RAP Executive Summary
ID No.: 1471
Report Date: April 2016
Use this worksheet to summarize the report. Be sure to complete and submit the Checklist for Report
Completeness. Attach a chronology of activities associated with the affected property.
Briefly describe the affected property and PCLE zones, the conclusions from the assessment activities,
identify any affected or threatened receptors, and describe any other major considerations taken into
account when developing this response action plan. If any portion of the response action is necessitated
due to an aesthetic or nuisance condition, identify the nature of that condition and identify that portion of
the response action proposed to address it. If any media that contains a PCLE zone is not addressed in
this RAP, provide justification.
The subject property, the Austin Energy (AE) Holly Street Power Plant (HSPP), is located on Holly Street
in east Austin, Texas. The site is a former gas- and fuel-oil-fired power plant that has been
decommissioned and is in the process of being demolished. At present, the majority of the surface
structures have been demolished, and the resulting demolition wastes removed. The remaining portions
of the facility include the turbine generator building basement, boiler foundations, and surface and
subsurface structures related to the stormwater system (pipes and oil/water separators). These will be
addressed in the upcoming phases of the project. Some structures at the site will remain in service with
AE, or will be transferred to the City of Austin Parks and Recreation Department (PARD). The structures
include the switch yard (retained by AE), STATCON (retained by AE), Building X (retained by AE), the onsite laboratory (retained by AE), and the warehouse (transferred to PARD). AE plans to either: 1) convert
the utility connections to new uses; or 2) isolate/take them out of service, demolish remaining power plant
structures, and redevelop a portion of the property as parkland. The surrounding property to the west,
north, and northeast of the site is primarily residential, with intermixed commercial shops and restaurants.
Public parks are located on the northern and western edge of the property. Lady Bird Lake is located to
the east of the property.
This Response Action Plan (RAP) describes the proposed soil response actions at the North Assessment
Area (NAA) of the HSPP. The South Assessment Area (SAA) was addressed in earlier phases of the
project. The NAA includes 15.2-acres located on the northern portion of the 19-acre HSPP. The NAA is
comprised of the former power generation facility and ancillary buildings/structures. The current phase of
the project addresses affected soil in the NAA. The NAA is split into two areas: the portion of the property
to be retained by AE, which will be remediated to Commercial/Industrial critical Protective Concentration
Limits (PCLs), and the portion of the property to be transferred to PARD, which will be remediated to
Residential Assessment Levels (RALs).
In addition to the affected soil, elevated concentrations of arsenic have been reported in the shallow
groundwater aquifer. Currently, a quarterly groundwater program is being implemented to determine the
extent and stability of the arsenic plume. Per agreement with TCEQ, the groundwater is not addressed in
this RAP related to the planned soil removal activities in the NAA, nor in those actions completed
previously in the SAA. The site layout is illustrated in Attachment 1A-1.
This RAP proposes appropriate response actions based on the findings of the NAA soil assessment,
which were described in the Affected Property Assessment Report (APAR) for the NAA dated February
2016. The RALs are considered the critical PCLs on the portion of the property being transferred to
PARD. The portion of the property being retained by AE will be deed-recorded as Commercial/Industrial;
therefore, the critical PCLs on this portion of the property are the Commercial/Industrial TotSoilComb PCLs.
AE also intends to deed record both the NAA and SAA to restrict the use of groundwater; therefore, the
GW
SoilIng pathways will be incomplete when this restriction is in place.
Surface Soils
A total of 1,181 surface soil (less than 15 feet [ft] below ground surface [bgs]) samples were collected
during Phase III and Phase IV investigation activities at the NAA. Trace amounts of non-aqueous phase
liquids (NAPL) were observed in surface soils during demolition activities at the NAA. The NAPL was
discovered in two locations within a utility trench adjacent to a buried natural gas/fuel oil pipe. It was
unknown if the NAPL was related to a historical leak, or was due to residual fuel oil leaking during pipe removal.
RAP Executive Summary
ID No.: 1471
Report Date: April 2016
The following COCs were reported above the RALs in one or more surface soil samples collected at the
subject property: TPH fractions C6-C12, >C12-C28, and >C28-C35; metals, including antimony, arsenic,
lead, and selenium; SVOCs, including bis(2-ethyl-hexyl)phthalate, carbazole, pentachlorophenol, and
PAHs benz(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenz(a,h)anthracene, and
indeno(1,2,3-cd)pyrene; VOC methylene chloride; and PCBs. Methylene chloride and bis(2-ethylhexyl)phthalate are recognized as common laboratory contaminants in 30 TAC 350.71(k)(2)(B).
On the portion of the property to be transferred to PARD, concentrations of antimony, arsenic,
benzo(a)pyrene, beno(b)fluoranthene, dibenz(a,h)anthracene, TPH, and PCBs exceeded the TotSoilComb
RALs. The soils in the grids with exceedances (depths ranging from 0.5 to 14.0 ft bgs) will be removed
during remediation activities. Verification (i.e., confirmation) soil samples will be collected and analyzed
after the soil is removed.
