Final Remedial Action Master Plan for the French Limited

> FIIJ/M, REMEDIAL ACTION MASTER PLAN FRENCH LIMITED SITE EPA NO. 01-6VOI.O May, 1983

••*!- J 1 t"-'i * "-4.-Jt3 I CONTENTS I Section I EXECUTIVE SUMMARY 1.1 Purpose of this Report 1.2 Site Location 1-1 I 1.3 Problem Statement 1-2 1.4 General Approach 1-2 1.5 Data Limitations 1-9 I 1.6 Initial Remedial Measures 1-11 1.7 Remedial Investigations 1-13 1-15 O I O 1.7.1 Pre-Sampling Activities 1-15 i 1.7.2 Site Investigations 1-15 r- i 1.8 Feasibility Study C\i 1.9 Cost/Schedule 1-16 04 1-16 O i DATA EVALUATION O 2.1 Objective 2-1 O 2.2 Background 2-1 I 2-1 2.2.1 Site Description 2.2.2 Site History 2-1 I 2.2.3 Chronology 2-5 2-8 2.3 Hazardous Materials I Characterization 2.3.1 2-8 i HazardouSources s Materials 2.3.2 Types and Levels of 2-9 Hazardous Material i 2.4 Environmental Setting 2.4.1 Physiography i 2.4.2 Geology 2.4.3 Hydrology 2.4.4 Geohydrology 2.4.5 Air Quality 2.4.6 Ecology 2.4.7 Socioeconomics 2.5 Assessment of Potential Impacts B EnvironmenPublic Healtt h and Safety 1 Socioeconomics Contents (Cont inued)

2'6 Data Limitations *EMEDIAL ACTION pLANNifjG 2-29 3-1 3>1 IniUal Re^ Measures ial 3-1 3-1.11 2 CosInitial Remedial - ' t Estimate 3-2 3 3-2 -2 Remedial Investinginstigatio- n Activities .V 9 1 3-4 3-4 Work Flan 3-3 Feasibility study 3-5 3.3.1 General 3-19 3.3.2 Determination of the 3-19 CriteriAppropriata e Cleanup 3.3.3 Development or Remedial Alternatives 3-20 3.3.4 Initial Screening of 3-21 Alternatives 3.3.5 Assessment of Alternatives 2-25 3-^ R(3t-*riv*Reportin- • "g ' 3-26 3-29 3-29 3-29 3-5 Remedial inv 3-31 Feasibility 3.5.1 Schedule 3-32 3.5.2 Costs 3-32 COMMUNITY RELATIONS 3-32 APPENDIX 4-1 A Site Visit Memorandum B Site Chronology I Ccr.tents (continued) I Appendix Soil Boring Logs I D Remedial Site Investigations - Locations, I LaboratorSite Selectioy Testinn Rationalesg / and Remedial Investigation/Feasibility I Study Schedule of Major Activities I Community Relations Plan GNR101 OJ CM O O O m^mmI I FIGURES I Figure GreateLocatior Houston n Area and Site I 1- 1-3 General Vicinity Map and Site Locatlon 1-4 French Limited Site I 1-5 Approach for Remedial Action Master Plan 1-10 I 2-; Greater Hoaston Area and si o te L cation 2-2 C 2-2 General Vicinity Hap and site Locafcion 2-3 I 2-3 French Limited Site C\J I 2-4 o I o I I I I I TABLES Table Page 1-1 Estimated Cost of Initial Remedial I Measures 1-14 2-1 Priority Pollutants Detected in Disposal Pit Sludge Samples Located at the French Limited Site 2-10 2-2 Priority Pollutant Heavy Metals Detected in Sediment and Sludge Samples Located at the French Limited Site 2-11 2-3 Prioirty Pollutants Detected in Surface Waters Located at the French Limited Site 2-13 CVJ 2-4 Priority Pollutants Detected in Groundwater O Monitoring Wells Located at the French o Limited Site 2-15 O 2-5 Priority Pollutants Detected in Soil Samples Located at the French Limited Site 2-16 3-1 Estimated Cost of Initial Remedial Measures 3-3 V^^M I Section 1 EXECUTIVE SUMMARY The Remedial Action Master Plan (RAMP) is prepared in accordance with the National Contingency Plan (NCP) (40 CFR i Part 300, July 1982) originally published pursuant to Sec- tion 311 of the Federal Water Pollution Control Act. Remedial actions are those responses to releases on the National Priority List that require longer-term efforts consistent i with permanent site remedy to prevent or mitigate the migration of a release of hazardous substances. The specific aspects of remedial actions are presented in Phase IV, OJ Section 300.66 of the NCP. A RAMP generally will form the ro basis of scoping decisions to be made by the United States OJ Environmental Protection Agency (EPA) or state agency that Oo will require remedial investigations, feasibility studies, O and other onsite or offsite remedial actions applicable to a specific uncontrolled hazardous waste site. Scoping decisions facilitate the implementation of limited remedial actions, where the RAMP has identified such action as appropriate, prior to more extensive remedial actions (source or offsite control). A RAMP generally will serve as the primary planning document for all remedial action activities at a specific site, including enforcement activities, following EPA and state review. The RAMP may be revised from time to time as additional information is gathered and the scope of remedial projects is better defined by the EPA or the state. 1.1 PURPOSE OF THIS REPORT The purpose of this RAMP is to assemble and analyze existing data and to identify the scope and sequence of remedial projects along with a comprehensive schedule for implementing them.

1-1 With respect to identifying the scope and sequence of remedial i projects, it should be noted that the Texas Department of Water Resources (TDWR), through a cooperative agreement with i E?A, has taken the lead in investigating the French Limited s;.te and has contracted (January 17, 1983) with the engineer- i ing firm of Lockwood, Andrews & Newnam, Inc. to conduct remedial investigations and complete a feasibility study for the i French Limited site. The engineers have already prepared detailed work plans that include: i Volume I: Project Activity and Sampling Plan Ki\ Volume II: Project Safety Plan 1O Volume III; Chain of Custody Plan Volume IV: Quality Assurance Plan The specific work elements describing the remedial investigations and feasibility study and the cost/scheduling information presented in the Remedial Action Planning section of this RAMP were taken from the LA&N work plan, Volume I, Project Activity and Sampling Plan. 1.2 SITE LOCATION The site is located near Crosby, Texas, approximately 21 miles northeast of downtown Houston (see Figure 1-1 and 1-2). The site, approximately 23 acres in size, is bounded on the north by U.S. Highway 90; on the south by Gulf Pump Road; and on the east and west by low wooded areas (see Figure 1-2 and 1-3). The site is located in the flocdplain of the San Jacinto River which is approximately 1 mile to the west.

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I 1.3 PROBLEM STATEMENT I The French Li.nited site is an abandoned hazardous waste site containing a 10- to 12-acre waste disposal pit. The pit is I unlined and is located in permeable soils. Analyses performed on sludge deposits, soils, surface and groundwater I in and around the pit have identified priority pollutants, including benzene, chloroform, carbon tetrachloride, trichloroethylene, vinyl chloride, PCB-1242, and heavy I metals such as lead, cadmium and chromium. Located less than 1/4 mile southwest of the disposal pit is the Riverdale subdivision of approximately 50-60 homes. These homes, which may be downgradient from the hazardous waste pit, I depend on shallow wells for supply. CM O O Reports indicate that approximately 100,000 barrels per year O of industrial waste, mostly from petrochemical industries in I the Houston area, were dumped at the French Limited site from 1965 to 1971, when the active operation ceased. In May, 1967, due to concerns about the pit being unlined and situated in sandy soils, the Texas Water Development Board was requested by the Texas Water Pollution Control Board to investigate the possibility of groundwater pollution at the site. The TWDB concluded t.^at contents of the pit would contaminate the groundwater if allowed to infiltrate. In July, 1967, the state required French Limited to apply for a waste control permit. In 1970, after 3 years of discussion and negotiations, French Limited was issued a permit to operate the facility. Waste Control Order No. 01344 contained special provisions that included requirements for installation of an impermeable liner to prevent seepage from the pit; proper diking around the pit to prevent loss of pit

1-6 contents to nearby surface waters; and containment of all I contents within the pit with * no discharge into waters of the state. I However, in March 1971, the permit was cancelled due to the I failure of French Limited to fully comply with the special provisions, particularly the one that required the I impermeable liner. French Limited was nonetheless ordered to clean up the pond contents and to install an impermeable liner. After failing to meet these requirements, French I Limited was sued by the State in 1973 for $10,000. As partial payment of the fine, French Limited deeded the I disposal site property to tre state of Texas, the current CM owner of the property. o I o Heavy rainfalls and high water levels in the pit caused I failure (in 1969, 1973, and 1979) of the dike separating the pit trom the pond located beneath the Highway 90 bridge. I Each dike failure permitted a large volume of the pond water to flow into the pond and drainage levee located along the I northerly right-of-way of U.S. 90. In the Fall of 1980, remedial action efforts were made that included repairing I the broken dike and installing an emergency overflow pipe. This pipe will permit pit water to drain to the adjacent pond during high water conditions and reduce stress on the repaired dike; however, it has not been used. Since the closing of the site in 1971 as an active disposal pit, numerous samples have been collected from within the French Limited pit {water and sludge); from surface waters and sediments outside the pit; from groundwat-ars on the site; and from local water wells. Analyses of sample., indicate the presence of priority pollutants, including heavy metals and PCS within the pit and in surface areas adjacent to the pit. On-site monitoring well analyses have shown high

1-7 I levels of organic compounds, including volatile aromatics, acids, and phenols. Analyses of Riverdale subdivision wells I conducted in 1979 to determine if halogenated organics were I present were negative. In early 1981, a Field Investigation Team (FIT) evaluated I the history of the site and concluded that, due to the sandy soils in the area, a high potential existed for groundwater I pollution and recommended installation of monitoring wells I at the tite to determine the extent of any contamination. Two monitoring wells were later installed. Well samples I collected in October 1981 revealed the presence of phenolic, C\J acid and volatile organic compounds and heavy metals. o Major threats to public health, safety and the environment include the potential for contamination of local aquifers; I the potential for contamination of nearby surface waters, including the San Jacinto River; and the potential for I direct human contact with hazardous substances present at I the site. Limited groundwater analyses have shown that contaminants I have entered the groundwater in the vicinity of the waste disposal pit. The potential for contamination of the water table aquifer is high, due to the location of the waste pit in the relatively homogeneous and highly permeable Voss sand, present throughout the area. Clay layers exist between the water table aquifer and the deeper Chicot Aquifer; however, because these layers may be discontinuous, the potential exists for contaminants to reach the deep aquifer. Another concern is the potential for human consumption of fish taken from surface waters which may be contaminated with heavy metals. Although no data has been presented to

1-8 suggest heavy metals may exist in the nearby pond (located i beneath U.S. 90} , heavy metals found in soils and grour.dwater analyses at the site suggest the possibility for i migration of these contaminants to the pond. The pond is known to be a local fishing spot. i 1.4 GENERAL APPROACH i The general approach for RAMP development is shown on Figure 1-4. This approach has been developed in accordance i with the NCP and is based on three types of remedial actions: i o Initial remedial measures C\J o Source control remedial act ions o Offsite remedial actions I The initial remedial measures are used when the problem re- quires prompt attention. Initial measures should be implerented before final selection of an appropriate remedial action, if such initial remedial measures are determined to be feasible and necessary to limit exposure or threat of exposure for a significant health or environmental hazard, and if such initial remedial measures are cost- effective. The initic.1 remedial measures require a minimum of planning and can be completed quickly. Examples of initial remedial measures are to fence the site for security precautions, to remove hazardous wastes in drums that pose a substantial threat of contamination, and to construct drainage ditches to provide an effective drainage control system. If the existing data are not adequate to propose, evaluate, and recommend remedial action alternatives, a remedial investigation is warranted. A remedial investigation is undertaken 1-9 Obtain Enforcement Plan

