology
and
Environment,
Inc.
Letter.
December
8,
1989.
6
pages.

39.
Ellison,
Raymond
H.,
Jr.,
President,
Hercules
Offshore
Corporation,
to
Jairo
A.
Guevara,
Ecology
and
Environment,
Inc.
Letter.
December
18,
1989.
33
pages.

40.
Chapter
7
U.
S.
Bankruptcy
Court.
Environmental
Proof
of
Claim,
Case
Number
98­
34630,
Hercules
Marine
Service
Corporation.
October
29,
1998.
13
pages.
41.
State
of
Texas,
County
of
Brazoria,
Special
Warranty
with
Vendor's
Lien.
Chapter
7
Bankruptcy
Estate,
Hercules
Marine
Services
Corporation.
August
2,
1999.
5
pages.

42.
Kennedy,
Johnny
W.,
Site
Investigation
Manager,
Texas
Natural
Resource
Conservation
Commission,
to
Jack
Palmer
(Owner
of
Lot
56
of
the
Gulfco
Site).
Telephone
Memo
to
the
File.
1
page.
January
11,
2000.

43.
Kennedy,
Johnny
W.,
Site
Investigation
Manager,
Texas
Natural
Resource
Conservation
Commission.
Expanded
Site
Inspection
Field
Logbook.
Gulfco
Marine
Maintenance,
Inc.
Site,
Freeport,
Brazoria
County,
Texas.
CERCLIS
No.
TXD055144539.
January
22
through
January
26,
2001.
41
pages.

44.
IT
Corporation.
Field
Activity
Report,
Gulfco
Marine
Maintenance,
Inc.,
906
Marlin
Avenue,
Freeport,
Texas,
IT
Corporation
Project
No.
821842.
Report
Prepared
for
the
Texas
Natural
Resource
Conservation
Commission.
March
26,
2001.
56
pages.

45.
Kennedy,
Johnny
W.,
Site
Investigation
Manager,
Texas
Natural
Resource
Conservation
Commission.
Expanded
Site
Inspection
Photographs.
Gulfco
Marine
Maintenance,
Inc.
Site,
Freeport,
Brazoria
County,
Texas.
CERCLIS
No.
TXD055144539.
January
24
through
January
26,
2001.
12
pages.

46.
Department
of
Housing
and
Urban
Development,
Federal
Insurance
Administration.
Flood
Hazard
Boundary
Map
H
­
01­
99,
Flood
Insurance
Rate
Map
I
­
01­
99,
Map
Index.
Brazoria
Co.,
TX
(unincorporated
areas),
Community
No.
485458C.
Map
Revisions
Effective
October
27,
1998.
Map
Index
with
Flood
Hazard
Boundary
and
Flood
Insurance
Rate
maps.
2
pages.
(Excerpt).

47.
United
States
Environmental
Protection
Agency,
Region
6,
Houston
Branch.
Case
Number
28927,
Sample
Designation
Group
Number
(SDG#)
F02KL,
Contract
Laboratory
Program
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
14
Data
Review.
From
Marvelyn
Humphrey,
Alternate
ESAT
RPO,
6MD­
HC,
to
B.
Rhotenberry,
6SF­
RA.
March
8,
2001.124
pages.

48.
United
States
Environmental
Protection
Agency,
Region
6,
Houston
Branch.
Case
Number
28927,
Sample
Designation
Group
Number
(SDG#)
MF02C8,
Contract
Laboratory
Program
Data
Review.
From
Marvelyn
Humphrey,
Alternate
ESAT
RPO,
6MD­
HC,
to
B.
Rhotenberry,
6SF­
RA.
March
8,
2001.
39
pages.

49.
United
States
Environmental
Protection
Agency,
Region
6,
Houston
Branch.
Case
Number
28927,
Sample
Designation
Group
Number
(SDG#)
F05H1,
Contract
Laboratory
Program
Data
Review.
From
Marvelyn
Humphrey,
Alternate
ESAT
RPO,
6MD­
HC,
to
B.
Rhotenberry,
6SF­
RA.
March
8,
2001.
99
pages.

50.
Galveston
Bay
National
Estuary
Program,
An
Environmental
Inventory
of
the
Christmas
Bay
Coastal
Preserve.
GBNEP­
7.
March
1991.
39
pages.
(Excerpt).

51.
U.
S.
Department
of
the
Interior,
Fish
and
Wildlife
Service,
Freeport
Quadrangle,
Texas.
7.5
Minute
Series
(Topographic).
National
Wetlands
Inventory
Map.
Draft
Edition.
1
page.

52.
U.
S.
Department
of
Agriculture,
Soil
Conservation
Service.
Soil
Survey
of
Brazoria
County,
Texas.
June
1981.
16
pages.
(Excerpt).

53.
Dunne,
Thomas
and
Leopold,
Luna
B.,
Water
in
Environmental
Planning.
1978.
W.
H.
Freeman
and
Company,
New
York.
10
pages.
(Excerpt).

54.
Kennedy,
Johnny
W.,
Site
Investigation
Manager,
Texas
Natural
Resource
Conservation
Commission,
to
Ernie
Schreiber,
Dow
Chemical
­
Texas
Operations.
Telephone
Memo
to
the
File.
June
7,
2000.
1
page.

55.
Meeks,
Jerry,
WS
Manager/
Superintendent,
City
of
Freeport,
to
Johnny
Kennedy,
Site
Investigation
Manager,
Texas
Natural
Resource
Conservation
Commission.
Telephone
Memo
to
the
File.
March
22,
2000.
1
page.

56.
U.
S.
Environmental
Protection
Agency.
Fact
Sheet
­
Using
Qualified
Data
to
Document
an
Observed
Release
and
Observed
Contamination.
November
1996.
18
pages.

57.
Kennedy,
Johnny
W.,
Site
Investigation
Manager,
Texas
Natural
Resource
Conservation
Commission,
to
Michael
Gay,
Offshore
Oil
Services,
Inc.,
Freeport,
Texas.
Telephone
Memo
to
the
File.
July
25,
2001.
1
page.

58.
Texas
Department
of
Health,
Seafood
Safety
Division.
Fish
Advisories
&
Bans,
1997.
11
pages.
(Excerpt).

59.
Kennedy,
Johnny
W.,
Site
Investigation
Manager,
Texas
Natural
Resource
Conservation
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
15
Commission,
to
Thomas
Byrom,
Jr.,
Environmental
Specialist,
Galveston
Bay
Estuary
Program.
Telephone
Memo
to
the
File.
May
15,
2000.
1
page.

60.
Galveston
Bay
Nation
Estuary
Program.
Environmental
Management
Inventory
of
Galveston
Bay.
GBNEP­
24.
October
1992.
7
pages.
(Excerpt).

61.
Texas
Parks
&
Wildlife
Department.
Texas
Threatened
&
Endangered
Birds.
Internet
URL:
http://
www.
tpwd.
state.
tx.
us/
nature/
endang/
birds/
index.
htm.
3
pages.

62.
Texas
Parks
&
Wildlife
Department.
Texas
Threatened
&
Endangered
Reptiles
and
Amphibians.
Internet
URL:
http://
www.
tpwd.
state.
tx.
us/
nature/
endang/
animals/
reptile.
htm.
3
pages.

63.
Texas
Parks
&
Wildlife
Department.
Commission
Agenda
Item
No.
17,
Action,
Texas
Coastal
Preserves,
Management
Plans
for
Armand
Bayou
and
Christmas
Bay,
August
1997.
Internet
URL:
http://
www.
tpwd.
state.
tx.
us/
involved/
pubhear/
0897/
no17.
htm.
4
pages.

64.
Texas
Parks
&
Wildlife
Department.
GEMS
­
Christmas
Bay
Coastal
Preserve.
Internet
URL:
http://
www.
tpwd.
state.
tx.
us/
conserve/
txgems/
christmas/
christma.
htm.
5
pages.
(Excerpt)

65.
U.
S.
Department
of
the
Interior,
Fish
and
Wildlife
Service,
Cedar
Lakes
East
Quadrangle,
Texas.
7.5
Minute
Series
(Topographic).
National
Wetlands
Inventory
Map.
Draft
Edition.
1
page.

66.
U.
S.
Department
of
the
Interior,
Fish
and
Wildlife
Service,
Hoskins
Mound
Quadrangle,
Texas.
7.5
Minute
Series
(Topographic).
National
Wetlands
Inventory
Map.
1998.
1
page.

67.
U.
S.
Department
of
the
Interior,
Fish
and
Wildlife
Service,
Oyster
Creek
Quadrangle,
Texas.
7.5
Minute
Series
(Topographic).
National
Wetlands
Inventory
Map.
1998.
1
page.

68.
U.
S.
Department
of
the
Interior,
Fish
and
Wildlife
Service,
Christmas
Point
Quadrangle,
Texas.
7.5
Minute
Series
(Topographic).
National
Wetlands
Inventory
Map.
1998.
1
page.

69.
U.
S.
Department
of
the
Interior,
Fish
and
Wildlife
Service,
Lake
Jackson
Quadrangle,
Texas.
7.5
Minute
Series
(Topographic).
National
Wetlands
Inventory
Map.
1998.
1
page.

70.
U.
S.
Department
of
the
Interior,
Fish
and
Wildlife
Service,
Jones
Creek
Quadrangle,
Texas.
7.5
Minute
Series
(Topographic).
National
Wetlands
Inventory
Map.
Draft
Edition.
1
page.

71.
State
of
Texas,
County
of
Brazoria.
General
Warranty
Deed
with
Venders
Lien,
89634,
pp.
512­
519.
January
20,
1989.
8
pages.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
16
SD­
Characterization
and
Containment
Source
No.
1,
Contaminated
Soil
2.2
SOURCE
CHARACTERIZATION
2.2.1
Source
Identification
Number
of
the
source:
1
Name
and
description
of
the
source:
Contaminated
Soil
Contaminated
soil
identified
at
the
former
Gulfco
facility
is
associated
with
barge
servicing
and
cleaning
operations.
Specific
areas
of
concern
include
two
former
sandblast
areas,
the
former
drum
storage
area,
the
former
wash
water
storage
area,
and
miscellaneous
areas
around
the
property
(Ref.
5,
pp.
12­
15,
and
35­
37).
It
appears
that
sometime
in
the
mid­
1990s,
Hercules
Offshore
Corporation
also
began
servicing
operations
on
parts
for
offshore
oil
rigs
(Ref.
14,
p.
11).
Additional
unknown
activities
conducted
at
the
former
Gulfco
facility
may
have
contributed
to
this
source.

Primary
operations
at
the
facility
reportedly
involved
the
cleaning,
servicing,
and
the
repair
of
various
chemical
barges
brought
to
the
facility
(Ref.
7,
p.
2;
Ref.
8,
p.
12;
Ref.
9,
p.
18).
Chemical
barges
were
drained
and
pumped
to
remove
product
heels,
which
were
stored
in
tanks
and
sold
as
product.
Each
barge
was
then
washed
with
water
or
a
detergent
solution
(Ref.
8,
p.
3;
Ref.
9,
p.
18).
Generated
wash
waters
were
stored
in
the
three
surface
impoundments
from
1971
through
1981
while
Gulfco
Marine
Maintenance
and
Fish
Engineering
owned
and
operated
the
facility
(Ref.
8,
p.
7).
After
1981,
waste
wash
waters
were
stored
in
a
rented
floating
barge
or
aboveground
storage
tanks
located
at
the
facility
(Ref.
9,
pp.
18;
Ref.
10,
p.
1;
Ref.
11,
pp.
8
&
9).

During
the
period
of
time
Fish
Engineering
operated
the
facility,
half
of
the
transport
barges
brought
to
the
facility
carried
oil
or
related
products,
and
the
other
half
carried
miscellaneous
organics
(alcohols,
ketones,
crude
oil,
chloroform,
trichloroethylene,
and
cumene,
etc.)
and
inorganics
(hydrochloric
acid,
calcium
chloride,
fertilizers,
etc.)
(
Ref.
7,
p.
2;
Ref.
8,
p.
3;
Ref.
11,
pp.
2
and
6).
For
the
period
from
June
1980
through
August
1981,
Fish
Engineering
cleaned
approximately
151
chemical
barges
(Ref.
13,
p.
7).
A
list
of
the
barge
cargoes
for
the
1980
through
1981
reported
period
is
shown
in
Table
1
(Ref.
13,
p.
7).
In
1982
Fish
Engineering
cleaned
a
total
of
150
barges.
In
December
1991
Hercules
Offshore
Corporation
reported
an
increase
of
the
number
of
barges
cleaned
annually
to
about
240
(Ref.
12,
p.
1).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
17
SD­
Characterization
and
Containment
Source
No.
1,
Contaminated
Soil
Table
1
Barge
Cargoes
Brought
to
the
Gulfco
Marine
Maintenance
Facility
by
Fish
Engineering
Period
from
June
1980
to
August
1981
Cargo
Number
of
Barges
Cargo
Number
of
Barges
No.
6
fuel
oil
23
Caustic
Soda
8
No.
2
fuel
oil
1
Hydrochloric
Acid
2
Crude
oil
3
Sulphuric
Acid
1
Diesel
oil
5
Fertilizer
1
C5
oil
1
Calcium
Chloride
7
Oil
residual
1
Ethylene
Glycol
3
C9
oil
1
Diethylene
Glycol
1
Naphtha
3
Polyalkylene
Glycols
6
gasoline
2
Methanol
1
Lactol
Solvent
(C6­
C8)
1
Butanol
2
Gasoline
Additives
1
Niax
Polyol
1
Silicate
Oil
1
Chloroform
2
Catalytic
Reformer
Feed
Oil
2
Perchloroethylene
1
Gas
Oil
1
Vinyl
Chloride
1
Benzene
24
Chlorine
4
Xylene
4
Acetic
Acid
5
Toluene
7
Acetone
3
Cyclohexane
9
Methylethyl
Ketone
2
Cumene
1
Vinyl
Acetate
1
Ethylbenzene
2
Ballast
Water
3
Styrene
3
(Reference
13,
page
7)
Total
Number
of
Barges:
151
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
18
SD­
Characterization
and
Containment
Source
No.
1,
Contaminated
Soil
In
1991,
Hercules
was
cleaning
approximately
240
chemical
barges
annually.
Much
of
the
increased
barge
cleaning
volume
was
attributed
to
an
increase
in
caustic
barges,
which
contributed
approximately
1/
3
of
the
total
barges
cleaned
at
the
facility
at
this
time
(Ref.
12,
p.
1).
Most
of
the
barges
sent
to
the
former
Gulfco
facility
for
repair
while
Hercules
Offshore
Corporation
operated
the
site
were
owned
by
Dow
Chemical
Company
(Ref.
11,
p.
2).

Potential
contaminants
associated
with
operational
activities
at
the
Gulfco
Marine
Maintenance
site
include
fuel
oil,
oil
wastes,
gas
condensate,
alcohols
(n­
butyl
alcohol,
methanol,
isobutyl
alcohol,
etc.),
ketones
(methyl
ethyl
ketone,
acetone,
etc.),
fertilizers,
phenols,
benzene,
cyclohexane,
urethane,
toluene,
xylene,
chloroethene,
naphthalene,
chloroform,
creosote,
tetrachloroethene,
1,1­
dichloroethylene,
1,1,1­
trichloroethane,
dichloro
methane,
cumene,
1,1,2­
trichloroethane,
trichloroethane,
acrilonitrile,
ethyl
ether,
tetrachloro
methane,
formaldehyde,
hydrochloric
acid,
calcium
chloride
and
others
(Ref.
8,
p.
5).

Barge
servicing
operations
at
the
facility
included
sandblasting
and
painting
of
barges,
as
well
as
mechanical
repair
and
welding.
The
dry
dock
area
associated
with
Barge
Slip
1
permitted
a
barge
to
be
completely
removed
from
the
water
for
necessary
repairs
on
its
bottom
or
to
sandblast
and
repaint
the
entire
hull
(Ref.
6,
p.
24).
In
1992,
Hercules
Offshore
Corporation
used
5000
tons
of
standard
blasting
sand.
By
1994,
the
company
had
switched
to
a
product
called
Black
Beauty
abrasive
blasting
grit,
and
the
estimated
amount
of
blasting
material
use
was
only
3350
tons
per
year.
The
fraction
of
airborne
material
generated
by
sandblasting
activities
at
the
facility,
assuming
3350
tons
per
year
of
100
percent
Black
Beauty
abrasive
blasting
grit
was
calculated
at
7.84
tons
per
year
(Ref.
6,
pp.
39).
However,
in
1996,
Hercules
Offshore
Corporation
used
only
52
tons
of
Black
Beauty
abrasive
blasting
grit
(Ref.
14,
p.
17).

Repainting
of
barges
involved
priming
and
painting
with
corrosion
resistant
surface
coatings.
These
surface
coatings
are
listed
as
primarily
being
urethane
and
epoxy
coatings
with
minimal
amounts
of
volatile
organic
compound
solvents
(Ref.
6,
pp.
26).
In
1994,
Hercules
Offshore
Corporation
conducted
painting
operations
on
approximately
six
(6)
barges
per
month
and
used
approximately
740
gallons
of
paint
and
primer
per
year
(Ref.
6,
p.
40).
A
coatings
usage
log
for
October
1996
shows
that
Hercules
Offshore
Corporation
used
approximately
73
gallons
of
zinc
primer
with
a
volatile
organic
compound
content
of
4.93
pounds
per
gallon
(Ref.
14,
pp.
11
&
36).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
19
SD­
Characterization
and
Containment
Source
No.
1,
Contaminated
Soil
The
barge
slips
and
dry
dock
area
where
barges
are
emptied
and
repaired
incorporate
no
containment
or
levees
to
contain
potential
contaminant
migration
(Ref.
11,
p.
8).
Dust
emanating
from
the
sandblasting
activities
has
been
reported
settling
on
adjacent
properties
and
in
the
Intracoastal
Waterway
(Ref.
11,
p.
8).
Hercules
Offshore
Corporation
received
a
Notice
of
Violation
(NOV)
in
1989
from
the
Texas
Air
Control
Board
for
nuisance
dust
carry
over
from
the
facility
(Ref.
6,
p.
8).

A
June
1999
Site
Characterization
Report
prepared
by
LT
Environmental
identified
two
areas
at
the
former
Gulfco
facility
where
sandblast
material
had
accumulated
on
the
ground
surface.
One
area
is
on
the
east
side
of
the
dry
dock
area
and
Barge
Slip
1,
and
the
second
area
is
northeast
of
the
Quonset
Hut
(Figure
2).
On
February
22,
1999,
LTE
collected
one
grab
sample
of
the
black
sandblasting
material
in
the
dry
dock
area.
The
only
analytical
data
presented
is
for
beryllium,
which
had
a
concentration
of
0.114
mg/
kg
(Ref.
5,
p.
13).
During
a
March
1999
site
characterization
sampling
event,
LTE
collected
one
surface
soil
sample
from
the
Dry
Dock
Area.
The
analytical
results
from
this
sample
indicated
the
following
contaminant
concentrations:
arsenic
6.05
mg/
kg,
barium
112
mg/
kg,
chromium
34.0
mg/
kg,
lead
130
mg/
kg,
and
mercury
0.16
mg/
kg.
LTE
also
collected
two
soil
samples
from
the
sand
blast
area
north
of
the
Quonset
Hut,
one
from
0
­
6
inches,
and
the
other
from
2
­
3
feet.
The
results
from
these
samples
indicated
levels
of
contaminants
ranging
from
1.57
to
1.75
mg/
kg
for
arsenic,
390
to
429
mg/
kg
for
barium,
14.9
to
15.0
mg/
kg
for
chromium,
and
43.3
to
46.8
mg/
kg
for
lead
(Ref.
5,
pp.
13,
14,
36,
and
37).

The
AST
Tank
Farm
Area
is
a
concrete
bermed
area
containing
numerous
aboveground
storage
tanks.
Material
stored
within
these
tanks
was
assumed
to
include
sandblasting
material,
fertilizer,
chlorinated
solvents,
crude
oil,
gasoline,
and
diesel
fuel.
LTE
installed
three
soil
borings
around
the
AST
Tank
Farm
Area
during
their
site
characterization
work
and
submitted
the
sample
with
the
highest
headspace
reading
for
laboratory
analysis.
Sample
B­
10,
which
was
collected
adjacent
to
the
Intracoastal
Waterway,
was
analyzed
for
VOCs,
SVOCs,
and
Total
Petroleum
Hydrocarbons
(TPH).
Detectable
levels
of
1,2­
dichloroethane,
ethylbenzene,
isopropylbenzene,
naphthalene,
1,2,4­
trimethylbenzene,
and
xylenes
were
found
in
this
sample,
and
the
TPH
concentration
was
792
mg/
kg.
One
surface
soil
sample
was
also
collected
adjacent
to
Barge
Slip
2
and
analyzed
for
VOCs
and
TPH.
TPH
was
detected
at
a
concentration
of
200
mg/
kg
(Ref.
5,
pp.
14,
15,
36,
&
37).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
20
SD­
Characterization
and
Containment
Source
No.
1,
Contaminated
Soil
The
former
drum
storage
area
was
located
adjacent
to
the
south
side
of
the
AST
Tank
Farm
Area
(Figure
2).
LTE
identified
a
total
of
103
55­
gallon
drums
at
the
facility,
with
many
of
these
drums
being
stored
in
the
drum
storage
area.
Sixty
one
of
these
drums
contained
either
solids
or
liquids,
with
the
remaining
drums
being
empty.
All
drums
were
relocated
to
a
central
staging
area
and
eight
composite
samples
collected
of
like
materials.
Five
of
the
composite
samples
indicated
that
42
of
the
61
drums
contained
material
(liquids
or
solids)
exceeding
TCLP
standards
for
VOCs
including
benzene,
carbon
tetrachloride,
chloroform,
1,2­
dichloroethane,
1,1­
dichloroethene,
methylethylketone,
tetrachloroethylene,
trichloroethylene,
and
vinyl
chloride
(Ref.
5,
pp.
12
&
35).
LTE
did
not
collect
any
soil
samples
from
this
area.
All
drums
had
been
removed
from
the
Gulfco
property
at
the
time
of
the
January
2000
SSI
sampling
event.

The
former
Wash
Water
AST
Farm
Area
is
located
south
of
Marlin
Avenue
on
the
east
side
of
the
facility
(Figure
2).
Originally,
this
area
contained
six
aboveground
storage
tanks
used
to
store
barge
wash
water.
The
waste
material
stored
in
these
tanks
were
the
same
as
the
wash
water
stored
in
the
tanks
at
the
AST
Farm
Area.
LTE
collected
two
soil
samples
from
the
former
Wash
Water
AST
Farm
Area
during
the
site
characterization
investigation
and
found
1,2­
dichloroethane
and
isopropyl­
benzene
at
0.0020
mg/
kg
and
0.0074
mg/
kg,
respectively
(Ref.
5,
pp.
15,
36,
&
37).

In
addition,
Source
1
includes
areas
of
contaminated
soil
in
vacant
lots
57
and
58
adjacent
to
the
area
of
the
former
surface
impoundments.
LTE
collected
one
surface
soil
sample
from
each
vacant
lot
to
determine
whether
the
sandblasting
material
had
migrated
across
Marlin
Avenue
due
to
the
prevailing
winds.
Sample
results
indicated
levels
of
arsenic
ranging
from
1.99
to
2.19
mg/
kg,
levels
of
barium
ranging
from
95.4
to
133
mg/
kg,
levels
of
chromium
ranging
from
5.17
to
8.76
mg/
kg,
and
levels
of
lead
ranging
from
48.6
to
54.3
mg/
kg
(Ref.
5,
p.
36).

During
the
week
of
January
24
through
January
27,
2000,
the
Texas
Natural
Resource
Conservation
Commission,
Superfund
Site
Discovery
Assessment
Program
conducted
an
Site
Screening
Inspection
(SSI)
sampling
event
at
the
Gulfco
Marine
Maintenance
site
(Ref.
15;
Ref.
16).
The
purpose
of
this
investigation
was
to
assess
potential
site
sources
and
evaluate
threats
related
to
these
potential
sources
along
the
surface
water
pathway.

All
source
samples
collected
during
this
sampling
event
were
analyzed
for
Organic
Target
Compound
List
(TCL)
and
Inorganic
Target
Analyte
List
(TAL)
constituents
following
the
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
21
SD­
Characterization
and
Containment
Source
No.
1,
Contaminated
Soil
Quality
Assurance
Project
Plan
for
Preliminary
Assessment/
Site
Inspection
Program
(FY
2000­
2001)
(Ref.
17,
pp.
1
­
62).
The
analytical
results
documented
organic
and
inorganic
concentrations
greater
than
the
background
concentrations
and
above
the
sample
quantitation
limits
(See
Tables
2
through
9).
Source
1
consists
of
contaminated
soil
associated
with
previous
barge
cleaning,
servicing,
and
repair
operations
at
the
facility.
Additional
unknown
activities
may
have
contributed
to
the
contamination
associated
with
this
source.
Source
1
is
classified
and
evaluated
as
HRS
source
type
Contaminated
Soil
(Ref.
3,
p.
42).

Location
of
the
source,
with
reference
to
a
map
of
the
site:

Contaminated
soil
at
the
former
Gulfco
facility
was
documented
through
chemical
analysis
at
various
locations
around
the
property.
These
areas
include
the
sandblast
areas,
former
drum
storage
area,
former
Wash
Water
Storage
Area,
the
AST
Farm
Area,
the
vacant
lots
north
of
Marlin
Avenue,
and
adjacent
to
the
former
surface
impoundments
(See
Figure
3)(
Ref.
18,
Photographs
10
­
17).
Operations
at
the
facility
involved
transferring
various
waste
and
generated
wash
waters
from
chemical
barges
to
various
storage
facilities
located
across
the
facility,
including
the
area
north
of
Marlin
Avenue.
Dust
emanating
during
sandblasting
and
repair
operations
at
the
facility
has
been
documented
migrating
to
adjacent
properties
and
to
the
Intracoastal
Waterway
(Ref.
11,
p.
8),
and
these
operations
were
conducted
during
periods
when
the
wind
was
blowing
from
different
directions
(Ref.
14,
pp.
14,
53­
54).
Since
facility
operations
were
widespread
across
the
property,
and
since
migration
of
airborne
materials
related
to
barge
repair
operations
has
been
documented,
the
contaminated
soil
documented
by
chemical
analysis
is
considered
to
exist
or
overlap
between
the
individual
source
sample
locations.