On the portion of the property to be retained for Commercial/Industrial use by AE, concentrations of lead,
benzo(a)pyrene, TPH, and PCBs exceeded the Commercial/Industrial TotSoilComb critical PCLs. The soils
in the grids with exceedances (depths ranging from 0.5 to 12.0 ft bgs) will be removed during remediation
activities. Verification (i.e., confirmation) soil samples will be collected and analyzed after the soil is
removed.
Subsurface Soils
A total of 52 subsurface (greater than 15 ft bgs) soil samples were collected during Phase IV investigation
activities. No subsurface soil samples were collected during Phase III demolition activities. The
subsurface soil sample results were compared to RALs and Texas Specific Background Concentrations
(TSBCs). No concentrations in the subsurface soil exceeded the applicable RALs or
Commercial/Industrial PCLs.
Response Actions
AE’s planned response actions for the NAA are based upon the proposed future uses of the property. AE
intends to perform the response actions in accordance with TRRP Remedy Standard B, employing a mix
of institutional controls and excavation and off-site disposal of soils that exceed the applicable critical
PCLs. AE intends to deed record the entire property, including both the SAA and the NAA, to prevent
future groundwater usage; therefore, the groundwater ingestion and soil-to-groundwater ingestion
pathways will be incomplete. The groundwater is being addressed separately.
Those areas that will be retained by AE for continued use will also be deed recorded for C/I use only.
After those deed restrictions are in place, the areas with COC concentrations in soil exceeding the RALs
for direct contact (TotSoilComb) on the PARD portion of the property and the Commercial/Industrial critical
PCLs for direct contact (TotSoilComb) on the AE portion of the property will be excavated, confirmation
samples will be collected and analyzed, and the resulting material disposed of off-site at a permitted
landfill. The excavated areas will be backfilled, and the surface returned to as appropriate for the
surrounding area and use.
What is the selected remedy standard for this affected property?
A
X
B
*The soil will be removed/remediated to Remedy Standard A; however the groundwater will be closed
under Remedy Standard B under a separate investigation. Therefore, in accordance with TCEQ guidance
document Application of Remedy Standards A and B (RG-366/TRRP-28), Remedy Standard B is applied
to the entire property.
List all media that contains a PCLE zone and specify the proposed response action for each media.
Indicate the type of removal, decontamination, physical control and/or institutional control action that is
proposed.
RAP Executive Summary
ID No.: 1471
Report Date: April 2016
COCs1
Media
Removal
Decontamination
Physical
Control
Soil
TPH, Metals,
SVOC, PCBs
X
Control
Modified Groundwater Response
Objective2
Restrictive
WCU
TI
Covenant
X
Is there a media that contains a PCLE zone that is not addressed in this RAP?
If yes, provide justification for not addressing the PCLE zone in this RAP.
X
yes
no
In addition to the affected soil, elevated concentrations of arsenic have been reported in the shallow
groundwater aquifer. Currently, a quarterly groundwater program is being implemented to determine the
extent and stability of the arsenic plume. Per agreement with TCEQ, the groundwater is not addressed
in this RAP.
On-site land use:
Off-site land use:
X
X
Residential
Residential
X
Commercial/Industrial
Commercial/Industrial
Is this a re-submittal or revision of a previous RAP?
Yes
If yes, explain why the RAP is being revised or resubmitted.
NA
(check all that apply)
X No
Were all the appropriate notifications made in accordance with §350.55?
If no, explain why notifications were not made:
X Yes
No
NA
1
Specify either a specific COC or, if the response action is the same for all COCs in one type, specify the type of
COC (for example, VOCs, SVOCs, metals).
2 If a modified groundwater response objective is proposed, check the type(s) of proposed modifications.
RAP Executive Summary
ID No.: 1471
Report Date: April 2016
Chronology
A chronology of events associated with the site is presented below.
1951
Prior to this date, the property was used for agricultural practices.
1951–1964
Units No. 1 and 2 of the Holly Power Plant were built and began operation at
2401 Holly Street in Austin, Texas.
1964–1970
Units No. 3 and 4 were added to the existing Holly Power Plant and began
operation.
1970–1980
Four fuel oil tanks were constructed in the tank yard area of the site. Tank No.
44 stored No. 2 fuel oil, and the other three tanks contained No. 5 fuel oil.
November 1991
Approximately 10,000 gallons of No. 5 fuel oil was released into the Tank No. 42
containment area due to a leak in the pipe flange. The free oil was immediately
removed and recycled; the contaminated soil was addressed by removal.
September 1992
Approximately 1,000 gallons of No. 5 fuel oil was released from Tank No. 45
containment area from a pipe coupling. The spill was due to operator error in
routing the fuel oil, which caused the line to overpressure. The free oil was
immediately removed and recycled; contaminated soil was removed.
March 1993
A fire occurred in the Tank No. 45 containment area, reportedly fueled by the
No.5 fuel oil contained in a length of surficial piping. The fire was extinguished
by the fire department. Approximately 200 gallons of No. 5 fuel oil was released.