Are Significant Health or Environmental Present or Potential Initial Remedial Measures HRM) Conduct Limited Remedial Investigation, U Data Feasibility Study & Adequate to Remedial Development Propose Remedial Alternatives (If Needed) ant) Pcftorn-i Preliminary Study

rnolomant Cost Alternative Identity Additional Data Requirements

Source Control Remedial Actions

Develop a Limited Number of Alternatives

Select Co»t 6"f-ctiv8 Sa'ict Co*t Effactivs Altornatiuai ACernativei Decgn and tmpiament Plamadv

Poit Closure Post Closure Monitoring Monitoring Approach for Remedial Action Master Plan. OH2KHIUM. to fill the data gaps concerning a hazardous waste site and could include: (1) defining the location of the hazardous wastes, (2) qualification and quantification of the hazardous wastes, (3) hydrogeology, and {4} defining the location of a contaminated groundwater plume, as well as other information characterizing the site in relation to the hazardous wastes. It should be noted that the higu majority of sites w.i 11 fit into this category. Source control remedial actions are taken when: (1) substantial concentrations of hazardous substances remain onsite, (2) barriers to retard migration of hazardous substances are inadequate, or (3) there is serious threat to public health, welfare, or the environment. Source control remedial actions ^ are not appropriate if. all hazardous substances have migrated O from the area where originally located or if it is determined that the material is adequately contained. An example of source control remedial action is removal of wastes that are contaminating a drinking water supply. Offsite remedial actions are taken when source control remedial actions are inappropriate or not effective in mi :igating a significant threat posed by the migration of hazardous substances from the site, (i.e., migration of contaminants from their point of original disposal). Offsite remedial actions may include construction of permanent alternative water supplies, management of groundwater plume, or treatment of contaminated groundwater. The source control and offsite remedial actions can proceed in parallel, if appropriate. 1.5 DATA LIMITATIONS Analytical data developed for the French Limited site have been sufficient to determine that contaminants are present at the site. However, the data are inadequate to fully

1-11 describe the extent and characteristics of the contamination and its potential impact on area ground and surface waters. To date, conclusions should be considered preliminary; addi- I tional testing is required to verify past results, expand on existing data, and to draw definitive conclusions. Aspects of the French Limited site that have not been adequately addressed include: i 1. Full characterization, quartification, and distribution of wastes located within and around the disposal pit; c\j 2. Identification of responsible hazardous waste gen- o erators; o o 3. Groundwater and flow patterns; •5. Horizontal :md vertical extent of any groundwater contamination;

5. Potential for contamination of the deeper Chicot and Evangeline Aquifers, both important fresh water sources in the Greater Houston area; Potential for contamination of nearby surface waters by surface-water runoff from the site; 7. Extent of contamination in nearby surface waters; Detailed characteristics of underlying geologic formations at the site;

General health impacts of the 8-ta ^ residents; and

1-12 I 10. Impacts on the environment, such as plant, fish, and wildlife communities, I Because of these limitations, a remedial investigation is Limiterecommended sited * as the first remedial activity for the French

Several limitations apply also to the RAMP process: o The RAMP does not provide specific remedial actions due to a lack of information necessary to conduct a feasibility study for proposed remedial actions. o C\) RAMP budget and development schedules do not permiOt a complete and exhaustive consideration of all o remedial planning activities. o A third limitation that generally applies to the RAMP process concerns the accuracy and intended use of cost estimates. Estimates are normally order-of-magnitude only and are prepared for guidance in project evaluation and implementation from the information available at the time of the estimate. However, such is not the case for this RAMP, because the TDWR has already contracted with an engineering firm to complete the investigations and feasibility study. Contractual cost arrangements have been made between the state and Lockwood, Andrews & Newnam, Inc.

1.6 INITIAL REMEDIAL MEASURES (IRM) One initial remedial measure has been recommended for the French Limited site. Due to the accessibility of the site to the public, a perimeter fence to enclose the entire site has been recommended. An estimated cost for this IRM is given in Table 1-1.

1-13 Table 1-1 ESTIMATED COSTS OF INITIAL REMEDIAL MEASURES

Estimated Costs ($) Low High ir\ Gate (I) KT $ 400 $ 600 C\J O Perimeter Fence {5,800') b* J,000 81,200 o Warning Signs (20) 800 1,000 o TOTAL $59,200 $82,800

Note: Cost of implementation cannot be accurately determined until property boundary survey is completed. Assumed 5,800 linear feet of ferica will be required. Costs of installing fence: high ~ $14/lin. ft; low = $10/lin. ft. Costs of $40/signinstallin.g warning signs: high = $50/sign; low = GNR101

1-14 I 1.7 REMEDIAL . INVEST I_G AT IONS A detailed work plan has been developed by Lockwood, Andrews & Newnam to determine the degree cf Hazardous cunditionr at the French Limited site. The work elements of the LA&N plan are presented below. 1.7.1

Pre-sampling activities include a comprehensive characterization of the site to establish site characteristics that are pertinent to the project; and site advance planning to establish basic program elements for the proper management of CM personnel safety, sample chain of custody, data storage, O O quality assurance, and community relations. O Included in the site characterization effort are boundary and topographic -irveys; a well inventory; and determination of surface drainage, geological, hydrogeological and hydrological characteristics.

Site advance planning includes the development of a Safety Contingency Plan, a sample Chain of Custody Plan, a Quality Assurance Plan, and the lanning for a field office. 1.7.2 Site Investigations. The purpose and objectives of the site investigations are to characterize the French Limited site in terms of pollutants present; the magnitude and extent of contamination; the rate of waste migration; and other physical site characteristics. Site investigations include site sampling and hydrogeological studies.

1-15 Site sampling will include sampling and analysis of soil borings, sediments, surface water, groundwater, and fish tissue. Hydrogeologic investigation will include: (1) soil borings; i (2) installation of monitoring wells; (3) determination of groundwater levels; (4) determination of soil permeabilities; (5) physical soil analyses; and (6) geophysical studies. 1 *8 FEASIBILITY STUDY

A work plan for a Feasibility Study has been developed by Lockwood, Andrews & Newnam. Elements :>f the plan include: CVJ (1) determination of appropriate cleanup criteria; (2) develop- o ment of remedial alternatives; (3) initial screening of alter- o natives; and (4) assessment of alternatives. o 1.9 CQST/SCHEDCLE

Lockwood, Andrews & Newnam has scheduled approximately 30 weeks to complete the remedial investigation and to complete the Feasibility Study (a copy of the LA&N schedule is included in Appendix E of this plan). A detailed cost breakdown was not made available for inclusion in this RAMP. However, costs provided for the three major areas of effort as developed by LA&N are presented below:

Cost Pre-Sampling Activities $ 40,039 Site Investigations 144,483 Feasibility Study .122,472 Total $306,994 R101 1-16 Section 2 I DATA EVALUATION 2.1 OBJECTIVE The objective of this section is to compile and evaluate available technical data and nontechnical information on the French Limited waste disposal site. While this section does not intend to present a complete compilation of data and information, the available data shall serve as a baseline to be used in an assessment of the site. Compilation of available data is a necessary first step toward the development of initial remedial measures and remedial investigation activities. The evaluation of existing data shall provide a CM mechanism for determining data limitations and the need for C additional data. O O 2.2 BACKGROUND 2.2.1 Site Location and Description The French Limited site is one of the 418 hazardous waste sites listed December 20, 1982, by the U.S. Environmental Protection Agency for Action under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, commonly known as "Supcrfund." The site is located near Crosby, Texas, approximately 21 miles northeast of downtown Houston (see Figures 2-1 and 2-2). The site/ approximately 23 acres in size, is bounded on the north by U.S. Highway 90; on the south by Gulf Pump Road; and on the east and west by low wooded areas {see Figures 2-2 arid 2-3). The site is located in the floodplain of the San Jacinto River, which is approximately 1 mile to the west.

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FIGURE 2-3. French Limited Site The main feature at the site is a 10- to 12-acre unlined liquid waste disposal pit. A slough borders the northern and western boundaries of the pit. A fence with warning signs surrounds the immediate area of t'^e pit. Two groundwater monitoring wells are located along the southern edge of the site between the pit and Gulf Pump Road. Riverdale, a subdivision of approximately 50--60 homes, is located less than 1/4 mile southwest of the disposal pit. The Sikes Disposal Pits, another hazardous waste site :mder investigation, is located on the opposite side of U.S. 90 C\i about 1/2 mile west of the French Limited site. The Sikes -ic\, site is reported to have received the same type of wastes as o Frencthe French Limiteh Limited sited . site and was in operation prior to the ^ O 2.2.2

The site was originally owned by B. G. Burton and operated as a commercial waste disposal operation starting in 1965, In 1967, the site was sold to French Limited of Houston, Inc. Prior to the opening of this site, French Limited used the Sikes Disposal Pits as their primary disposal site. It is believed that the French Limited site served as the largest off~site hazardous waste disposal facility in the Houston area in the years that followed. Reports indicate that approximately 100,000 barrels per year of industrial waste, mostly from petrochemical industries in the Houston area, were dumped at the French Limited site from 1965 to 1971, when the active operation ceased. Complaints of odors and burning wastes registered by local residents first brought the disposal site to the attention of the Texas Water Pollution Control Board and Harris County

2-5 I in 1966. Subsequent inspections conducted by state personnel concluded that an unpermitted waste disposal operation was being conducted at the site. I In May, 1967, due to concerns about the pit being unlined and situated in sandy soils, the Texas Water Development Board was requested by the Texas Water Pollution Control Board to investigate the possibility cf groundwater pollution at the site. Whether or not a field investigation was made was not clear from a review of the State's files; however, the TWDB concluded that contents of the pit would contaminate the groundwater if allowed to infiltrate. CM In July, 1967, the state required French Limited to apply O for a waste control permit. In 1970, after 3 years of dis- o cussion and negotiations, French Limited was issued a permit O to operate the facility. Waste Control Order No. 01344 contained special provisions that included requirements for installation of an impermeable liner to prevent seepage from the pit; proper diking around the pit to prevent loss of pit contents to nearby surface waters; and containment of all contents within the pit with no discharge into waters of the state. However, in March 1971, the permit was cancelled due to the failure of French Limited to fully comply with the special provisions, particularly the one that required the impermeable liner. French Limited was ordered to clean up the pond contents and to install an impermeable liner. After failing to meet these requirements, French Limited was sued by the State in 1973 for $10,000. As partial payment of the fine, French Limited deeded the disposal site property to the State of Texas, the current owner of the property.

2-6 Heavy rainfalls and high water levels in the pit have caused failure (in 1969, 1973, and 1979) of the dike separating the pit from the pond located beneath the Highway 90 bridge. The 1973 dike failure occurred after some interim remedial measures had begun, including removal of some of the oily sludge, neutralization of the pond liquid with cement plant flue dust, and aeration of the pond. Each dike failure permitted a large volume of the pond water to flow into the pond and drainage levee located along the northerly right-of-way of U.S. 90. In the Fall of 1980, additional remedial action efforts were made, including placing a fence and warning signs around the site, repairing the broken in dike, and installing an emergency overflow pipe. This pipe cvj will permit pit water to drain to the adjacent pond during o high water conditions and reduce stress on the repaired o dike; however, it has not been used. o

Since the closing of the site in 1971, as an active disposal pit, numerous samples have been collected from within the French Limited pit (water and sludge); from surface waters and sediments outside the pit; from groundwaters on the site; and from local water wells. Analyses of samples indicate the presence of priority pollutants, including heavy metals and PCB within the pit and in surface areas adjacent to the pit. On-site monitoring well analyses have shown high levels of organic compounds, including volatile aromatics, acids, and phenols. Analyses of Riverdale subdivision wells conducted in 1979 to determine if halogenated organics were present were negative. In early 1981, a Field Investigation Team (FIT) evaluated the history of the site and concluded that, due to the sandy soils in the area, a high potential existed for groundwater pollution and recommended installation of monitoring wells at the site to determine the extent of any contamination.