Containment
Gas
release
to
air:
The
air
migration
pathway
was
not
evaluated
for
Source
1,
Contaminated
Soil;
therefore,
gas
containment
was
not
evaluated.

Particulate
release
to
air:
The
air
migration
pathway
was
not
evaluated
for
Source
1,
Contaminated
Soil;
therefore,
particulate
containment
was
not
evaluated.

Release
to
ground
water:
The
ground
water
migration
pathway
was
not
evaluated
for
scoring
purposes;
therefore,
the
ground
water
containment
was
not
evaluated.

SD­
Hazardous
Substances
Source
No.
1,
Contaminated
Soil
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
22
Release
via
overland
migration
and/
or
flood:
Source
1
consists
of
contaminated
soil.
Hazardous
substances
detected
at
or
above
the
sample
quantitation
limit
and
above
background
concentrations
were
documented
by
chemical
analysis
in
all
soil
source
samples
collected
during
the
January
2000
sampling
event
(See
Tables
5­
8).
Hazardous
substances
associated
with
Source
1,
Contaminated
Soil,
have
been
documented
as
an
observed
release
in
the
nearest
surface
water
body
of
the
Intracoastal
Waterway
at
PPE1.
The
Intracoastal
Waterway
bounds
the
entire
southern
part
of
the
former
Gulfco
facility.
No
containment
or
levees
are
present
to
contain
contaminant
migration
from
Source
1;
therefore
contaminant
attribution
to
Source
1
can
be
established
for
the
Surface
Water
Pathway
overland/
flood
migration
route.
Source
1
will
be
evaluated
as
neither
of
the
following
present:
(1)
maintained
engineered
cover,
or
(2)
functioning
and
maintained
run­
on
control
system
and
runoff
management
system
(Ref.
1,
Table
4­
2).
A
containment
value
of
ten
(10)
is
assigned
from
Reference
1,
Table
4­
2.

2.2.2
Hazardous
Substances
Associated
with
a
Source
Table
5
identifies
the
soil
source
sample
locations
where
hazardous
substances
were
detected
by
chemical
analysis
at
or
above
the
sample
quantitation
limit
and
above
background
concentrations
during
the
January
2000
SSI
sampling
event.
Soil
sample
locations
are
depicted
in
Figure
3.

Those
substances
shown
in
bold
in
Table
6
were
detected
at
or
above
the
sample
quantitation
limit
and
above
the
background
concentrations
in
surface
soil
samples
collected
at
the
Gulfco
Marine
Maintenance
site
during
the
January
2000
SSI
sampling
event.
All
soil
samples
were
collected
at
depths
ranging
from
0
­
6
inches.
No
organic
contaminants
(volatiles,
semivolatiles,
pesticides,
and
PCBs)
were
detected
above
background
concentrations
and
above
the
sample
quantitation
limit
in
samples
SO­
02,
SO­
07
and
SO­
08.
Inorganic
contaminants
were
detected
at
or
above
the
sample
quantitation
limit
and
above
background
concentrations
in
all
soil
source
samples
(Table
6).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
23
Figure
3­
Contaminated
Soil
Samples
­
Source
No.
1
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
24
Table
2
Soil
Source
Samples
for
Source
No.
1
­
Contaminated
Soil
Station/
CLP
ID.
No.
Sample
Location
Sample
Depth
Date
Collected
Reference
SO­
01
FGK24/
MFJQ40
Sandblast
area
adjacent
to
Barge
Slip
1
Composite
Sample
0"
­
6"
01/
25/
00
Figure
3;
Ref.
16,
p.
57
Ref.
19,
pp.
1­
7,
9,
11­
12,
15,
38­
40,
74­
76,
95
Ref.
20,
pp.
1­
6,
10,
30
Ref.
18,
Photograph
10
SO­
02
MFJQ41
Sandblast
area
northeast
of
quonset
building
Composite
Sample
0"
­
6"
01/
25/
00
Figure
3;
Ref.
16,
p.
58
Ref.
20,
pp.
1­
6,
10,
31
Ref.
18,
Photograph
11
SO­
03
FGK26/
MFJQ42
Former
Drum
Storage
Area
Composite
Sample
0"
­
6"
01/
25/
00
Figure
3;
Ref.
16,
p.
59
Ref.
21,
pp.
1­
8,
11,
16­
17,
21,
62­
64,
134­
136,
172
Ref.
20,
pp.
1­
6,
10,
32
Ref.
18,
Photograph
12
SO­
04
FGK27/
MFJQ43
Former
Wash
Water
Storage
Area
Composite
Sample
0"
­
6"
01/
25/
00
Figure
3;
Ref.
16,
p.
60
Ref.
21,
pp.
1­
8,
11,
16­
17,
21,
65­
67,
137­
139,
173
Ref.
20,
pp.
1­
6,
10,
33
Ref.
18,
Photograph
13
SO­
05
FGK28/
MFJQ44
AST
Tank
Farm
Area
Composite
Sample
0"
­
6"
01/
25/
00
Figure
3;
Ref.
16,
p.
61
Ref.
21,
pp.
1­
8,
12,
16­
17,
21,
68­
70,
140­
142,
174
Ref.
22,
pp.
1­
6,
8,
12
Ref.
18,
Photograph
14
SO­
06
FGK29/
MFJQ45
Vacant
Lot
57/
58,
North
of
Marlin
Avenue
Composite
Sample
0"
­
6"
01/
25/
00
Figure
3;
Ref.
16,
p.
62
Ref.
21,
pp.
1­
8,
12,
18­
19,
22,
74­
76,
143­
145,
175
Ref.
22,
pp.
1­
6,
8,
13
Ref.
18,
Photograph
15
SO­
07
MFJQ46
Adjacent
to
Former
Surface
Impoundment
Composite
Sample
0"
­
6"
01/
25/
00
Figure
3;
Ref.
16,
p.
64
Ref.
22,
pp.
1­
6,
8,
14
Ref.
18,
Photograph
16
SO­
08
MFJQ47
Adjacent
to
Former
Surface
Impoundment
Composite
Sample
0"
­
6"
01/
25/
00
Figure
3;
Ref.
16,
p.
66
Ref.
22,
pp.
1­
6,
8,
15
Ref.
18,
Photograph
17
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
25
Table
3
Source
Characterization
Table
for
Source
No.
1
­
Contaminated
Soil
Hazardous
Substance
Evidence
FGK24
(S0­
O1)
FGK25
(SO­
02)
FGK26
(SO­
03)
FGK27
(SO­
04)
FGK28
(SO­
05)
FGK29
(SO­
06)
FGK30
(SO­
07)
FGK31
(SO­
08)

Volatile
Organics
Concentration
in
ug/
Kg
(SQL)

Methylene
Chloride
ND
[10]
6
J
[10]
17
[11]
13
[13]
25
J
[11]
6
J
[10]
8
J
[14]
5
J
[10]

Reference
Ref.
19
1­
6,
9,
38­
40
Ref.
21
1­
8,
11,
59­
61
Ref.
21
1­
8,
11,
62­
64
Ref.
21
1­
8,
11,
65­
67
Ref.
21
1­
8,
12,
71­
73
Ref.
21
1­
8,
12,
74­
76
Ref.
21
1­
8,
12,
77­
79
Ref.
21
1­
8,
12,
80­
82
Semivolatile
Organics
Concentrations
in
ug/
Kg
(SQL)

Phenanthrene
250
J
[720]
ND
[350]
ND
[380]
ND
[1900]
ND
[37000]
2500
[1900]
ND
[470]
ND
[390]

Fluoranthene
580
J
[720]
ND
[350]
73
J
[380]
ND
[1900]
ND
[37000]
5100
[1900]
ND
[470]
ND
[390]

Pyrene
460
J
[720]
ND
[350]
71
J
[380]
ND
[1900]
ND
[37000]
4400
[1900]
ND
[470]
ND
[390]

Benzo(
a)
anthracene
290
J
[720]
ND
[350]
ND
[380]
ND
[1900]
ND
[37000]
2400
[1900]
ND
[470]
ND
[390]

Chrysene
400
J
[720]
ND
[350]
43
J
[380]
ND
[1900]
ND
[37000]
2800
[1900]
ND
[470]
ND
[390]

Bis(
2­
Ethylhexyl)
phthalate
2600
J
[720]
400
[350]
61
J
[380]
220
J
[1900]
ND
[37000]
ND
[1900]
84
J
[470]
60
J
[390]

Benzo(
b)
fluoranthene
380
J
[720]
ND
[350]
49
J
[380]
ND
[1900]
ND
[37000]
2700
[1900]
ND
[470]
ND
[390]

Benzo(
k)
fluoranthene
33
J
[720]
ND
[350]
ND
[380]
ND
[1900]
ND
[37000]
2500
[1900]
ND
[470]
ND
[390]

Benzo(
a)
pyrene
360
J
[720]
ND
[350]
ND
[380]
ND
[1900]
ND
[37000]
2600
[1900]
ND
[470]
ND
[390]

Indeno(
1,2,3­
cd)
pyrene
360
J
[720]
ND
[350]
63
J
[380]
ND
[1900]
ND
[37000]
2200
[1900]
ND
[470]
ND
[390]

Benzo(
g,
h,
i)
perylene
450
J
[720]
ND
[350]
79
J
[380]
ND
[1900]
ND
[37000]
2400
J
[1900]
ND
[470]
ND
[390]
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
26
Reference
Ref.
19,
pp.
1­
7,
11­
12,
74­
76
Ref.
21,
pp.
1­
8,
16­
17,
131­
133
Ref.
21,
pp.
1­
8,
16­
17,
134­
136
Ref.
21,
pp.
1­
8,
16­
17,
137­
139
Ref.
21,
pp.
1­
8,
16­
17,
140­
142
Ref.
21,
pp.
1­
8,
18­
19,
143­
145
Ref.
21,
pp.
1­
8,
18­
19,
146­
148
Ref.
21,
pp.
1­
8
18­
19,
149­
151
Table
3
­
Continued
Source
Characterization
Table
for
Source
No.
1
­
Contaminated
Soil
Hazardous
Substance
Evidence
FGK24
(SO­
01)
FGK25
(SO­
02)
FGK26
(SO­
03)
FGK27
(SO­
04)
FGK28
(SO­
05)
FGK29
(SO­
06)
FGK30
(SO­
07)
FGK31
(SO­
08)

Pesticides/
PCBs
Concentrations
in
ug/
Kg
(SQL)

Dieldrin
ND
[3.6]
ND
[3.4]
6.2
[3.7]
15
J
[3.8]
NDJv
[3.7]
9.9
J^
[3.7]
ND
[4.7]
ND
[3.9]

4,4'­
DDE
ND
[3.6]
ND
[3.4]
ND
[3.7]
8.9
J^
[3.8]
4
Jv
[3.7]
5
J^
[3.7]
ND
[4.7]
ND
[3.9]

Endrin
ND
[3.6]
ND
[3.4]
ND
[3.7]
ND
[3.8]
4
Jv
[3.7]
ND
[3.7]
ND
[4.7]
ND
[3.9]

4,4'­
DDD
ND
[3.6]
ND
[3.4]
ND
[3.7]
6.4
J^
[3.8]
NDJv
[3.7]
7.9
J
[3.7]
ND
[4.7]
ND
[3.9]

4,4'­
DDT
ND
[3.6]
ND
[3.4]
ND
[3.7]
15
J^
[3.8]
NDJv
[3.6]
7.4
J^
[3.7]
ND
[4.7]
ND
[3.9]

Endrin
Ketone
ND
[3.6]
ND
[3.4]
ND
[3.7]
13
J
[3.8]
NDJv
[3.6]
ND
[3.7]
ND
[4.7]
ND
[3.9]

Endrin
Aldehyde
ND
[3.6]
ND
[3.4]
ND
[3.7]
18
J^
[3.8]
NDJv
[3.6]
ND
[3.7]
ND
[4.7]
ND
[3.9]

alpha­
Chlordane
ND
[1.8]
ND
[1.8]
ND
[1.9]
8.4^
[1.9]
ND
[1.9]
ND
[1.9]
ND
[2.4]
ND
[2.0]

gamma­
Chlordane
ND
[1.8]
ND
[1.8]
ND
[1.9]
20
[1.9]
ND
[1.9]
ND
[1.9]
ND
[2.4]
ND
[2.0]

Aroclor­
1254
ND
[36]
ND
[34]
34
J
[39]
150
[37]
NDJv
[37]
70
[37]
ND
[47]
ND
[39]

Reference
Ref.
19,
pp.
1­
7,
15,
95
Ref.
21,
pp.
1­
8,
21,
171
Ref.
21,
pp.
1­
8,
21,
172
Ref.
21,
pp.
1­
8,
21,
173
Ref.
21,
pp.
1­
8,
21,
174
Ref.
21,
pp.
1­
8,
22,
175
Ref.
21,
pp.
1­
8,
22,
176
Ref.
21,
pp.
1­
8,
22,
177
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
27
Table
3
­
Continued
Source
Characterization
Table
for
Source
No.
1
­
Contaminated
Soil
Hazardous
Substance
Evidence
MFJQ40
(S0­
O1)
MFJQ41
(SO­
02)
MFJQ42
(SO­
03)
MFJQ43
(SO­
04)
MFJQ44
(SO­
05)
MFJQ45
(SO­
06)
MFJQ46
(SO­
07)
MFJQ47
(SO­
08)

Inorganics
Concentrations
in
mg/
Kg
(SQL)

Aluminum
4350
[42.3]
9090
[42]
10900
[46]
6900
[46]
7870
[43.7]
2360
[44.7]
26600
[57.3]
6520
[49.3]

Arsenic
1.9
[2.1]
1.5
[2.1]
3.8
[2.3]
2.6
[2.3]
3.6
[2.2]
2.7
[2.2]
6.3
[2.9]
2.1
[2.5]

Barium
269
[42.3]
271
[42]
266
[46]
1510
[46]
371
[43.7]
159
[44.7]
247
[57.3]
105
[49.3]

Chromium
13.5
[2.1]
14.9
[2.1]
14.8
[2.3]
18.7
[2.3]
24.0
J
[2.2]
21.6
J
[2.2]
27.6
J
[2.9]
17.1
J
[2.5]

Copper
10.7
[5.3]
23.5
[5.3]
13.1
[5.8]
40.2
[5.8]
21.8
[5.5]
47.8
[5.6]
32.0
[7.2]
11.2
[6.2]

Iron
15900
[21]
15200
[21]
13500
[23]
12400
[23]
13800
[22]
20800
[22]
26500
[29]
8110
[25]

Lead
17.3
[0.63]
11.9
[0.63]
18.5
[0.69]
79.0
[0.69]
65.7
J
[0.66]
221
J
[0.67]
22.7
[0.86]
46.4
J
[0.74]

Manganese
85.6
Jv
[3.2]
90.3
Jv
[3.2]
265
Jv
[3.5]
207
Jv
[3.5]
292
[3.3]
194
[3.4]
962
[4.3]
168
[3.7]

Nickel
10.1
[8.5]
10.6
[8.4]
11.9
[9.2]
9.1
[9.3]
11.1
[8.7]
11.4
[8.9]
26.3
[11.5]
8.2
[9.9]

Vanadium
8.0
[10.6]
15.9
[10.5]
18.2
[11.5]
14.6
[11.6]
15.7
[10.9]
6.6
[11.2]
41.0
[14.3]
13.0
[12.3]

Zinc
368
[4.2]
1150
[4.2]
124
[4.6]
580
[4.6]
416
J
[4.4]
431
J
[4.5]
86.2
J
[5.7]
92.9
J
[4.9]

Reference
Ref.
20,
pp.
1­
6,
10,
30
Ref.
20,
pp.
1­
6,
10,
31
Ref.
20,
pp.
1­
6,
10,
32
Ref.
20,
pp.
1­
6,
10,
33
Ref.
22,
pp.
1­
6,
8,
12
Ref.
22,
pp.
1­
6,
8,
13
Ref.
22,
pp.
1­
6,
8,
14
Ref.
22,
pp.
1­
6,
8,
15
Notes:

Bold
=
Constituents
detected
at
or
above
the
sample
quantitation
limit
and
above
background.
ND
=
Not
detected
at
the
sample
quantitation
limit
SQL
=
Sample
Quantitation
Limit
=
(CRQL/
CRDL)
x
df/%
solids,
where
%solids
=
[100
­
%moisture]
/100
L
=
Reported
concentration
is
below
the
CRQL
J
=
The
value
is
an
estimate
concentration
because
one
or
more
of
the
quality
control
criteria
have
not
been
met.
It
is
included
to
show
that
the
substance
has
been
qualitatively
identified
as
present
in
the
source.
^
=
High
biased.
Actual
concentration
may
be
lower
than
the
concentration
reported.
v
=
Low
biased.
Actual
concentration
may
be
higher
than
the
concentration
reported.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
28
SD­
Hazardous
Substances
Source
No.
1,
Contaminated
Soil
Table
4
identifies
the
three
(3)
background
soil
sample
locations
for
the
January
2000
SSI
sampling
event
for
the
Gulfco
Marine
Maintenance
site.
These
background
soil
samples
were
all
collected
at
depths
ranging
from
0
­
6
inches.
The
locations
of
these
background
samples
are
shown
in
Figure
4.

Table
4
Background
Sample
Locations
for
Source
No.
1­
Contaminated
Soil
Station/
CLP
ID.
No.
Sample
Location
Sample
Depth
Date
Collected
Reference
SO­
09
FGK32
MFJQ48
Approximately
0.8
mile
northeast
of
Gulfco
facility,
on
north
side
of
Marlin
Ave.
Composite
Sample
0"
­
6.0"
01/
25/
00
Figure
4;
Ref.
16,
p.
57
Ref.
21,
pp.
1­
8,
12,
18­
19,
22,
86­
88,
152­
154,
178
Ref.
22,
pp.
1­
6,
8,
16
SO­
10
FGK33
MFJQ49
Approximately
0.5
mile
north­
northwest
of
the
facility,
in
undeveloped
wetland
area
Composite
Sample
0"
­
6.0"
01/
25/
00
Figure
4;
Ref.
16,
p.
69;
Ref.
21,
pp.
1­
8,
13,
18­
19,
22,
92­
94,
155­
157,
179
Ref.
22,
pp.
1­
6,
8,
17
SO­
11
FGK34
MFJQ50
Duplicate
soil
sample
collected
at
same
location
as
sample
SO­
10
Composite
Sample
0"
­
6.0"
01/
25/
00
Figure
4;
Ref.
16,
p.
70
Ref.
21,
pp.
1­
8,
13,
18­
19,
22,
98­
100,
158­
160,
180
Ref.
22,
pp.
1­
6,
8,
18
Table
5
presents
the
background
levels
of
contaminants
and
their
SQLs
detected
in
the
source
soil
samples.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
29
Figure
4
­
Background
Soil
Sample
Location
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
30
Table
5
Background
Sample
Table
for
Source
No.
1
­
Contaminated
Soil
Hazardous
Substance
Evidence
FGK32
(S0­
09)
FGK33
(SO­
10)
FGK34
(SO­
11)

Volatile
Organics
Concentration
in
ug/
Kg
(SQL)

Methylene
Chloride
ND
[13]
ND
UJv
[13]
6
LJ
[13]

Reference
Ref.
21,
pp.
1­
8,
12,
86­
88
Ref.
21,
pp.
1­
8,
13,
92­
94
Ref.
21,
pp.
1­
8,
13,
98­
100
Semivolatile
Organics
Concentrations
in
ug/
Kg
(SQL)

Phenanthrene
ND
[440]
ND
[440]
ND
[430]

Fluoranthene
ND
[440]
ND
[440]
ND
[430]

Pyrene
ND
[440]
ND
[440]
ND
[430]

Benzo(
a)
anthracene
ND
[440]
ND
[440]
ND
[430]

Chrysene
ND
[440]
ND
[440]
ND
[430]

Bis(
2­
Ethylhexyl)
phthalate
46
LJ
[440]
ND
[440]
ND
[430]

Benzo(
b)
fluoranthene
ND
[440]
ND
[440]
ND
[430]

Benzo(
k)
fluoranthene
ND
[440]
ND
[440]
ND
[430]

Benzo(
a)
pyrene
ND
[440]
ND
[440]
ND
[430]

Indeno(
1,2,3­
cd)
pyrene
ND
[440]
ND
[440]
ND
[430]

Benzo(
g,
h,
i)
perylene
ND
[440]
ND
[440]
ND
[430]

Reference
Ref.
21,
pp.
1­
8,
18­
19,
152­
154
Ref.
21,
pp.
1­
8,
18­
19,
155­
157
Ref.
21,
pp.
1­
8,
18­
19,
158­
160
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
31
Table
5
­
Continued
Background
Sample
Table
for
Source
No.
1
­
Contaminated
Soil
Hazardous
Substance
Evidence
FGK32
(S0­
09)
FGK33
(S0­
10)
FGK34
(S0­
11)

Pesticides/
PCBs
Concentrations
in
ug/
Kg
(SQL)

Dieldrin
ND
[4.3]
ND
[4.5]
ND
[4.3]

4,4'­
DDE
ND
[4.3]
ND
[4.5]
ND
[4.3]

Endrin
ND
[4.3]
ND
[4.5]
ND
[4.3]

4,4'­
DDD
ND
[4.3]
ND
[4.5]
ND
[4.3]

4,4'­
DDT
ND
[4.3]
ND
[4.5]
ND
[4.3]

Endrin
Ketone
ND
[4.3]
ND
[4.5]
ND
[4.3]

Endrin
Aldehyde
ND
[4.3]
ND
[4.5]
ND
[4.3]

alpha­
Chlordane
ND
[2.2]
ND
[2.3]
ND
[2.2]

gamma­
Chlordane
ND
[2.2]
ND
[2.3]
ND
[2.2]

Aroclor­
1254
ND
[43]
ND
[45]
ND
[43]

Reference
Ref.
21,
pp.
1­
8,
22,
178
Ref.
21,
pp.
1­
8,
22,
179
Ref.
21
1­
8,
22,
180
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
32
Table
5
­
Continued
Background
Sample
Table
for
Source
No.
1
­
Contaminated
Soil
Hazardous
Substance
Evidence
MFJQ48
(S0­
O9)
MFJQ49
(SO­
10)
MFJQ50
(SO­
11)

Inorganics
Concentrations
in
mg/
Kg
(SQL)

Aluminum
13800
[51.7]
25300
[53]
12500
[52.7]

Arsenic
3.1
[2.6]
4.9
[2.7]
3.8
[2.6]

Barium
223
[51.7]
180
[53]
147
[52.7]

Chromium
14.6
J
[2.6]
25.0
J
[2.7]
14.0
J
[2.6]

Copper
12.6
[6.5]
18.3
[6.6]
30.0
[6.6]

Iron
15500
[26]
21700
[27]
13300
[26]

Lead
14.3
J
[0.78]
13.3
J
[0.79]
12.9
J
[0.79]

Manganese
224
[3.9]
512
[4]
381
[4]

Nickel
13.1
[10.3]
20.7
[10.6]
13.7
[10.5]

Vanadium
20.4
[12.9]
35.4
[13.3]
21.3
[13.2]

Zinc
50.1
J
[5.2]
49.2
J
[5.3]
42.2
J
[5.3]

Reference
Ref.
22,
pp.
1­
6,
8,
16
Ref.
22,
pp.
1­
6,
8,
17
Ref.
22,
pp.
1­
6,
8,
18
Notes:

ND
=
Not
detected
at
the
sample
quantitation
limit
SQL
=
Sample
Quantitation
Limit
=
(CRQL/
CRDL)
x
df/%
solids,
where
%solids
=
[100
­
%moisture]
/100
L
=
Reported
concentration
is
below
the
CRQL
J
=
The
value
is
an
estimate
concentration
because
one
or
more
of
the
quality
control
criteria
have
not
been
met.
It
is
included
to
show
that
the
substance
has
been
qualitatively
identified
as
present
in
the
source.
^
=
High
biased.
Actual
concentration
may
be
lower
than
the
concentration
reported.
v
=
Low
biased.
Actual
concentration
may
be
higher
than
the
concentration
reported.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
33
SD­
Hazardous
Substances
Source
No.
1,
Contaminated
Soil
2.2.3
Hazardous
Substances
Available
to
a
Pathway
Because
the
containment
factor
value
for
Source
1,
Contaminated
Soil,
is
greater
than
0,
the
following
hazardous
substances
associated
with
the
source
are
available
to
migrate
via
the
surface
water
migration
pathway.

°
Methylene
Chloride
°
Dieldrin
°
Aluminum
°
Phenanthrene
°
4,4'­
DDE
°
Arsenic
°
Fluoranthene
°
Endrin
°
Barium
°
Pyrene
°
4,4'­
DDD
°
Chromium
°
Benzo(
a)
anthracene
°
4,4'­
DDT
°
Copper
°
Chrysene
°
Endrin
Ketone
°
Iron
°
Bis(
2­
Ethylhexyl)
phthalate
°
Endrin
aldehyde
°
Lead
°
Benzo(
b)
fluoranthene
°
alpha­
Chlordane
°
Manganese
°
Benzo(
k)
fluoranthene
°
gamma­
Chlordane
°
Nickle
°
Benzo(
a)
pyrene
°
Aroclor
1254
°
Vanadium
°
Indeno(
1,2,3­
cd)
pyrene
°
Zinc
°
Benzo(
g,
h,
i)
perylene
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
34
SD­
Likelihood
of
Release
Source
No.
1,
Contaminated
Soil
2.3
LIKELIHOOD
OF
RELEASE
Refer
to
Section
4.1.2.1
of
this
Documentation
Record
for
specific
information
related
to
the
Likelihood
of
Release
to
the
Surface
Water
Pathway.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
35
SD­
Waste
Characteristics
Source
No.
1,
Contaminated
Soil
2.4
WASTE
CHARACTERISTICS
2.4.1
Selection
of
Substance
Potentially
Posing
Greatest
Hazard
All
of
the
hazardous
substances
listed
above
are
associated
with
this
source.

Specific
toxicity
factor
values,
combined
with
the
mobility,
persistence,
and/
or
bioaccumulation
(or
ecosystem
bioaccumulation)
potential
factor
values
are
hazardous
substance
specific
and
applicable
to
the
migration
pathway
being
evaluated.
The
selection
of
the
hazardous
substances
with
the
highest
factor
values
(toxicity,
persistence,
and
bioaccumulation)
applicable
to
the
pathway
(or
threat)
being
evaluated
(Ref.
1,
Section
2.4.1.2)
are
presented
under
the
Surface
Water
Migration
Pathway
section
of
this
Documentation
Record.