The free oil and water were immediately removed, and the contaminated soil was
addressed.
1993
Monitoring wells MW-1 through MW-7 were installed around the perimeter of the
Tank Yard and Laydown Areas.
1988–1997
Two of the four fuel oil tanks (Tank 44 and Tank 45) in the tank yard were
dismantled.
April/May 2003
The remaining two ASTs were removed from the tank yard area. Aboveground
piping leading from the tanks to the fuel oil pump room (currently, the Reverse
Osmosis building) was also removed.
2003
Assessment and abandonment of a 2,000,000-gallon underground storage tank
(UST).
2005
Units No. 1 and 2 were no longer used for power generation, and Units No. 3 and
4 were used during peak power demands only.
March 2005
Shallow soil borings and three monitoring wells, MW-8 through MW-10, were
installed in the former tank yard and laydown areas. Soil and groundwater
samples were collected and analyzed for the constituents of concern at the site.
June 2006
An APAR for the Holly site was submitted to the TCEQ.
RAP Executive Summary
ID No.: 1471
Report Date: April 2016
November 2006
A Final Technical Report for Supplemental Site Investigation of the UST 11 Area
was submitted to City of Austin Watershed Protection Department.
2007
Plant was designated for decommissioning starting in 2007.
February 2008
A report, The Evaluation of Arsenic Concentrations in Groundwater at Holly
Street Power Plant, described the results of arsenic sampling in soil groundwater,
surface water, and sediment from the subject property and adjacent Lady Bird
Lake (formerly Town Lake). Monitoring wells MW-2A, MW-6A, MW-21, and MW22 were installed.
Arsenic concentrations were not reported above the
applicable soil, surface water, or sediment PCLs. Arsenic concentrations were
reported in groundwater above the critical PCL and below the groundwater to
surface water PCL at the points of exposure (POE) wells. The report postulated
that the elevated arsenic in groundwater could result from biodegradation of TPH
in soil causing a change in the geochemistry in the area (reducing environment)
and leaching naturally occurring arsenic from the soil. In addition, soil samples
were collected from the soil cores for TPH, and reported concentrations were
below the critical PCLs based on the TX-1006 results.
October 2010
Slug tests were conducted to hydraulically characterize the affected
groundwater-bearing unit. Based on the results, the affected groundwaterbearing unit was classified as a Class 2 Aquifer.
January 2011
A groundwater sampling event was conducted for arsenic and included all on-site
monitoring wells.
August 2011
A RAP was submitted to TCEQ for the soil and groundwater response actions of
the Partial Response Action Area A (PRAA-A) located on the southern half of the
property in the former tank yard and laydown area. Data collected during the
January 2011 groundwater sampling event were presented within the RAP.
September 2011
TCEQ approved the PRAA-A RAP.
November 2011
A groundwater sampling event was conducted that included all on-site monitoring
wells. Permanent groundwater monitoring wells MW-22R and MW-23 were
installed, and MW-22 was plugged and abandoned.
December 2011
Austin Energy began decommissioning activities at the Holly site.
July–August 2012
A groundwater sampling event included all on-site monitoring wells. Soil borings
were advanced within PRAA-A to delineate COCs in the soils.
September 2012
A RAP Addendum for PRAA-A was submitted. The RAP Addendum described
the variance from the original RAP since the PRAA-A was not used as a staging
area during power plant demolition. TCEQ approved the RAP Amendment in a
letter dated 24 September 2012. (Austin Energy, 2012a)
October 2012
A memorandum proposed an amendment to select soil RALs and CPCLs for
PRAA-A. TCEQ accepted the proposed RALs and CPCLs in a letter dated 31
October 2012. (Austin Energy, 2012b)
November–
December 2012
Soil removal and confirmation sampling were completed in PRAA-A. Monitoring
wells MW-08 and MW-09 were plugged and abandoned. The 2011/2012 Annual
RAP Executive Summary
ID No.: 1471
Report Date: April 2016
Groundwater Monitoring Report was submitted and summarized the groundwater
sampling events performed November 2011 through August 2012.
January 2013
A groundwater sampling event included all on-site monitoring wells. TCEQ
approved the 2011/2012 Annual Groundwater Monitoring Report Holly Street
Power Report in a letter dated 9 January 2013.
April 2013
A groundwater sampling event included all on-site monitoring wells. A Response
Action Completion Report (RACR) was submitted to TCEQ for the soil response
actions of PRAA-A located on the southern half of the property in the former tank
yard and laydown area.
June 2013
TCEQ approved the PRAA-A RACR in a letter dated 6 June 2013.
December 2013
The 2013 Annual Groundwater Monitoring Report was submitted and
summarized the groundwater sampling events performed January 2013 through
October 2013.
January 2014
A groundwater sampling event was conducted. TCEQ approved the 2013 Annual
Groundwater Monitoring Report Holly Street Power Report in a letter dated 16
January 2014. Phase III decommissioning activities were completed, with the
exception of the following structures: Turbine Generator Building basement,
Boiler 3 foundation, and transformer foundations. WESTON and Austin Energy
met with TCEQ to discuss the decommissioning status and a path forward with
soil sampling.