2-7 Two monitoring wells were later installed. Well samples I collected in October 1981 revealed the presence of phenolic, acid and volatile organic compounds and heavy metals. Shortly thereafter, in 1981, the State of Texas applied for Federal assistance to conduct a full investigation of the site. In April, 1982, a Cooperative Agreement was signed giving the TDWR authorization to spend federal funds to conduct a remedial investigation and feasibility study for the French Limited site. Shortly thereafter, the State advertised for interested con- ^ sultants to submit their qualifications for performing the Lfi investigations. In January, 1983, the firm of Lockwood, ^ Andrews & Newnam, Inc. of Houston, Texas was contracted by Oo the TDWR to perform the engineering services. O A kickoff meeting to discuss the preparation of this Remedial Action Master Plan (RAMP) was held between CH2M HILL and EPA Region VI on January 3, 1983. A sate visit was conducted on January 7, 1983. A site visit memorandum is included in Appendix A. 2.2.3 Chronology A site chronology developed from a review of the Texas Depart- ment of Water Resources and the EPA Region VI files is included in Appendix B.

2.3 HAZARDOUS MATERIALS CHARACTERIZATION Since a comprehensive literature review .to determine toxic and/or hazardous concentrations of various parameters is not intended to be a part of the RAMP process, no criteria are offered here upon which to specifically and definitively declare hazardous levels or characteristics.

2-8 D I 2.3.1 Hazardous Materials Sources Very little data exist regarding the origin of the waste material dumped at the French Limited site. However, based on discussions with the parties involved and documentation of early regulatory action, it is believed that the waste I came from petrochemical industries in the Houston area. More specific data are not available. 2.3.2 Types and Levels of Hazardous Material The tables presented in this section contain a summary of ^O available data on waste characterization. The summary is CQM limited to data on priority pollutants as classified by the o EPA. The major efforts toward analysis of the wastes and ^ their distribution throughout the site were undertaken by the EPA, TDWR, and the Harris County Pollution Control Depart- ment. Samples were collected from sludge and sediments, disposal pit surface water, groundwater and soils. Approxi- mate sampling locations are shown on Figure 2-3. Sludge and Sediments

Table 2-1 summarizes data from the August, 1981, analysis of sludge samples collected from the bottom of the disposal pit at three locations. The analysis revealed the presence of numerous priority pollutants including benzene, chloroform, and vinyl chloride.

Table 2-2 contains data from the June, 1979, priority pollutant heavy metals analysis of sludge and sediment samples collected from within the pit area. Two 18-inch core samples (No. 1 and 2) were collected from below 2 feet of water along the south and north banks of the pit. A sediment sample was

2-9 Table 2-1 PRIORITY POLLITANTS DETECTED IN DISPOSAL PIT SLUDGE SAMPLES LOCATED AT THE FRENCH LIMITED SITE (August 1981) Sample _Lp_cat ion* No. 1 No. 2 No. 3 Volatile Compounds (ppm) Acrclein Benzene 21 Chlcrobenzene 8.2 Chloroform 1.1-Dichloroethane 1.2-Dichloroethane 3.0 1.1-Dlchloroethene 1.2-Dichloropropane Ethylbenzene 26 3.9 8.3 Methylene Chloride <1 2.2 150 Tetrachloroethene 1.6 Toluene 25 U. 3 1,1,1-Trichloroethane

2-10 Table 2-2 PRIORITY POLLUTANT HEAVY METALS DETECTED IN SEDIMENT AMD SLUDGE SAMPLES LOCATED AT THE FRENCH LIMITED SITE (June 1979)

S_ampJ.e Location' No, 1 No. 2 A B C A B _£_ NO_- .3 No. 4 Metals, Total (ppm)b Cadmium, Cd 4.7 _ — — ** 37 Chrorr.ium, Cr 427 205 12 100 2.5 1,082 64 Copper, Cu 3,560 916 7.4 1,349 5.0 4.9 113 17 :r Lead, Pb 285 346 368 147 in Nickel, Ni 130 82 17 71 182 ~ CM Zinc, Zn 570 289 162 130 35 7.3 2,409 54 O_ Oo Location Legend No. 1—Six feet from the middle south bank; taken under 2 feet of water No. 2 — Five feet from the middle north bank; taken under 2 feet of water No. 3—Middle of pit; taken under 12 feet of water. No. 4—Taken from south bank of pit Samples collected and analyzed by Harris County Pollution Control Department; samples collected 6/20/79. Samples at Locations No. 1 and No. 2 were 18-inch core samples of pit bottom: A = Top 6 inches of core; mostly sludge B * Middle 6 inches of core; sludge and sediment C » Bottom 6 inches; mostly sediment Sample at location No. 3 consisted of sludge from top 4 inches of pit bottom. Sample at location No. 4 consisted of oily sludge from pit bank. Dry weight basis--ppm or mg/kg. Concentrations represent total metals as determined by acid extraction.

GNR89

2-11 collected from the pit bottom near the center of ths pit (No. 3) and an oil sludge sample was collected from the south bank of the pit (No. 4). Analyses of samples from locations No. 1, 2, and 3 revealed the presence of a highly contaminated sludge layer at the bottom of the pit. The top 6-inches of core samples taken from locations No. 1 and 2 indicated a high level of chromium, copper, lead, nickel, and zinc.

———————————Surface —Water IA Table 2-3 contains data from the September, 1979, and August, ^ 1981 , priority pollutant analysis of surface water samples _ collected within the pit and one sample collected from the ***—r pond beneath the U.S. 90 bridge. Sample locations are described in the table. Samples collected from within the pit (locations 1 through 4) revealed priority pollutants, including chloroform and methylene chloride at locations 1 , 2 , and 3; and PCB-1242 at location 4. It should be noted that the PCB finding was in 1979, approximately 2 years prior to the 1981 sampling at locations 1 , 2 , and 3 . One sample collected outside of the pit (location No. 5) , in the nearby pond beneath the U*S. 90 bridge, revealed the presence of three semi- volatile priority pollutants — bis (2 -ethyl hexyl) phthalate, di-n-butyl phthalate, and die thy 1 phthlate, Groundwater Table 2-4 contains data from the October, 1981 , analysis of samples from two groundwater monitoring wells installed in the summer of 1981 by the TDWK. Monitoring Well No, I is

2-12 Table 2-3 PRIORITY POLLUTANTS DETECTED IN SURFACE WATERS LOCATED AT THE FRENCH LIMITED SITE (September, 1979 & August, 1981}

Sample^Locations

Acenapthylene Acrolein 26 - 1.2 Eis (2-ethylhexyl)phthalate 20 Di-N-Butylphthalate Diethyl phthalate - 0.45 Chloroform 32 - 0.25 Fluoranthene 29 2B 0,19 \0 Methylene Chloride 19 - C\J Fyrene 21 21 1.1 o FCB-1242 - 1.2 Phenols, Total 3.6 - o 5.2 11.2 2,680 o Metals, Total (ppb) 52 Cadmium, Cd Chromium, Cr <10 <5 <5 <20 Copper, Cu <2C <10 <10 110 Lead, Pb <40 <20 <20 80 Mercury, Hg <1 <40 <40 <20 t»i>^ri.t?xMi '-(co 1 , Mitji , C\ U

No. 1—Middle of western half of pit No. 2—Middle of pit No. 3-—Middle of eastern half of pit No. 4—Southeast corner of pit No. 5—Small pond adjacent to pit beneath Highway 90 Samples at locations No. 1, 2, and 3 collected by the FIT Laboratories(Ecology and, EnvironmentInc. , Inc.) on 8/27/81. Analysis by Versar

samplinSamples g atdate locatio: 9/20/79n No.. 4 and No. 5 collected and analyzed by EPA; GNR89

2-13 Table 2-4 PRIORITY POLLUTANTS DETECTED IN GROUNDWATER MONITORING WELLS LOCATED AT THE FRENCH LIMITED SITE (October, 1981)

Monitoring Wells NIPDWR1 Benzene MCL Carbon Tecrachloride 148 122 Chlorobenzene 29 Chloroform <10 1.1-Dichloroethane 584 465 1.2-Dichloroethane 255 174 1,1-Dichloroethylene 1,631 1,073 Ethyl Benzene 49 _ Xethylene Chloride 16 _ 52 Tetrachloroethylene 728 306 166 Tcluene 2, 143 M CM 47 1, 2-Trar.s-dichloroethylene 77 58 O Trichloroethylene 1, 924 O Vir.yl Chloride 217 ^_ 209 O

2,4-Dimethylphenol Phenol 57 102 122 Base/Neutral Compounds

112 26 Metals, Total (ppb) Arsenic, As Cadmium, Cd 21.8 _ 39 2.9 50 Chromium, Cr 5.0 2.0 Copper, Cu 59 103 100 10 Lead, Pb 46 88 50 44 81 6.0 Mercury, Hg 45 150 24 50 Nickel, Ni 0.4 0.5 <.05 Selenium, Se 55 83 130 2 Silver, Ag 36 .5 31 - 5 <2.0 10 Zinc, Zn 5.0 2.0 50 420 54 130 270 Two sets of analyses are reported: A = Samples collected by the FIT (Ecology and Environment, Inc.) on 10/07/81 and analyzed by Sverdrup Technology, Inc. L- B « Samples collected and analyzed by TDWR; sampling date 10/21/81. MaximuNationam l ContaminanInterim tPrimar Levey l Drinkin(MCL)g . Water Regulations (NIPDWR), GNR89 located near uhf» southeast corner of the site, while Monitoring Well Wo. 2 is located near the southwest corner. In both cases, the wells are located close to the pit. High levels of priority pollutants were detected in each well. Monitoring well No. 1 revealed the presence of organic compounds including benzene, carbon tetrachloride, chloroform, methylene chloride, tetrachloroethylene, and vinyl chloride. The heavy metals chromium, lead, and selenium were found in concentrations close to or exceeding NIPDWR maximum contaminant levels. In Monitoring Well No. 2, organic priority pollutants found included benzene CM and methylene chloride. The heavy metals chromium and lead MD were found in concentrations exceeding the NIPDWR maximum CM contaminant levels. It should be noted that significant O O differences exist between values reported by the FIT and O those reported by the TDWR. For example, the lead analysis completed on Monitoring Well Mo. 2 was reported as 150 ppb by the FIT, but only 24 ppb was reported by the TDWR. Boils

Table 2-5 lists data from the June and September 1979, priority pollutant analysis of soil samples collected from areas adjacent to the disposal pit. Samples were collected from a slough on the western side of the pit (Location No. 1) ; the ground surface on the south side jf the pit (Location No. 2) ; and the ground surface on the southeast sid(Locatioe of n theNo .pi t3) . in the vicinity of the old unloading area

All of these locations are outside of the pit and could reflect relocation of contaminants as a result of past flooding of the site. Samples from locations No. 1 and 2 both revealed high concentrations of heavy metals, particularly chromium, copper and zinc. Lead was found in high levels at location No. 1, but was not recorded at Location No. 2. Phenols were detected at both locations. 2-15 Table 2-5 PRIORITY POLLUTANTS DETECTED IN SOIL SAMPLES LOCATED AT THE FRENCH LIMITED SITE (June & September, 1979)

Crgar. i cs Phenols, Total FCB-1242 2.93 5.98 1,560 283 Metals, _Total fppm) Arsenic, As Cadmium, Cd 13.4 4.3 CM Chromiua, Cr 2.3 " ^37 (Lie,-, 430 107 32 127 49 1,733 (i Copper, Cu 345 17 4.9 Lead, Fb 45.4 27 2.5 198 Mercury, Hg 326 — 50 O 0.77 0.37 •*. ~ rUckel, Mi 144 ™" ~ - Seleniuc, Se 63.3 17 Silver, Ag 1.9 _ ~ — 57 Zinc, Zr. 3.5 5.9 " - * 667 140 79 ~ — - 215

No. 1 — Slough west of site No. 2 — South side of pit No. 3 — Southeast berm of pit; old unloading area A = Top 6 inches of soil; mostly clay. B - Next 12 inches of soil; mostly sandy soil. C =s Next 8 inches of soil; mostly dark sand. D - shelNextl 4 (possiblinches y of olsoild roadbed; mostl) y . dark earth intermingled with sampleSampleds 9/20/79at location. s No. 1 and No. 2 collected and analyzed by EPA; Samples at location No. 3 collected and analyzed by Harris County Pollution Control Department; sampled 6/20/79. DrDr y wweighe t basis — ppm or mg/kg- ppValuem wes t inbasis parenthese. s indicate concentrations present in sample leachates,

2-16 PCB-1242 was found at both locations with Location No. 1 having the higher level. The sanple collected at Location No. 3 was a core sample taken down to a depth of 30 inches. High levels of cadmium were detected in the top layer and successively lesser quantities in the next two lower layers. However, the bottom 4 inches revealed a significantly higher level of cadimum than the top layer. This same pattern exists for chromium, copper, nickel, and zinc. The bottom 4 inches was described as mostly dark earth intermingled with shells and thought to be an old roadbed. Other "^°r ———— CM During a 1979 inspection, EPA representatives observed waste O drums submerged in the disposal pit. They were unable to determine the number of drums or the nature of their contents. As part of the Hazard Ranking System process, based on the analyses completed at the site, the EPA estimated the total quantity of hazardous waste to be between 125,000 and 194,000 cubic yards, including the water and sludge in the disposal pit.