2.4.2.
Hazardous
Waste
Quantity
2.4.2.1.1.
Hazardous
Constituent
Quantity
(Tier
A)
­
Not
Evaluated
The
information
available
is
not
sufficient
to
evaluate
Tier
A
for
Source
No.
1,
Contaminated
Soil,
as
required
in
Section
2.4.2.1.1
of
the
HRS
Rule.
As
a
result,
the
evaluation
of
Hazardous
Waste
Quantity
proceeds
to
the
evaluation
of
Tier
B,
hazardous
waste
stream
quantity
(Ref.
1,
Section
2.4.2.1.1).

2.4.2.1.2.
Hazardous
Waste
stream
Quantity
(Tier
B)
­
Not
Evaluated
The
information
available
is
not
sufficient
to
evaluate
Tier
B
for
Source
No.
1,
Contaminated
Soil,
as
required
in
Section
2.4.2.1.2
of
the
HRS
Rule.
As
a
result,
the
evaluation
of
Hazardous
Waste
Quantity
proceeds
to
the
evaluation
of
Tier
C,
volume
(Ref.
1,
Section
2.4.2.1.2).

2.4.2.1.3
Volume
(Tier
C)
­
Not
Evaluated
The
information
available
is
not
sufficient
to
evaluate
Tier
C
for
Source
No.
1,
Contaminated
Soil,
as
required
in
Section
2.4.2.1.3
of
the
HRS
Rule.
As
a
result,
the
evaluation
of
Hazardous
Waste
Quantity
proceeds
to
the
evaluation
of
Tier
D,
area
(Ref.
1,
Section
2.4.2.1.3).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
36
SD­
Waste
Characteristics
Source
No.
1,
Contaminated
Soil
2.4.2.1.4.
Area
(Tier
D)
­
Evaluated
The
former
Gulfco
facility
was
utilized
for
barge
cleaning
and
refurbishing,
and
offshore
platform
construction
from
1971
through
1998
(Ref.
5,
p.
6).
Chemical
barges
brought
to
the
facility
were
drained
to
remove
product
heels,
which
were
transferred
to
storage
tanks
located
at
the
facility
for
subsequent
sale
as
product.
Each
barge
was
then
washed
with
water
or
a
detergent
solution
(Ref.
9,
p.
18;
Ref.
8,
p.
3).
Generated
wash
waters
were
initially
hard
piped
across
the
site
for
storage
in
the
three
surface
impoundments
located
on
Lot
56
north
of
Marlin
Avenue
(Ref.
8,
p.
7).
Following
closure
of
the
surface
impoundments,
generated
waste
wash
waters
were
stored
either
in
a
floating
barge
moored
in
the
Intracoastal
Waterway
or
in
aboveground
storage
tanks
at
the
facility
(Ref.
9,
p.
18;
Ref.
10,
p.
1;
Ref.
11,
pp.
8
&
9).

During
the
period
of
time
Fish
Engineering
operated
the
facility,
half
of
the
transport
barges
brought
to
the
facility
carried
oil
or
related
products,
and
the
other
half
carried
miscellaneous
organics
(alcohols,
ketones,
crude
oil,
chloroform,
trichloroethylene,
and
cumene,
etc.)
and
inorganics
(hydrochloric
acid,
calcium
chloride,
fertilizers,
etc.)
(Ref.
7,
p.
2;
Ref.
8,
p.
3;
Ref.
11,
p.
6).
During
the
period
when
Hercules
Offshore
Corporation
operated
the
site,
most
of
the
barges
sent
to
the
facility
for
repair
were
owned
by
Dow
Chemical
Company
(Ref.
11,
p.
2).

The
site
contains
hazardous
substances
from
CERCLA­
eligible
petroleum
related
wastestreams,
nonpetroleum
related
wastestreams
and
excluded
petroleum
products
that
were
commingled
(Ref.
8,
p.
3;
Ref.
9,
p.
18;
Ref.
11,
p.
8).
Potential
contaminants
associated
with
operational
activities
at
the
Gulfco
Marine
Maintenance
site
include
fuel
oil,
oil
wastes,
gas
condensate,
alcohols
(n­
butyl
alcohol,
methanol,
isobutyl
alcohol,
etc.),
ketones
(methyl
ethyl
ketone,
acetone,
etc.),
fertilizers,
phenols,
benzene,
cyclohexane,
urethane,
toluene,
xylene,
chloroethene,
naphthalene,
chloroform,
creosote,
tetrachloroethene,
1,1­
dichloroethylene,
1,1,1­
trichloroethane,
dichloro
methane,
cumene,
1,1,2­
trichloroethane,
trichloroethane,
acrilonitrile,
ethyl
ether,
tetrachloro
methane,
formaldehyde,
hydrochloric
acid,
calcium
chloride
and
others
(Ref.
8
p.
5).

Barge
servicing
operations
at
the
facility
included
sandblasting
and
painting
of
barges,
as
well
as
mechanical
repair
and
welding.
The
dry
dock
area
associated
with
Barge
Slip
1
permitted
a
barge
to
be
completely
removed
from
the
water
for
necessary
repairs
on
its
bottom
or
to
sandblast
and
repaint
the
entire
hull.
In
1992,
Hercules
Offshore
Corporation
used
5000
tons
of
standard
blasting
sand.
By
1994,
the
company
had
switched
to
a
product
called
Black
Beauty
abrasive
blasting
grit,
and
the
estimated
amount
of
blasting
material
used
was
only
3350
tons
per
year.
The
fraction
of
airborne
material
generated
by
sandblasting
activities
at
the
facility,
assuming
3350
tons
per
year
of
100
percent
Black
Beauty
abrasive
blasting
grit,
was
calculated
at
7.84
tons
per
year
(Ref.
6,
pp.
39).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
37
SD­
Waste
Characteristics
Source
No.
1,
Contaminated
Soil
However,
in
1996,
Hercules
Offshore
Corporation
used
only
52
tons
of
Black
Beauty
abrasive
blasting
grit
(Ref.
14,
p.
17).

Repainting
of
barges
involved
priming
and
painting
with
corrosion
resistant
surface
coatings.
These
surface
coatings
are
listed
as
primarily
being
urethane
and
epoxy
coatings
with
minimal
amounts
of
volatile
organic
compound
solvents
(Ref.
6,
p.
26).
In
1994,
Hercules
Offshore
Corporation
conducted
painting
operations
on
approximately
six
(6)
barges
per
month
and
used
approximately
740
gallons
of
paint
and
primer
per
year
(Ref.
6,
p.
40).
A
coatings
usage
log
for
October
1996
shows
the
Hercules
Offshore
Corporation
used
approximately
73
gallons
of
zinc
primer
with
a
volatile
organic
compound
content
of
4.93
pounds
per
gallon
(Ref.
14,
pp.
11
&
36).

The
barge
slips
and
dry
dock
area
where
barges
are
emptied
and
repaired
incorporate
no
containment
or
levees
to
contain
potential
contaminant
migration.
Dust
emanating
from
the
sandblasting
activities
has
been
reported
settling
on
adjacent
properties
and
in
the
Intracoastal
Waterway
(Ref.
11,
p.
8).
Hercules
Offshore
Corporation
received
a
Notice
of
Violation
(NOV)
in
1989
from
the
Texas
Air
Control
Board
for
nuisance
dust
carry
over
to
adjacent
properties
(Ref.
6,
p.
8).
Hercules
Offshore
Corporation
made
at
least
one
attempt
to
install
a
fabric
curtain
to
prevent
wind­
borne
dust
from
migrating
off­
site,
however,
this
attempt
proved
to
be
short
lived
as
the
fabric
curtain
was
damaged
by
the
wind
within
months
(Ref.
6,
pp.
10
&
26).
Sandblasting
records
included
in
a
1996
(Fiscal
Year
1997)
State
Implementation
Plan
Inspection
for
Hercules
Offshore
Corporation
document
sandblasting
operations
and
wind
directions
at
the
facility
for
the
month
of
October
1996,
showing
that
the
operations
were
conducted
when
the
wind
was
blowing
from
various
directions
(Ref.
14,
pp.
14,
53­
54).

Eight
(8)
soil
samples
collected
during
the
January
2000
Gulfco
SSI
sampling
event
documented
an
area
of
contaminated
soil
(Figure
3).
Since
facility
operations
were
widespread
across
the
property,
and
since
airborne
migration
of
materials
related
to
barge
repair
operations
has
been
documented,
the
area
of
contamination
has
been
delineated
by
taking
the
area
between
sample
locations
to
establish
an
observed
release
(Ref.
3,
pp.
344
and
346).
The
total
area
lying
between
these
sample
locations
that
meet
the
criteria
for
observed
contamination
was
determined
to
be
317,518
square
feet
(Figure
5).
The
base
map
for
Figure
5
is
the
Digital
Ortho
Quarter
Quad,
Freeport
Quadrangle,
Northeast
Quarter
(Ref.
23).
Outermost
soil
sample
locations
meeting
the
criteria
for
observed
contamination
were
connected
by
lines,
and
the
outlined
area
was
calculated
using
ArcView
3.2a
GIS
software.

SD­
Waste
Characteristcs
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
38
Source
No.
1,
Contaminated
Soil
Areas
covered
by
buildings
and
or
maintained,
impenetrable
materials
(such
as
paved
areas),
normally
deducted
from
the
calculation
of
total
areas,
were
not
excluded
from
the
area
calculation
because
they
could
not
be
adequately
delineated
and/
or
identified.
Therefore,
the
area
of
observed
soil
contamination
will
be
assigned
an
area
hazardous
waste
quantity
value
of
greater
than
(>)
0.
The
value
of
>0
reflects
that
the
area
value
is
known
to
be
greater
than
0,
but
unknown.

Area
of
source
(ft
2
):
A
>
0
Area
Assigned
Value:
>
0,
but
unknown.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
39
Figure
5
­
Area
of
contamination
for
Source
No.
1
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
40
SD­
Source
Hazardous
Waste
Quantity
Value
Source
No.
1,
Contaminated
Soil
2.4.2.1.5.
Source
Hazardous
Waste
Quantity
Value
As
described
in
the
HRS
Rule,
the
highest
value
assigned
to
a
source
from
among
the
four
tiers
of
hazardous
constituent
quantity
(Tier
A),
hazardous
waste
stream
quantity
(Tier
B),
volume
(Tier
C),
or
area
(Tier
D)
shall
be
selected
as
the
source
hazardous
waste
quantity
value.
(Ref.
1,
Sections
2.4.2.1.1
2.4.2.1.4

Tier
Evaluated
Source
1
Values
Tier
A
­
Constituent
Quantity
NE
Tier
B
­
Wastestream
Quantity
NE
Tier
C
­
Volume
NE
Tier
D
­
Area
>
0,
but
unknown
NE
=
not
evaluated
According
to
the
HRS
Rule,
the
source
Hazardous
Waste
Quantity
Value
is
the
highest
value
determined
for
the
source
(Ref.
1,
Section
2.4.2.1.5).
The
assigned
Hazardous
Waste
Quantity
Value
for
Source
1,
Contaminated
Soil,
was
determined
for
Tier
D
(Area)
=
>
0.
The
value
of
>
0
reflects
that
the
area
is
known
to
be
greater
than
0,
but
the
area
measurement
has
not
been
determined.

Source
No.
1,
Contaminated
Soil,
Hazardous
Waste
Quantity
Value:
>
0
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
41
SD­
Characterization
and
Containment
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

2.2
SOURCE
CHARACTERIZATION
2.2.1
Source
Identification
Number
of
the
source:
2
Name
and
description
of
the
source:
Surface
Impoundments
(buried/
backfilled)

The
surface
impoundments
located
at
the
former
Gulfco
facility
were
associated
with
servicing
and
cleaning
of
chemical
barges
brought
to
the
facility
(Ref.
7,
p.
2;
Ref.
8,
p.
7;
Ref.
10,
p.
1).
Additional
unknown
activities
conducted
at
the
former
Gulfco
facility
may
have
contributed
to
this
source.

Three
(3)
surface
impoundments
were
located
on
Lot
56
north
of
Marlin
Avenue
at
the
former
Gulfco
facility
(Figure
2).
These
surface
impoundments
were
operated
by
Gulfco
Marine
Maintenance
beginning
in
1971,
and
then
by
Fish
Engineering
until
October
16,
1981
when
they
were
taken
out
of
service
(Ref.
7,
p.
2;
Ref.
24,
p.
1).
These
surface
impoundments
were
apparently
earthen
pits,
lined
with
a
natural
site
clay
layer
(Ref.
7,
pp.
6
&
7;
Ref.
8,
p.
7;
Ref.
25,
p.
6).

These
surface
impoundments
contained
hazardous
substances
from
eligible
petroleum
related
wastestreams,
non­
petroleum
related
wastestreams
and
excluded
petroleum
products
that
were
commingled
(Ref.
8,
p.
3;
Ref.
9,
p.
18;
Ref.
11,
p.
8).
The
surface
impoundments
received
wash
waters
generated
during
the
cleaning
of
barges
and
other
transport
vessels
that
carried
miscellaneous
organics
(alcohols,
ketones,
crude
oil,
etc.)
and
inorganics
(hydrochloric
acid,
calcium
chloride,
fertilizers,
etc.)
(Ref.
7,
p.
2).
During
the
period
from
June
1980
through
August
1981,
Fish
Engineering
cleaned
approximately
151
chemical
barges
(Ref.
13,
p.
7).
A
list
of
the
barge
cargoes
for
the
1980
through
1981
reported
period
is
shown
in
Table
1.
In
1982
Fish
Engineering
cleaned
a
total
of
150
barges.
In
December
1991
Hercules
Offshore
Corporation
reported
an
increase
of
the
number
of
barges
cleaned
annually
to
about
240
(Ref.
12,
p.
1).
Much
of
the
increased
barge
cleaning
volume
was
attributed
to
an
increase
in
caustic
barges,
which
contributed
approximately
1/
3
of
the
total
barges
cleaned
at
the
facility
at
this
time
(Ref.
12,
p.
1).
An
Environmental
Priority
Initiative
(EPI)
Preliminary
Assessment
for
Fish
Engineering
Construction,
Inc.,
dated
August
2,
1989,
lists
the
following
potential
contaminants
related
to
cleaning
of
chemical
barges
at
the
facility
during
the
period
in
which
Hercules
operated
the
facility:
fuel
oil,
oily
waste,
gas
condensate,
alcohols
(n­
butyl
alcohol,
methanol,
isobutyl
alcohol,
etc.),
ketones
(methylethyl
ketone,
acetone,
etc.),
fertilizers,
phenols,
benzene,
cyclohexane,
urethane,
toluene,
xylenes,
chlorethene,
naphthalene,
chloroform,
creosote,
tetrachloroethene,
1,1­
dichloroethylene,
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
42
SD­
Characterization
and
Containment
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

1,1,1­
trichloro­
ethane,
dichloro
methane,
cumene,
1,1,2­
trichloroethane,
trichloroethane,
acrilonitrile,
ethyl
ether,
tetrachloro
methane,
formaldehyde,
hydrochloric
acid,
calcium
chloride,
and
others
(Ref.
8,
p.
5).
Waste
wash
waters
generated
during
the
cleaning
of
chemical
barges
and
other
vessels
were
hard­
piped
to
the
surface
impoundments
for
evaporation
and
separation.
Two
overflow
pipes
issued
from
surface
impoundment
#1,
with
one
pipe
directed
to
surface
impoundment
#2
and
the
other
directed
to
surface
impoundment
#3
(Ref.
7,
p.
4;
Ref.
8,
pp.
6
&
7).

Two
references
provide
approximate
dimensions
for
the
surface
impoundments
located
on
Lot
56
of
the
Gulfco
property.
An
attachment
to
April
29,
1982
letter
from
Fish
Engineering
and
Construction,
Inc.
to
the
Texas
Department
of
Water
Resources
includes
a
Pond
Layout
map
showing
the
approximate
dimensions
of
the
surface
impoundments.
Surface
impoundment
#1,
the
southwest
pond,
had
the
dimensions
of
152
feet
long
by
147
feet
wide.
Surface
impoundment
#2,
the
west
pond,
the
largest
surface
impoundment,
had
the
dimensions
of
317
feet
long
by
173
wide.
Surface
impoundment
#3,
the
northwest
lagoon,
had
the
dimensions
of
145
feet
long
by
147
feet
wide.
No
depths
for
the
surface
impoundments
are
indicated
(Ref.
26,
p.
6).
The
August
2,
1989
Environmental
Priority
Initiative
(EPI)
Preliminary
Assessment
report
for
Fish
Engineering
Construction,
Inc.
documents
the
following
information
on
the
size
of
the
surface
impoundments:

"The
overall
dimensions
of
these
surface
impoundments
were
300
feet
long
by
297
feet
wide.
The
depths
were
not
determined.
The
impoundments
were
interconnected
with
overflow
pipes.
Surface
impoundment
#1
(southeast
pond)
is
listed
as
being
156
feet
long
by
96
feet
wide
with
an
undetermined
depth;
surface
impoundment
#2
(west
pond)
is
listed
as
being
330
feet
long
by
197
feet
wide
with
an
undetermined
depth;
and
surface
impoundment
#3
(northeast
pond)
is
listed
as
being
145
feet
long
by
96
feet
wide
with
an
undetermined
depth"
(Ref.
7,
p.
6).

The
description
of
the
surface
impoundment
layout
map
reported
in
the
Environmental
Priority
Initiative
report
differs
significantly
from
the
pond
layout
shown
in
Reference
43.
Maximum
inventory
of
waste
at
any
given
time
was
5.5
million
gallons
(Ref.
7,
p.
7;
Ref.
8,
p.
7).

On
May
14,
1981,
Fish
Engineering
and
Construction,
Inc.,
submitted
a
plan
to
the
Texas
Department
of
Water
Resources
to
close
the
three
surface
impoundments
(Ref.
27).
The
Texas
Department
of
Water
Resources
found
this
closure
plan
deficient
(Ref.
28).
On
October
16,
1981,
Fish
Engineering
deactivated
the
on­
site
surface
impoundments
(Ref.
24,
p.
1).
Fish
Engineering
and
Construction,
Inc.,
requested
that
the
Texas
Department
of
Water
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
43
SD­
Characterization
and
Containment
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

Resources
classify
the
waste
in
the
surface
impoundments
as
Class
II
waste,
and
based
upon
this
determination,
issue
a
waste
classification
number.
In
addition,
Fish
Engineering
requested
a
one­
time
discharge
permit
which
would
allow
Fish
Engineering
to
discharge
the
liquid
in
the
surface
impoundments
to
the
Intracoastal
Waterway
(Ref.
24,
pp.
1
&
2).
An
addendum
to
the
closure
plan
submitted
to
the
Texas
Department
of
Water
Resources
on
January
26,
1982
included
the
proposal
to
install
four
monitor
wells
around
the
perimeter
of
the
surface
impoundments
(Ref.
10).

During
March
and
April,
1982,
Fish
Engineering
and
Construction,
Inc.,
collected
samples
from
the
soils,
sludges,
and
water
in
the
surface
impoundments.
These
samples
were
collected
in
an
attempt
to
reclassify
the
sludges/
waste
so
as
they
could
remain
at
the
facility
following
closure
of
the
surface
impoundments.
These
samples
were
analyzed
for
total
volatile
matter,
oil
and
grease,
phenols,
and
benzene,
with
the
sample
results
indicating
the
total
volatile
matter
ranged
from
2.2
percent
to
5.47
percent;
the
oil
and
grease
ranged
from
0.65
percent
to
34.89
percent;
the
levels
of
phenol
ranged
from
0.05
ppm
to
5.6
ppm;
and
the
levels
of
benzene
ranged
from
0.05
ppm
to
11.6
ppm
(Ref.
26,
pp.
6
­
10).
In
addition
to
these
data,
a
consultant
for
Fish
Engineering
attempted
to
estimate
the
organic
halogens
in
some
of
the
samples,
but
the
results
were
not
satisfactory
in
that
the
least
contaminated
sample
contained
the
highest
level
of
organic
halogen
(Ref.
26,
pp.
1
and
4).
Based
upon
these
sample
analytical
data,
the
Texas
Department
of
Water
Resources
denied
the
reclassification
of
the
waste
materials
and
contaminated
soils
as
Class
II
waste.
The
Texas
Department
of
Water
Resources
designated
the
waste
materials
as
Class
I
waste
pursuant
to
the
waste
determination
specified
in
the
Texas
Administrative
Code,
Title
30,
Chapter
335,
Subchapter
R,
Rule
§§
335.505
­
335.507(
Ref.
29,
p.
2;
Ref.
30).

Closure
of
the
surface
impoundments
reportedly
involved
removal
of
the
liquids,
removal
of
the
majority
of
the
sludges,
solidifying
the
remaining
sludge
with
soil,
and
capping
the
surface
impoundments
with
three
feet
of
clay
cover
and
a
hard
wearing
surface
(Ref.
7,
pp.
4
&
9;
Ref.
31;
Ref.
32,
p.
1).
Approximately
100
cubic
yards
of
solidified
sludge
was
reportedly
left
in
place,
primarily
in
surface
impoundment
#2
(Ref.
7,
p.
9).
The
surface
impoundments
were
certified
closed
by
Clair
A.
Carden,
P.
E.,
pursuant
to
an
August
18,
1982
letter
to
Mr.
Glen
J.
Gill,
Senior
Vice­
President,
Fish
Engineering
&
Construction,
Incorporated
(Ref.
31).
The
removal
action
undertaken
at
the
former
Gulfco
facility
does
not
meet
the
criteria
for
a
qualifying
removal
action
because
the
available
information
regarding
the
removal
does
not
provide
evidence
that
the
waste
was
physically
removed
from
the
site
and
disposed
of
at
a
RCRA
permitted
facility.
Therefore,
the
three
former
surface
impoundments
may
still
be
evaluated
as
an
HRS
source
(Ref.
3.
p.
12).

SD­
Characterization
and
Containment
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
44
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

As
part
of
the
closure
activities,
Fish
Engineering
installed
four,
fifty
(50)
foot
monitor
wells
screened
between
38
to
48
feet
around
the
former
surface
impoundments
(Ref.
33).
These
wells
were
sampled
at
least
four
times
from
July
1982
through
September
1982.
The
analyses
performed
were
for
benzene,
phenolics
(total
recoverable),
chlorides,
conductivity,
pH,
total
dissolved
solids,
and
total
organic
carbon
(TOC).
Total
organic
halogens
(TOX)
could
not
be
determined
due
to
high
interference
with
high
inorganic
chlorides.
The
analysis
revealed
concentrations
of
benzene
ranging
from
8.5
to
8180
ppb,
levels
of
inorganic
chlorides
greater
than
15,700
ppb,
levels
of
phenol
ranging
from
<10
to
1092
ppb,
and
levels
of
TOC
ranging
from
60
to
290
ppb
(Refs.
34­
37).
These
wells
were
reportedly
plugged
in
December
1983
(Ref.
7,
p.
7).

Hercules
Offshore
Corporation
purchased
the
facility
from
Fish
Engineering
in
January
1989
(Ref.
71,
pp.
1­
8).
Prior
to
this
purchase,
Hercules
Offshore
Corporation
installed
three,
eighteen
(18)
foot
monitor
wells
near
the
former
surface
impoundments
in
January
1989
(Ref.
38,
pp.
2
­
5).
Analysis
of
the
ground
water
samples
from
these
three
wells
indicated
detectable
concentrations
of
volatile
organic
compounds
and
pesticides.
Soil
samples
collected
during
the
construction
of
the
monitor
wells
indicated
elevated
levels
of
heavy
metals
(Ref.
39,
pp.
14
&
19).
Based
upon
the
laboratory
analysis
of
these
samples,
Hercules
elected
not
to
include
Lot
56
in
the
property
purchase
(Ref.
11,
p.
2).

Hercules
Offshore
Corporation
conducted
barge
cleaning
and
refurbishing
operations
at
the
facility
until
May
1998,
when
the
company
declared
bankruptcy
(Ref.
40,
pp.
1
&
2).
In
early
1999,
LT
Environmental
conducted
a
Site
Characterization
investigation
of
the
former
Hercules
Offshore
Corporation
part
of
the
property
for
LDL
Coastal,
Inc.
(Ref.
5),
which
was
interested
in
purchasing
the
property
from
the
bankruptcy
court.
LT
Environmental
installed
two
temporary
monitor
wells
on
the
west
side
of
Lot
55,
between
the
area
of
the
former
surface
impoundments
and
the
large
fresh
water
pond
during
this
investigation
in
1999.
These
wells
were
completed
to
a
total
depth
of
8
feet.
Ground
water
samples
collected
from
the
wells
were
submitted
for
VOC
analysis,
with
the
results
indicating
no
VOCs
detected
(Ref.
5,
pp.
16
&
38).

LDL
Coastal,
Inc.
purchased
Lots
21
through
25
on
the
south
side
of
Marlin
Avenue
and
Lots
55,
57
and
58
on
the
north
side
of
Marlin
Avenue
through
the
Chapter
7
bankruptcy
court
in
mid­
1999
(Ref.
41).
KTI
Fish
(KTI
purchased
Fish
Engineering
forming
KTI
Fish)
sold
Lot
56
of
the
original
Gulfco
property
to
Messrs.
Jack
Palmer
and
Ron
Hudson
sometime
in
1999
(Ref.
42).

SD­
Characterization
and
Containment
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
45
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

During
the
week
of
January
22
through
January
26,
2001,
the
Texas
Natural
Resource
Conservation
Commission,
Superfund
Site
Discovery
Assessment
Program
conducted
an
Expanded
Site
Inspection
(ESI)
sampling
event
at
the
Gulfco
Marine
Maintenance
site
(Ref.
43;
Ref.
44).
Four
ground
water
samples
and
one
duplicate
ground
water
sample
were
collected
from
these
wells
to
characterize
potential
waste
materials
remaining
in
the
surface
impoundments
at
the
former
Gulfco
facility
and
document
the
potential
to
release
of
contaminants
related
to
the
surface
impoundments
to
the
shallow
ground
water
beneath
the
property
(See
Figure
6,
Sample
Location
Map;
Ref.
43,
pp.
6,
7,
8,10,
30­
34).
Temporary
monitor
wells
were
installed
by
a
vehicularly­
mounted,
direct­
push
sampling
probe
at
the
toe
of
the
surface
impoundment
cap,
on
each
of
the
four
sides
(Figure
6).
Temporary
wells
GW­
01
and
GW­
04
were
completed
to
a
total
depth
of
20
feet,
and
temporary
wells
GW­
02
and
GW­
03
were
completed
to
total
depths
of
24
feet.
Each
temporary
well
was
constructed
of
one­
inch
diameter,
schedule
40
PVC
casing,
with
10
feet
of
0.010­
inch
slotted
screen
installed
in
the
lower
ten­
foot
interval
of
each
well
(Ref.
44,
pp.
4,
12,
15­
18;
Ref.
45,
Photographs
1­
4).