April/May 2014
A groundwater sampling event was conducted. The Holly Phase III Building
Decommissioning Report was submitted to Austin Energy.
June 2014
Austin Energy approved additional site investigation activities and scopes of work
for the demolition of the remaining structures.
July 2014
A groundwater sampling event was conducted. A driveway (Holly Street
Extension) caulk investigation and the Southeast Warehouse soil sampling for
antimony and PCBs analysis were conducted.
July 2014
A soil investigation was conducted near the South Oil/Water Separator in the
SAA.
September 2014
The following investigation summary letter reports were submitted to Austin
Energy: Driveway Caulk Investigation, South Oil/Water Separator Soil
Investigation, and Southeast Warehouse Soil Sample Investigation for PCBs.
The North Assessment Area Investigation Scope of Work for the soil gridsampling was submitted to TCEQ.
October 2014
A groundwater sampling event included all on-site monitoring wells. WESTON
and Austin Energy met with TCEQ to discuss the North Assessment Area
Investigation Scope of Work and details of the soil sampling event. TCEQ
approved the North Assessment Area Investigation Scope of Work in an email
dated 16 October 2014.
November 2014
NAA soil sampling began following the 50-foot-by-50-foot grid pattern.
RAP Executive Summary
ID No.: 1471
Report Date: April 2016
December 2014
Storm-sewer sediment and pipe-invert investigations for PCB analysis were
performed.
January 2015
The NAA grid soil sampling was completed.
February 2015
The storm-sewer sediment and pipe-invert investigation summary letter reports
were submitted to Austin Energy.
May 2015
A groundwater sampling event was conducted.
September 2015
AE and WESTON meet with TCEQ to review soil sampling results and to discuss
a path forward for APAR submittal, AE plans for site remediation and RAP
submittal.
September 2015
A groundwater sampling event was conducted.
December 2015
A groundwater sampling event was conducted.
January 2016
Ownership of a portion of the property was transferred to PARD.
Checklist for Report Completeness
ID No.: 1471
Report Date: April 2016
Use this checklist to determine the portions of the form that must be submitted for this report. Answer all questions by
checking Yes or No. If the answer is Yes include that portion of the report. If the answer is No, do not complete or submit
that portion of the report. All form contents that are marked "Required" must be submitted. Form contents marked with an
asterisk (*) are not included in the blank form and are to be provided by the person.
Report
Contents
No
Have new data been collected that was not previously
submitted?
Required
Cover Page
Required
Executive Summary
Required
Checklist for Report
Completeness
Required
Worksheet 1.0
Response Action Objectives
Yes
Attachment 1A*
Maps and Cross Sections
Attachment 1B*
Graphs of Concentration versus
Time
Required
Worksheet 2.0
Response Action Design
Required
Attachment 2A*
Response Action Diagrams and
Component/Equipment
Descriptions
Required
Attachment 2B*
Proposed Well Design
No
Is an ecological services analysis or compensatory
restoration plan part of the proposed response action?
Yes
Attachment 2C*
ESA and Compensatory
Restoration Plan
No
Is a plume management zone proposed as part of the
response action?
Yes
Worksheet 2.1
Plume Management Zone
Attachment 2D*
Plume Management Zone Map
Attachment 2E*
Attenuation Action Levels
Determination
No
Is a waste control unit proposed as part of the response
action?
Yes
Worksheet 2.2
Waste Control Unit
Attachment 2F*
Map of Waste Control Unit
No
Is a technical impracticability area proposed as part of the
response action?
Yes
Worksheet 2.3
Technical Impracticability
Attachment 2G*
Map of Technical
Impracticability Area
Checklist for Report Completeness
ID No.: 1471
Report Date: April 2016
Report
Contents
No
No
Is the response action a remedy standard B?
Is the response action a Remedy Standard B?
Yes
Worksheet 2.4
Institutional Controls
Required
Worksheet 3.0
Performance Measures and
Potential Problems
Required
Worksheet 3.1
Monitoring and Sampling
Required
Attachment 3A*
Map of Monitoring and Sampling
Points
Required
Worksheet 3.2
Operation and Maintenance
Required
Worksheet 4.0
Confirmation Sampling Plan
Required
Attachment 4A*
Map of Confirmation Sampling
Points
Yes
Worksheet 5.0
Post Response Action Care
Attachment 5A*
Map of PRAC Monitoring and
Sampling Points
Attachment 5B*
PRAC Costs
No
Does the person, who is a small business, desire to
modify the financial assurance requirement?
Yes
Attachment 5C*
Small Business Affidavit
Required
Worksheet 6.0
Implementation Schedule
Required
Appendix 1*
References
No
Was any data collected that was not previously
reported?
Yes
Appendix 2*
Data Tables and Boring Logs
No
Were any studies or tests conducted?