2.4 ENVIRONMENTAL SETTING 2.4.1

The French Limited site is located on the Gulf Coastal Plain of southeast Texas, 21 miles northeast of Houston in Harris County. The site is flat to gently sloping and has an average elevation of approximately 10 to 15 feet above mean sea level (insl). The site is located in the alluvial valley (flood plain) of the San Jacinto River, approximately 16 miles north of Galveston Bay and 4 miles south of Lake Houston. The French Limited site is located in a region of

2-17 i land surface subsidence centered at Houston, Texas, and apparently caused by withdrawal of water from aquifers, with resulting compaction of geologic strata. Nearly 3 feet of subsidence at the French Limited site has been recorded in the interval from 1890 to 1973. i 2.4.2 Geology The Texas Coastal Plain is developed on a great thickness of unconsolidated sands, gravels, and clays generally spread in thin but extensive beds which dip gently to the southeast. These sediments have a thickness of several thousand feet and are composed of alternating pervious and impervious CM members. These deposits are of Cenor.oic and Mesozoic Age, c and are underlain by Paleozoic and older basement rocks of c the Appalachian and Ouachita foldbelts. o The waste storage pit at the French Limited site was developed in an area of sandy soils of the Voss series. Voss sands are found on low terraces, flood plains, and sandbars along the San Jacinto River throughout this area. These soils typically are flooded one or more times each year. The water table is generally at a depth of 2 to 5 feet and rarely more than 7 feet below the surface. Surface runoff is slew but permeability is high. Internal drainage is impeded by underlying clay layers. A review of soil boring logs for monitoring wells installed in 1981 indicates that a clay layer begins at about 30 feet below the ground surface (see Appendix C). Subsurface geology at the French Limited site is character- istic of an alluvial system of Holocena to Modern Age created by flooding of the adjacent San Jacinto River. These surficial deposits overlie a broad Pleistocene fluvial system composed of meanderbelt sand and silt. The uppermost Pleistocene

2-18 formation is the Beaumont Clay, which consists of calcareous clays containing lime nodules; lenses of fine- to medium- grained sands and sandy clays; unmineralized logs, peat, and plants; and some shells. Below the Beaumont Clay is the Lissie Formation, consisting of alternating beds of fine to coarse sand and thin lenses of fine gravel interbedded with clayey sand and sandy clay. Clay predominates in the upper part of the formation and sand in the lower part. The lower portion of the Lissie Formation and the underlying Willis Sand Formation, also of Pleistocene Age, form a massive sand unit known locally as the Alta Loma Sand. \c ^O Tertiary systems found at increasing depths below the French CM_ Limited site include the Goliad Sand of Pliocene Age, the o Fleming Formation (Lagarto Clay and Oakville Sandstone) of ° Miocene Age, and the Catahoula Sandstone of Oligocene and Miocene Age. Recoverable mineral resources in the vicinity of the French Limited site are limited to sand and gravel deposits mined from surficial "borrow pits," and isolated oil fields. The disposal area at French Limited is reported to have been a former sand borrow pit, 2.4.3 Hydrology Hydrology of the French Limited site is controlled by climatic factors, physiographic features, vegetation and soil inter- actions, and the close proximity of the San Jacinto River. The climate in the vicinity of the site is predominantly marine and is periodically modified by surges of continental air. The proximity of the Gulf of Mexico, the persistent flow of xvarm tropical maritime air from the Gulf, and adequate rainfall, combine to produce a humid subtropical climate.

2-19 Mean annual precipitation recorded in southeast Houston is 46 inches. Monthly rainfall is well distributed throughout the year; however, a maximum 24-hour rainfall ovei 15 inches has been recorded. Summer rainfall is generally associa ed with convective storms, with an average of 59 days per year with thundershower activity. Winter rainfall may last for several days and is usually associated with frontal activity. Lake evaporation in the vicinity of the French Limited site averages approximately 53 inches per year. £v ootranspiration over land areas may be greater or less than this, depending on vegetative cover type. Annual average net precipitation at the site is approximately -7 (minus seven) inches. CM Rain falling on the site is expected to leave by a combina- O tion of evapotranspiration, overland flow to adjacent water O bodies, and infiltration. The actual proportion of loss via each of these routes is not known for this site; however, each of the routes is expected to provide significant water loss under certain specific conditions. The French Limited site is located on the upper flood plain of the San Jacinto River, one mile east of the river and Jackson Bayou, and reportedly has been flooded in 1969, 1973, and 1979. The periodicity and magnitude of flooding may be increasing because of land subsidence in the area. Other surface-water features near the site include Tank Lake (across U.S. 90, within the Sikes Disposal Pits site), Gordon Lake, Rickett Lake, Faucet Lake, McCracken Lake, and several small sand and gravel borrow pits. Surface water runoff from the French Limited.site is expected to flow either south through the culvert on Gulf Pump Road to a drainage ditch that flows to the San Jacinto river, or north under U.S. 90 through the Sikes Hazardous Waste site and on to the river.

2-20 I 2.4.4 Geohydrolpgy The geologic formations which supply most of the groundwater I in the Houston area are composed of interbedded sedimentary I deposits of gravel, sand, silt, and clay. The formations, from youngest to oldest, that form the important hydrologic units are the Quaternary to recent alluvium; the Beaumont Clay; the Lissie Formation; the Willis Sand (Alta Loma Sand); the Goliad Sand; the Fleming Formation; and the Catahoula Sandstone. The most important water- CC bearing units are the alluvium and the Chicot and Evangeline Aquifers, described below. CM O O In the vicinity of the French Limited site a water-table O aquifer occurs in the alluvium. This layer of permeable sands and low permeability silts and sandy clays is generally less than 40 feet in thickness. The alluvium yields relatively small quantities of freshwater suitable only as domestic supplies. The Chicot Aquifer, beginning from 30 to 100 feet or more below the ground surface, is composed of the Beaumont Clay, the Lissie Formation, and the Willis Sand. The base of the Chicot Aquifer lies at about 550 feet below msl in the vicinj.ty of the French Limited site. The basal part of the Chicot Aquifer is formed by a massive sand section (Alta Loma Sand) with high hydraulic conductivity which is heavily pumped for municipal supplies. The direction of regional groundwater flow in the Chicot Aquifer, based on piezometric surface elevation maps, appears to be to the south and southwest, towards areas of high groundwater withdrawal. The Evangeline Aquifer, connected hydraulically with the Chicot Aquifer, is considered a separate unit based primarily on a difference in hydraulic conductivity.

2-21 The Evangeline Aquifer consists of layers of sand and clay in the Fleming Formation and the Goliad Sand, and is an important source of fresh groundwater in the Houston metropolitan area. This aquifer is underlain by the Burkeville confining layer at a depth of approximately 2,000 feet below msl at the French Limited site. The shallow water-table aquifer in the vicinity of the French Limited site is fed by a combination of infiltration of local precipitation and infiltration from the San Jacintc River, depending on river stage and prevailing water table conditions onsite. In general, during the late spring, summer, and early fall, most of the water that enters the soil from rain CM is lost by evaporation and transpiration. During the cool O non-growing season, however, a larger proportion of rainfall G infiltrates to less permeable underlying beds, which may result in a temporary shallow perched water table within 2 feet of the ground surface at the site. Evidence from this area indicates that the clay zones are poorly stratified and generally persist for only short distances. Thus, these clay layers may not function strictly as aquicludes and the water table and Chicot aquifers may be hydraulically connected. The Chicot and Evangeline Aquifers are primarily artesian in nature. Groundwater usage in the Houston area has significantly decreased the artesian pressure in these deeper aquifers, as measured by static water levels in wells penetrating these strata. The decline in the potentiometric surface of the Chicot Aquifer between 1890 and 1975 was about 150 feet in the vicinity of the French iJinited site. The center of the cone of depression, located near Houston, had a maximum decline during this same time interval of over 300 feet.

2-22 I At least 6 water wells with depths ranging from 120 to I 315 feet are present within one mile of the French Limited site. Two of these are developed as public water supplies, I three are for domestic use/ and one is for industrial use. Wells with depths greater than 30 feet may be developed into the Chicot Aquifer. A potential for contamination of the Chicot Aquifer by contaminants from the French Limited site main y thiexiss tarea du.e to the discontinous nature of confining beds

The potential for contaminatior. of the water table aquifer is considered to be great. This is because the waste site was a former borrow pit in the relatively homogeneous, CM highly permeable Voss sand , present throughout the area . Oo Liquid wastes leaching through the walls or floor of this O pit could migrate of f site. Several shallow wells varying from 35 to 90 feet in depth are reported to be present in the Riverdale subdivision located less than 1/4 mile southwest of the site. 2.4.5 Air Quality

Very limited data are available on ambient air quality in the vicinity of the French Limited site. On May 13 , 1981 , the Texas Air Control Board collected qualitative air samples downwind from the French Limited site for analysis by gas chromatography and mass spectroscopy. The following compounds were detected in low concentrations: aliphatic and olef inic hydrocarbons in the C, to C_ range; C? and higher esters, ketones , ethers , and alcohols; several nitriles; some acids of C , or shorter carbon chains; and severasev l sulfur-containing corapounds .

2-23 2.4,6 Ecology

Plant communities in the vicinity of the French Limited site are varied depending on the land surface elevation above the San Jacinto River and the nature of the soil in any particular area. Natural communities that can be found within 1 mile of the site include disturbed prairie grassland, pine-oak forest, freshwater marshes, and alluvial swamplands. Urban i and industrial development in the area has modified most of the native ecosystems, although the flood-influenced areas surrounding the site are probably the most natural. «— r- The vegetation on the levees around the site consists of CM pines, sweetgums, oaks, and other flood-resistant species O and is typical of a successional forest. A small fresh-water marsh has developed along the west end of the site. Little information is available on wildlife populations in the vicinity of the site, although bird and small mammal species occutypicallr onsitey foun. d in river bottom land areas are expected to

The main San Jacinto River channel and Jackson Bayou are both within one mile of the site. These waters vary from fresh to brackish depending on rainfall, river stage, and tidal conditions downstream. A variety of sport fishes including bass, bream, and catfish are expected to occur near the site. The upper end of Galveston Bay, which receives the flow of the San Jacinto River, is only about 16 miles south of the site, Galveston Bay is the center of an shellfishimportant. fishery for estuarine finfish species and

Several threatened or endangered species are known or sus- pected to occur in Harris County, Texas. Endangered species include the American alligator, Houston toad, brown pelican.