All
source
samples
collected
during
this
sampling
event
were
analyzed
for
Organic
Target
Compound
List
(TCL)
and
Inorganic
Target
Analyte
List
(TAL)
constituents
following
the
Quality
Assurance
Project
Plan
for
Preliminary
Assessment/
Site
Inspection
Program
(FY
2000­
2001)
(Ref.
17,
pp.
1
­
62).
The
analytical
results
documented
organic
and
inorganic
concentrations
at
or
above
the
sample
quantitation
limits
and
above
the
background
concentrations
(See
Tables
1
through
4).

Location
of
the
source,
with
reference
to
a
map
of
the
site:

The
former
surface
impoundments
at
the
former
Gulfco
facility
are
located
on
Lot
56,
north
of
Marlin
Avenue
(See
Figures
2
&
6).

Containment:

Gas
release
to
air:
The
air
migration
pathway
was
not
evaluated
for
Source
No.
2,
Surface
Impoundments;
therefore,
gas
containment
was
not
evaluated.

Particulate
release
to
air:
The
air
migration
pathway
was
not
evaluated
for
Source
No.
2,
Surface
Impoundments;
therefore,
particulate
containment
was
not
evaluated.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
46
SD­
Characterization
and
Containment
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

Release
to
ground
water:
The
ground
water
migration
pathway
was
not
evaluated
for
scoring
purposes
for
Source
No.
2,
Surface
Impoundments;
therefore,
ground
water
containment
was
not
evaluated.

Release
via
overland
migration
and/
or
flood:
Source
2
consists
of
three
surface
impoundments
operated
from
1971
through
1981.
These
surface
impoundments
and
the
entire
former
Gulfco
facility
is
located
within
an
area
of
100­
year
coastal
flood
with
velocity
(wave
action);
base
flood
elevation
and
flood
hazard
of
13
feet
mean
sea
level
(Ref.
46,
p.
2).
Historically,
unauthorized
discharge
events
from
the
surface
impoundments
were
documented
in
July
1974
and
August
1979,
contaminating
adjacent
waters
(Ref.
25,
p.
3).
The
surface
impoundments
were
closed
in
1982.
Closure
of
the
surface
impoundments
involved
removal
of
the
contained
liquids,
removal
of
the
majority
of
the
sludges,
solidifying
the
remaining
sludge
with
soil,
and
capping
the
surface
impoundments
with
three
feet
of
clay
cover
and
a
hard
wearing
surface
(Ref.
7,
pp.
4
&
9;
Ref.
31;
Ref.
32,
p.
1).
Approximately
100
cubic
yards
of
sludge
was
left
in
the
surface
impoundments
following
closure,
primarily
in
surface
impoundment
2
(Ref.
7,
p.
9).
Hazardous
substances
detected
at
or
above
the
sample
quantitation
limits
and
above
the
background
concentrations
were
documented
by
chemical
analysis
in
ground
water
samples
GW­
01
(and
duplicate
ground
water
sample
GW­
05),
GW­
03,
and
GW­
04
collected
during
the
January
2001
ESI
sampling
event
(Figure
6;
Tables
1­
4).
Historical
documentation
indicates
evidence
of
hazardous
substance
migration
from
the
source,
and
there
is
no
known
documentation
of
the
presence
of
liners
or
maintenance
controls
for
the
surface
impoundments.
A
Containment
factor
value
of
10
is
assigned
to
the
source
as
specified
in
Table
4­
2
of
the
HRS
Rule
(Ref.
1,
Section
4.1.2.1.2.1.1).

2.2.2
Hazardous
Substances
Associated
with
a
Source
Table
6
identifies
the
ground
water
sample
locations
used
to
characterize
the
potential
waste
material
remaining
in
the
closed
surface
impoundments
at
the
former
Gulfco
facility.
The
ground
water
samples
were
collected
from
temporary
monitor
wells
installed
on
each
of
the
four
sides
of
the
former
surface
impoundments
at
the
toe
of
the
surface
impoundment
cap.
The
location
of
each
of
these
samples
is
shown
in
Figure
6.

Those
substances
shown
in
bold
in
Table
2
were
detected
at
or
above
the
sample
quantitation
limits
and
above
the
background
concentrations
in
ground
water
samples
collected
around
the
closed
surface
impoundments
during
the
January
2001
ESI
field
sampling
event.
Each
ground
water
sample
was
collected
from
a
temporary
monitor
well
using
dedicated
tubing
and
a
peristaltic
pump.
No
inorganic
ground
water
samples
(total
metals
and
cyanide)
were
collected
at
temporary
monitor
well
GW­
04
due
to
the
lack
of
ground
water
recharge
to
the
well.

SD­
Characterization
and
Containment
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
47
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

No
contaminants
were
detected
at
or
above
the
sample
quantitation
limits
and
above
the
background
concentrations
in
the
ground
water
samples
collected
from
temporary
monitor
well
GW­
02.
No
PCBs
were
detected
at
or
above
the
sample
quantitation
limits
and
above
the
background
concentrations
in
any
of
ground
water
samples
from
the
temporary
monitor
wells
installed
around
the
perimeter
of
the
closed
surface
impoundments.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
48
Figure
6­
Source
Samples
for
Source
No.
2
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
49
Table
6
Ground
Water
Samples
Used
to
Characterize
Source
No.
2
­
Surface
Impoundments
Station/
CLP
ID.
No.
Sample
Location
Well
Data
Date
Collected
Reference
GW­
01
FGK62
MFHX50
North
side
of
the
former
surface
impoundments
at
the
toe
of
the
surface
impoundment
cap
Total
Depth
20'

Screened
Interval
10'
­
20'
01/
25/
01
Figure
6
Ref.
43,
pp.
8
&
32
Ref.
44,
pp.
12,
15
Ref.
45,
Photograph
1
GW­
02
F05G6
MF02C3
East
side
of
the
former
surface
impoundments
at
the
toe
of
the
surface
impoundment
cap
Total
Depth
24'

Screened
Interval
14'
­
24'
01/
25/
01
Figure
6;
Ref.
43,
p.
34
Ref.
44,
pp.
12,
16
Ref.
45,
Photograph
2
GW­
03
F05G7
MF02C4
West
side
of
the
former
surface
impoundments
at
the
toe
of
the
surface
impoundment
cap
Total
Depth
24'

Screened
Interval
14'
­
24'
01/
25/
01
Figure
6;
Ref.
43,
p.
33
Ref.
44,
pp.
12,
17
Ref.
45,
Photograph
3
GW­
04
F05G8
South
side
of
the
former
surface
impoundments
at
the
toe
of
the
surface
impoundment
cap
Total
Depth
20'

Screened
Interval
10'
­
20'
01/
25/
01
Figure
6
Ref.
43,
pp.
10
&
30­
31
Ref.
44,
pp.
12,18
Ref.
45,
Photograph
4
GW­
05
F05G9
MF02C6
Duplicate
ground
water
sample
at
same
location
as
GW­
01
Total
Depth
N/
A
Screened
Interval
N/
A
01/
25/
01
Figure
6;
Ref.
43,
p.
32
Ref.
45,
Photograph
1
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
50
Table
7
Source
Characterization
Table
for
Source
No.
2
­
Surface
Impoundments
Hazardous
Substance
Evidence
FGK62
(GW­
O1)
F05G6
(GW­
02)
F05G7
(GW­
03)
F05G8
(GW­
04)
F05G6
(GW­
05)

Volatile
Organics
Concentrations
in
µg/
L
(SQL)

Vinyl
Chloride
1100J
[10]
ND
[10]
1900
J
[10]
17000
[5000]
1600
LJ
[5000]

1,1­
Dichloroethene
32000
LJ
[50000]
ND
[10]
29000
LJ
[50000]
2000
LJ
[5000]
30000
[5000]

Carbon
Disulfide
48
J
[10]
ND
[10]
ND
[10]
ND
[5000]
ND
[5000]

Methylene
Chloride
750000
Jv
[50000]
ND
[10]
670000
[50000]
77000
[5000]
450000
Jv
[50000]

trans­
1,2­
Dichloroethene
ND
[10]
ND
[10]
53
J
[10]
ND
[5000]
ND
[5000]

1,1­
Dichloroethane
1700
J
[10]
ND
[10]
1600
J
[10]
12000
[5000]
ND
[5000]

cis­
1,2­
Dichloroethene
ND
[10]
ND
[10]
4900
J
[10]
ND
[5000]
ND
[5000]

Chloroform
72
J
[10]
ND
[10]
79
J
[10]
1200
LJ
[5000]
ND
[5000]

1,1,1­
Trichloroethane
93000
Jv
[50000]
ND
[10]
12000
LJ
[50000]
93000
[5000]
83000
[5000]

Benzene
18000
LJ
[50000]
2
LJ
[10]
6200
LJ
[50000]
5100
N
[5000]
16000
[5000]

1,2­
Dichloroethane
ND
[10]
ND
[10]
99000
[50000]
2800000
Jv
[430000]
9700
[5000]

Trichloroethene
53000
Jv
[50000]
ND
[10]
92000
[50000]
11000
[5000]
49000
[5000]

1,2­
Dichloropropane
1900
J
[10]
ND
[10]
2100
J
[10]
ND
[5000]
ND
[5000]

4­
Methyl­
2­
pentanone
300
J
[10]
ND
[10]
170
[10]
ND
[5000]
ND
[5000]

Toluene
610
J
[10]
ND
[10]
590
J
[10]
780
LJ
[5000]
ND
[5000]

1,1,2­
Trichloroethane
46
[10]
ND
[10]
35
[10]
ND
[5000]
ND
[5000]
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
51
Table
7
­
Continued
Source
Characterization
Table
for
Source
No.
2
­
Surface
Impoundments
Hazardous
Substance
Evidence
FGK62
(GW­
O1)
F05G6
(GW­
02)
F05G7
(GW­
03)
FO5G8
(GW­
04)
F05G9
(GW­
05)

Volatile
Organics
Concentration
in
µg/
L
(SQL)

Tetrachloroethene
29000
LJ
[50000]
ND
[10]
22000
LJ
[50000]
3400
LJ
[5000]
25000
[5000]

Ethylbenzene
ND
[10]
ND
[10]
40
[10]
ND
[5000]
ND
[5000]

Xylenes
(total)
ND
[10]
ND
[10]
130
[10]
ND
[5000]
ND
[5000]

Isopropylbenzene
24000
LJ
[50000]
4
LJ
[10]
120
[10]
1600
LJ
[5000]
22000
[5000]

1,1,2,2­
Tetrachloroethane
16
[10]
ND
[10]
ND
[10]
ND
[5000]
ND
[5000]

Reference
Ref.
47,
pp.
1­
11,
13,
60­
65
Ref.
47,
pp.
1­
11,
14,
33­
35
Ref.
47,
pp.
1­
11,
14,
36­
41
Ref.
47,
pp.
1­
11
14,
42­
47
Ref.
47
pp.
1­
11,
15,
48­
53
Semivolatile
Organics
Concentrations
in
µg/
L
(SQL)

Benzaldehyde
ND
Jv
[10]
ND
[10]
ND
[10]
56
[10]
ND
[10]

Phenol
24
J
[10]
ND
[10]
42
[10]
51
[10]
46
J
[10]

2­
Methylphenol
4
LJ
[10]
ND
[10]
29
[10]
27
LJ
[10]
7
LJ
[10]

2,2'­
oxybis(
1­
Chloropropane)
ND
Jv
[10]
ND
[10]
23
J
[10]
380
J
[10]
ND
[10]

Acetophenone
64
Jv
[10]
ND
[10]
23
[10]
120
[10]
94
[20]

4­
Methylphenol
8
LJ
[10]
ND
[10]
41
[10]
42
LJ
[10]
11
[10]

Naphthalene
5
LJv
[10]
ND
[10]
12
[10]
230
[10]
8
LJ
[10]

References
Ref.
47,
pp.
1­
11,
16­
17,
102­
107
Ref.
47,
pp.
1­
11,
16­
17,
84­
86
Ref.
47,
pp.
1­
11,
16­
17,
87­
89
Ref.
47,
pp.
1­
11,
16­
17,
90­
92
Ref.
47,
pp.
1­
11,
18­
19,
93­
98
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
52
Table
7
­
Continued
Source
Characterization
Table
for
Source
No.
2
­
Surface
Impoundments
Hazardous
Substance
Evidence
FGK62
(GW­
O1)
F05G6
(GW­
02)
F05G7
(GW­
03)
F05G8
(GW­
04)
F05G9
(GW­
05)

Pesticides/
PCBs
Concentrations
in
µg/
L
(SQL)

alpha­
BHC
0.34
J
[0.050]
ND
[0.050]
0.48
J
[0.050]
ND
[0.050]
ND
J
[0.050]

beta­
BHC
0.25
J
[0.050]
ND
[0.050]
ND
[0.050]
ND
[0.050]
0.75
J
[0.050]

delta­
BHC
0.06O
J
[0.050]
ND
[0.050]
0.092
J
[0.050]
ND
[0.050]
ND
[0.050]

gamma­
BHC
(Lindane)
0.21
J
[0.050]
ND
[0.050]
ND
[0.050]
0.59
J
[0.050]
0.33
J
[0.050]

Heptachlor
0.17
[0.050]
ND
[0.050]
ND
[0.050]
ND
[0.050]
0.15
J
[0.050]

Aldrin
0.099
J
[0.050]
ND
[0.050]
0.085
J
[0.050]
ND
[0.050]
0.096
J
[0.050]

Heptachlor
epoxide
0.58
J
[0.050]
ND
[0.050]
ND
[0.050]
ND
[0.050]
1.5
J
[0.50]

Dieldrin
ND
[0.10]
ND
[0.10]
ND
[0.10]
0.19
J
[0.10]
ND
[0.10]

Endrin
0.13
J
[0.10]
ND
[0.10]
ND
[0.10]
ND
[0.10]
0.32
J
[0.10]

Endosulfan
II
ND
[0.10]
ND
[0.10]
ND
[0.10]
0.42
J
[0.10]
ND
[0.10]

4,4'­
DDT
ND
[0.10]
ND
[0.10]
ND
[0.10]
1.4
J
[0.10]
ND
[0.10]

alpha­
Chlordane
ND
[0.050]
ND
[0.050]
ND
[0.050]
ND
[0.050]
0.053
[0.050]

Reference
Ref.
47,
pp.
1­
11,
20,
121­
122
Ref.
47,
pp.
1­
11,
20,
114
Ref.
47,
pp.
1­
11,
20,
115
Ref.
47,
pp.
1­
11,
20­
21,
116­
117
Ref.
47,
pp.
1­
11,
21,
118­
119
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
53
Table
7
­
Continued
Source
Characterization
Table
for
Source
No.
2
­
Surface
Impoundments
Hazardous
Substance
Evidence
MFHX50
(GW­
O1)
MF02C3
(GW­
02)
MF02C4
(GW­
03)
MF02C6
(GW­
05)

Inorganics
Concentrations
in
µg/
L
(SQL)

Arsenic
77.7
[10]
10.2
[10]
42.6
[10]
70.6
[10]

Cobalt
66.9
[50]
ND
[50]
ND
[50]
60.6
[50]

Copper
273
[25]
42.6
[25]
22.3
L
[25]
266
[25]

Lead
94.7
[3]
20.3
[3]
ND
[3]
86.4
[3]

Manganese
8460
[15]
2010
[15]
14100
[15]
8660
[15]

Nickel
217
[40]
30.9
L
[40]
17.2
LJ^
[40]
216
[40]

Vanadium
196
[50]
53.7
[50]
14.4
LUC
[50]
178
[50]

Reference
Ref.
48,
pp.
1­
8,
10,
28
Ref.
48,
pp.
1­
8,
11,
20
Ref.
48,
pp.
1­
8,
11,
21
Ref.
48,
pp.
1­
8,
12,
22
Notes:

Bold
=
Constituents
detected
at
or
above
the
sample
quantitation
limit
and
above
background.
ND
=
Not
detected
at
the
sample
quantitation
limit
SQL
=
Sample
Quantitation
Limit
=
(CRQL/
CRDL)
x
df/%
solids,
where
%solids
=
[100
­
%moisture]
/100
N
=
Analysis
indicates
the
presence
of
the
analyte
because
of
presumptive
evidence
for
a
tentative
identification.
L
=
Reported
concentration
is
below
the
CRQL
J
=
The
value
is
an
estimated
concentration
because
one
or
more
of
the
quality
control
criteria
have
not
been
met.
It
is
included
to
show
that
the
substance
has
been
qualitatively
identified
as
present
in
this
source.
^
=
High
biased.
Actual
concentration
may
be
lower
than
the
concentration
reported.
v
=
Low
biased.
Actual
concentration
may
be
higher
than
the
concentration
reported.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
54
SD­
Characterization
and
Containment
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

Table
8
identifies
the
two
(2)
background
ground
water
sample
locations
for
the
January
2001
ESI
sampling
event
for
the
former
Gulfco
Marine
Maintenance,
Inc.
facility.
These
background
ground
water
samples
were
collected
from
temporary
monitor
wells
constructed
of
one­
inch
diameter,
schedule
40
PVC
casing
and
0.010­
inch
slotted
screens
(Ref.
43,
pp.
12­
15;
Ref.
44,
pp.
4).
The
locations
of
these
background
temporary
monitor
wells
are
shown
in
Figure
7.

Table
8
Background
Sample
Locations
for
Source
No.
2
­
Surface
Impoundments
Station/
CLP
ID.
No.
Sample
Location
Well
Data
Date
Collected
Reference
GW­
10
FGK84
MFJP71
Temporary
monitor
well
approximately
0.6
mile
southwest
of
the
Gulfco
facility.
Total
Depth
20'

Screened
Interval
10'
­
20'
01/
24/
01
Figure
7;
Ref.
43,
pp.
12­
14;
Ref.
44,
pp.
12,
23;
Ref.
45,
Photograph
5
GW­
11
F05H0
MF02C7
Temporary
monitor
well
approximately
0.34
mile
northeast
of
the
Gulfco
facility.
Total
Depth
20'

Screened
Interval
10'
­
20'
01/
25/
01
Figure
7;
Ref.
43,
pp.
12­
13,
15­
16,
27
Ref.
44,
pp.
12,
24;
Ref.
45,
Photograph
6
Table
9
presents
the
level
of
contaminants
and
their
sample
quantitation
limits
for
background
ground
water
samples
collected
during
the
January
2001
ESI
sampling
event.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
55
Figure
7
­
Background
Ground
Water
Samples
for
ESI
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
56
Table
9
Background
Sample
Table
for
Source
No.
2
­
Surface
Impoundments
Hazardous
Substance
Evidence
FGK84
(GW­
10)
F05H0
(GW­
11)

Volatile
Organics
Concentrations
in
µg/
L
(SQL)

Vinyl
Chloride
ND
[10]
ND
[10]

1,1­
Dichloroethene
ND
[10]
ND
[10]

Carbon
Disulfide
ND
[10]
ND
[10]

Methylene
Chloride
ND
[10]
ND
[10]

trans­
1,2­
Dichloroethene
ND
[10]
ND
[10]

1,1­
Dichloroethane
ND
[10]
ND
[10]

cis­
1,2­
Dichloroethene
ND
[10]
ND
[10]

Chloroform
ND
[10]
ND
[10]

1,1,1­
Trichloroethane
ND
[10]
ND
[10]

Benzene
ND
[10]
ND
[10]

1,2­
Dichloroethane
ND
[10]
ND
[10]

Trichloroethene
ND
[10]
ND
[10]

1,2­
Dichloropropane
ND
[10]
ND
[10]

4­
Methyl­
2­
pentanone
ND
[10]
ND
[10]

Toluene
ND
[10]
ND
[10]

1,1,2­
Trichloroethane
ND
[10]
ND
[10]
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
57
Table
9
­
Continued
Background
Sample
Table
for
Source
No.
2
­
Surface
Impoundments
Hazardous
Substance
Evidence
FGK84
(GW­
10)
F05H0
(GW­
11)

Volatile
Organics
Concentration
in
µg/
L
(SQL)

Tetrachloroethene
ND
[10]
ND
[10]

Ethylbenzene
ND
[10]
ND
[10]

Xylenes
(total)
ND
[10]
ND
[10]

Isopropylbenzene
ND
[10]
ND
[10]

1,1,2,2­
Tetrachloroethane
ND
[10]
ND
[10]

Reference
Ref.
47,
pp.
1­
11,
13,
78­
80
Ref.
47,
pp.
1­
11,
15,
54­
56
Semivolatile
Organics
Concentrations
in
µg/
L
(SQL)

Phenol
ND
[10]
ND
[10]

2­
Methylphenol
ND
[10]
ND
[10]

2,2'­
oxybis(
1­
Chloropropane)
ND
[10]
ND
[10]

Acetophenone
ND
[10]
ND
[10]

4­
Methylphenol
ND
[10]
ND
[10]

Naphthalene
ND
[10]
ND
[10]

References
Ref.
49,
pp.
1­
6,
9­
10,
66­
68
Ref.
49,
pp.
1­
6,
11­
12,
51­
53
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
58
Table
9
­
Continued
Background
Sample
Table
for
Source
No.
2
­
Surface
Impoundments
Hazardous
Substance
Evidence
FGK84
(GW­
10)
F05H0
(GW­
11)

Pesticides/
PCBs
Concentrations
in
µg/
L
(SQL)

alpha­
BHC
ND
[0.050]
ND
[0.050]

beta­
BHC
ND
[0.050]
ND
[0.050]

delta­
BHC
ND
[0.050]
ND
[0.050]

gamma­
BHC
(Lindane)
ND
[0.050]
ND
[0.050]

Heptachlor
ND
[0.050]
ND
[0.050]

Aldrin
ND
[0.050]
ND
[0.050]

Heptachlor
epoxide
ND
[0.050]
ND
[0.050]

Dieldrin
ND
[0.10]
ND
[0.10]

Endrin
ND
[0.10]
ND
[0.10]

Endosulfan
II
ND
[0.10]
ND
[0.10]

4,4'­
DDT
ND
[0.10]
ND
[0.10]

alpha­
Chlordane
ND
[0.050]
ND
[0.050]

References
Ref.
49,
pp.
1­
6,
13,
93
Ref.
49,
pp.
1­
6,
14,
88
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
59
Table
9
­
Continued
Background
Sample
Table
for
Source
No.
2
­
Surface
Impoundments
Hazardous
Substance
Evidence
MFJP71
(GW­
10)
MF02C7
(GW­
11)

Inorganics
Concentrations
in
µg/
L
(SQL)

Arsenic
9.1
L
[10]
10.2
[10]

Cobalt
ND
[50]
17.4
L
[50]

Copper
26.4
[25]
36.4
[25]

Lead
ND
[3]
24.4
[3]

Manganese
2810
[15]
1360
[15]

Nickel
10.8
LUC
[40]
46.8
[40]

Vanadium
16.1
LJ^
[50]
64.9
[50]

Reference
Ref.
48,
pp.
1­
8,
10,
33
Ref.
48,
pp.
1­
8
12,
23
Notes:
ND
=
Not
detected
at
the
sample
quantitation
limit
SQL
=
Sample
Quantitation
Limit
=
(CRQL/
CRDL)
x
df/%
solids,
where
%solids
=
[100
­
%moisture]
/100
J=
The
value
is
an
estimated
concentration
because
one
or
more
of
the
quality
control
criteria
have
not
been
met.
It
is
included
to
show
that
the
substance
has
been
qualitatively
identified
as
present
in
the
source.
Jv
­
biased
low;
J^
­
biased
high.
L
=
Reported
Concentration
is
below
the
CRQL
UC
=
Reported
concentration
should
be
used
as
a
raised
detection
limit
because
of
apparent
blank
contamination.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
60
SD­
Hazardous
Substances
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

2.2.3
Hazardous
Substances
Available
to
a
Pathway
Because
the
containment
factor
value
for
Source
No.
2,
Surface
Impoundment,
is
greater
than
0,
the
following
hazardous
substances
associated
with
the
Source
No.
2
are
available
to
migrate
via
the
Surface
Water
Migration
pathway.

°
Vinyl
Chloride
°
Phenol
°
Manganese
°
1,1­
Dichloroethene
°
2­
Methylphenol
°
Nickel
°
Carbon
Disulfide
°
2,2'­
oxybis(
1­
Chloropropane)
°
Vanadium
°
Methylene
Chloride
°
Acetophenone
°
trans­
1,2­
Dichloroethene
°
4­
Methylphenol
°
1,1­
Dichloroethane
°
Naphthalene
°
cis­
1,2­
Dichloroethene
°
alpha­
BHC
°
Chloroform
°
beta­
BHC
°
1,1,1­
Trichloroethane
°
delta­
BHC
°
Benzene
°
gamma­
BHC
(Lindane)
°
1,2­
Dichloroethane
°
Heptachlor
°
Trichloroethene
°
Aldrin
°
1,2­
Dichloropropane
°
Heptachlor
epoxide
°
4­
Methyl­
2­
pentanone
°
Dieldrin
°
Toluene
°
Endrin
°
1,1,2­
Trichloroethane
°
Endosulfan
II
°
Tetrachloroethene
°
4,4'DDT
°
Ethylbenzene
°
alpha­
Chlordane
°
Xylenes
(total)
°
Arsenic
°
Isopropylbenzene
°
Cobalt
°
1,1,2,2­
Tetrachloroethane
°
Copper
°
Benzaldehyde
°
Lead
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
61
SD­
Likelihood
of
Release
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

2.3
LIKELIHOOD
OF
RELEASE
Refer
to
Section
4.1.2.1
of
this
Documentation
Record
for
specific
information
related
to
the
Likelihood
of
Release
to
the
Surface
Water
Pathway.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
62
SD­
Waste
Characterization
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

2.4
WASTE
CHARACTERIZATION
2.4.1
Selection
of
Substance
Potentially
Posing
Greatest
Hazard
All
of
the
hazardous
substances
listed
above
are
associated
with
this
source.

