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 <IP_ADDRESS>.1 Hazardous Constituent Quantity ................................. 36 <IP_ADDRESS>.2 Hazardous Waste Stream Quantity ............................... 36 <IP_ADDRESS>.3 Volume ................................................... 36 <IP_ADDRESS>.4 Area ..................................................... 37 <IP_ADDRESS>.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 <IP_ADDRESS>.1 Hazardous Constituent Quantity ................................. 63 <IP_ADDRESS>.2 Hazardous Waste Stream Quantity ............................... 63 <IP_ADDRESS>.3 Volume ................................................... 63 <IP_ADDRESS>.4 Area ..................................................... 64 <IP_ADDRESS>.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 <IP_ADDRESS> 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 <IP_ADDRESS> Likelihood of Release .............................................. 78 <IP_ADDRESS>.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 <IP_ADDRESS> Human Food Chain Threat  Likelihood of Release ........................ 90 <IP_ADDRESS> Human Food Chain Threat  Waste Characteristics ........................ 90 <IP_ADDRESS>.1 Toxicity/ Persistence/ Bioaccumulation ............................. 90 <IP_ADDRESS>.1.1 Toxicity Factor Value ......................................... 90 <IP_ADDRESS>.1.2 Persistence Factor Value ...................................... 90 <IP_ADDRESS>.1.3 Bioaccumulation Potential Factor Value ........................... 91 <IP_ADDRESS>.2 Hazardous Waste Quantity ..................................... 97 <IP_ADDRESS>.3 Waste Characteristics Factor Category Value ....................... 98 <IP_ADDRESS> 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 <IP_ADDRESS>.1 Food Chain Individual ....................................... 100 <IP_ADDRESS>.2 Population ................................................ 102 <IP_ADDRESS>.2.1 Level I Contamination ....................................... 102 <IP_ADDRESS>.2.2 Level II Contamination ....................................... 102 <IP_ADDRESS>.2.3 Potential Human Food Chain Contamination ....................... 103 <IP_ADDRESS>.2.4 Calculation of Population Factor Value ........................... 104 <IP_ADDRESS>.3 Calculation of HFC Threat  Targets Factor Category Value ........... 104 <IP_ADDRESS> Calculation of Food Chain Threat Score ............................... 104 4.1.4 Environmental Threat ........................................ 105 <IP_ADDRESS> Environmental Threat  Likelihood of Release ........................... 105 <IP_ADDRESS> Environmental Threat  Waste Characteristics ........................... 105 iii <IP_ADDRESS>.1 Ecosystem Toxicity/ Persistence/ Bioaccumulation ................... 105 <IP_ADDRESS>.1.1 Ecosystem Toxicity ......................................... 105 <IP_ADDRESS>.1.2 Persistence ............................................... 105 <IP_ADDRESS>.1.3 Ecosystem Bioaccumulation ................................... 105 <IP_ADDRESS>.2 Hazardous Waste Quantity .................................... 111 <IP_ADDRESS>.3 Waste Characteristics Factor Category Value ...................... 112 <IP_ADDRESS> Environmental Threat  Targets ...................................... 113 <IP_ADDRESS>.1 Sensitive Environments ....................................... 113 <IP_ADDRESS>.1.1 Level I Concentrations ....................................... 113 <IP_ADDRESS>.1.2 Level II Concentrations ...................................... 113 Sensitive Environments ....................................... 113 Wetlands ................................................. 113 <IP_ADDRESS>.1.3 Potential Contamination ...................................... 114 Sensitive Environments ....................................... 114 Wetlands ................................................. 115 <IP_ADDRESS>.1.4 Calculation of Environmental Threat  Targets Factor Category Value ............................................ 117 <IP_ADDRESS> 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 <IP_ADDRESS> 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 <IP_ADDRESS>) are presented under the Surface Water Migration Pathway section of this Documentation Record.

2.4.2. Hazardous Waste Quantity <IP_ADDRESS>.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 <IP_ADDRESS>.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 <IP_ADDRESS>.1).

<IP_ADDRESS>.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 <IP_ADDRESS>.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 <IP_ADDRESS>.2).

<IP_ADDRESS>.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 <IP_ADDRESS>.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 <IP_ADDRESS>.3). HRS Documentation Record Gulfco Marine Maintenance February 2002 TXD055144539 36 SD Waste Characteristics Source No. 1, Contaminated Soil <IP_ADDRESS>.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 <IP_ADDRESS>.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 <IP_ADDRESS>.1 <IP_ADDRESS>.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 <IP_ADDRESS>.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 <IP_ADDRESS>.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 <IP_ADDRESS> 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 <IP_ADDRESS>) are presented under the Surface Water Migration Pathway section of this Documentation Record.

2.4.2. Hazardous Waste Quantity <IP_ADDRESS>.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 <IP_ADDRESS>.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 <IP_ADDRESS>.1).

<IP_ADDRESS>.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 <IP_ADDRESS>.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 <IP_ADDRESS>.2).

<IP_ADDRESS>.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 <IP_ADDRESS>.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)

<IP_ADDRESS>.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 <IP_ADDRESS>.1 <IP_ADDRESS>.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 <IP_ADDRESS>.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 <IP_ADDRESS>, 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 <IP_ADDRESS> 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)