2-24 southern bald eagle, peregrine falcon, Attwater's prairie chicken, least tern, red-cockaded woodpecker, and the paddle- fish. Threatened species that occur in the county include the southeastern bat, reddish egret, white-tailed hawk, white' faced ibis, swallow-tailed kite, osprey, wood stork, Texas horned lizard, the Louisiana milk snake, and the Rio Grande frog. Based on habitat preference, several of these species may occasionally have direct contact with the French Limited site; however, no specific information concerning the occur- ence of these species on the site is available. CM 2.4.7 Socioeconomics r- OJ Harris County, Texas, is a region of very rapid urban and o industrial growth. Although the French Limited site is o located in the less developed eastern portion of Harris o County, urban sprawl from growth centers such as Houston, Pasadena, and Baytown is encircling the area. Several small communities, including Riverdale, Barrett, Magnolia Gardens, and Crosby/ are within 3 miles of the site, and have an estimated population of 5,400 permanent residents. The only major industrial development within 3 miles of the site is the St. Regis Paper Company plant, north of U.S. 90 and west of the San Jacinto River, Information concerning other industries and agricultural activities adjacent to the French Limited site was not available for this report. The commercial fishing industry is substantial in the lower reach of the San Jacinto River and throughout Galveston Bay, Total weight in pounds of catches reported in 1977 for several commercial species including shrimp, blue crabs, oysters, and finfish was 7.8 million pounds. In addition, the recreational finfish harvest from Galveston Bay in 1977 was estimated to be 583,500 pounds. Recreational fishing near the French Limited site in the San Jacinto River and Jackson Bayou is known to occur, but has not been quantified. The

2-25 waters of the San Jacinto River in the vicinity of the site are designated by Texas surface water quality standards as being suitable for contact and noncontact recreation and the i propagation of fish and wildlife. 2.5 ASSESSMENT.. OF. POTENTIAL IMPACTS 2.5.1 Public Heal_th and Safety The most significant threat to public health and safety posed by the French Limited site is the potential contamination of tr\ potable groundwater supplies by infiltration and migration of pollutants present at the site. As discussed earlier,

2-26 Another health and safety concern is the potential for human contact with the contaminated liquids, sludge, and soils located at the site. People entering the site may be r - posed to the contaminated materials through direct contact or vapor inhalation. Danger to the general public has been reduced by the installation of a fence and warning signs around the immediate area of the disposal pit. Additional health and safety concern is posed by the human consumption of fish taken from surface waters which may be contaminated. The site has the potential to contaminate surface waters, most notably the San Jacinto River, Jackson Bayou, the pond beneath U.S. 90 and nearby lakes. C\J Another potential impact on public health and safety is pose O by the air quality present at or near the site. Analysis in 1981 of ambient air samples (reported in Section 2.4,5 - Air Quality) has revealed the presence of organic components (identities unknown) in low concentrations. 2.5.2 Environment The most significant threat to the environment is posed by the potential contamination of nearby surface waters, including the San Jacinto River, Jackson Bayou, the pond beneath U.S. 90, and the resultant potential nearby lakes, and introduction of the contaminants into the aquatic food chain. Contaminants could enter the water by lateral migration in groundwater or through surface-water runoff during rainfall and flooding. The disposal pit and other contaminated areas lie within the flood plain of the San Jacinto River.

2-27 Since 1969, the pit has overflowed its banks three times. The primary drainageway appears to be to the north, into the marsh and drainage levee adjacent to and north of U.S. Highway 90. This drainage path proceeds westward through the Sikes site connecting to a drainageway coming from the Sikes site. From here the combined runoff proceeds southward, passing through Gordon Lake, Rickett Lake, Faucet Lake, and McCracken Lake and eventually enters the San Jacinto River south of the U.S. Highway 90 bridge. The normal discharge would be slow and it is possible that contaminants would be impounded in these drainageways. in 2.5.3 Soc ioe conomic s CM O The most significant socioeconomic impact created by the o French Limited site could be the decline of property values O in the vicinity of the site. Although no definite data has been presented, real estate values in the Riverdale subdivision could suffer as a result of: (1) the subdivision's proximity to both the French Limited and Sikes sites and (2) the questionable quality of the shallow groundwater supply used as potable water. Another socioeconomic impact could be loss of the can Jacinto River or the Jackson Bayou to fishing. Significant contamination of these surface waters could result in a ban on the taking of fish for recreational or commercial reasons. A third socioeconomic impact could be the loss of sand mining operations in the near vicinity of the site. Infiltration of contaminated groundwater into the sand mining pits could result in contamination of the sand and a ban on further removal of sand.

2-28 2.6 DATA LIMITATIONS Analytical data have been developed for the French Limited site and were briefly described in Section 2.3, Hazardous Materials Characteristics. Organic compound and heavy metal analyses have been completed on sludge deposits, surface water, and groundwater collected at various locations on the site. Data have been sufficient to determine that contaminants are present at the site, both on and below the ground surface. However, the data are inadequate to fully describe the extent and characteristics of the contamination and its potential impact on area ground and surface waters. vO r- To date, conclusions should be considered preliminary; C\J additional testing is required to verify past rei, Its, O expand on existing data, and to draw definitive conclusions. O O Many aspects of the French Lima ted site have not been adequately addressed. Aspects which must be addressed prior to the implementation of remedial actions, include:

1. Full characterization, quantification, and distribution of wastes located within and around the disposal pit; 2. Identification of responsible hazardous waste gen- erators; 3. Groundwater flow patterns; 4. Horizontal and vertical extent of any groundwater contamination; 5. Potential for contamination of the deeper Chicot and Evangeline Aquifers, both important fresh water sources in the Greater Houston area;

2-29 6. Potential for contamination of nearby 1 surface waters by surface-water runoff from the site; 1 ~> Extent of contamination in nearby surface waters; 1 6. Detailed characteristics ,-iOf underlying geologic I 9. General health impacts of the site on nearby residents; and 10 Impacts on the environment, such as plant, fish, r- I and wildlife communities. r- CM O O GNR89 O i

2-30 •^^H I Section 3 REMEDIAL ACTION PLANNING Section 3 is devoted to scoping the various remedial activities judged necessary based on the data presently available. These activities include Initial Remedial Measures (IRM) and Remedial Investigation (RI) activities. A general scope of 1 work for the development of a Feasibility Study (FS) is also presented in this section. Information obtained during the RI will be used as a data base for the preparation of a more detailed feasibility study. It is normal practice to prepare a work plan for IRM/RI activities and the Feasibility Study as part of the RAMP c\j process. However, for the French Lifted site, a detailed o RI/FS work plan has already been developed by the state's o contractor, Lockwood, Andrews & Newnam (LA&N). (see "French r> Limited Site, Crosby, Texas; Work Plan - Volume I, Project Activity and Sampling Plan" submitted to: Texas Department of Water Resources by Lockwood, Andrews & Newnam, Inc. (no date)). 3-1 INITIAL REMEDIAL MEASURES _(IRM), Initial remedial measures are those actions considered necessary to reduce imminent hazards to public health or the environment. The potential hazard is the unknowing or accidental direct contact with hazardous substances by the local population. Factors for determining appropriate IRMs are outlined in 40 CFR 300.68(ej, Phase VI - Remedial Action. Actions that have already been completed at the French Limited site include the heightening and strengthening of the dikes around the waste pit; the repair of the dike that

3-1 1 washed out during one of the floods; the cleanup of the material that was washed out of the pit on the west end of the site; and fencing of the immediate boundaries of the I waste pit. I 3.1.1 Initial Remedial Measures I An IRM that is appropriate at the French Limited site is the installation of a perimeter fence and warning signs around I the entire property. A fence does currently exist at the site; however, it surrounds the waste pit only. There is no security at the site to prevent unauthorized access to contaminated areas adjacent to the waste pit. Human activity at the site occurs, as was evidenced by signs of c\j unauthorized dumping and the observation of several in- o dividuals making an emergency automobile repair during the o joint CH2M HILL/TDVJR/EPA site visit January 7, 1983. A gate should be placed at the access road into the site and warning signs should be posted at the gate and along the fence at regular intervals (approximately every 300 feet). The location and linear footage of perimeter fence cannot be precisely determined until a property boundary survey is completed. The LA&N work plan includes a property boundary survey as part of the Pre-Sampling Activities. Final plans for installing a perimeter fence, gate, and warning signs can be completed during or after the Pre-Sampling activities and prior to the on-site investigation activities. 3.1.2 Cost Estimate An estimated cost for implementation of this IRM is given in Table 3-1. Note that a more pi cise cost for installing the perimeter fence, gate, and signs can not be developed until

3-2 I I COSTS

Gate (l) Perimeter Fence (5,300') CM Warning Signs (20) C O TOTAL O $59,200

Note: a SUrVey is Assumed 5 800 H» r ? et f fen "ill be required , C costs or ^\ ff ° « - S14/lin. ft; low = °f^°ln^stalling ft< Costs fence: high installin g warninag Slgns«=i^ : hlu h of 540/sign. ? = 550/sign; low = GNR101

3-3 the property boundaries are adequately determined. However, low and high costs were developed based on an assumption of 5,800 linear feet of fence, 20 warning signs, and one gate.- 3.2 REMEDIAL INVESTIGATION ACTIVITIES i 3.2.1 General Objectives Before a remedial action can be proposed, sufficient data and information must be made available in order to evaluate and select the most cost-effective alternative. Work efforts to assemble these data and information are called remedial investigation activities. Oo Remedial investigation activities are generally structured O to accomplish one or more of the following objectives: 1. Determine if the site poses an imminent public health hazard or environmental problem. 2. Determine the nature and extent of contamination on the project site. 3. Define the pathways of migration from the site as well as impact of contaminants on potential receptors. 4. Define onsite physical features and facilities which could impact contaminant migration, containment, or cleanup. The information presently available concerning the French Limited site is insufficient to permit the screening/ selection, and feasibility study of remedial action alternatives. The following sections contain the scope of work prepared by

3-5 Lockwood, Andrews & Newnam designed to accomplish the above I objectives. The LA&N work plan has been partially condensed and paraphrased. For complete details , the reader must refer to the complete LA&N work plan referenced earlier in this section .

The Lockwood , Andrews & Newnam work plan is organi2ed into three major areas of effort: CM (1 ) Pre-Sampling Activities (100 series) G?/

3-6 (a) Boundary Survey i The purpose of boundary survey will be to clearly i define the property and disposal site locations with respect to nearby roads and other major features near the property. Included will be a survey of ma3or features on the site, near reaches of the San Jacinto River and the property fencelines. A legal description and deed of the property i will be obtained. The data will be used to generate a comprehensive site map depicting these and other salient i thesfeaturese surveys. Permanen. t boundary markers will be set during cc CM This information will be used in subsequent geological O and hydrogeological studies and for locating samples of O soils, surface waters/ ground waters, vegetation, sludge O sediirents, etc. This boundary and major features survey will be accomplished by aerial photogrammetry. Only limited ground control will be required. (b)

The purpose of the topographic survey (one-foot contours) will be to clearly define the relative elevations of the property and the disposal site's salient features. Topographic data is vital in the assessment of the extent of contamination,, the assessment of remedial actions and the cost-effectiveness analyses of alternative remedial measures. Aerial photography will be used for the topographic survey also.