Specific
toxicity
factor
values,
combined
with
the
mobility,
persistence,
and/
or
bioaccumulation
(or
ecosystem
bioaccumulation)
potential
factor
values
are
hazardous
substance
specific
and
applicable
to
the
migration
pathway
being
evaluated.
The
selection
of
the
hazardous
substances
with
the
highest
factor
values
(toxicity,
persistence,
and
bioaccumulation)
applicable
to
the
pathway
(or
threat)
being
evaluated
(Ref.
1,
Section
2.4.1.2)
are
presented
under
the
Surface
Water
Migration
Pathway
section
of
this
Documentation
Record.

2.4.2.
Hazardous
Waste
Quantity
2.4.2.1.1.
Hazardous
Constituent
Quantity
(Tier
A)
­
Not
Evaluated
The
information
available
is
not
sufficient
to
evaluate
Tier
A
for
Source
No.
2,
Surface
Impoundments,
as
required
in
Section
2.4.2.1.1
of
the
HRS
Rule.
As
a
result,
the
evaluation
of
Hazardous
Waste
Quantity
proceeds
to
the
evaluation
of
Tier
B,
hazardous
waste
stream
quantity
(Ref.
1,
Section
2.4.2.1.1).

2.4.2.1.2.
Hazardous
Waste
stream
Quantity
(Tier
B)
­
Not
Evaluated
The
information
available
is
not
sufficient
to
evaluate
Tier
B
for
Source
No.
2,
Surface
Impoundments,
as
required
in
Section
2.4.2.1.2
of
the
HRS
Rule.
As
a
result,
the
evaluation
of
Hazardous
Waste
Quantity
proceeds
to
the
evaluation
of
Tier
C,
volume
(Ref.
1,
Section
2.4.2.1.2).

2.4.2.1.3
Volume
(Tier
C)
­
Evaluated
The
equation
for
assigning
a
Hazardous
Waste
Quantity
Value
for
Volume
(Tier
C)
from
Table
2­
5
is
V
/
2.5,
where
V
is
the
volume
of
the
surface
impoundments
(Ref.
1,
Table
2­
5).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
63
SD­
Waste
Characterization
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

The
maximum
inventory
of
waste
stored
in
the
surface
impoundments
was
5.5
million
gallons
(Ref.
7,
p.
7;
Ref.
27,
p.
2).

The
equation
to
convert
gallons
to
cubic
yards
is:
200
gallons
=
1
cubic
yard
5,500,000
gallons
/
200
=
27,500
cubic
yards
27,500
cubic
yards
/
2.5
=
11,000
Because
the
site
contains
hazardous
substances
from
CERCLA­
eligible
petroleum
related
wastestreams,
non­
petroleum
related
wastestreams
and
excluded
petroleum
products
that
are
commingled,
all
of
the
Source
2
volume
hazardous
waste
quantity
is
CERCLA­
eligible
and
will
be
assigned
a
value
accordingly
(Ref.
8,
p.
3;
Ref.
9,
p.
18;
Ref.
11,
p.
8).
The
value
for
the
Source
2
Tier
D
volume
was
calculated
as
11,000
(Ref.
7,
p.
7;
Ref.
27,
p.
2).

Volume
of
source
(yd
3
):
27,500
Volume
Assigned
Value:
11,000
2.4.2.1.4.
Area
(Tier
D)
­
Not
Evaluated
A
Hazardous
Waste
Quantity
Value
was
assigned
for
Source
1,
Surface
Impoundments
using
the
volume
(Tier
C)
for
the
source.
Therefore,
the
area
(Tier
D)
for
this
source
has
not
been
evaluated
(Ref.
3,
Highlight
6­
8).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
64
SD­
Source
Hazardous
Waste
Quantity
Value
Source
No.
2,
Surface
Impoundments
(buried/
backfilled)

2.4.2.1.5.
Source
Hazardous
Waste
Quantity
Value
As
described
in
the
HRS
Rule,
the
highest
value
assigned
to
a
source
from
among
the
four
tiers
of
hazardous
constituent
quantity
(Tier
A),
hazardous
waste
stream
quantity
(Tier
B),
volume
(Tier
C),
or
area
(Tier
D)
shall
be
selected
as
the
source
hazardous
waste
quantity
value.
(Ref.
1,
Sections
2.4.2.1.1
2.4.2.1.4

Tier
Evaluated
Source
1
Values
Tier
A
­
Constituent
Quantity
NE
Tier
B
­
Wastestream
Quantity
NE
Tier
C
­
Volume
11,000
Tier
D
­
Area
NE
NE
=
not
evaluated
According
to
the
HRS
Rule,
the
source
Hazardous
Waste
Quantity
Value
is
the
highest
value
determined
for
the
source
(Ref.
1,
Section
2.4.2.1.5).
The
assigned
Hazardous
Waste
Quantity
Value
for
Source
2,
Surface
Impoundment,
was
determined
for
Tier
C
(Volume)
=
11,000.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
65
Source
No.
2,
Surface
Impoundments,
Hazardous
Waste
Quantity
Value:
11,000
SD
­
Summary
Site
Summary
of
Source
Descriptions
Table
10
Source
Number
Source
Hazardous
Waste
Quantity
Value
Containment
Ground
Water
Surface
Water
Gas
Air
Particulate
1
>
0,
but
unknown
Not
Evaluated
10
Not
Evaluated
Not
Evaluated
2
11,000
Not
Evaluated
10
Not
Evaluated
Not
Evaluated
The
sum
of
the
Hazardous
Waste
Quantity
Values
for
Source
No.
1,
Contaminated
Soil,
and
Source
2,
Surface
Impoundment
is
>
11,000.
The
sum
of
the
Source
Hazardous
Waste
Quantity
Values
for
the
Gulfco
Marine
Maintenance
site,
rounded
to
the
nearest
integer,
is
11,000.

According
to
HRS
Table
2­
6,
the
Hazardous
Waste
Quantity
Factor
Value
assigned
to
a
Source
Hazardous
Waste
Quantity
Value
of
11,000
is
10,000
(Ref.
1,
Section
2.4.2.2,
Table
2­
6).

Source
No.
1,
Contaminated
Soil,
Hazardous
Waste
Quantity
Value:
>0
Source
No.
2,
Surface
Impoundment,
Hazardous
Waste
Quantity
Value:
11,000
Hazardous
Waste
Quantity
Factor
Value:
10,000
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
66
3.0
GROUND
WATER
MIGRATION
PATHWAY
3.0.1
GENERAL
CONSIDERATIONS
Although
an
observed
release
to
the
ground
water
has
been
documented
to
the
shallow
aquifer,
the
Ground
Water
Migration
Pathway
was
not
scored
since
inclusion
of
this
pathway
would
not
significantly
affect
the
site
score
(Ref.
15,
p.
55).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
67
SWOF­
Surface
Water
Overland
Flow/
Flood
Migration
Pathway
4.0
SURFACE
WATER
MIGRATION
PATHWAY
4.1
OVERLAND/
FLOOD
MIGRATION
COMPONENT
4.1.1.1
DEFINITION
OF
HAZARDOUS
SUBSTANCE
MIGRATION
PATH
FOR
OVERLAND/
FLOOD
COMPONENT
General
Considerations
The
Gulfco
facility
is
located
the
north
bank
of
the
Intracoastal
Waterway
between
Oyster
Creek
on
the
east
and
the
Old
Brazos
River
Channel
and
the
Dow
Barge
Canal
on
the
west
(Figure
1).
The
southern
part
of
the
Gulfco
property,
south
of
Marlin
Avenue,
drains
toward
the
south
where
it
enters
into
the
Intracoastal
Waterway
(See
for
example,
Ref.
18,
Photographs
1
&
2).
Areas
north
of
Marlin
Avenue
are
relatively
level.
Drainage
from
these
areas
is
to
the
northeast
into
an
adjacent
wetlands,
then
to
Oyster
Creek
(Ref.
23;
Ref.
7,
p.
8).

The
Intracoastal
Waterway
is
a
tidally
influenced
man­
made
canal
that
parallels
the
entire
Texas
Gulf
Coast.
East
of
the
Gulfco
facility
and
the
confluence
with
Oyster
Creek,
the
Intracoastal
Waterway
actually
consists
of
two
segments.
The
first
segment
was
authorized
by
Congress
in
June
1927.
It
was
a
channel
9
feet
deep
and
100
feet
wide
traversing
the
natural
bays
of
Bastrop
Bay,
Christmas
Bay,
and
Drum
Bay.
The
segment
from
Bastrop
Bay
to
Freeport
was
constructed
between
July
1939
and
March
1940.
The
second
segment
is
a
larger
(12
feet
deep
and
125
feet
wide),
inland
route
authorized
by
Congress
in
March
1939.
This
segment,
which
cuts
across
the
land
for
most
of
its
length,
was
completed
in
August
1944
Ref.
50,
p.
14).
As
this
water
body
is
tidally
influenced,
the
surface
water
pathway
target
distance
limit
(TDL)
extends
in
a
15­
mile
arc
in
all
directions
within
the
contiguous
surface
water
bodies.
The
surface
water
pathway
TDL
extends
from
Cedar
Lakes
on
the
southwest,
through
Drum
Bay,
Christmas
Bay,
and
Bastrop
Bay
(older
Intracoastal
Waterway
segment),
Oyster
Lake
(more
recent
Intracoastal
Waterway
segment),
and
West
Bay
on
the
northeast
(Figure
8).
Surface
water
bodies
emptying
into
the
Intracoastal
Waterway
along
this
TDL
include:

Oyster
Creek
Dow
Barge
Canal
Old
Brazos
River
Channel
Brazos
River
Jones
Creek
San
Bernard
River
Cedar
Lakes
Bastrop
Bayou
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
68
SWOF­
Surface
Water
Overland
Flow/
Flood
Migration
Pathway
The
northern
part
of
the
Gulfco
property,
north
of
Marlin
Avenue,
drains
to
the
northeast
into
adjacent
wetlands
(Ref.
7,
p.
8;
Ref.
51).
The
National
Wetlands
Inventory
map
for
the
Freeport
Quadrangle
shows
these
wetlands
to
be
estuarine,
intertidal,
emergent,
persistent,
irregularly
flooded
(Ref.
51).
These
wetlands
extend
approximately
0.48
miles
to
Oyster
Creek.

The
Gulfco
property
is
located
within
an
area
of
100­
year
coastal
flood
with
velocity
(wave
action);
base
flood
elevation
and
flood
hazard
of
13
feet
mean
sea
level
(Ref.
46,
pp.
1
&
2).

The
average
annual
rainfall
for
Brazoria
County
is
52.12
inches
(Ref.
52,
p.
15)
and
the
2­
year
24­
hour
rainfall
for
the
area
of
the
Gulfco
property
is
approximately
5.25
inches
(Ref.
53,
p.
10).

The
Surface
Water
Migration
Pathway
15­
mile
TDL
for
the
Intracoastal
Waterway
and
the
contiguous
surface
water
bodies
is
depicted
in
Figure
8.

Definition
of
Overland
Segment
and
Probable
Point
of
Entry
(PPE)

Two
sources
have
been
identified
at
the
former
Gulfco
facility.
Source
1
consists
of
contaminated
soil
defined
by
soil
samples
collected
both
north
and
south
of
Marlin
Avenue.
Source
No.
2
consists
of
three
surface
impoundments
located
on
Lot
56,
north
of
Marlin
Avenue.

The
Freeport
Quadrangle
7.5
minute
topographic
map
shows
the
topography
of
the
property
to
be
relatively
flat,
with
little
indication
of
property
drainage
(Ref.
4).
Actual
conditions
on
the
southern
part
of
the
facility
show
several
elevated
areas
including
the
sloping
concrete
apron
associated
with
the
dry
dock
facilities
and
barge
slip
1,
the
area
around
the
metal
maintenance
building,
and
the
metal
quonset
hut.
Drainage
for
the
southern
part
of
the
property
is
toward
the
south
to
the
Intracoastal
Waterway
(Ref.
18,
Photographs
1
&
2).
The
Surface
Water
Migration
Pathway
overland
segment
for
the
southern
part
of
the
property
begins
at
Source
1,
Contaminated
Soil,
extending
toward
the
south
to
the
nearest
surface
water
body
of
the
Intracoastal
Waterway
bordering
the
Gulfco
property
on
the
south
(Figure
9).
There
are
no
containment
structures
or
levees
present
to
contain
contaminant
migration
from
Source
1,
Contaminated
Soil,
to
the
Intracoastal
Waterway
(Ref.
11,
p.
8).
The
shortest
distance
from
Source
1
to
PPE1
(at
Barge
Slip
2)
is
less
than
10
feet.
The
Intracoastal
Waterway
is
a
tidally
influenced,
man­
made
canal
that
parallels
the
entire
Texas
Gulf
Coast
and
is
contiguous
with
numerous
rivers
and
bays.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
69
SWOF­
Surface
Water
Overland
Flow/
Flood
Migration
Pathway
Areas
of
the
Gulfco
property
north
of
Marlin
Avenue
drain
to
the
northeast
into
HRS
qualifying
intertidal,
emergent,
estuarine,
persistent,
irregularly
flooded
wetlands.
These
wetlands
are
directly
adjacent
to
the
upland
area
of
the
surface
impoundments
on
the
north,
east,
and
west
(Ref.
7,
p.
8;
Ref.
51,
p.
1).
The
overland
segment
for
Source
No.
2,
Surface
Impoundments,
begins
in
the
upland
area
of
the
surface
impoundments
and
extends
to
the
adjacent
wetlands.
The
overland
segment
distance
from
Source
No.
2,
Surface
Impoundment,
to
PPE2
(HRS
qualifying
wetlands
contiguous
to
Oyster
Creek)
is
less
than
10
feet.
These
wetlands
extend
approximately
0.48
miles
to
Oyster
Creek.
The
Digital
Ortho
Quarter
Quad,
Freeport
Quadrangle,
Northeast
Quarter
clearly
shows
the
off­
site
drainage
pathway
from
Source
No.
2,
Surface
Impoundments,
toward
the
northeast
to
Oyster
Creek
(See
Figure
10)
(Ref.
23).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
70
Figure
8
­
Surface
Water
Pathway
15
mile
segment
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
71
Figure
9
­
Off­
site
Drainage
for
southern
part
of
the
site.
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
72
Figure
10
­
Off­
site
drainage
for
the
northern
part
of
the
site.
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
73
SWOF­
Surface
Water
Overland
Flow/
Flood
Migration
Pathway
Probable
Points
of
Entry
(PPEs)

The
Probable
Points
of
Entry
(PPE)
is
defined
as
the
point
at
which
the
overland
segment
of
a
hazardous
substance
migration
path
intersects
with
surface
water
(Ref.
3,
p.
204).
Two
PPEs
have
been
identified
for
the
former
Gulfco
facility,
one
PPE
applicable
for
the
southern
part
of
the
property
for
Source
1,
Contaminated
Soil,
and
the
second
PPE
applicable
to
the
northern
part
of
the
property
(north
of
Marlin
Avenue)
for
Source
2,
Surface
Impoundments.

PPE1
for
the
former
Gulfco
facility
is
considered
the
entire
southern
boundary
of
the
property
along
the
Intracoastal
Waterway,
a
distance
of
approximately
2170
feet
(Figure
9).
Overland
flow
from
Source
1,
Contaminated
Soil,
is
toward
the
south
to
the
Intracoastal
Waterway.
There
are
no
containment
structures
or
levees
to
prevent
contaminant
migration
to
this
surface
water
body
bordering
the
southern
part
of
the
property
(Ref.
11,
p.
8).
Four
sediment
samples
were
collected
in
the
Intracoastal
Waterway
at
PPE1
during
the
January
2000
sampling
event
(Figure
11).
Sediment
sample
FGK15/
MFJQ31
(SE­
08)
was
collected
in
Barge
Slip
#1,
sediment
sample
FGK16/
MFJQ32
(SE­
09)
was
collected
in
Barge
Slip
#2,
sediment
sample
FGK17/
MFJQ33
(SE­
10)
was
collected
in
the
Intracoastal
Waterway
east
of
Barge
Slip
#2,
and
sediment
sample
FGK18/
MFJQ34
(SE­
11)
was
collected
in
the
Intracoastal
Waterway
east
of
Barge
Slip
#2
and
adjacent
to
the
Former
Wash
Water
Storage
Area
(Figure
11;
Ref.
16,
pp.
19­
22;
Ref.
18,
Photographs
29
­
31).
Analytical
evidence
for
two
of
these
samples,
sediment
sample
FGK15/
MFJQ31
(SE­
08)
and
sediment
sample
FGK17/
MFJQ33
(SE­
10),
document
an
observed
release
to
the
surface
water
body
of
the
Intracoastal
Waterway
at
PPE1.
From
PPE1,
the
15­
mile
in­
water
segment
extends
in
a
15
mile
arc.
The
Intracoastal
Waterway
is
evaluated
as
Coastal
Tidal
Waters
as
defined
by
Reference
1,
Section
4.0.2
(Ref.
1,
Section
4.0.2).

PPE2
for
the
former
Gulfco
facility
is
defined
where
the
overland
segment
from
Source
2,
Surface
Impoundments,
meets
the
intertidal,
emergent,
estuarine,
persistent,
irregularly
flooded
wetlands
adjacent
to
the
surface
impoundments
on
the
north,
east,
and
west
(See
Figure
10).
As
there
are
no
containment
structures
or
levees
around
the
upland
area
of
the
surface
impoundments,
direct
runoff
from
the
source
area
entered
the
adjacent
HRS
qualifying
wetlands.
The
overland
segment
distance
from
Source
2,
Surface
Impoundments,
to
PPE2
is
considered
to
be
less
than
10
feet.
Surface
water
flow
in
the
wetlands
is
toward
the
northeast
(Ref.
7,
p.
8;
Ref.
11,
p.
10;
Ref.
23)
for
approximately
0.48
miles
to
Oyster
Creek(
Ref.
23).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
74
SWOF­
Surface
Water
Overland
Flow/
Flood
Migration
Pathway
The
former
Gulfco
facility
has
two
overland
segments
and
two
PPEs
to
a
single
surface
water
body
that
intersects
within
the
Target
Distance
Limit
(TDL)
for
a
single
watershed
(Ref.
3,
pp.
220
and
222).

Definition
of
In­
Water
Segment
The
TDL
for
the
former
Gulfco
facility
is
comprised
of
four
(4)
Hazard
Ranking
System
(HRS)
in­
water
segments
from
the
PPEs
downstream
to
the
15­
mile
extent
of
the
TDL.
These
segments
include
the
Intracoastal
Waterway
and
contiguous
segments
along
the
15­
mile
in­
water
TDL.
The
components
of
the
HRS
in­
water
segment
are
discussed
below,
and
depicted
in
Figure
8.

Zone
of
Level
I
Concentrations
Since
actual
contamination
is
established
solely
by
sediment
samples,
Level
I
concentrations
cannot
be
established
for
this
threat.

Zone
of
Level
II
Concentrations
The
zone
of
Level
II
concentrations
is
defined
by
the
most
distant
sampling
point
at
which
an
observed
release
was
documented
in
the
surface
water
body
being
evaluated
during
the
January
2000
SSI
sampling
event
at
the
former
Gulfco
facility.
Two
sediment
samples,
FGK15/
MFJQ31
(SE­
08)
and
MFJQ33
SE10
were
collected
in
the
Intracoastal
Waterway
at
PPE1
(Figure
11;
Ref.
16,
pp.
19,
21).
Each
sample
documented
Level
II
contaminant
concentrations
by
chemical
analysis
attributable
to
the
former
Gulfco
facility
at
the
PPE.
The
extent
of
this
segment
is
identified
as
being
the
distance
between
the
samples
documenting
Level
II
contaminant
concentrations
(approximately
1100
feet)
within
the
Intracoastal
Waterway
(Figure
11).

Zone
of
Potential
Contamination
Intracoastal
Waterway,
Drum
Bay,
Christmas
Bay,
Bastrop
Bay,
West
Bay,
Intracoastal
Waterway,
Brazos
River
Tidal
,
Old
Brazos
River
Channel
Tidal,
Dow
Barge
Canal,
San
Bernard
River
Tidal,
Oyster
Creek
Tidal,
Bastrop
Bayou
Tidal,
and
the
Gulf
of
Mexico.

The
zone
of
potential
contamination
includes
the
contiguous
coastal
tidal
waters
of
the
Intracoastal
Waterway,
Drum
Bay,
Christmas
Bay,
Bastrop
Bay,
and
West
Bay
west
of
the
most
distant
Level
ll
sample
points
at
PPE1.
Drum
Bay
is
located
approximately
2.8
miles
east
of
the
former
Gulfco
facility,
entered
through
the
old
Intracoastal
Waterway
channel.
Drum
Bay
is
then
interconnected
with
Christmas
Bay,
which
is
then
interconnected
with
Bastrop
Bay
and
West
Bay.
South
and
west
of
the
former
Gulfco
facility,
continuous
tidal
segments
include:
the
Intracoastal
Waterway,
the
Brazos
River,
the
Old
Brazos
River
Channel,
the
Dow
Barge
Canal,
the
San
Berard
River,
Oyster
Creek,
and
Bastrop
Bayou.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
75
SWOF­
Surface
Water
Overland
Flow/
Flood
Migration
Pathway
West
of
the
Gulfco
facility,
surface
water
enters
the
Gulf
of
Mexico
from
the
Old
Brazos
River
Channel,
from
the
Brazos
River,
and
possibly
from
the
San
Bernard
River.
The
greatest
length
of
the
in­
water
segment
within
the
Gulf
of
Mexico
is
approximately
12.3
miles.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
76
Figure
11
­
PPE
Sediment
Sample
Locations
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
77
SWOF
­
Observed
Release
4.1.2
DRINKING
WATER
THREAT
The
Drinking
Water
Threat
was
not
evaluated
due
to
lack
of
targets
for
this
component
(Ref.
54;
Ref.
55).
The
documentation
for
an
observed
release
follows,
then
scoring
will
proceed
to
the
Human
Food
Chain
Threat
and
Environmental
Threat.

4.1.2.1
LIKELIHOOD
OF
RELEASE
4.1.2.1.1
Observed
Release
An
observed
release
to
a
qualifying
surface
water
body
can
be
documented
in
the
HRS
system
by
two
methods:
a)
direct
observation
and
b)
chemical
analysis.
We
will
document
the
observed
release
by
chemical
analysis
in
this
Documentation
Record.

Chemical
Analysis
An
observed
release
has
been
documented
to
the
Surface
Water
Pathway
for
the
former
Gulfco
facility
by
chemical
analysis.
Establishing
an
observed
release
by
chemical
analysis
requires
attributing
the
hazardous
substance(
s)
to
the
facility,
and
also
requires
determining
a
background
level
of
the
contaminant,
demonstrating
that
the
concentration
of
the
hazardous
substance(
s)
in
a
release
sample
is
significantly
increased
above
the
background
level,
and
attributing
some
portion
of
the
significant
increase
to
the
facility.
In
order
to
document
a
significant
increase
above
a
background
level,
it
is
necessary
to
establish
the
presence
of
a
hazardous
substance(
s)
at
a
concentration
at
or
above
three
times
a
designated
background
level
when
the
hazardous
substance(
s)
has
been
detected
in
the
background
sample
or
at
a
concentration
above
the
SQL
when
a
hazardous
substance(
s)
has
been
reported
as
not
detected
in
background
samples
(Ref.
1,
Table
2­
3).

Background
Concentration
Four
(4)
background
sediment
samples,
sample
SE­
01
(FGK08/
MFJQ24)
and
its
duplicate
sample
SE­
02
(FGK09/
MFJQ25),
sample
SE­
05
(FGK12/
MFJQ28),
and
sample
SE­
15
(FGK22/
MFJQ38),
were
collected
in
the
Intracoastal
Waterway
east
and
west
of
PPE1
(the
southern
boundary
of
the
Gulfco
property)
during
the
January
2000
SSI
sampling
event
(Figure
12).
Samples
SE­
01,
its
duplicate
sample
SE­
02,
and
sample
SE­
15
were
collected
east
of
PPE1
and
the
confluence
of
Oyster
Creek
(Ref.
18,
Photographs
24
and
32).
Sample
SE­
05
was
collected
in
the
Intracoastal
Waterway
west
of
PPE1
and
the
confluence
with
the
Old
Brazos
River
Channel
(Ref.
18,
Photograph
26).
Table
11
identifies
the
locations
of
the
background
sediment
samples
collected
during
the
January
2000
SSI
sampling
event
at
the
facility.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
78
SWOF
­
Observed
Release
Background
sediment
sample
SE­
01
and
duplicate
sample
SE­
02
were
collected
using
an
Ekman
Dredge.
Background
sediment
samples
SE­
05
and
SE­
15
were
collected
using
a
30"
long
sediment
core
sampling
tool
(Ref.
16,
pp.
12­
13,
16,
26).
A
summary
of
the
highest
constituent
concentrations
detected
in
the
background
sediment
samples
is
presented
in
Table
12.
These
hazardous
substances
are
those
that
have
also
been
detected
in
Source
No.
1,
Contaminated
Soil,
above
the
source
background
level
or
background
sample
quantitation
limit.