Yes
Appendix 3*
Studies and Tests
Documentation
No
Is the response action a Remedy Standard B?
Yes
Appendix 4*
Proposed Institutional Controls
No
Are any institutional controls proposed/required on
property not owned by the person?
Yes
Appendix 5*
Landowner Concurrence
No
Are any of the sample collection or handling
procedures different from those reporting in the APAR
or other previously submitted report?
Yes
Appendix 6*
Sampling Procedures
No
Are statistics or geostatistics proposed to be used as
part of the response action?
Yes
Appendix 7*
Statistical Methodology
No
Was approval received from the TCEQ regarding the
use of different rules to address a media?
Yes
Appendix 8*
Split Media Approval
Form contents marked with an asterisk (*) are not included in the blank form.
Response Action Objectives
RAP Worksheet 1.0
ID No.: 1471
Page 1 of 2
Report Date: April 2016
Use this worksheet to describe the objectives for the response action in each media.
Response Action Objectives
List the environmental media to which this applies Soil
Repeat this section for each medium that has a different response action objective.
State the property-specific response objectives for the PCLE zone in each media in the context of the
response objectives set forth in §350.32 or §350.33 as applicable. Explain how the response action is
appropriate based on the hydrogeologic characteristics, COC characteristics, and potential unprotective
conditions that could continue or result during the remedial period.
The objective of the response action for the soil PCLE zones is to remove affected soils exceeding
applicable PCLs for off-site disposal. The affected soils above the RALs (on the portion of the property
being transferred to PARD) and above the Commercial/Industrial critical PCLs (on the portion of the
property remaining in use by AE) are located in the vadose zone. The soil response action will result in
complete removal of the soil PCLE zones at the NAA.
Explain how the COCs will be handled, treated, disposed, or transferred to another media and document that
the response action will not result in any additional potential exposure conditions due to response action
activities.
Excavated affected soil will be stored in a secure location within one or more designated Soil Staging
Areas on the facility. The exact locations of the soil staging areas will be identified prior to soil removal
activities. Stockpiled soil will be lined and covered at all times with a waterproof plastic covering secured
to remain in place during high winds and rain.
The stockpiled or stored soils will be sampled and analyzed for waste characterization purposes. Based
on these results, soil piles will be classified as Class 1 or Class 2 Non-hazardous industrial solid waste, or
hazardous waste as appropriate. Specific analyses will be selected based on landfill requirements, but
may include total and/or Toxicity Characteristic Leaching Procedure (TCLP) metals (USEPA Method
6010), TPH (Texas Method 1005), total and/or TCLP VOCs (USEPA Method 8620), and total and/or
TCLP SVOCs (including PAHs) (USEPA Method 8081/8082).
Waste characterization samples will be collected from each soil pile using the following procedure. Each
soil pile will be divided into estimated volumes required by the receiving landfill for waste profiling. An
equivalent aliquot of soil will be collected from each section, at a location approximately 4 ft above the
ground surface and approximately 1 ft deep below the pile surface. The four aliquots of soil from each
pile will be placed in laboratory-supplied containers. The aliquots of soil will be composited in the
laboratory under inert conditions prior to laboratory analysis.
During the soil response action, airborne particulate concentrations will be monitored and logged using an
aerosol monitor such as a Personal DataRAM (PDR). The action level for particulates was determined
using half of the American Conference of Governmental Industrial Hygienists (ACGIH)-established
nuisance dust concentration of 3.0 milligrams per cubic meter (mg/m3). If particulate readings of 3.0
mg/m3 are sustained in the air immediately downwind of remediation activities or within the breathing
zone of the remediation workers, dust control measures will be implemented. Dust control measures
could include spraying the area with water or using a wind screen. If these measures do not reduce
particulate readings to less than 3.0 mg/m3, remediation will stop until alternative dust control measures
can be put into place and are demonstrated to be effective at reducing particulates to an acceptable level.
Stormwater management and sediment controls will be maintained throughout the project site during soil
remediation activities. A Stormwater Pollution Prevention Plan detailing stormwater controls will be
prepared and available on-site during remediation and construction activities.
Response Action Objectives
RAP Worksheet 1.0
ID No.: 1471
Page 2 of 2
Report Date: April 2016
State the proposed “reasonable time frame” and provide the justification for that time frame in the context of
any potential for unprotective exposures to exist or develop, COC characteristics, hydrogeologic and affected
property characteristics. If the reasonable time frame is different for the different affected media or for
particular tracts of land, be sure to discuss that. Provide how the proposed response action will meet the
objectives in a reasonable timeframe.
Soil response action activities will start after removal of the remaining structures and after TCEQ approval
of the RAP, tentatively scheduled for May or June 2016, and response action activities will be complete
within four months of initiation.
Based on the sensitive receptor analysis and exposure pathway evaluations completed for the APAR, it is
unlikely that exposures will develop during RAP implementation. The affected soil is within the limits of a
fenced industrial facility, and response action will result in the complete removal of the soil PCLE zones
above the applicable RALs or critical PCLs.