3-7 I (c) The location of domestic water wells in the site I vicinity will be an important consideration during the site characterization. Therefore, a field inventory of well locations (both private and public) within an approximately 3/4-mile radius of the French Limited site will be performed. The purpose of the inventory will be to locate existing sources where water samples, hydrogeological and geological information can be obtained to optimize sampling and site investigation activities. (d) co oCvJ o Preliminary site and area geological information will o be obtained from published information, TDWR files and a ground reconnaissance. The published geological maps, fault maps, and soil surveys of the Crosby area will be general in nature and/or generally limited to the upper few feet of soil. However, they will be valuable in evaluating the site specific geology with respect to the regional setting. Con- sidering the rura^. site location and lack of major development in the area, it is expected that the TDWR files wilinformationl be th. e best source u£ r.ite specific geological

Existing aerial photos will be examined to assist in locating geologic features and conditions which should be examined by field reconnaissance. These photos will be a valuable tool in locating faults which might intersect the actiosite n arplansd coul. d affect the groundwater flow or remedial

3-8 (e) Hydrogeplogical Studies Pre-sampling hydrogeoicgical studies will consist of evaluating the ground-water regime based on the data in the existing monitoring wells and private weils identified during the well inventory. Accurate ground-surface and water level elevations will be determined at each well where stabilized water levels can be obtained. Current and historical dewatering and water level elevations in the sand pits located south and southwest of the site as well as the nearby San Jacintc River tributaries will also be used in ir\ contouring the area groundwater elevation. oo CM (f) Hydrological Studies Oo Historic flood water elevations will be researched to O assist in evaluating surface contaminant flow directions. Flood and rain water runoff patterns will assist in determining optimum location^ to sample the surface soils and water to check for the extent of the near surface contamination. The historic flood pattern will be utilized not only to study pit migration but also as a valuable tool in planning remedial actions. (2) Site Advance Planning Site Advance Planning includes the development of plans for safety, sample chain of custody and quality assurance. It also includes planning for on-site field office facilities. (a) Safety Contingency Plan The performance of the objectives of this project in a safe, effective manner is a primary objective of the project team. The corporate commitment to the protection of

3-9 individuals, property, and the environment is exemplified in the Safety Plan. The Project Safety Plan is contained in Volume II of the I.A&N work plan. A key individual in implementing the Safety Plan on site is the designated site Safety Officer. He will primarily be responsible for the provisions of the Safety Plan on site. A detailed Contingency Plan will be prepared as part of the Safety Plan in Volume II to cover emergency evacuation CO routes and procedures and emergency spill and fire control. CM O (b) Chain of_ Custody Plan O O A Chain of Custody program will be developed prior to the field investigations to ensure that samples are collected, handled, and identified in a complete and efficient manner. The Chain of Custody Plan is contained in Volume III of the LA&N work plan. (c) Quality Assurance Quality assurance encompasses all actions taken by an organization to ensure that the results and conclusions produced by its programs and projects are accurate and reliable. This activity involves two distinct, but related, concepts: quality control (QC) and quality assurance (QA). Quality control is adherence to the set of policies and procedures which ensure that collected, supporting data are accurate and that the lists of accuracy and precision for the data are known. As such, the concept of quality control is one component of quality assurance.

3-10 Quality assurance involves audits and review by management to assure that quality control practices and procedures are being properly implemented and that appropriate levels of accuracy, reliability, and comparability are being achieved in all facets of a project including all written documents. The Quality Assurance Plan is contained in Volume IV of the LA&N work. plan. id) Field Office A field office will be established during mobilization prior to the site investigation. Electrical and telephone CO service will be installed. This office will provide secure CM facilities for safety equipment, sampling supplies, and O files which are utilized over the course of the field o investigation. An equipment and personnel decontamination' O station will be located adjacent to the field office.

3. Site Investigations The purpose and objectives of the site investigations are to characterize the French Limited site in terms of pollutants present; the magnicuJe and extent of contamination; the rate of waste migration; and other physical site characteristics. Site investigations includes site sampling and hydrogeological studies. I*) Site Sampling The engineering feasibility study must be based upon the character and quantities of contaminants and their potential for migration. Thus, the site investigation will entail sampling of environmental media to supplement prior site investigations.

3-11 I a < ) Soil Bor_i_ng_syGroun_dwater Eleven new soil borings and twelve groundwater samples will be analyzed from the site vicinity. Seven of these groundwatsr samples will be taken from wells to be installed in boreholes following the boring program* The site selection rationale for these borings and groundwater samples and the chemical analyses are given in Tables A and B, respectively, located in the LA&N work plan, Section 4.0, Site Sampling and Appendix D of this RAM1P

Borings B001 will be drilled and logged west of the CM site near the base of the hill in an upgradient direction, O A shallow well, approximately 40 feet deep, will be o installed in this hole to serve as a background groundwater O sample, GW01. These well locations are shown in Figure 4-1 of the LA&N work plan, Section 4.C, Site Sampling and Appendix D of this RAMP. Boring B002 will be a deep boring (about 100 feet deep) just east of the Riverdale subdivision and will have a well installed afterward (GW02) tc provide data of the deeper aquifer. A shallow well (GW07) will be installed close by to form a piezometer cluster with the deep well. Downward vertical gradients can be measured at this cluster, and field permeability tests can be run if appropriate. Borings BOOS and B004 and shallow wells GW03 and GW04 will be installed further east of Riverdale. These wells, coupled with composite groundwater samples GW10 and GW11 (in Riverdale) and GW12 will provide insight into groundwater conditions downgradient from the site.

Figures and Tables referenced in the Site Investigations Section have been included in Appendix D of this RAMP for quick reference.

3-15 Boring BOOS and Well GW05 will be installed north of i V.S. 90 to provide comparative water levels against those wells south of the site and to determine groundwater i chemistry north of the waste pit. Boring B006 and Well GW06 will be installed into deep strata (approximately 100 feet i deep) near the existing EPA well southeast of the waste pit, This well and the existing shallow well will serve as a second piezometer cluster to determine vertical groundwater i gradients. i Three shallow borings 8007, B008, and B009 will be installed along the south site boundary to provide information CO i on soil layers along a potential slurry wall alignment. Two CM additional bores (B010 and B011) will be placed along the o theseastere nbor boundarye holes.. Monitoring wells will not be installed in I Groundwater samples GW08 and GW09 will be collected I from the existing monitoring wells along the southeast and southwest boundary of the site. (b) S ediment s I Nine sediment samples will be collected for analysis (see Table C in the LA&N work plan, Section 4.0, Site Sampling or Appendix D of this RAMP). Three samples (SE01, SE02, and SE03) will be composited from the eastern, central, and western zones of the waste pit. Sample SE04 will be taken from the small pit at the eastern end of the site. Samples SE05 and SE06 will be composited along transects across the swamp north of the waste pit. Sample SE07 will be composited beneath the U.S. 90 bridge. Sample SE08 will be taken north of the bridge to indicate whether PCB and heavy organic compounds have been carried

3-13 ^^™

I off site. Sample SE09 will be collected from the drainage ditch passing southward eat of the Riverdale subdivision. I These sample locations and the laboratory analyses are shown in Figure 4-2 and Table D, respectively, in the LA&N work plan. Section 4,0, Site Sampling and in Appendix D of this RAMF. I {c) Surface Water Six surface water samples will be collected for I analysis {see Table £ in the LA&N work plan, Section 4,0, Site Sampling or Appendix D of this PA^P). Samples SW01 and CM SW02 will be collected from the waste pit at depths to be O I selected based on stratification of pH or conductivity. o Sample SW03 will be taken from the east pit. Samples SW04, O I SW05, ard SW06 would be composited from the swamp north of the waste pit and beneatn the U.S. 90 bridge. The locations I and chemical parameters to be analyzed are shown in Figure 4-3 and Table F, respectively, in the LA&N work plan, I Section 4.0, Site Sampling and Appendix D of this RAMP. I In addition to these surface water samples, a survey will be done to determine water stratification and to define bottom contours in the waste pit. (d) Soils Recent flood events have dispersed sludge and scum residues into the forested areas in the immediate site vicinity. A site reconnaissance walk-though survey will be done to map areas affected by past flooding. Samples of residues will be composited by area {see Table G in the LA&N work plan. Section 4.0, Site Sampling or Appendix D of this RAMP). Six soil samples will be collected from areas west (S001) , south (S002), east (S003), and north (S004, 5, 6) of

3-14 I the waste pit. These locations and chemical parameters to be analyzed are given in Figure 4-4 and Table H, respectively, in the LA&N work plan, Section 4.0, Site Sampling and in Appendix D of this RAMP, (e) Fish Tissue Three composite samples of fish tissue will be taken from the fishing area beneath of the U.S. 90 bridge and i analyzed to determine if metals and PCBs are accumulating in aquatic organisms (see Table I in the LA&N work plan, Sec- tion 4.0, Site Sampling or Appendix D of this RAMP). The location of this site antl the chemical analyses to be completed are given in Figure 4-4 and Table J, respectively, oCO in the LA&N work plan, Section 4.0, Site Sampling and in o Appendix D of this RAMP. o (2) Hydrggeologic Investigations The hydrogeologic investigation program was developed from a review of existing hydrogeologic data and is intended to substantially improve the existing data base. Modifica- tions to the program may be made as field data collection proceeds. (a) Soil Borings Soil borings to obtain information regarding the geology and groundwater and to obtain samples for analytical and physical property testing will be performed using truck- mounted or swamp buggy-mounted rotary wash drilling equipment. Rotary wash equipment will be used because of the relatively high water table and sandy soils which are not suited to flight and hollow-auger drilling methods. However, dry auger drilling may be used until groundwater or

3-15 I seepage is encountered. All the borings will be drilled under the direction of a geologist or filed engineer who I will log the borings and obtain samples of the soils encountered. Undisturbed samples will be obtained at approximately 5-foot intervals by pushing 3-inch diameter Shelby tubes or driving a 3-inch diameter split barrel I sampler. Because the French Limited pit once contained very acidic waste (pH-2) , the pH of each soil sample will be measured in the field to help identify the lateral and vertical extent of the contaminated zone(s) and check that the boring depth is sufficient to penetrate it. Completed CVJ boreholes will be logged with a Johnson-Keck SR-3000 •_ resistivity and natural gamma borehole logger to accurately CM identify clay and sand layers and for later correlation with O other geophysical methods. After the borings are logged, O they will be either grouted with a cement bentonite mixture O or converted to a groundwater monitoring well. Tube samples from the borings will be returned to the laboratory for geotechnical testing. Eleven new soil borings are planned for the site vicinity. The site selection rational for these borings is presented in Table K in the LA&N work plan, Section 5.0, Hydrcgeologic Investigations and in Appendix D of this RAMP. Boring B001 will be drilled and logged east of the site near the base of the hill in an upgradient direction. A shallow well, approximately 40 feet deep, will be installed in this hole to serve as a background groundwater sample, GWO1. These well locations are shown in Figure 4-1 of the LA&N work plan, Section 4.0, Site Sampling and in Appendix D of this RAMP. Boring B002 will be a deep boring (about 100 feet deep) just east of the River dale Subdivision and will have a well installed afterward (GW02) to provide data of the deeper aquifer. A shallow weJ 1 (GW07) will be

3-16 I installed close by to form a piezometer cluster with the deep well. Downward vertical gradients can be measured at I this cluster, and field permeability tests can be run if appropriate. I Borings B003 and B004 and shallow wells GW03 and GWQ4 will be installed further east of Riverdale. These wells, coupled with composite groundwater samples GW10 and GW11 (in Riverdale) and GW12 will provide insight into the groundwater conditions downgradient from the site. Boring B005 and Well GW05 will be installed north of ",S. 90 to provide comparative water levels against those CM wells south of the site and to determine groundwater O chemistry north of the waste pit. Boring B006 and Well GW06 o will be installed into deep strata (approximately 100 feet O deep) near the existing EPA v/ell southeast of the waste pit. This well and the existing shallow well will serve as a second piezometer cluster to determine vertical groundwater gradients. Three shallow borings BOOT, BOOS, and B009 will be installed along the south site boundary to provide information en soil layers along a potential slurry wall alignment. Two additional bores (B010 and B011) will be placed along the eastern boundary. Monitoring wells will not be installed in these bore holes. (b) Monitoring Wells Eight of the 11 new soil borings will be converted to permanent groundwater monitoring and sampling wells. Both 4-inch and 2-inch diameter monitoring wells will be installed. Four-inch wells will be required where pumping/recovery tests are planned. Tamper-proof security

3-17 I covers will be installed at each monitoring well to prevent I unauthorized removal of the well cap. Details of the proposed monitoring well installation procedures are I contained in Appendix B, LA&N work plan, Volume I. (c) Groundwater Level Measurements Accurate groundwater level measurements will be obtained at each of the new and existing monitoring wells and the accessible private wells during the site investigation. In order to accurately determine the water levels, the elevation of each well casing will be surveyed to the nearest .01 foot. c- oOJ Water levels in the casing will be measured with an o electronic sounding device (Olympic Model 250 well probe), and the elevation of che groundwater will be determined from the permanent casing benchmark. Water level readings will be taken weekly and after periods of heavy rainfall so that the longterm groundwater gradient and flow direction can be determined and changes monitored. (d ) Field Permeability Tes