Table
11
Background
Sediment
Sample
Locations
in
the
Intracoastal
Waterway
Station/
CLP
ID.
No.
Sample
Location
Sample
Type
Date
Collected
Location
Reference
(see
Figure
12)

SE­
01
FGK08/
MFJQ24
Intracoastal
Waterway
east
of
PPE
1
and
the
confluence
of
Oyster
Creek
Composite
Ekman
Dredge
01/
25/
00
Figure
12
Ref.
16,
p.
12
Ref.
18,
Photo
24
SE­
02
FGK09/
MFJQ25
Duplicate
sample
of
SE­
01
Composite
Ekman
Dredge
01/
25/
00
Figure
12
Ref.
16,
p.
13
Ref.
18,
Photo
24
SE­
05
FGK12/
MFJQ28
Intracoastal
Waterway
west
of
PPE
1
and
the
confluence
of
the
Old
Brazos
River
Channel
Composite
Sediment
Core
01/
25/
00
Figure
12
Ref.
16,
p.
16
Ref.
18,
Photo
26
SE­
15
FGK22/
MFJQ38
Intracoastal
Waterway
east
of
PPE
1
and
the
confluence
of
Oyster
Creek
Composite
Sediment
Core
01/
25/
00
Figure
12
Ref.
16,
p.
26
Ref.
18,
Photo
32
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
79
Figure
12
­
Off­
site
Sediment
Sample
Location
Map
A
copy
of
this
figure
is
available
at
the
EPA
Docket
Center
U.
S.
EPA
Docket
Center
EPA
West
Room
B102
1301
Constitution
Avenue,
NW
Washington
DC,
20460
Telephone:
703­
603­
9232
Email:
superfund.
docket@
epa.
gov
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
80
SWOF­
Observed
Release
TABLE
12
SUMMARY
OF
HIGHEST
CONSTITUENTS
DETECTED
IN
BACKGROUND
SEDIMENT
SAMPLES
COLLECTED
FROM
THE
INTRACOASTAL
WATERWAY
Constituent
Station/
CLP
No.
Highest
Concentration
(SQL)
[µg/
Kg]
3
x
Highest
Background
Concentration
[µg/
Kg]
Reference
Semivolatile
Organics
Phenanthrene
SE­
05/
FGK12
ND
(490)
N/
A
Ref.
21,
pp.
1­
8,
14,
114
Fluoranthene
SE­
05/
FGK12
ND
(490)
N/
A
Ref.
21,
pp.
1­
8,
15,
114
Pyrene
SE­
05/
FGK12
ND
(490)
N/
A
Ref.
21,
pp.
1­
8,
15,
114
bis(
2­
Ethylhexyl)
phthalate
SE­
02/
FGK09
150
J
(460)
450
Ref.
21,
pp.
1­
8,
15,
105
Pesticide/
PCBs
Organics
Heptachlor
epoxide
SE­
05/
FGK12
ND
(2.6)
N/
A
Ref.
21,
pp.
1­
8,
20,
165
gamma­
Chlordane
SE­
05/
FGK12
ND
(2.6)
N/
A
Ref.
21,
pp.
1­
8,
20,
165
Aroclor
1254
SE­
05/
FGK12
ND
(50)
N/
A
Ref.
21,
pp.
1­
8,
20,
165
Inorganics
(mg/
Kg)

Lead
SE­
15/
MFJQ38
12.6
(0.84)
37.8
Ref.
20,
pp.
1­
6,
10,
28
Zinc
SE­
15/
MFJQ38
54.4
(5.6)
163.2
Ref.
20,
pp.
1­
6,
10,
28
(
)
=
SQL
values
for
each
constituent.
ND
=
Not
detected.
Concentrations
for
these
constituents
were
not
detected
at
the
reported
sample
quantitation
limit
(SQL).
N/
A
=
Not
applicable
J
=
Sample
results
are
estimated.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
81
SWOF
­
Observed
Release
Contaminated
Samples
The
sediment
samples
shown
in
Table
13
qualified
as
"observed
releases"
based
on
the
criteria
in
the
HRS
Rule
(Ref.
1,
Table
2­
3).
The
constituents
found
in
the
sediment
samples
which
qualify
as
observed
releases
are
shown
in
Table
14
with
their
concentrations
and
SQLs.
These
hazardous
substances
are
attributable
to
on­
site
sources
and
were
found
in
the
sediment
samples
collected
from
the
Intracoastal
Waterway
during
the
January
2000
SSI
sampling
event.
All
contaminated
samples
were
collected
using
a
30"
long
sediment
core
sampling
tool.
See
Figure
11
for
the
locations
of
the
sediment
samples
collected
at
the
PPE1.

Table
13
Contaminated
Sediment
Sample
Collected
From
the
Intracoastal
Waterway
Station/
CLP
ID
Sample
Location
Sample
Type
Date
Collected
Location
Reference
SE­
08
FGK15/
MFJQ31
Barge
Slip
1
Grab
sample
Sediment
Core
01/
25/
00
Figure
11;
Ref.
16,
p.
19;
Ref.
18,
Photograph
29
SE­
09
FGK16
Barge
Slip
2
Grab
Sample
Sediment
Core
01/
25/
00
Figure
11;
Ref.
16,
p.
20;
Ref.
18,
Photograph
30
SE­
10
MFJQ33
East
of
Barge
Slip
2
Grab
sample
Sediment
Core
01/
25/
00
Figure
11;
Ref.
16,
p.
21
SE­
11
FGK18
East
of
Barge
Slip
2
Grab
Sample
Sediment
Core
01/
25/
00
Figure
11;
Ref.
16,
p.
22;
Ref.
18,
Photograph
31
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
82
Table
14
Surface
Water
Pathway
­
Contaminated
Sediment
Samples
Station
No.
CLP
Nos.
Hazardous
Substance
Concentration
(µg/
Kg)
Sample
Quantitation
Limit
(µg/
Kg)
Reference
SE­
08
FGK15/
MFJQ31
Phenanthrene
1200
940
Ref.
21,
pp.
1­
8,
16,
123
Fluoranthene
2000
940
Ref.
21,
pp.
1­
8,
17,
123
Pyrene
2000
940
Ref.
21,
pp.
1­
8,
17,
123
bis(
2­
Ethylhexyl)
phthalate
1200
940
Ref.
21,
pp.
1­
8,
17,
123
Heptachlor
epoxide
ND
2.4
Ref.
21,
pp.
1­
8,
21,
168
gamma­
Chlordane
5.5
2.4
Ref.
21,
pp.
1­
8,
21,
168
Aroclor
1254
27
J
47
Ref.
21,
pp.
1­
8,
21,
168
Lead
46.8
(mg/
Kg)
0.8
(mg/
Kg)
Ref.
20,
pp.
1­
6,
9,
21
Zinc
314
(mg/
Kg)
5.3
(mg/
Kg)
Ref.
20,
pp.
1­
6,
9,
21
SE­
09
FGK16/
MFJQ32
Phenanthrene
350
J
2300
Ref.
21,
pp.
1­
8,
16,
126
Fluoranthene
600
J
2300
Ref.
21,
pp.
1­
8,
17,
126
Pyrene
640
J
2300
Ref.
21,
pp.
1­
8,
17,
126
bis(
2­
Ethylhexyl)
phthalate
240
J
2300
Ref.
21,
pp.
1­
8,
17,
126
Heptachlor
epoxide
3.8
2.4
Ref.
21,
pp.
1­
8,
21,
169
gamma­
Chlordane
ND
2.4
Ref.
21,
pp.
1­
8,
21,
169
Aroclor
1254
23
J
46
Ref.
21,
pp.
1­
8,
21,
169
Lead
27.9
(mg/
Kg)
0.87
(mg/
Kg)
Ref.
20,
pp.
1­
6,
9,
22
Zinc
130
(mg/
Kg)
5.8
(mg/
Kg)
Ref.
20,
pp.
1­
6,
9,
22
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
83
Table
14
­
Continued
Surface
Water
Pathway
­
Contaminated
Sediment
Samples
Station
No.
CLP
Nos.
Hazardous
Substance
Concentration
(µg/
Kg)
Sample
Quantitation
Limit
(µg/
Kg)
Reference
SE­
10
FGK17/
MFJQ33
Phenanthrene
ND
460
Ref.
21,
pp.
1­
8,
16,
129
Fluoranthene
ND
460
Ref.
21,
pp.
1­
8,
17,
129
Pyrene
ND
460
Ref.
21,
pp.
1­
8,
17,
129
bis(
2­
Ethylhexyl)
phthalate
110
J
460
Ref.
21,
pp.
1­
8,
17,
129
Heptachlor
epoxide
ND
2.4
Ref.
21,
pp.
1­
8,
21,
170
gamma­
Chlordane
ND
2.4
Ref.
21,
pp.
1­
8,
21,
170
Aroclor
1254
ND
46
Ref.
21,
pp.
1­
8,
21,
170
Lead
21.8
(mg/
Kg)
0.84
(mg/
Kg)
Ref.
20,
pp.
1­
6,
9,
23
Zinc
220
(mg/
Kg)
5.6
(mg/
Kg)
Ref.
20,
pp.
1­
6,
9,
23
SE­
11
FGK18/
MFJQ34
Phenanthrene
ND
430
Ref.
19,
pp.
1­
7,
11,
57
Fluoranthene
ND
430
Ref.
19,
pp.
1­
7,
12,
57
Pyrene
ND
430
Ref.
19,
pp.
1­
7,
12,
57
bis(
2­
Ethylhexyl)
phthalate
550
J
430
Ref.
19,
pp.
1­
7,
12,
57
Heptachlor
epoxide
ND
2.2
Ref.
19,
pp.
1­
7,
15,
89
gamma­
Chlordane
ND
2.2
Ref.
19,
pp.
1­
7,
15,
89
Aroclor
1254
ND
44
Ref.
19,
pp.
1­
7,
15,
89
Lead
32.8
(mg/
Kg)
0.78
(mg/
Kg)
Ref.
20,
pp.
1­
6,
9,
24
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
84
Zinc
37.8
(mg/
Kg)
5.2
(mg/
Kg)
Ref.
20,
pp.
1­
6,
9,
24
Notes:
Shaded/
Bold
=
Meets
the
criteria
for
establishing
an
observed
release
ND
=
Not
detected.
Concentrations
for
these
constituents
were
not
detected
at
the
reported
SQL
J
=
Sample
results
are
estimated
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
85
SWOF­
Attribution
Table
15
Surface
Water
Pathway
Data
Usability
for
Release
Sediment
Samples
Sample
Location/
CLP
ID
Hazardous
Substance
Concentration
[SQL]
µg/
Kg
Bias
Bias
Correction
Calculation
Release
Concentration
Corrected
for
Bias
µg/
Kg
Usable
as
a
Release
Value
SE­
11
FGK18
bis(
2­
Ethylhexyl)
phthalate
550
J
[430]
unknown
÷
10
(Ref.
56,
pp.
4­
8,
14)
55
NO
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
86
SWOF
­
Observed
Release/
Attribution
Attribution:

Source
1
consists
of
contaminated
soil
documented
at
the
former
Gulfco
facility
through
chemical
analysis
of
soil
samples
collected
during
the
January
2000
SSI
sampling
event
(see
Table
3
for
contaminants
documented
in
Source
1).
Source
2
consists
of
three,
buried/
backfilled
surface
impoundments
which
were
operated
by
Gulfco
Marine
Maintenance,
Inc.,
and
Fish
Engineering
and
Construction,
Inc.,
from
1971
through
1981.
Hazardous
substance
associated
with
the
surface
impoundments
were
documented
through
chemical
analysis
of
ground
water
samples
collected
around
the
perimeter
of
the
surface
impoundments
during
the
January
2001
ESI
sampling
event
(See
Table
7
for
contaminants
documented
in
Source
No.
2).

Primary
operations
conducted
at
the
facility
reportedly
involved
the
cleaning,
servicing,
and
the
repair
of
various
chemical
barges
brought
to
the
facility
on
the
Intracoastal
Waterway
(Ref.
7,
p.
2;
Ref.
8,
p.
12).
Chemical
barges
were
drained
and
pumped
to
remove
product
heels,
which
were
transferred
and
stored
in
aboveground
tanks
and
sold
as
product.
Each
barge
was
then
washed
with
water
or
a
detergent
solution
(Ref.
9,
p.
13;
Ref.
8,
p.
3).
Generated
wash
waters
were
transferred
to
and
stored,
depending
upon
the
time
period
of
operation,
in
either
the
three
on­
site
surface
impoundments
(Ref.
7,
p.
7),
a
floating
barge
(Ref.
9,
p.
13;
Ref.
8,
p.
7),
or
on­
site
storage
tanks
(Ref.
11,
p.
6).
The
barges
were
then
allowed
to
air
dry
and
certified
as
safe
prior
to
repair
work
such
as
welding,
sandblasting,
and
painting
(Ref.
9,
p.
13).
Repairs
of
the
barges
apparently
occurred
both
at
the
plant
docks
(Ref.
8,
p.
10)
and
the
dry
dock
area
associated
with
barge
slip
1
(Ref.
11,
p.
8).
Airborne
particulates
were
generated
during
these
repair
activities
(Ref.
6,
p.
39),
and
the
dust
emanating
from
such
repair
operations
at
the
facility
were
documented
settling
on
neighboring
properties
and
on
the
Intracoastal
Waterway
(Ref.
6,
p.
8;
Ref.
11,
p.
8).

The
site
contains
hazardous
substances
from
CERCLA­
eligible
petroleum
related
wastestreams,
nonpetroleum
related
wastestreams
and
excluded
petroleum
products
that
were
commingled,
and
are
therefore
considered
CERCLA­
eligible
hazardous
substances
(Ref.
8,
p.
3;
Ref.
9,
p.
18;
Ref.
11,
p.
8).
Potential
contaminants
associated
with
operational
activities
at
the
former
Gulfco
Marine
Maintenance
facility
include
fuel
oil,
oil
wastes,
gas
condensate,
alcohols
(n­
butyl
alcohol,
methanol,
isobutyl
alcohol,
etc.),
ketones
(methyl
ethyl
ketone,
acetone,
etc.),
fertilizers,
phenols,
benzene,
cyclohexane,
urethane,
toluene,
xylene,
chloroethene,
naphthalene,
chloroform,
creosote,
tetrachloroethene,
1,1­
dichloroethylene,
1,1,1­
trichloroethane,
dichloro
methane,
cumene,
1,1,2­
trichloroethane,
trichloroethane,
acrilonitrile,
ethyl
ether,
tetrachloromethane,
formaldehyde,
hydrochloric
acid,
calcium
chloride
and
others
(Ref.
8,
p.
5).
A
list
of
cargoes
brought
by
barge
to
the
facility
for
the
period
June
1980
through
August
1981
is
shown
in
Table
1.
This
list
documents
only
a
short
duration
of
time
for
the
waste
management
activities
which
occurred
over
the
operational
lifetime
for
this
site.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
87
SWOF
­
Observed
Release/
Attribution
The
ground
surface
at
the
facility
is
generally
level
(Ref.
4).
Conditions
on
the
southern
part
of
the
facility
(south
of
Marlin
Avenue)
exhibit
several
elevated
areas
including
the
sloping
concrete
apron
associated
with
the
dry
dock
facilities
and
barge
slip
1,
the
area
around
the
metal
maintenance
building,
and
the
metal
quonset
hut.
Drainage
for
the
southern
part
of
the
property
is
generally
toward
the
south
to
the
Intracoastal
Waterway
(Figure
9)
(Ref.
18,
Photographs
1
&
2).

Areas
north
of
Marlin
Avenue
are
also
relatively
flat.
Drainage
from
these
areas
is
into
HRS
qualifying
wetlands,
then
northeast
to
Oyster
Creek
(Figure
10)
(Ref.
23;
Ref.
7,
p.
8;
Ref.
11,
p.
10).

The
prevailing
wind
in
Brazoria
County
is
from
the
south­
southeast,
with
an
average
highest
windspeed
of
10
miles
per
hour
in
March
(Ref.
52,
p.
10).
Areas
south
and
southeast
of
the
former
Gulfco
facility
include
the
Intracoastal
Waterway,
wetland
areas,
and
residential
properties
in
the
Village
of
Surfside
Beach
(See
background
in
Ref.
18,
Photograph
27).

The
nearest
industrial
facility
identified
during
field
activities
is
the
Offshore
Oil
Services,
Inc.,
(See
background
in
Ref.
18,
Photograph
23)
facility
located
adjacent
to
the
former
Gulfco
Marine
Maintenance,
Inc.,
facility
on
the
east.
This
facility
is
a
docking
and
staging
area
for
supplying
fuel,
drilling
mud
and
chemical
additives,
and
cement
to
offshore
drilling
rigs.
Specific
materials
transported
from
the
facility
include
diesel
fuel,
drilling
mud
(barite),
lube
oil,
and
on
occasion,
methanol.
Diesel
fuel
is
stored
in
a
large
aboveground
storage
tank.
Chemicals
supplied
to
the
offshore
rigs
are
packaged
in
100
pound
sacks
which
are
placed
on
pallets
and
wrapped
in
plastic.
Methanol
is
pumped
from
tanker
trucks
directly
onto
the
supply
boats.
No
open
chemical
containers
are
used.
Waste
materials
brought
back
from
the
rigs
generally
consist
of
cutting
boxes;
metal
boxes
containing
well
cuttings
and
drilling
mud.
No
waste
chemicals
such
as
found
on
chemical
barges
are
brought
to
the
facility
(Ref.
57).
Ground
water
samples
GW­
06
(FGK80/
MFJD8)
and
GW­
09
(FGK83/
MFJP70)
were
collected
between
the
Offshore
Oil
Services,
Inc.,
facility
and
the
former
Gulfco
surface
impoundments
(Figure
6).
Chemical
analysis
of
these
samples
indicated
no
hazardous
substances
migration
from
the
Offshore
Oil
Services,
Inc.,
facility
toward
the
former
Gulfco
surface
impoundments
(See
Refs.
47
­
49).
Therefore,
hazardous
substances
detected
in
ground
water
samples
around
the
perimeter
of
surface
impoundments
at
or
above
the
sample
quantitation
limit
and
above
the
background
concentrations
are
not
attributable
to
off­
site
sources.

The
Dow
Chemical
Company
facility
is
located
in
excess
of
1­
mile
west­
southwest
of
the
former
Gulfco
facility
(Figure
1).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
88
SWOF
­
Observed
Release/
Attribution
No
Industrial
operations
or
contaminant
sources
have
been
identified
south
of
the
former
Gulfco
facility
across
the
Intracoastal
Waterway,
upwind
of
the
prevailing
wind
direction.
As
a
result,
the
areas
of
observed
soil
contamination
must
be
the
result
of
on­
site
activities
and
not
the
result
of
deposition
from
offsite
sources.

Hazardous
substances
detected
at
or
above
the
sample
quantitation
limits
and
above
the
background
concentrations
for
Source
1,
Contaminated
Soil,
and
Source
2,
Surface
Impoundments,
are
shown
in
Tables
3
and
7,
respectively.
These
hazardous
substances
are
available
to
migrate
along
the
surface
water
migration
pathway
since
the
containment
values
are
greater
than
0.
Hazardous
substances
documented
as
an
observed
release
at
PPE1
in
the
Intracoastal
Waterway
are
shown
in
Table
14.

Four
(4)
semivolatile
organic
contaminants
including
phenanthrene,
fluoranthene,
pyrene
and
bis
(2­
Ethylhexyl)
phthalate
were
detected
as
an
observed
release
to
the
Intracoastal
Waterway
at
PPE1
(Figure
11).
These
four
contaminants
were
detected
at
sediment
sample
location
SE­
08
in
barge
slip
1.
One
pesticide,
gamma­
Chlordane,
and
two
inorganic
contaminants,
lead
and
zinc,
were
also
detected
as
an
observed
release
to
the
Intracoastal
Waterway
at
PPE1
in
sediment
sample
location
SE­
08.
The
presence
of
any
pesticides
attributable
to
the
site
is
unlikely
from
agricultural
uses.
Zinc
was
also
detected
as
an
observed
release
at
sediment
sample
location
SE­
10
(Figure
11).
This
sample
location
was
located
east
of
barge
slip
2
in
the
Intracoastal
Waterway
at
PPE1.
This
was
the
only
contaminant
detected
as
an
observed
release
at
this
sample
location.
The
seven
contaminants
listed
above
were
found
at
concentrations
at
or
above
the
sample
quantitation
limits
and
above
the
background
concentrations
in
Source
1,
Contaminated
Soil.
Lead
was
found
at
concentrations
at
or
above
the
sample
quantitation
limits
and
above
the
background
concentrations
in
Source
No.
2,
Surface
Impoundments.

Heptachlor
epoxide
was
detected
as
an
observed
release
to
the
Intracoastal
Waterway
at
PPE1
in
sediment
sample
location
SE­
09
in
barge
slip
2
(Figure
11).
This
contaminant
was
documented
at
or
above
the
sample
quantitation
limit
and
above
the
background
concentration
in
Source
2,
Surface
Impoundments.

Bis
(2­
Ethylhexyl)
phthalate
was
detected
as
an
observed
release
at
sample
location
SE­
11
in
the
Intracoastal
Waterway
at
PPE1
(Figure
11).
However,
applying
data
usability
criteria
(See
Table
15)
indicates
that
this
hazardous
substance
is
not
usable
as
a
release
value
for
the
Surface
Water
Pathway.

Additional
sediment
samples
were
collected
in
the
Intracoastal
Waterway
and
in
Oyster
Creek
to
determine
potential
sediment
contamination
related
to
potential
sources
east
and
west
of
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
89
SWOF
­
Observed
Release/
Attribution
the
former
Gulfco
facility
(see
Figure
12
for
sediment
sample
locations).
One
sediment
sample
was
collected
in
Oyster
Creek
upstream
from
the
confluence
with
the
Intracoastal
Waterway.
This
sample,
SE03
(FGK10/
MFJQ26),
was
obtained
to
determine
whether
there
is
any
upstream
contribution
of
contaminants
not
attributable
to
operations
at
the
former
Gulfco
facility
(Ref.
18,
Photograph
25).
Similarly,
sediment
sample
SE­
16
(FGK23/
MFJQ39)
was
collected
in
the
Intracoastal
Waterway
adjacent
to
the
confluence
of
the
Old
Brazos
River
Channel
(Ref.
18,
Photograph
33).
This
sample
was
obtained
to
determine
whether
there
is
any
contribution
of
contaminants
from
the
Old
Brazos
River
Channel
and/
or
the
Dow
Barge
Canal
not
attributable
to
the
facility.
Sediment
sample
SE­
06
(FGK13/
MFJQ29)
was
collected
just
east
of
sample
SE­
16
to
assess
potential
contamination
related
to
potential
sources
west
of
the
facility
(Ref.
18,
Photograph
27).

Sediment
samples
SE­
04
(FGK11/
MFJQ27)
and
SE­
07
(FGK14/
MFJQ30)
were
collected
in
the
Intracoastal
Waterway,
less
than
½
mile
east
and
west
of
the
facility,
respectively
(Ref.
18,
Photograph
28).
These
samples
were
collected
to
determine
whether
there
has
been
any
contaminant
migration
away
from
the
facility
and/
or
to
determine
potential
sediment
contamination
related
to
sources
east
and
west
of
the
facility.

No
contaminants
which
met
the
criteria
for
an
observed
releases
were
detected
in
sediment
samples
collected
in
the
Intracoastal
Waterway
at
a
distance
away
from
the
PPE1.

Hazardous
Substances
Released:

Phenanthrene
Fluoranthene
Pyrene
bis
(2­
Ethylhexyl)
phthalate
Heptachlor
epoxide
gamma­
Chlordane
Lead
Zinc
Since
an
observed
release
has
been
established
for
the
watershed,
an
Observed
Release
Factor
Value
of
550
is
assigned
to
the
watershed
(Ref.
1,
Section
4.1.2.1.1).

Observed
Release
Factor
Value:
550
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
90
SWOF/
Food
Chain
­
Toxicity/
Persistence/
Bioaccumulation
4.1.3
HUMAN
FOOD
CHAIN
THREAT
4.1.3.1
HUMAN
FOOD
CHAIN
THREAT
­
LIKELIHOOD
OF
RELEASE
An
observed
release
has
been
documented
to
the
Surface
Water
Pathway
for
the
Intracoastal
Waterway
by
chemical
analysis.
The
same
likelihood
of
release
category
value
established
for
the
drinking
water
threat
is
assigned
for
the
human
food
chain
threat.

4.1.3.2
HUMAN
FOOD
CHAIN
THREAT­
WASTE
CHARACTERISTICS
4.1.3.2.1
Toxicity/
Persistence/
Bioaccumulation
The
hazardous
substances
eligible
to
be
evaluated
for
toxicity/
persistence/
bioaccumulation
under
the
Human
Food
Chain
Threat­
Waste
Characteristics
includes
all
those
hazardous
substances
eligible
to
be
evaluated
for
toxicity/
persistence
in
the
Drinking
Water
Threat
(Ref.
1,
Section
4.1.3.2.1).
Hazardous
substances
available
to
migrate
from
the
source(
s)
at
the
facility
to
the
surface
water
in
the
watershed
via
the
overland/
flood
hazardous
substance
migration
pathway
include:
a)
hazardous
substances
that
meet
the
criteria
of
an
observed
release
to
surface
water
in
the
watershed,
and
b)
hazardous
substances
associated
with
a
source(
s)
with
a
surface
water
containment
factor
greater
than
0
(Ref.
1,
Section
4.1.2.2).
The
hazardous
substances
listed
in
Table
16
have
been
documented
in
Source
1,
Contaminated
Soil,
and
Source
2,
Surface
Impoundments,
at
the
former
Gulfco
facility
at
concentrations
at
or
above
the
sample
quantitation
limits
and
above
background
concentrations.

4.1.3.2.1.1
Toxicity
Factor
Value
The
human
food
chain
toxicity
factor
value
for
each
hazardous
substance
was
obtained
from
the
Superfund
Chemical
Data
Matrix
(SCDM),
1996
(Ref.
2).
The
factor
value
for
each
hazardous
substance
evaluated
is
assigned
in
Table
16.