Soil Response Action Objectives
When using removal and/or decontamination with controls or controls only, demonstrate how that physical
control or combination of measures will reliably contain COCs within and/or derived from the surface soil and
subsurface soil PCLE zone materials over time.
The soil response action will result in the complete removal of the soil PCLE zones for future conversion
of a portion of the property to public parkland, and continued use by AE on the remaining portion.
Explain how the removal or decontamination action will reduce the concentration of COCs to the critical
surface soil and subsurface soil PCL throughout the soil PCLE zone and prevent COC concentrations above
the critical soil PCLs from migrating beyond the existing boundary of the soil PCLE zone.
The soil response action will result in the complete removal of the soil PCLE zones for future conversion
of a portion of the property to public parkland, and continued use by AE on the remaining portion.
Use this worksheet to describe the objectives for the response action in each media.
Response Action Design
RAP Worksheet 2.0
ID No.: 1471
Page 1 of 1
Report Date: April 2016
Response Action Design
Use this worksheet to provide detailed descriptions of the response action. Attach design and layout drawings
and equipment specifications in Attachment 2A.
Media:
Soil
List all media to which this information applies. If the response action is different for another media, complete
a separate worksheet.
Provide a detailed description of the response action. Describe the removal action, decontamination,
treatment system(s), and/or physical or institutional control actions that are proposed for each media and
discuss the reasons for choosing the response action(s). Identify and describe any ecological services
analysis and compensatory restoration plan that will be utilized (if so, include the complete ESA and
compensatory restoration plan in Attachment 2C).
The response action will include the excavation of affected soil with concentrations of COCs above the
RALs on the portion of the property to be transferred to PARD and above Commercial/Industrial critical
PCLs on the portion of the property to be retained for use by AE. After excavation is completed,
confirmation samples will be collected and analyzed to verify that COC concentrations remaining in soils
are less than the applicable RALs or critical PCLs. Institutional controls (land use restricted to
commercial/industrial) will be placed on the portion of the property that will be retained for use by AE.
This response action was selected because it will result in compete removal of the soil PCLE zones at
the NAA.
Describe all major treatment system components and equipment of the response action. Illustrate the
response action design and provide equipment specifications in Attachment 2A.
There are no major treatment system components or equipment proposed for the response action.
List permits or registrations needed to construct or implement the response action, including permits or
registrations needed to conduct studies or tests. For VCP sites, list the permits that would be required if the
site was not in the VCP (required by the VCP).
Permitting/Registration
Type of permit/registration
Permit or registration
Anticipated
Authority
number if already
application date
issued
NA
RAP Worksheet 2.4
Institutional Controls
ID No.: 1471
Associated Information: Appendices 4, 5
Page 1 of 1
Report Date: April 2016
Complete this worksheet if an institutional control will be used as part of the response action. Include a draft of the proposed institutional controls
in Appendix 4. Provide a list of landowners from whom landowner concurrence will be requested, as necessary, in Appendix 5.
Specify the property for which this applies. Holly Street Power Plant – Portion of NAA to be Retained by AE for Commercial/Industrial Use
Repeat this worksheet for each different property for which an institutional control will be used.
Type of Institutional Control1
Institutional Control
Deed
Notice
Document use of commercial/industrial land use
(§350.31(g))
X
Document establishing a PMZ (§350.33(f)(4)(C)(I))
Document the demonstration of technical impracticability
(§350.33(f)(3)(F))
Relocation of soils containing COCs for reuse (§350.36(b)(4)
and (c)(4))
2
Anticipated
Filing Date2
Restrictive
VCP
Equivalent
Check if
Check if the
Covenant Certificate of
zoning or
Completion governmental pertinent tract pertinent tract of
of land is
land is owned by
ordinance
owned by the
an innocent
person
owner or
operator
X
Prior to
excavation of
soil PCLE
zones
Document use of physical or institutional control under
Remedy Standard B §350.31(g))
Document notice of on-going long term response action
(§350.31(h))
Document use of occupational inhalation criteria as RBELs
(§350.74(b)(1))
Document variance from the default exposure factors
(§350.74(j)(2)(L))
Document the use of a non-default soil exposure area
(§350.51(l)(3)&(4))
Document WCU exclusion area (§350.33(f)(2))
1
Property Ownership
Check the appropriate box(es) to indicate the type of institutional control required for the proposed response action.
Specify date or amount of time after RAP approval.
Performance Measures and
Potential Problems
RAP Worksheet 3.0
Page 1 of 1
Report Date: April 2016
ID No.: 1471
Performance Measures
List and describe the performance measures for each environmental medium containing a PCLE zone
that will be used to determine if reasonable progress is being made by the response action in a timely
manner. Use these measures to document effectiveness of the response action in the RAER.
The performance measures are based on adherence to schedule and the results from confirmation
sampling. The soil response actions are projected to be completed within four months after TCEQ
approval to proceed and will most likely coincide with the removal of remaining structures.