Field permeability tests will be performed in the new monitoring wells where the formation permeability is not high (i.e., where nearly instantaneous rising or lowering of the groundwater level in the well can be achieved). A slug test procedure is a rapid means of determing the permeability of an aquifer from the rate that the water level in the well rises after a certain volume (or slug) is suddenly added. The change in water level in each well will be measured with a Paroscientific Digiquartz pressure transducer and the data recorded on a Hewlett Packard digital printer at intervals as close as one second. The

3-18 I theory and procedure for analyzing slug test data developed oy Bouwer and Rive (1976) for unconfined aquifers and by I Peed (1980) for confined aquifers will be used. Because of the relatively large screened interval in I niost of the monitoring wells and the possibility that the alluvial materials are highly permeable, the time required I to introduce or remove the slug may not be instantaneous in comparison to the time required for the water level to fall or rise to its equilibrium level. In this case, a pumping/recovery test will be conducted. The pumping/recovery test will involve pumping the well long enough to achieve a m stabilized drawdown and recording the rate of recovery of CVJ t.he water level in the well after pumping has stopped. The o quantity of water pumped will be measured using a volumetric o flow meter. During recovery of the water table, the in-well o pressure changes will be recorded by the pressure transducer. It is anticipated that the pumping/recovery test will be used in the deeper monitoring wells or the highly permeable zones in the shallow monitoring wells. (e) Physical Soil Analyses Laboratory testing on selected samples from the soil borings v/ill be performed. The laboratory program will be designec to evaluate the physical properties of the soil for use in contaminant transport modeling and analysis and to provide a correlation between the rings and with field tests. It is anticipated that the following laboratory tests will be performed: constant head permeability on granular soils, falling head permeability on fine-grained materials, Atterberg limits, grain-size analysis, moisture content, dry density, and specific gravity. All tests will be performed according to the current ASTM, EPA, or U.S. Army Corps of Engineers standards (see Appendix C of LA&N

3-19 I work plan - Volume I). If required Ly the Project Safety I Plan (LA&N work plan - Volume II), the soil samples will be discarded into containers for transport to an approved disposal facility, or be returned to the site for disposal. Table L in LA&N work plan - Volume I (also given in Appendix D of this RAMP) summarizes the number of analyses I initially assumed. The results of laboratory testing will be reviewed by geotechnical engineers, and copies of the laboratory data sent to the corporate Laboratory Director for quality control checks. (f) Geophysics CM Various remote sensing geophysical techniques have been O considered to help define the contaminant plume location and o reduce the number of soil borings. The techniques consist O of electromagnetic (EM) profiling, and electric resistivity profiling. However, our review of existing data and a site inspection indicates that the contaminants may be so dispersed that they cannot be accurately detected by geophysical techniques and that site access is limited by heavy vegetation in many areas. The team has strong geophysical capabilities and is prepared to use remote techniques should additional studies indicate that they would be beneficial. 3•3 FEASIBILITY.STUDY Lockwood, Andrews & Newnam have prepared a work plan for the Feasibility Study as part of their overall effort. The plan is presented below.

3-20 3.3.1 General I Following the site investigation, alternatives will be I developed which incorporate remedial technologies and cleanup objectives into a comprehensive, site-specific I approach. A meeting will be held with TDWR to discuss the objectives of the remedial action and the cleanup criteria. I After the meeting, specific recommendations based upon either water quality criteria or upon a pollutant fate I analysis could be developed for application at the French Limited site. I Remedial alternatives could entail structural or non- OJ structural strategies, as well as non-cleanup actions such o I as alternative water supplies or fishing restrictions and o no-action options. The development of these alternatives, o I as well as the selection of site-specific cleanup criteria, will be done in close consultation with the state, I To the extent possible, the feasibility study will be conducted in accordance with the National Oil and Hazardous Substance Contingency Plan as published in the July 16, 1982 I federal Register. 3.3.2 Determination of the Appropriate Cleanup Criteria The remedial action alternatives to be evaluated will be capable of producing an acceptable level of cleanup as defined by criteria established in cooperation with TDWR. These criteria will depend to an extent on the findings of the site investigation and the identification of target receptors. If private wells are threatened by the site or contaminated groundwater migration, the cleanup criteria will be based on established and anticipated drinking water standards.

3-21 I Data developed during the site investigation coupled I with existing data will yield information on the migration of contaminants via surface water and groundwater pathways I into the near site environment. The distribution and fate of these contaminants in the aquatic environment may be examined using a simulation model such as the EPA Exposure I Analysis Modeling System (EXAMS), developed by Burns et al (1981). This model may be applied to the San Jacinto River I and to the "fishing hole" near the U.S. 90 bridge to assess the effectiveness of different remedial alternatives in I reducing the exposure of nearby target receptors. Site- specific input could include basin morphometry, flow charac- I teristics, sedimentary organic content, and residual contam- CVJ inant levels. o 3.3. o Development of Remedial Alternati i. V *5 In developing remedial alternatives, results of the I site investigation report will be examined to determine the extent and types of contamination that have been identified, both onsite and offsite. The relative success of the I initial remedial measures which have been completed to date will also be considered. These include the heightening and strengthening of the dikes around the pit, the repair of the dike that washed out during one of the floods, and the cleanup of the material that was washed out of the pit on the west end of the site. This information, in conjunction with the determined appropriate extent of remedial action, will be used to develop the remedial alternatives. The alternatives that are developed for final remedial action will be of two types: Source Control and Offsite Remedial Actj ;n.

3-22 (A) Source Control I Source control remedial actions will deal with four I major areas of contamination: waters within the pit, the contaminated ground water onsite, the sludges in the pit, I and the contaminated soils onsite. The following criteria will be assessed in determining whether and what type of source control remedial actions should be considered: I o The extent to which substances post: a danger to I public health, welfare, or the environment. I o The extent to which substances are migrating or OJ are contained by either natural or man-made Oo I barriers. o I o The experiences and approaches used in similar situations. I o Environmental effects and welfare concerns. I An initial analysis of the data available on the site is best discussed by looking at each of the four major areas of contamination individually:

Available data indicates that the waste pit waters contain organics and oil and grease; however, no PCB1 s were detected. The feasibility study will have to address both surface water controls and direct wastewater treatment. Potential surface water controls could include surface seals, surface water diversion and collection systems, grading and revegetation. Potential direct wastewater treatment methods include: biological treatment, chemical treatment, and physical treatment.

3-23 I An analysis of the existing available data indicates I likely treatment methods include: air stripping, carbon adsorption, filtration, and neutralization. The water will probably have to be removed from the pit, treated, and either discharged, disposed or returned to I the pit. I (2) Grpundvater I Available data indicates that the groundwater onsite o may not be as contaminated as the leachate plume which has o I migrated offsite. This is due to the fact that once dumping ro at the site was halted, various attempts were made to neu- o I tralize the water within the pit. Also the waste within the o pit has been diluted due to floods and normal rainfall. Therefore, water leaving the pit now as leachate may be of I higher quality than the leachate produced when the pit was in operation.

In any event, groundwater contamination is of particular concern because once an aquifer has besn contaminated, it can usually not be cleaned up without the expenditure of a great deal of time and money. Potential methods of controlling the groundwater movement offsite are: impermeable barriers, permeable treatment beds, groundwater pumping, or some type of leachate control. The potential treatment techniques for groundwater would be the same as those for the surface waters. (3) Sludges

Available data indicates that the sludges in the waste pit contain high levels* of heavy metals, PCB1 s and solvent

3-24 extractable organics. The concentration of these vary Throughout the depth of the sludge, with the highest concentrations in the top layers and the lowest on the bottom. Relatively few of the hazardous compounds found in the i sludges have appeared in the groundwater samples. This indicates that there is very little leaching of these compounds to the groundwater * (4) Soil Available data on the site indicates that soil on the O inside of the dikes is contaminated with the same compounds fO that show up in the sludges. This will probably be true O throughout the pit. The site investigation could O potentially identify other areas onsite where soil has been O contaminated. Likely places are the area north of where the dike was breached and the marsh area to the west. Contaminated soils which require remedial, action will probably have to be treated in much of the same way as the sludges. (B) Offsite Remedial Action Existing data indicates that leachate has migrated offsite and has been found in monitoring wells and domestic wells in the area. There have also been several floods on the site which have washed sludge and water out of the pit and onto surrounding property. Data indicates that groundwater gradient and the majority of the offsite groundwater problems will be to the southwest of the site. The soil and sediments contaminated by the flooding, however, are to the north of the site as

3-25 this is the major drainage course from the site to the San Jacinto River. The soil sediments in this drainage course are likely to be contaminated with PCB's and organics. (1) Groundwater

As discussed under the source control groundwater section, the leachate p^ume leaving the site probably varies in quality with distance from the site. The leachate that left the site while the pit was in operation and before any remedial efforts began is probably the most contaminated. CM The further the leachate plume is from the pit, however, the O more dilute it will be. The site investigation will be n O relied upon extensively to identify the extent and severity O of the offsite groundwater contamination. There has likely been some intermingling of the leachate plumes from this site and the Sikes site, (2) Soils

Existing data indicates that the soils and sediments in the drainage ditch to the north of the site have been contaminated. The potential remedial alternatives for the contaminated offsite soils and sediments would be similar to those onsite.

In both the source control alternatives and offsite remedial action alternatives, air emissions must be considered. There does not presently appear to be a major problem with lateral movement of volatile gases or minor atmos- pheric emissions. The actual remedial actions, however, could potentially cause serious air quality problems due to stripping of volatile organic compounds or disturbance of the sludges. Potential treatment alternatives include vapor phase adsorption or thermal oxidation.

3-26 3.3.4 Initial Screening of Alternatives The remedial action alternatives which are identified will be put through an initial screening ta narrow the list of potential alternatives to those which appear to be reasonable for this specific site. The criteria for this initial screening is outlined in the National Oil and Hazardous Substances Contingency Plan as follows: Cost

For each alternative, the cost of installing or imple- O menting remedial action must be considered, including opera- rA tion and maintenance costs. An alternative that far exceeds O the costs of other alternatives evaluated and that does not O provide substantially greater public health or environmental O benefit will be excluded from further consideration. (B) Effects of the Alternative The effect of each alternative should be evaluated in two ways: (i) whether the alternative itself or its implementation has any adverse environmental effects; and (ii) for source control remedial actions, whether the alternative is likely to achieve adequate control of source material, or for offsite remedial actions, whether the alternative is likely to effectively mitigate and minimize the threat of harm to public health, welfare or the environment. If an alternative has significant adverse effects, it will be excluded from further consideration. Only those alternatives that effectively contribute to the protection of public health, welfare, or the environment will be considered, further.

3-27 i I (C) Acceptable Engineering Pract Alternatives must be feasible for the location and con- I ditions of the site, applicable to the problem, and represent a reliable means of addressing the problem. Only those alternatives which are considered reasonable for this specific site will be considered for a detailed feasibility analysis.