4.1.3.2.1.2
Persistence
Factor
Value
Surface
water
human
food
chain
persistence
factor
values
for
each
hazardous
substance
of
the
predominant
water
category
"River"
were
obtained
from
the
Superfund
Chemical
Data
Matrix
(SCDM),
1996
(Ref.
2).
The
factor
value
for
each
hazardous
substance
evaluated
is
assigned
in
Table
16.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
91
SWOF/
Food
Chain
­
Toxicity/
Persistence/
Bioaccumulation
4.1.3.2.1.3
Bioaccumulation
Potential
Factor
Value
Surface
water
human
food
chain
bioaccumulation
potential
factor
value
for
each
hazardous
substance
is
defined
for
both
fresh
water
and
salt
water
in
the
Superfund
Chemical
Data
Matrix
(SCDM)
(Ref.
2).
The
factor
value
for
each
hazardous
substance
is
evaluated
under
the
salt
water
criteria
and
the
value
is
assigned
in
Table
16.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
92
SWOF/
Food
Chain
­
Toxicity/
Persistence/
Bioaccumulation
Table
16
Human
Food
Chain
Threat
­
Waste
Characteristics
Toxicity/
Persistence/
Bioaccumulation
Factor
Values
Hazardous
Substance
Toxicity
Factor
Value
1
Persistence
Factor
Value
2
Tox/
Per
Factor
Value
Bioaccumulation
Factor
Value
Tox/
Per/
Bio
Factor
Value
(Table
4­
16)
Reference
Vinyl
Chloride
10
0.4
4
5
20
Ref.
1;
Ref.
2
1,1­
Dichloroethene
100
0.4
40
50
20
Ref.
1;
Ref.
2
Carbon
Disulfide
10
0.4
4
500
2000
Ref.
1;
Ref.
2
Methylene
Chloride
10
0.4
4
5
20
Ref.
1;
Ref.
2
trans­
1,2­
Dichloroethene
100
0.4
40
50
2000
Ref.
1;
Ref.
2
1,1­
Dichloroethane
10
0.4
4
5
20
Ref.
1;
Ref.
2
cis­
1,2­
Dichloroethene
100
0.4
40
5
200
Ref.
1;
Ref.
4
Chloroform
100
0.4
40
5
200
Ref.
1;
Ref.
2
1,1,1­
Trichloroethane
1
0.4
0.4
5
2
Ref.
1;
Ref.
2
Benzene
100
0.4
40
5000
2
x
1
0
4
Ref.
1;
Ref.
2
1,2­
Dichloroethane
100
0.4
40
5
200
Ref.
1;
Ref.
2
Trichloroethene
10
0.4
4
50
200
Ref.
1;
Ref.
2
1,2­
Dichloropropane
1000
0.4
400
5
2000
Ref.
1;
Ref.
2
4­
Methyl­
2­
pentanone
100
0.4
40
5
200
Ref.
1;
Ref.
2
Toluene
10
0.4
4
50
200
Ref.
1;
Ref.
2
1,1,2­
Trichloroethane
1000
0.4
400
50
2
x
1
0
4
Ref.
1;
Ref.
2
Tetrachloroethene
100
0.4
40
50
2000
Ref.
1;
Ref.
2
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
93
SWOF/
Food
Chain
­
Toxicity/
Persistence/
Bioaccumulation
Table
16
­
Continued
Human
Food
Chain
Threat
­
Waste
Characteristics
Toxicity/
Persistence/
Bioaccumulation
Factor
Values
Hazardous
Substance
Toxicity
Factor
Value
1
Persistence
Factor
Value
2
Tox/
Per
Factor
Value
Bioaccumulation
Factor
Value
Tox/
Per/
Bio
Factor
Value
(Table
4­
16)
Reference
Ethylbenzene
10
0.4
4
5
20
Ref.
1;
Ref.
2
Xylenes
(total)
10
0.4
4
50
200
Ref.
1;
Ref.
2
Isopropylbenzene
1000
0.4
400
500
2
x
1
0
5
Ref.
1;
Ref.
2
1,1,2,2­
Tetrachoroethane
10
0.4
4
5
20
Ref.
1;
Ref.
2
Phenanthrene
Not
Listed
1.0
N/
A
50
N/
A
Ref.
1;
Ref.
2
Fluoranthene
100
1.0
100
5000
5
x
1
0
5
Ref.
1;
Ref.
2
Pyrene
100
1.0
100
5000
5
x
1
0
5
Ref.
1;
Ref.
2
Benzo(
a)
anthracene
1000
1.0
1000
50,000
5
x
1
0
7
Ref.
1;
Ref.
2
Chrysene
10
1.0
10
500
5000
Ref.
1;
Ref.
2
bis
(2­
Ethylhexyl)
phthalate
100
1.0
100
50,000
5
x
1
0
6
Ref.
1;
Ref.
4
Benzo(
b)
fluoranthene
1000
1.0
1000
50,000
5
x
1
0
7
Ref.
1;
Ref.
2
Benzo(
k)
fluoranthene
100
1.0
100
50,000
5
x
1
0
6
Ref.
1;
Ref.
2
Benzo(
a)
pyrene
10,000
1.0
10,000
500
5
x
1
0
6
Ref.
1;
Ref.
2
Indeno(
1,2,3­
cd)
pyrene
1000
1.0
1000
50,000
5
x
1
0
7
Ref.
1;
Ref.
2
benzo(
g,
h,
i)
perylene
Not
Listed
1.0
N/
A
50,000
N/
A
Ref.
1;
Ref.
2
Benzaldehyde
Not
Listed
N/
A
N/
A
N/
A
N/
A
Ref.
1;
Ref.
2
Phenol
1
1
1
5
5
Ref.
1;
Ref.
2
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
94
Table
16
­
Continued
Human
Food
Chain
Threat
­
Waste
Characteristics
Toxicity/
Persistence/
Bioaccumulation
Factor
Values
Hazardous
Substance
Toxicity
Factor
Value
1
Persistence
Factor
Value
2
Tox/
Per
Factor
Value
Bioaccumulation
Factor
Value
Tox/
Per/
Bio
Factor
Value
(Table
4­
16)
Reference
2­
Methylphenol
10
1
10
5
50
Ref.
1;
Ref.
2
2,2'­
oxybis
(1­
Chloropropane)
10
0.4
4
50
200
Ref.
1;
Ref.
2
Acetophenone
10
1
10
5
50
Ref.
1;
Ref.
2
4­
Methylphenol
100
0.4
40
5
200
Ref.
1;
Ref.
2
Naphthalene
100
0.4
40
5
200
Ref.
1;
Ref.
2
alpha­
BHC
10,000
1
10,000
500
5
x
1
0
6
Ref.
1;
Ref.
2
beta­
BHC
100
1
100
500
5
x
1
0
4
Ref.
1;
Ref.
2
delta­
BHC
1
1
1
500
500
Ref.
1;
Ref.
2
gamma­
BHC
(Lindane)
10,000
1
10,000
500
5
x
1
0
6
Ref.
1;
Ref.
2
Dieldrin
10,000
1.0
10,000
5000
5
x
1
0
7
Ref.
1;
Ref.
2
4,4'­
DDE
100
1.0
100
50,000
5
x
1
0
6
Ref.
1;
Ref.
2
Endrin
10,000
1.0
10,000
5000
5
x
1
0
7
Ref.
1;
Ref.
2
4,4'­
DDD
100
1.0
100
50,000
5
x
1
0
6
Ref.
1;
Ref.
2
4,4'­
DDT
1000
1.0
1000
50,000
5
x
1
0
7
Ref.
1;
Ref.
2
Endrin
Ketone
100
0.4
40
0.5
50
Ref.
1;
Ref.
2
Endrin
aldehyde
Not
Listed
0.4
N/
A
500
N/
A
Ref.
1;
Ref.
2
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
95
SWOF/
Food
Chain
­
Toxicity/
Persistence/
Bioaccumulation
Table
16
­
Continued
Human
Food
Chain
Threat
­
Waste
Characteristics
Toxicity/
Persistence/
Bioaccumulation
Factor
Values
Hazardous
Substance
Toxicity
Factor
Value
1
Persistence
Factor
Value
2
Tox/
Per
Factor
Value
Bioaccumulation
Factor
Value
Tox/
Per/
Bio
Factor
Value
(Table
4­
16)
Reference
Endosulfan
II
100
1
100
5000
5
x
1
0
5
Ref.
1;
Ref.
2
Aldrin
10,000
1
10,000
50,000
5
x
1
0
8
Ref.
1;
Ref.
2
Heptachlor
1000
1
1000
5000
5
x
1
0
6
Ref.
1;
Ref.
2
Heptachlor
epoxide
10,000
1.0
10,000
5
5
x
10
4
Ref.
1;
Ref.
2
alpha­
Chlordane
10
1.0
10
500
5000
Ref.
1;
Ref.
2
gamma­
Chlordane
10
1.0
10
50,000
5
x
1
0
5
Ref.
1;
Ref.
2
Aroclor
1254
10,000
1.0
10,000
50,000
5
x
1
0
8
Ref.
1;
Ref.
2
Aluminum
Not
Listed
1.0
N/
A
50
N/
A
Ref.
1;
Ref.
2
Arsenic
10,000
1.0
10,000
500
5
x
1
0
6
Ref.
1;
Ref.
2
Barium
10,000
1.0
10,000
0.5
5000
Ref.
1;
Ref.
2
Cobalt
1
1
1
0.5
0.5
Ref.
1;
Ref.
2
Chromium
10,000
1.0
10,000
500
5
x
1
0
6
Ref.
1;
Ref.
2
Copper
Not
Listed
1.0
N/
A
50,000
N/
A
Ref.
1;
Ref.
2
Iron
1
1.0
1
0.5
0.5
Ref.
1;
Ref.
2
Lead
10,000
1.0
10,000
5000
5
x
1
0
7
Ref.
1;
Ref.
2
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
96
SWOF/
Food
Chain
­
Toxicity/
Persistence/
Bioaccumulation
Table
16
­
Continued
Human
Food
Chain
Threat
­
Waste
Characteristics
Toxicity/
Persistence/
Bioaccumulation
Factor
Values
Hazardous
Substance
Toxicity
Factor
Value
1
Persistence
Factor
Value
2
Tox/
Per
Factor
Value
Bioaccumulation
Factor
Value
Tox/
Per/
Bio
Factor
Value
(Table
4­
16)
Reference
Manganese
10,000
1.0
10,000
0.5
5000
Ref.
1;
Ref.
2
Nickel
10,000
1.0
10,000
500
5
x
1
0
6
Ref.
1;
Ref.
2
Vanadium
100
1.0
100
0.5
50
Ref.
1;
Ref.
2
Zinc
10
1.0
10
50,000
5
x
1
0
5
Ref.
1;
Ref.
2
Notes:
Not
Listed
­
No
Toxicity
Value
listed
in
SCDM
N/
A
­
Not
Applicable
1
"Rivers"
was
the
predominate
surface
water
body
type
used
for
factor
value
determination
(Ref.
3,
p.
230).
Factor
values
for
each
hazardous
substance
were
obtained
from
the
Superfund
Chemical
Data
Matrix
(SCDM)
1996.
2
Bioaccumulation
factor
(BCF)
data
are
available
in
the
Superfund
Chemical
Data
Matrix
(SCDM)
1996
for
both
fresh
water
and
salt
water
for
the
hazardous
substances
evaluated
at
a
site.
The
Intracoastal
Waterway
is
classified
as
being
salt
water
and
the
salt
water
BCF
data
were
used
in
evaluating
this
facility.

Two
contaminants
with
the
highest
Toxicity/
Persistence/
Bioaccumulation
Factor
Value
are
Aldrin
and
Aroclor­
1254
with
a
value
of
5
x
10
8
(Ref.
1,
Table
4­
16;
Ref.
2).

Toxicity/
Persistence/
Bioaccumulation
Factor
Value:
5
x
10
8
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
97
SWOF/
Food
Chain
­
Hazardous
Waste
Quantity
4.1.3.2.2
Hazardous
Waste
Quantity
TABLE
17
Human
Food
Chain
­
Hazardous
Waste
Quantity
Source
Number
Source
Hazardous
Waste
Quantity
Value
(Sec.
2.4.2.1.5)
Is
Source
Hazardous
Constituent
Quantity
data
complete?
(yes/
no)

1
>
0,
but
unknown
No
2
11,000
No
Sum
of
Values:
>
11,000
Areas
covered
by
buildings
and
or
maintained,
impenetrable
materials
(such
as
paved
areas),
normally
deducted
from
the
calculation
of
total
areas,
were
not
excluded
from
the
area
calculation
because
they
could
not
be
adequately
delineated
and/
or
identified.
Therefore,
the
area
of
observed
soil
contamination
for
Source
1
will
be
assigned
an
area
hazardous
waste
quantity
value
of
greater
than
(>)
0,
but
unknown.
The
value
of
>0
reflects
that
the
area
value
is
known
to
be
greater
than
0,
but
the
area
measures
have
not
been
determined.

Because
the
site
contains
hazardous
substances
from
CERCLA­
eligible
petroleum
related
wastestreams,
non­
petroleum
related
wastestreams
and
excluded
petroleum
products
that
are
commingled,
all
of
the
Source
1
and
Source
2
hazardous
waste
quantity
is
CERCLA­
eligible
and
will
be
assigned
a
value
accordingly.

The
sum
of
the
Hazardous
Waste
Quantity
Values
for
Source
No.
1,
Contaminated
Soil,
and
Source
2,
Surface
Impoundment
is
>
11,000.
The
sum
of
the
Source
Hazardous
Waste
Quantity
Values
for
the
Gulfco
Marine
Maintenance
site,
rounded
to
the
nearest
integer,
is
11,000.

According
to
HRS
Table
2­
6,
the
Hazardous
Waste
Quantity
Factor
Value
assigned
to
a
Source
Hazardous
Waste
Quantity
Value
of
11,000
is
10,000
(Ref.
1,
Section
2.4.2.2,
Table
2­
6).

Hazardous
Waste
Quantity
Factor
Value:
10,000
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
98
SWOF/
Food
Chain
­
Hazardous
Waste
Quantity
4.1.3.2.3
Waste
Characteristics
Factor
Category
Value
A
Waste
Characteristics
Factor
Value
is
based
on
the
Waste
Characteristics
Product.
The
Waste
Characteristics
Product
is
the
product
of
the
Toxicity/
Persistence
Factor
Value,
the
Hazardous
Waste
Quantity
Factor
Value,
and
the
Bioaccumulation
Potential
Factor
Value.

(Toxicity/
Persistence
x
Hazardous
Waste
Quantity)
x
Bioaccumulation
Potential
=
Waste
Characteristics
Factor
Category
Value
Where:
Toxicity/
Persistence
Factor
Value
=
10,000
Hazardous
Waste
Quantity
Factor
Value
=
10,000
And:
Toxicity/
Persistence
x
Hazardous
Waste
Quantity
=
10,000
x
10,000
=
1
x
10
8
Where:
Toxicity/
Persistence
x
Hazardous
Waste
Quantity
=
1
x
10
8
Bioaccumulation
Potential
Factor
Value
=
50,000
And:
(Toxicity/
Persistence
x
Hazardous
Waste
Quantity)
x
Bioaccumulation
Potential
=
1
x
10
8
x
50,000
=
5
x
10
12
A
Waste
Characteristics
Product
of
5
x
10
12
receives
a
Waste
Characteristics
Factor
Category
Value
of
1,000
(Ref.
1,
Table
2­
7).

Waste
Characteristics
Factor
Category
Value:
1,000
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
99
SWOF/
Food
Chain
­
Targets
4.1.3.3
HUMAN
FOOD
CHAIN
THREAT­
TARGETS
According
to
the
HRS,
each
watershed
is
evaluated
based
upon
two
target
factors:
food
chain
individual
and
population.
For
both
factors,
each
target
fishery
is
evaluated
whether
it
is
subject
to
actual
or
potential
human
food
chain
contamination.

Actual
Human
Food
Chain
Contamination
According
to
the
HRS,
a
fishery
(or
portion
of
a
fishery)
within
the
TDL
of
the
watershed
is
considered
to
be
subject
to
actual
human
food
chain
contamination
if
a
hazardous
substance
having
a
bioaccumulation
potential
factor
value
of
500
or
greater
is
present
in
a
sediment
sample
from
the
watershed
at
a
level
that
meets
the
criteria
for
an
observed
release
(Ref.
1,
Section
4.1.3.3).
Sediment
samples
FGK15/
MFJQ31
(SE­
08)
and
MFJQ33
(SE­
10)
meet
the
criteria
of
an
observed
release
for
the
watershed,
are
attributable
to
sources
at
the
facility,
and
the
hazardous
substances
detected
in
the
samples
have
bioaccumulation
potential
factor
values
of
500
or
greater.

These
sediment
samples
were
collected
in
the
Intracoastal
Waterway
at
PPE1.
The
Intracoastal
Waterway
is
considered
a
fishery
(See
Ref.
16,
p.
29;
Ref.
18,
Photographs
34
&
35);
therefore,
a
portion
of
a
fishery
within
the
target
distance
limit
is
subject
to
actual
food
chain
contamination.
The
length
of
the
fishery
subject
to
actual
food
chain
contamination
is
considered
the
distance
between
the
sediment
samples
FGK15/
MFJQ31
(SE­
08)
and
MFJQ33
(SE­
10)
collected
at
PPE1,
which
is
approximately
1100
feet
(Figure
11).
The
remainder
of
the
fisheries
identified
within
the
target
distance
limit
will
be
evaluated
based
upon
potential
food
chain
contamination
(Ref.
1,
Section
4.1.3.3).

Closed
Fisheries
There
is
no
data
available
that
indicates
that
any
portion
of
the
surface
water
pathway
within
the
target
distance
limit
is
closed
due
to
contamination
related
to
hazardous
substances
documented
as
an
observed
release
during
the
Gulfco
sampling
events
(Ref.
58).

Most
Distant
Level
II
Samples
Sediment
samples
FGK15/
MFJQ31
(SE­
08)
and
MFJQ33
(SE­
10)
listed
in
Table
14
are
the
samples
which
document
actual
food
chain
contamination
in
the
Intracoastal
Waterway.
These
sediment
samples
were
collected
at
PPE1
and
they
are
within
the
Intracoastal
Waterway.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
100
SWOF/
Food
Chain
­
Targets
Sample
ID:
FGK15/
MFJQ31
(SE­
08)
­
Sample
collected
at
PPE1
Reference:
Ref.
16,
p.
19;
Table
14;
Figure
11;
Ref.
18,
Photograph
29
Sample
ID:
MFJQ33
(SE­
10)
­
Sample
collected
at
PPE1
Reference:
Ref.
16,
p.
21;
Table
14;
Figure
11
Level
II
Fisheries
The
Intracoastal
Waterway
is
the
identified
fishery
which
is
partially
located
within
the
in­
water
segment
subject
to
Level
II
concentrations
(Ref.
16,
p.
29;
Ref.
18,
Photographs
34
&
35).

TABLE
18
EXTENT
OF
LEVEL
II
FISHERY
Identity
of
Fishery
Extent
of
Level
II
Fishery
Intracoastal
Waterway
1100
feet
4.1.3.3.1
Food
Chain
Individual
The
following
samples
were
collected
in
the
Intracoastal
Waterway
and
the
sample
analyses
indicate
concentrations
of
hazardous
substances
meeting
the
criteria
of
an
observed
release
and
having
a
bioaccumulation
potential
factor
value
of
500
or
greater.

Hazardous
Substance
Bioaccumulation
Potential
(Ref.
1,
Ref.
2)

Sample
ID.
No.
FGK15/
MFJQ31
(SE­
08)
Fluoranthene
5000
Pyrene
5000
bis
(2­
Ethylhexyl)
phthalate
50,000
gamma­
Chlordane
50,000
Lead
5000
Zinc
50,000
Sample
ID.
No.
MFJQ34
(SE­
10)
Zinc
50,000
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
101
SWOF/
Food
Chain
­
Targets
These
sediment
samples
were
collected
in
the
Intracoastal
Waterway
at
PPE1.
The
Intracoastal
Waterway
is
within
the
watershed
being
evaluated.
Photographs
taken
during
the
January
2000
SSI
sampling
event
documented
the
Intracoastal
Waterway
as
being
a
fishery
(Ref.
18,
Photographs
34
&
35).

Since
a
portion
of
the
Intracoastal
Waterway
fishery
is
documented
to
be
subject
to
Level
II
concentrations,
and
the
hazardous
substance
documenting
an
observed
release
has
a
bioaccumulation
potential
factor
value
greater
than
500,
a
food
chain
individual
factor
value
of
45
is
assigned
(Ref.
1,
Section
4.1.3.3.1).

Food
Chain
Individual
Factor
Value:
45
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
102
SWOF/
Food
Chain
­
Targets
4.1.3.3.2
Population
The
population
factor
value
for
the
watershed
is
based
upon
three
factors:
Level
I
concentrations,
Level
II
concentrations,
and
potential
human
food
chain
contamination
(Ref.
1,
Section
4.1.3.3.2).

4.1.3.3.2.1
Level
I
Concentrations
Level
I
concentrations
were
not
documented
in
the
Intracoastal
Waterway
or
within
the
contiguous
water
bodies
which
are
considered
fisheries.

4.1.3.3.2.2
Level
II
Concentrations
Level
II
concentrations
were
detected
in
sediment
samples
FGK15/
MFJQ31
(SE­
08)
and
MFJQ34
(SE­
10)
in
the
Intracoastal
Waterway
at
PPE1.
The
Intracoastal
Waterway
is
considered
a
fishery
(Ref.
18,
Photographs
34
&
35).
Therefore,
the
Intracoastal
Waterway
fishery
is
subject
to
Level
II
concentrations.

Table
19
Surface
Water
Pathway
Estimated
Annual
Production
­
Human
Food
Chain
Organism
Identity
of
Fishery
Annual
Production
(lbs)
Reference
Human
Food
Chain
Population
Value
Intracoastal
Waterway
(15­
mile
In­
water
Segment)
>
0
Ref.
1;
Ref.
2,
pp.
216
&
217;
Ref.
16,
p.
29;
Ref.
18,
Photographs
34
&
35
0.03
Level
I
Concentration
Factor
Value:
0
Level
II
Concentration
Factor
Value:
0.03
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
103
SW­
Food
Chain
­
Targets
4.1.3.3.2.3
Potential
Human
Food
Chain
Contamination
PPE1
is
defined
as
the
part
of
the
Intracoastal
Waterway
that
borders
the
entire
southern
boundary
of
the
former
Gulfco
facility.
The
Intracoastal
Waterway
is
considered
a
fishery
(Ref.
16,
p.
29;
Ref.
18,
Photographs
34
&
35).
From
PPE1,
the
15­
mile
in­
water
segment
extends
in
a
15­
mile
arc
in
all
directions
within
the
contiguous
surface
water
bodies
since
these
surface
water
bodies
are
tidally
influenced
(Ref.
3,
pp.
216
and
217).
There
is
no
documentation
of
closed
fisheries
within
the
TDL
(Ref.
66);
therefore,
the
entire
limit
of
the
in­
water
segment
is
subject
to
potential
food
chain
contamination.

TABLE
20
Surface
Water
Pathway
Potential
Human
Food
Chain
Contamination
Identity
of
Fishery
Annual
Production
(lbs)
Surface
Water
Body
Type
Average
Annual
Flow
Population
Value
(Pi)
Dilution
Weight
(Di)
Pi
x
Di
Reference
Intracoastal
Waterway
(15­
mile
Inwater
Segment)
>0
Coastal
Tidal
0
Tidal
Flow
0.03
0.0001
0.000003
Ref.
1;
Ref.
3,
p.
216
&
217
Ref.
16,
p.
29;
Ref.
18,
Photographs
34
&
35
To
calculate
the
Potential
Human
Food
Chain
Contamination
Factor
Value,
the
product
of
the
potentially
contaminated
fishery
values
are
multiplied
by
the
dilution
weight,
summed
and
then
divided
by
10
(Ref.
1,
Section
4.1.3.3.2.3).
Where:
Population
Values
(Pi)
x
Dilution
Weight
(Di)
=
Potentially
Contaminated
Fishery
Values
Pi
(0.03)
x
Di
(.
0001)
=
0.000003
0.000003
x
1/
10
=
0.0000003
A
Potential
Human
Food
Chain
Contamination
Factor
Value
of
0.000003
is
assigned.

Potential
Human
Food
Chain
Contamination
Factor
Value:
0.0000003
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
104
SW­
Food
Chain
­
Targets
4.1.3.3.2.4
Calculation
of
Population
Factor
Value
The
Population
Factor
Value
is
calculated
by
summing
the
value
of
the
Level
I
Concentration
Factor
Value
(0),
Level
II
Concentration
Factor
Value
(0.03),
and
the
Potential
Human
Food
Chain
Factor
Value
(0.0000003)
for
the
watershed.
The
resulting
value
of
0.0300003
is
assigned
as
the
Human
Food
Chain
Population
Factor
Value
(Ref.
1,
Section
4.1.3.3.2.4).

4.1.3.3.3
Calculation
of
Human
Food
Chain
Threat­
Targets
Factor
Category
Value
The
Human
Food
Chain
Threat­
Targets
Factor
Category
is
calculated
by
summing
the
Food
Chain
Individual
(45)
and
Population
Factor
value
for
a
watershed
(0.0300003).
The
resulting
value
of
45.0300003
is
assigned
as
the
Human
Food
Chain
Treat­
Targets
Factor
Category
Value
(Ref.
1,
Section
4.1.3.3.3).

4.1.3.4
Calculation
of
Food
Chain
Threat
Score
The
Human
Food
Chain
Threat
Score
is
calculated
by
multiplying
the
Human
Food
Chain
Threat
Factor
Category
values
for
Likelihood
of
Release
(550),
Waste
Characteristics
(1,000),
and
Targets
(45.0300003).
The
product
of
these
values
is
then
rounded
to
the
nearest
integer
(24,766,500)
and
divided
by
82,500.
The
resulting
value,
subject
to
a
maximum
of
100,
is
assigned
as
the
Human
Food
Chain
Threat
Score
for
the
watershed
(Ref.
1,
Section
4.1.3.4).

Potential
Human
Food
Chain
Contamination
Factor
Value:
0.0000003
Population
Factor
Value:
0.0300003
Targets
Factor
Category
Value:
45.0300003
Human
Food
Chain
Threat
Score:
100
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
105
SW­
Environmental
Threat
4.1.4
ENVIRONMENTAL
THREAT
4.1.4.1
ENVIRONMENTAL
THREAT­
LIKELIHOOD
OF
RELEASE
An
observed
release
has
been
documented
to
the
surface
water
pathway
for
the
Intracoastal
Waterway
by
chemical
analysis.
The
same
likelihood
of
release
factor
category
value
that
is
established
for
the
drinking
water
threat
is
also
assigned
for
the
environmental
threat.

4.1.4.2
ENVIRONMENTAL
THREAT­
WASTE
CHARACTERISTICS
4.1.4.2.1
Ecosystem
Toxicity/
Persistence/
Bioaccumulation
The
hazardous
substances
eligible
to
be
evaluated
for
ecosystem
toxicity/
persistence/
bioaccumulation
under
the
Environmental
Threat
­
Waste
Characteristics
are
those
eligible
to
be
evaluated
for
toxicity/
persistence
in
the
Drinking
Water
Threat
for
the
watershed
(Ref.
1,
Section
4.1.4.2.1).

4.1.4.2.1.1
Ecosystem
Toxicity
The
surface
water
ecosystem
toxicity
factor
value
for
each
hazardous
substance
is
defined
for
both
fresh
water
and
salt
water
in
the
Superfund
Chemical
Data
Matrix
(SCDM),
1996
(Ref.
2).
The
factor
value
for
each
hazardous
substance
is
evaluated
under
the
salt
water
criteria
and
assigned
in
Table
21.

4.1.4.2.1.2
Persistence
The
surface
water
environmental
persistence
factor
value
for
each
hazardous
substance
of
the
predominant
surface
water
category
"River"
was
obtained
from
the
Superfund
Chemical
Data
Matrix
(SCDM),
1996
(Ref.
2).
The
factor
value
for
each
hazardous
substance
evaluated
is
assigned
in
Table
21.