The confirmation samples collected after completion of the soil response actions will be compared to
applicable RALs or Commercial/Industrial critical PCLs to verify that excavation goals have been met.
Potential Problems
Complete the table for the response action. When the response action consists of several
components or multiple actions, complete one table for each major component or action.
Response Action Name/Designation:
NAA Soil
List the potential problems that might be reasonably anticipated for the response action, describe the
impact of each problem, and the response to the problem.
Description of the Potential
Impact
Will this
Corrective Response
Problem
cause a
response
action
failure?
Yes
No
Confirmation samples
collected after excavation
report COC concentrations
above critical PCLs
Schedule delay and
financial impact
X
Excavate additional material and
resample
RAP Worksheet 3.1
Monitoring and Sampling
ID No.: 1471
Associated Information: Attachment 3A
Page 1 of 1
Report Date: April 2016
List the monitoring and sampling of COC concentrations or other parameters that will be conducted during the response action. Illustrate the
monitoring or sampling locations in Attachment 3A. If statistics or geostatistics will be used, provide details in Appendix 7. If monitoring or observation
wells will be constructed for the response action, provide well construction details in Attachment 2B if not previously provided.
Monitored Media
COC1
Other
Sampling
Sampling
Depth/Height4 Analytical or Field
Sampling or
parameter
Method2
(ft.)
Screening
points or
Monitoring
(specify)
Method
locations3
Frequency5
Surface Soil
See RAP Worksheet 4.0 - Confirmation Sampling and Attachment 4A-1.
Subsurface Soil
Groundwater
Surface water
Sediment
Air
Dust
Aerosol monitor
Working
area
Breathing
height
During concrete
excavation
Explain the reasons for the above-listed monitoring and sampling plan.
1
Specify the COCs to be monitored in this media. List either type of COC (such as VOCs, metals) if all the COCs of that type will be monitored the same way.
Describe the sampling or monitoring methods and QC procedures in Appendix 1 unless the proposed sampling or monitoring procedure is the same as the sampling
or monitoring procedure described in the APAR.
3 Specify the sampling or monitoring point, such as the specific monitor well or general sampling or monitoring location.
4 Specify the depth or height of the sampling or monitoring points.
5 Specify the frequency at which this monitoring or sampling will occur.
2
Operation and Maintenance
RAP Worksheet 3.2
ID No.: 1471
Page 1 of 1
Report Date: April 2016
Use this worksheet to describe the operation and maintenance (O&M) activities for each response action. In
situations where the response action consists of more than one major component, for clarity one worksheet
can be completed for each major component.
Response Action Name/Designation: NAA Soil
List all portions of the response action to which this information applies.
Describe the O&M and inspection activities that will be required to operate and maintain response action
components.
No O&M activities will be required for the affected soil response action. The proposed response action
will completely remove all affected soil. Soil will be backfilled to meet surrounding land use.
List and discuss the key operating parameters for a properly functioning response action. Address how
changes in these parameters will result in operating changes, providing sufficient detail to explain how the
operator will know the component is functioning properly.
NA
List the routine tasks required to operate the response action.
NA
List the routine tasks required to maintain the response action, including scheduled inspections, maintenance,
and component replacement.
NA
Confirmation Sampling Plan
Associated Information: Attachment 4A
RAP Worksheet 4.0
ID No.: 1471
Page 1 of 2
Report Date: April 2016
List the COCs and other parameters that will be sampled to confirm completion of the response action. Illustrate the monitoring or sampling locations
in Attachment 4A. If monitoring or observation wells will be constructed for the response action, provide well construction details in Attachment 2B if
not previously provided. If needed, describe the sample collection and handling methods, if not previously provided, in Appendix 6.
Media
COC1
Other
Sampling
Sampling
Depth
Analytical
Sampling Frequency
parameter
Method
points2
Method
(ft.)
(specify)
Metals
(Antimony,
Grab
On-site
2 ft bgs
EPA Method
As indicated in APAR
Surface Soil
Arsenic, Lead)
samples
6020
Figure 11A-1 and
RAP Attachment 4A
SVOCs (PAHs)
Grab
On-site
5 ft bgs
EPA Method
As indicated in APAR
samples
8270B
Figure 11A-2 and
RAP Attachment 4A
TPH
Grab
On-site
20 ft bgs
TX 1005
As indicated in APAR
samples
Figure 11A-3 and
RAP Attachment 4A
PCB
Grab
On-site
8 ft bgs
EPA Method
As indicated in APAR
samples
8082
Figure 11A-4 and
RAP Attachment 4A
Subsurface Soil
Groundwater
Surface water
Sediment
Explain the reasons for the above-listed sampling plan. Discuss statistical or geostatistical methodology(ies) which will be applied, if any, in the data
collection process. Discuss any assumptions made in the statistical/geostatistical assessment, and how they will be met.