4.1.4.2.1.3
Ecosystem
Bioaccumulation
The
surface
water
environmental
bioaccumulation
potential
factor
value
for
each
hazardous
substance
is
defined
for
both
fresh
water
and
salt
water
in
the
Superfund
Chemical
Data
Matrix
(SCDM),
1996
(Ref.
2).
The
bioaccumulation
factor
values
for
each
hazardous
substance
is
evaluated
under
the
salt
water
criteria
and
assigned
in
Table
21.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
106
SW­
Environmental
Threat
Table
21
Environmental
Threat
­
Waste
Characteristics
Toxicity/
Persistence/
Bioaccumulation
Factor
Values
Hazardous
Substance
Ecosystem
Toxicity
Factor
Value
1
Persistence
Factor
Value
2
Tox/
Per
Factor
Value
Ecosystem
Bioaccumulation
Factor
Value
Tox/
Per/
Bio
Factor
Value
(Table
4­
21)
Reference
Vinyl
Chloride
Not
Listed
0.0007
N/
A
5
N/
A
Ref.
1;
Ref.
2
1,1­
Dichloroethene
1
0.4
0.4
50
20
Ref.
1;
Ref.
2
Carbon
Disulfide
100
0.4
40
500
2
x
1
0
4
Ref.
1;
Ref.
2
Methylene
Chloride
10
0.4
4
5
20
Ref.
1;
Ref.
2
trans­
1,2­
Dichloroethene
1
0.4
0.4
50
20
Ref.
1;
Ref.
2
1,1­
Dichloroethane
Not
Listed
0.4
N/
A
5
N/
A
Ref.
1;
Ref.
2
cis­
1,2­
Dichloroethene
Not
Listed
0.4
N/
A
5
N/
A
Ref.
1;
Ref.
2
Chloroform
10
0.4
4
5
20
Ref.
1;
Ref.
2
1,1,1­
Trichloroethane
10
0.4
4
5
20
Ref.
1;
Ref.
2
Benzene
1000
0.4
400
50,000
2
x
1
0
7
Ref.
1;
Ref.
2
1,2­
Dichloroethane
1
0.4
0.4
5
2
Ref.
1;
Ref.
2
Trichloroethene
10
0.4
4
50
20
Ref.
1;
Ref.
2
1,2­
Dichloropropane
1
0.4
0.4
5
2
Ref.
1;
Ref.
2
4­
Methyl­
2­
pentanone
1
0.4
0.4
5
2
Ref.
1;
Ref.
2
Toluene
100
0.4
40
50
2000
Ref.
1;
Ref.
2
1,1,2­
Trichloroethane
10
0.4
4
50
200
Ref.
1;
Ref.
2
Tetrachloroethene
10
0.4
4
50
200
Ref.
1;
Ref.
2
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
107
SW­
Environmental
Threat
Table
21
­
Continued
Environmental
Threat
­
Waste
Characteristics
Toxicity/
Persistence/
Bioaccumulation
Factor
Values
Hazardous
Substance
Ecosystem
Toxicity
Factor
Value
1
Persistence
Factor
Value
2
Tox/
Per
Factor
Value
Ecosystem
Bioaccumulation
Factor
Value
Tox/
Per/
Bio
Factor
Value
(Table
4­
21)
Reference
Ethylbenzene
10
0.4
4
50
200
Ref.
1;
Ref.
2
Xylenes
(total)
100
0.4
40
50
2000
Ref.
1;
Ref.
2
Isopropylbenzene
1
0.4
0.4
500
200
Ref.
1;
Ref.
2
1,1,2,2­
Tetrachloroethane
10
0.4
4
5
20
Ref.
1;
Ref.
2
Phenanthrene
1000
1.0
1000
50
5
x
1
0
4
Ref.
1;
Ref.
2
Fluoranthene
1000
1.0
1000
5000
5
x
1
0
6
Ref.
1;
Ref.
2
Pyrene
10,000
1.0
10,000
5000
5
x
1
0
7
Ref.
1;
Ref.
2
Benzo(
a)
anthracene
10,000
1.0
10,000
50,000
5
x
1
0
8
Ref.
1;
Ref.
2
Chrysene
1000
1.0
1000
500
5
x
1
0
5
Ref.
1;
Ref.
2
bis(
2­
Ethylhexy)
phthalate
1
1.0
1
50,000
5
x
1
0
4
Ref.
1;
Ref.
2
Benzo(
b)
fluoranthene
Not
Listed
1.0
N/
A
50,000
N/
A
Ref.
1;
Ref.
2
Benzo(
k)
fluoranthene
Not
Listed
1.0
N/
A
50,000
N/
A
Ref.
1;
Ref.
2
Benzo(
a)
pyrene
1000
1.0
1000
500
5
x
1
0
5
Ref.
1;
Ref.
2
Indeno(
1,2,3­
cd)
pyrene
Not
Listed
1.0
N/
A
50,000
N/
A
Ref.
1;
Ref.
2
Benzo(
g,
h,
i)
perylene
Not
Listed
1.0
N/
A
50,000
N/
A
Ref.
1;
Ref.
2
Benzaldehyde
Not
Listed
Not
Listed
N/
A
Not
Listed
N/
A
Ref.
1;
Ref.
2
Phenol
100
1.0
100
5
500
Ref.
1;
Ref.
2
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
108
Table
21
­
Continued
Environmental
Threat
­
Waste
Characteristics
Toxicity/
Persistence/
Bioaccumulation
Factor
Values
Hazardous
Substance
Ecosystem
Toxicity
Factor
Value
1
Persistence
Factor
Value
2
Tox/
Per
Factor
Value
Ecosystem
Bioaccumulation
Factor
Value
Tox/
Per/
Bio
Factor
Value
(Table
4­
21)
Reference
2­
Methylphenol
100
1.0
100
5
500
Ref.
1;
Ref.
2
2,2'­
oxybis
(1­
Chloropropane)
Not
Listed
0.4
N/
A
50
N/
A
Ref.
1;
Ref.
2
Acetohenone
1
1.0
1
5
5
Ref.
1;
Ref.
2
4­
Methylphenol
Not
Listed
0.4
N/
A
5
N/
A
Ref.
1;
Ref.
2
Naphthalene
1000
0.4
400
5000
2
x
1
0
6
Ref.
1;
Ref.
2
alpha­
BHC
1000
1.0
1000
5000
5
x
1
0
6
Ref.
1;
Ref.
2
beta­
BHC
Not
Listed
1.0
N/
A
5000
N/
A
Ref.
1;
Ref.
2
delta­
BHC
Not
Listed
1.0
N/
A
500
N/
A
Ref.
1;
Ref.
2
gamma­
BHC
(Lindane)
10,000
1.0
10,000
500
5
x
1
0
6
Ref.
1;
Ref.
2
Dieldrin
10,000
1.0
10,000
5000
5
x
1
0
7
Ref.
1;
Ref.
2
4,4'­
DDE
10,000
1.0
10,000
50,000
5
x
1
0
8
Ref.
1;
Ref.
2
Endrin
10,000
1.0
10,000
5000
5
x
1
0
7
Ref.
1;
Ref.
2
4,4'­
DDD
10,000
1.0
10,000
50,000
5
x
1
0
8
Ref.
1;
Ref.
2
4,4'­
DDT
10,000
1.0
10,000
50,000
5
x
1
0
8
Ref.
1;
Ref.
2
Endrin
Ketone
Not
Listed
0.4
N/
A
0.5
N/
A
Ref.
1;
Ref.
2
Endrin
Aldehyde
Not
Listed
0.4
N/
A
500
N/
A
Ref.
1;
Ref.
2
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
109
SW­
Environmental
Threat
Table
21
­
Continued
Environmental
Threat
­
Waste
Characteristics
Toxicity/
Persistence/
Bioaccumulation
Factor
Values
Hazardous
Substance
Ecosystem
Toxicity
Factor
Value
1
Persistence
Factor
Value
2
Tox/
Per
Factor
Value
Ecosystem
Bioaccumulation
Factor
Value
Tox/
Per/
Bio
Factor
Value
(Table
4­
21)
Reference
Endosulfan
II
10,000
1.0
10,000
5000
5
x
1
0
7
Ref.
1;
Ref.
2
Aldrin
10,000
1.0
10,000
50,000
5
x
1
0
8
Ref.
1;
Ref.
2
Heptachlor
10,000
1.0
10,000
50,000
5
x
1
0
8
Ref.
1;
Ref.
2
Heptachlor
epoxide
10,000
1.0
10,000
50,000
5
x
1
0
8
Ref.
1;
Ref.
2
alpha­
Chlordane
10,000
1.0
10,000
500
5
x
1
0
6
Ref.
1;
Ref.
2
gamma­
Chlordane
10,000
1.0
10,000
500
5
x
1
0
6
Ref.
1;
Ref.
2
Aroclor
1254
10,000
1.0
10,000
50,000
5
x
1
0
8
Ref.
1;
Ref.
2
Aluminum
100
1.0
100
50
5000
Ref.
1;
Ref.
2
Arsenic
100
1.0
100
500
5
x
1
0
4
Ref.
1;
Ref.
2
Barium
1
1.0
1
0.5
0.5
Ref.
1;
Ref.
2
Cobalt
Not
Listed
1.0
N/
A
5000
N/
A
Ref.
1;
Ref.
2
Chromium
100
1.0
100
500
5
x
1
0
4
Ref.
1;
Ref.
2
Copper
100
1.0
100
50,000
5
x
1
0
6
Ref.
1;
Ref.
2
Iron
10
1.0
10
0.5
5
Ref.
1;
Ref.
2
Lead
1000
1.0
1000
5000
5
x
1
0
6
Ref.
1;
Ref.
2
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
110
SW­
Environmental
Threat
Table
21
­
Continued
Environmental
Threat
­
Waste
Characteristics
Toxicity/
Persistence/
Bioaccumulation
Factor
Values
Hazardous
Substance
Ecosystem
Toxicity
Factor
Value
1
Persistence
Factor
Value
2
Tox/
Per
Factor
Value
Ecosystem
Bioaccumulation
Factor
Value
Tox/
Per/
Bio
Factor
Value
(Table
4­
21)
Reference
Manganese
Not
Listed
1.0
N/
A
50,000
N/
A
Ref.
1;
Ref.
2
Nickel
1000
1.0
1000
500
5
x
1
0
5
Ref.
1;
Ref.
2
Vanadium
Not
Listed
1.0
N/
A
0.5
N/
A
Ref.
1;
Ref.
2
Zinc
100
1.0
100
50,000
5
x
1
0
6
Ref.
1;
Ref.
2
Note:
1
"Rivers"
was
the
predominate
surface
water
body
type
used
for
factor
value
determination.
Factor
values
for
each
hazardous
substance
were
obtained
from
the
Superfund
Chemical
Data
Matrix
(SCDM)
1996.
2
Bioaccumulation
factor
(BCF)
data
are
available
in
the
Superfund
Chemical
Data
Matrix
(SCDM)
1996
for
both
fresh
water
and
salt
water
for
the
hazardous
substances
evaluated
at
a
site.
The
Intracoastal
Waterway
is
classified
as
being
salt
water
and
the
salt
water
BCF
data
were
used
in
evaluating
this
facility.

Eight
(8)
hazardous
substances
listed
in
Table
21
above
have
the
highest
Ecosystem
Toxicity/
Persistence/
Bioaccumulation
Factor
Value
of
5
x
10
8
.
Therefore,
an
Ecosystem
Toxicity/
Persistence/
Bioaccumulation
Factor
Value
of
5
x
10
8
is
assigned
(Ref.
1,
Table
4­
21).

Ecosystem
Toxicity/
Persistence/
Bioaccumulation
Factor
Value:
5
x
10
8
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
111
SW­
Environmental­
Hazardous
Waste
Quantity
4.1.4.2.2
Hazardous
Waste
Quantity
TABLE
22
Surface
Water
Pathway
Environmental
Threat
­
Hazardous
Waste
Quantity
Source
Number
Source
Hazardous
Waste
Quantity
Value
(Sec.
2.4.2.1.5)
Is
Source
Hazardous
Constituent
Quantity
data
complete?
(yes/
no)

1
>
0,
but
unknown
No
2
11,000
No
Sum
of
Values:
>
11,000
Areas
covered
by
buildings
and
or
maintained,
impenetrable
materials
(such
as
paved
areas),
normally
deducted
from
the
calculation
of
total
areas,
were
not
excluded
from
the
area
calculation
because
they
could
not
be
adequately
delineated
and/
or
identified.
Therefore,
the
area
of
observed
soil
contamination
for
Source
1
will
be
assigned
an
area
hazardous
waste
quantity
value
of
greater
than
(>)
0,
but
unknown.
The
value
of
>0
reflects
that
the
area
value
is
known
to
be
greater
than
0,
but
the
area
measures
have
not
been
determined.

Because
the
site
contains
hazardous
substances
from
CERCLA­
eligible
petroleum
related
wastestreams,
non­
petroleum
related
wastestreams
and
excluded
petroleum
products
that
are
commingled,
all
of
the
Source
1
and
Source
2
hazardous
waste
quantity
is
CERCLA­
eligible
and
will
be
assigned
a
value
accordingly.

The
sum
of
the
Hazardous
Waste
Quantity
Values
for
Source
No.
1,
Contaminated
Soil,
and
Source
2,
Surface
Impoundments
is
>
11,000.
The
sum
of
the
Source
Hazardous
Waste
Quantity
Values
for
the
Gulfco
Marine
Maintenance
site,
rounded
to
the
nearest
integer,
is
11,000.

According
to
HRS
Table
2­
6,
the
Hazardous
Waste
Quantity
Factor
Value
assigned
to
a
Source
Hazardous
Waste
Quantity
Value
of
11,000
is
10,000
(Ref.
1,
Section
2.4.2.2).

Hazardous
Waste
Quantity
Factor
Value:
10,000
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
112
SWOF/
Environmental­
Hazardous
Waste
Quantity
4.1.3.2.3
Waste
Characteristics
Factor
Category
Value
A
Waste
Characteristics
Factor
Value
is
based
on
the
Waste
Characteristics
Product.
The
Waste
Characteristics
Product
is
the
product
of
the
Ecosystem
Toxicity/
Persistence
Factor
Value,
the
Hazardous
Waste
Quantity
Factor
Value,
and
the
Ecosystem
Bioaccumulation
Potential
Factor
Value.

(Ecosystem
Toxicity/
Persistence
x
Hazardous
Waste
Quantity)
x
Bioaccumulation
Potential
=
Waste
Characteristics
Factor
Category
Value
Where:
Ecosystem
Toxicity/
Persistence
Factor
Value
=
10,000
Hazardous
Waste
Quantity
Factor
Value
=
10,000
And:
Ecosystem
Toxicity/
Persistence
x
Hazardous
Waste
Quantity
=
10,000
x
10,000
=
1
x
10
8
Where:
Ecosystem
Toxicity/
Persistence
x
Hazardous
Waste
Quantity
=
1
x
10
8
Ecosystem
Bioaccumulation
Potential
Factor
Value
=
50,000
And:
(Ecosystem
Toxicity/
Persistence
x
Hazardous
Waste
Quantity)
x
Bioaccumulation
Potential
=
1
x
10
8
x
50,000
=
5
x
10
12
A
Waste
Characteristics
Product
of
5
x
10
12
receives
a
Waste
Characteristics
Factor
Category
Value
of
1,000
(Ref.
1,
Table
2­
7).

Waste
Characteristics
Factor
Category
Value:
1,000
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
113
SW­
Environmental
Threat
­
Targets
4.1.4.3
ENVIRONMENTAL
THREAT
­
TARGETS
4.1.4.3.1
Sensitive
Environments
4.1.4.3.1.1
Level
I
Concentrations
No
Level
I
contaminant
concentrations
can
be
documented
for
Surface
Water
Pathway
since
surface
water
samples
or
fish
tissue
samples
were
not
collected
during
the
January
2000
SSI
sampling
event
or
during
the
January
2001
ESI
sampling
event
at
the
former
Gulfco
facility.

4.1.4.3.1.2
Level
II
Concentrations
No
sediment
samples
were
collected
during
either
the
January
2000
SSI
sampling
event
or
during
the
January
2001
ESI
sampling
event
which
subject
sensitive
environments
to
Level
II
concentrations.

Sensitive
Environments
No
data
is
currently
available
to
indicate
the
presence
of
sensitive
environments
subject
to
Level
II
Concentrations.

Wetlands
No
wetland
environments
are
located
within
the
zone
of
Level
II
concentrations
(Ref.
51).
Therefore,
Level
II
contamination
has
not
been
documented
for
a
wetland.

Level
I
Concentration
Factor
Value:
0
Level
II
Concentration
Factor
Value:
0
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
114
SW­
Environmental
Threat
­
Targets
4.1.4.3.1.3
Potential
Contamination
Sensitive
Environments
The
15­
mile
in­
water
segment
of
the
Surface
Water
Pathway
extends
eastward
into
the
Drum
Bay,
Christmas
Bay,
Bastrop
Bay,
and
a
small
portion
of
West
Galveston
Bay.
These
contiguous
surface
water
bodies
are
part
of
the
Galveston
Bay
System
(Ref.
59).
Galveston
Bay
is
the
seventh
largest
estuary
in
the
United
States
and
is
designated
as
a
National
Estuary
as
part
of
the
National
Estuary
Program
(Ref.
60,
p.
7).
Designation
as
a
National
Estuary
is
considered
a
sensitive
environment
for
HRS
purposes
(Ref.
1,
Table
4­
23).
In
addition,
Christmas
Bay
is
designated
as
the
Christmas
Bay
Coastal
Preserve
of
the
Texas
Coastal
Preserve
Program
(Ref.
50).

The
12,199
acre
Brazoria
National
Wildlife
Refuge
lies
south
of
Bastrop
Bayou
and
borders
the
entire
western
shoreline
of
Drum
Bay,
Christmas
Bay,
and
Bastrop
Bay.
The
Intracoastal
Waterway
east
of
Oyster
Creek
extends
through
the
Brazoria
National
Wildlife
Refuge.
Christmas
Bay
harbors
eight
endangered
or
threatened
species
including
the
following
(Ref.
50,
pp.
10,
37
­
39;
Ref.
61;
Ref.
62):

State
(S),
Federal
(F),
Threatened
(T),
Endangered
(E),
Proposed
for
Delisting
(PDL)

Bald
Eagle
(Haliaeetus
leucocephalus)
­
ST,
FT
(PDL)
Brown
Pelican
(Pelecanus
occidentalis)
­
SE,
FE
Peregrine
Falcon
(Falco
peregrinus
tendrils)
­
SE,
ST,
F
Delisted
Whooping
Crane
(Grus
americana)
­
SE,
FE
Piping
Plover
(Charadrius
melodus)
­
ST,
FT
Reddish
Egret
(Egretta
rufescens)
­
ST
White­
faced
Ibis
(Pleads
chichi)
­
ST
Green
Sea
Turtle
(Chelonia
mydas)
­
ST,
FT
Three
additional
species
inhabit
the
adjacent
Brazoria
National
Wildlife
Refuge
including
the
following
(Ref.
50,
pp.
10,
37
­
39,
Ref.
61):

Wood
Stork
(Mycteria
americana)
­
ST
White­
tailed
Hawk
(Buteo
albicaudatus)
­
ST
Swallow­
tailed
Kite
(Elanoides
forficatus)
­
ST
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Documentation
Record
Gulfco
Marine
Maintenance
February
2002
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SW­
Environmental
Threat
­
Targets
Table
23
Surface
Water
Pathway
Sensitive
Environments
Type
of
Surface
Water
Body
Sensitive
Environment
Sensitive
Environment
Value
Reference
Coastal
Tidal
Waters
Intracoastal
Waterway
Christmas
Bay
Drum
Bay
Bastrop
Bay
West
Galveston
Bay
Galveston
Bay
(National
Estuary)
100
Ref.
59;
Ref.
60,
p.
7
Brazoria
National
Wildlife
Refuge
(Wildlife
Refuge)
75
Ref.
50
Federal
Threatened/
Endangered
Species
Habitat
75
Ref.
50;
Ref.
61;
Ref.
62
State
Threatened/
Endangered
Species
Habitat
50
Ref.
50;
Ref.
61;
Ref.
62
Christmas
Bay
Coastal
Preserve
(State
wildlife
management
area)
25
Ref.
50;
Ref.
63;
Ref.
64
Total
325
Wetlands
The
wetland
area
nearest
to
the
former
Gulfco
facility
is
located
approximately
500
feet
south
of
the
facility
across
the
Intracoastal
Waterway.
This
area
is
classified
as
intertidal
estuarine,
emergent,
persistent,
and
regularly
flooded
(Ref.
51).
Additional
intertidal
emergent
estuarine
and
emergent
palustrine
environments
are
located
along
the
surface
water
in­
water
segment.
Total
wetland
frontage
within
the
target
distance
limit
greater
than
20
miles
(Refs.
51,
and
65
­
70;
Ref.
1,
Table
4­
24).
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
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SW­
Environmental
Threat
­
Targets
Table
24
Surface
Water
Pathway
Wetlands
Frontage
Type
of
Surface
Water
Body
Wetlands
Frontage
(Length)
Wetland
Value
for
type
of
Surface
Water
Body
Reference
Coastal
Tidal
Waters
Intracoastal
Waterway
Christmas
Bay
Drum
Bay
Bastrop
Bay
West
Galveston
Bay
>
20
miles
500
Ref.
50
Ref.
65;
Ref.
66;
Ref.
67;
Ref.
68;
Ref.
69;
Ref.
70
Total
500
The
potential
contamination
factor
value
for
the
watershed
is
calculated
by
summing
the
values
for
the
sensitive
environments
including
wetlands
which
are
subject
to
potential
contamination
in
a
particular
surface
water
body
type.
This
value
is
then
multiplied
by
the
dilution
weight
for
the
surface
water
body
type
and
then
multiplied
by
1/
10.

For
a
Surface
Water
Body
Type
([
Value
assigned
for
sensitive
environments
+
value
assigned
for
wetlands]
x
Dilution
weight
for
surface
water
body
type)
x
1/
10
Where:
Value
assigned
for
sensitive
environments
=
325
Value
assigned
for
wetlands
=
500
Dilution
weight
(coastal
tidal
waters)
=
0.0001
(500
+
325)
x
0.0001
=
0.0825
0.0825
x
1/
10
=
0.00825
The
potential
contaminant
value
is
0.00825
Potential
Contamination
Factor
Value:
0.00825
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
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SW­
Environmental
Threat
­
Targets
4.1.4.3.1.4
Calculation
of
Environmental
Threat­
Targets
Factor
Category
Value
The
Environmental
Threat­
Target
Factor
Category
Value
for
the
watershed
is
the
sum
of
the
values
for
the
Level
I
(0),
Level
II
(0),
and
Potential
Contamination
(0.00825)
Factor
Values.
The
resulting
value
of
0.00825
is
assigned
as
the
Environmental
Threat­
Target
Factor
Category
Value
(Ref.
1,
Section
4.1.4.3.1.4).

4.1.4.4
Calculation
of
Environmental
Threat
Score
for
a
Watershed
The
Environmental
Threat
Score
is
calculated
by
multiplying
the
Environmental
Threat
Factor
Category
Values
for
Likelihood
of
Release
(550),
Waste
Characteristics
(1,000),
and
Targets
(0.00825).
The
product
of
these
values
is
then
rounded
to
the
nearest
integer
(4538)
and
divided
by
82,500.
The
resulting
value
(0.055),
subject
to
a
maximum
of
60,
is
assigned
as
the
Environmental
Threat
Score
for
the
watershed
(Ref.
1,
Section
4.1.4.4).

4.1.5
Calculation
of
Overland/
Flood
Migration
Component
Score
for
a
Watershed
The
Overland/
Flood
Migration
Component
Score
for
the
watershed
is
calculated
by
summing
the
scores
for
the
Drinking
Water
Threat
(0),
the
Human
Food
Chain
Threat
(100),
and
the
Environmental
Threat
(0.055).
The
resulting
score,
subject
to
a
maximum
value
of
100,
is
assigned
as
the
Surface
Water
Overland/
Flood
Migration
Component
Score
for
the
watershed
(Ref.
1,
Section
4.1.5).

4.1.6
Calculation
of
Overland/
Flood
Migration
Component
Score
The
highest
surface
water
overland/
flood
migration
component
score
for
the
watershed
evaluated
(only
one
watershed
was
evaluated
for
this
Documentation
Record)
is
selected
and
assigned
as
the
Surface
Water
Overland/
Flood
Migration
Component
Score
for
the
facility,
subject
to
a
maximum
of
100.
The
Surface
Water
Overland/
Flood
Migration
Component
Score
is
assigned
a
value
of
100
(Ref.
1,
Section
4.1.6).

Environmental
Threat­
Target
Factor
Category
Value:
0.00825
Environmental
Threat
Score:
0.055
Surface
Water
Overland/
Flood
Migration
Component
Score:
100
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
118
SW
­
GW/
SW
Migration
Component
4.2
GROUND
WATER
TO
SURFACE
WATER
MIGRATION
COMPONENT
The
ground
water
to
surface
water
migration
component
was
not
evaluated
since
the
ground
water
to
surface
water
component
score
would
not
be
greater
than
the
surface
water
overland/
flood
component.

4.3
CALCULATION
OF
SURFACE
WATER
MIGRATION
PATHWAY
SCORE
Only
the
Overland/
Flood
Migration
Component
(100)
was
scored.
The
value
of
100
is
assigned
as
the
Surface
Water
Migration
Pathway
Score.

Surface
Water
Migration
Pathway
Score:
100
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
119
5.0
SOIL
EXPOSURE
PATHWAY
5.0.1
GENERAL
CONSIDERATIONS
The
Soil
Exposure
Pathway
was
not
scored
due
to
the
lack
of
residential
targets
and
because
inclusion
of
this
pathway
would
not
significantly
affect
the
site
score.
HRS
Documentation
Record
Gulfco
Marine
Maintenance
February
2002
TXD055144539
120
6.0
AIR
MIGRATION
PATHWAY
6.1.1
OBSERVED
RELEASE
The
Air
Migration
Pathway
was
not
scored
due
to
the
lack
of
an
observed
release
to
the
pathway
and
because
inclusion
of
this
pathway
would
not
significantly
affect
the
site
score.