A systematic (i.e., regularly spaced) sampling approach has been chosen for the confirmation sampling of soils at the base (floor) and sidewalls of the
excavation areas. Confirmation sampling will be performed to verify that the affected soil has been removed and that the remaining soil has COC
concentrations below the applicable RALs, or Commercial/Industrial critical PCLs, for this project. The process will be to excavate soil to the initial
planned depth of excavation and then collect soil samples from the floor of the excavation on a 20-ft spaced grid for large areas. For excavation areas
smaller than 20 ft across, a minimum of three samples will be collected. Confirmation samples will be collected at the locations of previous assessment
samples that had concentrations greater than the applicable PCLs. Sidewall samples of excavation areas will also be collected at the vertical horizon of
the soil sample(s) with chemical concentrations greater than the applicable PCLs. WESTON will start collecting confirmation samples in a designated
1
2
Specify either a specific COC or type of COC (such as VOCs, metals).
Specify the sampling point to the degree it is known, (for example, MW-1, or near former boring #2).
Confirmation Sampling Plan
Associated Information: Attachment 4A
RAP Worksheet 4.0
ID No.: 1471
Page 2 of 2
Report Date: April 2016
excavation area within two business days of the completion of the authorized excavation in that area. After collection, the samples will be transported to
DHL Analytical Laboratory, Inc. (DHL), located in Round Rock, Texas. Samples for PCB analysis will be delivered to the Austin Energy Environmental
Laboratory. The analyses of the confirmation samples will receive expedited turnaround times at the laboratory to minimize the amount of time needed
to determine if the remediation is complete in that area (or portion of an excavation area).
Post-Response Action Care
Associated Information: Attachments 5A-5C
RAP Worksheet 5.0
Page 1 of 2
Report date: April 2016
ID No.: 1471
Complete this worksheet only if Remedy Standard B will be used.
What is the proposed initial post-response action care period? (default 30 yr.)
NA
Years
There is no Post-Response Action Care proposed for soils as all soils exceeding applicable PCLs will be
removed. The PRAC for groundwater will be addressed under a separate investigation.
If the proposed initial post-response action care period is less than 30 years, provide a technical justification in
accordance with §350.33(h).
The response action for soil will remove the PCLE zones for future conversion to parkland or continued
use by AE.
Parkland, Industrial
use by AE
What is the foreseeable land use during the post-response action care period?
Describe how the future use of the property will not compromise the integrity of the physical controls, will not
interfere with the function of the monitoring systems, will not pose a threat to human health or the environment,
and will be in accordance with any institutional controls.
The soil response actions will result in the complete removal of the PCLE zones. The area retained by AE
will be deed recorded for use as commercial/industrial only. Therefore, the future land use will be in
accordance with the institutional control.
Briefly describe the proposed post-response action care activities. Describe the type of monitoring and/or
inspections to be performed. Discuss the rationale for not including COC(s) analyzed during the response
action, monitoring or sampling point location, frequency of monitoring and/or inspections, and the duration of
the monitoring program.
The soil response actions will result in the complete removal of the PCLE zones.
Will PRAC sampling procedures be the same as those as previously documented
for monitoring and/ or confirmation sampling?
NA – There is no PRAC recommended for soils because all soils exceeding
applicable PCLs will be removed.
Yes
No
If no, provide in Appendix 6 a description of the monitoring or sampling collection procedures to be conducted
during the post-response action care period.
Cost Estimate
Complete this portion of the form only if a physical control is proposed (installed hydraulic control system,
slurry wall, cap, etc.). Provide in Attachment 5B a detailed cost estimate for a third party to operate and
maintain the physical control during the PRAC period, based on current dollar amount.
Specify the physical control to which this information applies
NA
Complete this worksheet for each physical control that will be used as part of the response action.
What is the total estimated annual cost of O&M for the PRAC period?
NA
What is the total estimated cost for a third party to perform PRAC activities?
NA
Post-Response Action Care
Associated Information: Attachments 5A-5C
RAP Worksheet 5.0
ID No.: 1471
Page 2 of 2
Report date: April 2016
Identify the type of financial assurance mechanism to be used, and the contact person managing fiduciary
responsibility, if known.
NA
Does the person meet the criteria and definition of a small business? (see §350.33(n))
Yes
No
If yes and the person desires to pursue the reduced amount of financial assurance, provide a legally binding
affidavit as Attachment 5C. Include in the affidavit the information requested in 30 TAC §350.33(l), (m), and
(n). An example affidavit is attached in the instructions.
Implementation Schedule
RAP Worksheet 6.0
ID No.: 1471
Page 1 of 1
Report Date: April 2016
Document the proposed schedule for implementing the response action. Include all major response action
activities through the life of the project, including all removal, decontamination, and control actions, component
installations, O&M, monitoring, and post-response action care activities.
Implementation of Response Action
Start
Finish
Duration
(specify component or action)
On-site soil excavation and confirmation sampling and backfilling
Tentatively set
to start after
building
demolition, and
after approval
of the RAP, in
3rd Quarter of
2016
4 months after
start
4 months
List the proposed schedule for report submittals. Add additional lines if more reports than listed will be needed
to complete the response action.
Reports
Submittal date
Response Action Completion Report (RACR)
2016