3.3,5 Assessment of Alterntaives (A) General o K\ o The reasonable alternatives which survive the initial O screening will be subjected to a detailed evaluation. This O detailed analysis will consider the factors listed below. The results of the assessment will be tabulated and a recommendation made. o Technical Feasibilit y o Economic Feasibility o Environmental Acceptability o Regulatory Acceptability o Potential for Phasing (B) Technical Feasibility

Each alternative will be described in detail with appropriate figures. In the event that a treatment option is recommended, a determination will be made as to whether

3-28 treatability studies will be required to confirm the process. The established safety plan and chain of custody procedures will be followed. The analysis of potential groundwater remedial actions i will probably require the use of an appropriate groundwater flow model. A model would be appropriate when evaluating slurry walls and various groundv/ater pumping strategies to reduce or contain offsite contamination. When models are used, they will be calibrated to the extent possible with the observed water quality and quantity data collected in during the site investigation. o K^ The technical feasibility will also consider the o methods of construction, site characteristics, effectiveness o of any slurry walls, types of liners proposed, leachate o collection systems, monitoring, operation and maintenance, final disposal, etc. (C) Economic Feasibility Once the viable alternatives have been thoroughly defined in the technical review, a cost estimate v/ill be made of the capital cost required to implement each proposed remedial action. Any required monitoring and operation and maintenance costs will also be calculated. These costs will all be calculated on a present worth basis at an accepted discount rate at the time of the study. Information available in Cost Comparisons of Treatment and Disposal Alternatives for Hazardous Wastes , Volume I and II will be utilized in the economic analysis. Environmental Acceptability One of the outputs of the technical feasibility analysis will be an estimate of the quantity and quality of

3-29 I contaminants remaining. The environmental acceptability portion of this study will assess each alternative in terms of the extent to which it is expected to effectively mitigate and minimize damage to the public health and t!-* environment* Any adverse environmental impacts will also be considered. This section of the feasibility study will be particularly important to be sure that such problems are mitigated. Regalatory Acceptability Each alternative will be evaluated to see that all the applicable regulations of the Comprehensive Environmental

Response, Compensation and Liability Act of 1980 (CERCLA) t The National Contingency Plan (NCP) , the Clean Water Act (CWA) , and the State of Texas are followed. Also to be considered under this section will be the degree to which the alternative is ac 3p table to the public and the political acceptability of the remedy, (F) Potential for Phasing Different alternatives will offer a variety of oppor- tunities for phasing the work to accommodate factors such as incremented funding or fast- track requirements. The potential for phasing will be a criterion considered during the feasibility study. 3.4 REPORTING According to the LA&N work plan, certain submittals will be made as shown below.

3-30 3.4.1 Pre-Sampling _Submi11a1s I The following materials are to be submitted to TDWR by the dates indicated:

A. Worker Safety Plan, February 7, 1983; containing safety procedures.

B. Quality Assurance Plan, February 7, _1983; containing detailed procedures relative to sampling and analysis programs , o C. i Chai.in u» nr n ii- ••o inf i^»^—•. Custody. i_.ri—.111 .j^rfi ,- - - - -Februar------^- —^-- y-- * -^-- -7- , ——%^—•_—_1983_ ; containing —' detailed tA procedures on sample chain of custody. o o D. Site-Specific Sampling____ , ______,„..February^ 7,_, _ ^t.^/1983 u ^,- ; containin<_:urn:ain.i g detaileHpt-Ai'l^d ^ proceduret^,.,^,,^^.-..s- on site activities L, schedule, and c a ivii-i 1 i •-» '-

3.4.2

The following materials are to be submitted to indicated. TDWR by dates

A. Draft Site Investigation_Report, June 2, 1983; containing preliminary results of si':^ sampling effort for TDWR review. To be in a technical report format, containing headings similar to the following: o Executive Summary o Introduction/Background o Field Sampling o Laboratory Analyses

3-31 o Analytical Results o Discussion of Significance o Conclusions and Recommendations o Appendices B. Final Site Investigation Report, July 18, 1983; containing the final results of the site sampling effort with TDWR comments. Report to be in a technical report format, containing headings similar to those indicated above O the draft report . n o . Feasibility Report, .July 31, _ 1983; containing o preliminary evaluation of remedial measures for TDWR review. Report to be in a technical report format, containing headings similar to the following: o Executive Summary o Introduction/ Background o Goals/ Objectives o Selection Criteria o Technical Feasibility o Economic Feasibility o Environmental Acceptability o Regulatory Acceptability

3-32 o Phasing o Conclusions and Recommendations o Appendices

D. Final Feasibility Report, October 14, 1983; containing final evaluations and recommendations of remedial measures for site reclamation with TDWR comments. Report be in a technical report format, with headings similar to those indicated for the draft report. O 1^ 3.4.3 Periodic Submittals O O Monthly Status Reports containing pertinent activities will O be submitted.

3.5 REMEDIAL INVESTIGATION AND FEASIBILITY STUDY COST/SCHEDULE 3.5.1 Schedule A schedule of major activities is presented in the LA&N work plan, Volume I, Section 3.0. A copy has been included in Appendix E cf this document for quick reference. Specific due dates for deliverables is given in the preceding Section 3.4, Reporting. 3.5.2 Costs A detailed cost breakdown was not made available for inclusion into this RAMP. However, costs were provided for the three major areas of effort and are presented below.

3-33 I Cost ($) Pre-Sampling Activities $ 40,^39 (100 Series) Site Investigations 144,483 (200 Series) Feasibility Study 122,472 (300 Series) Total $306,994 O o The cost estimates shown are those developed by Lockwood, o Andrews & Newnam, o

GNR101

3-34 Section 4 COMMUNITY RELATIONS PLAN The Community Relations Plan for remedial action at the French Limited site, Texas was developed jointly by EPA Region VI and TDWR. The Community Relations Plan is included in Appendix F.

GNR101

O O O

4-1 CM

Oo Appendix A O SITE VISIT MEMORANDUM I MEMORANDUM CH2MBHILL TO: File I FROM: Greg Mclntyre DATE: January 14, 1983 SUBJECT: Site Visit to French Limited Site PROJECT: W66101.00.00

The site visit of the French Limited Disposal Pit was conducted on Friday, January 7, 1983. The following individuals participated in the site visit: o o Dave Moccia/CH2M HILL o Greg Mclntyre/CH2M HILL Mike Thompson/CH2M HILL Reid Dennis/CH2M HILL Tom Kearns/Texas Department of Water Resources (TDWR) Steve Ramanow/EPA, Region VI Tom Kearns, the TDWR field representative, has been to the French Limited Disposal Pit Site on several occasions and led us to the site. The French Limited Site is located south of State Highway 90 and approximately 1 mile east of the San Jacinto River in Crosby, Texas. The following comments are based on information conveyed and observations made during the site visit: 1. There is no residential housing directly adjacent to the site. However, a housing subdivision (Riverdale) is located approximately 1,500 feet west by southwest and hydraulically downgradient from the site. File Page 2 Jar.uarv 14, 1983 W66101.00.00

The site is bordered on the north by State Highway 90, on the south by a dirt access road, and on the east and west by wooded areas. A barbed wire fence encloses the immediate area surrounding the disposal pit. Warning signs are posted on the fence at regular intervals. The site was in operation from approximately 1966 o to 1972 and received unsegregated liquid petro- o chemical wastes. The liquid wastes were trucked o in to the unloading area on the southeast side of the disposal pit. It was reported that there once was an incinerator on site and burning of the waste was common. The disposal pit is approximately 5 to 6 acres in area and is located on a 23-acre site. The TDWR representative indicated that the disposal pit was excavated to the bottom of the sand layer approximately 28 to 30 feet below land surface. (Sampling conducted by E&E indicated the disposal pit depth to be approximately 18 feet and 10 to 12 inches of sludge). 8. An oil sheen was observed on the surface of the disposal pit. A light brown sludge was observed floating along the banks in several areas. I File I Page 3 January 14, 1983 W66101.CO.OO

The west end of the pit contained a dense area of thick black sludge which was contained in the corner of the pit by a floating boom. 10 An odor which I associate with oils was noted at the site. in 11. It was reported that two major floods have occurred at the site since its closure. The disposal pit o contents reportedly overtopped the diked walls o during the flooding. o

12. Several small pits and drainage ditches located outside of the fenced area were also observed to have an oil sheen on the surface. 13. The TDWR representative reported that at one time during the operation of the disposal pit, the pH in the pit dropped to about 1.5. In an effort to neutralize the disposal pit, approximately 1,000 "loads" of cement kiln ash were dumped into the pit.

14. It was also reported that during the early 1970 's an odor was detected in the private wells of a nearby subdivision and the pH was abnormally low. The wells were out-of-service for an unknown length of time. It was reported that the pH eventually returned to "normal" levels. File Page c January 14, 1933 W66101.00.00 i 15. Seme initial remedial measures have already been sitconductee visitd .at the site and were evident during the These measures include:

Some areas of the dike wall were rebuilt and vO reinforced. This action was due to breaching of the dike caused by flooding. o o An overflow standpipe was installed along the o north bank to prevent overtopping- of the dike walls. The overflow valve which discharges to an adjacent slough has reportedly never c been opened. Contaminated sludge frcm the drainage ditches to the west of the disposal pit was excavated and put back into the pit. This is the thick black sludge, mentioned in comment No. 9. d. The fence and warning signs were installed. 16 There are two monitoring wells at the site, one to the west, and one to the southeast. Both wells were inspected and found to be locked. 17 Protective suits worn by personnel working at the abandoned disposal pit were observed to be discarded inside the fenced area. I File Page 5 January 14, ?983 W66101.00.00 To document the above observations, the site visit was recorded on video tape.

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o . oo O O Appendix B O SITE CHROWOLOGY ••I• FRENCH LTD. DBAFT SITE CHRONOLOGY (1966 - 1982) 1966 - 1979 Complaints of odors and burning wastes registered by local residents brought the French Ltd. site to the attention of the Texas Water Pollution Control Board and Harris County in 1966. Subsequent inspections conducted by state personnel concluded that an unpermitted waste disposal operation was being conducted at the site. In 1967 French Ltd. of Houston, Inc. was informed of the need and instructed to apply for a waste control permit. After three years of negotiation over specific state application requirements and several court actions prompted by continuing citizen complaints over tions at the site, French Ltd. was issued a permit (Waste Control Order No. 01344) in January, 1970. In March, 1971, o the permit was cancelled due to the failure of French Ltd. Q to fully comply with special provisions of the permit that ^ required, among other things, the installation of an impermeable liner in the pond to prevent percolation of pond contents and lateral infiltration of pond contents through dikes. French Ltd. was nonetheless ordered to clean up the pond contents and to install an impermeable liner. After failing ro meet these requirements, French Ltd. was sued by the State in 1973 for $10,000. As partial payment of the fine, French Ltd. deeded the disposal site property to the State of Texas. From 1973 to 1979, periodic investigations of the site were made and samples were collected and analyzed to better determine types and levels of pollutants existing at the site and in local ground and surface t\raters. A flood in 1973 inundated the pond water with an apparent significant dilution of the pond liquid. May 23, 1979 Site visit conducted by Charles Kirkpatrick and George Rejsek. Detected a break in dike near U.S. 90 bridge allowing water to enter adjacent pit. Noted floating oil in body of water outside of dike. Six water samples were collected within and outside the main pit. June 20, 1979 Soil and water samples collected at French's pit "to ascertain whether a potential for pollution to surface or ground waters still exists."

B-l July 9,1979 Report on halogenated components found in 6/20/79 soil and werwatee r positivsamplese . forHexan halogenatee extractd s componentsof the .soil and core samples July 11, 1979 RiverdalWater samplee Subdivisions were collecte. d from ten wells in the adjacent July 12.,_1979 Report on analysis of 6/20/79 samples. Results showed presence of aromatic and polynuclear aromatic hydrocarbons. f* _ .- • • CVJ EPA representative (Ken Cooper) inspected the French Ltd. site. Noted a gap in the north side of the levee which allowed water to flow into or out of the disposal pond. Collected one water sample (from southeast corner of pond). o haNoted d neithesite r xvawarnins easilg ysign accessibls or fencee .to the general public and

Follow-up inspection at site made by EPA's Ken Cooper. Ob- served oily sludges and waste disposal drums on the bottom of disposal pond. Collected sample of bottom sludge and a pondsampl.e from a dead-end slough located west of the disposal December 11 , 1979 TDWR Interoffice memo that provides an update on French Ltd. site history, and recommends restoration of dike breached by April 1979 flood; posting of warning signs; and fencing of sitsitee . closurAlsoe recommendplan. s seeking financial help to develop June 13, 1980 dikEPA e fielis d breachedinspectio. n made at site by E, W. Cooper. Notes March 30, 1981 poseInternad groundwatel EPA memr o studtransmittiny for gth e foFrencr revieh wLtd . andsite commen. t e pro-

B--2 I May 6, 1981 Meeting held between EPA and Texas Department of Water Resources to "develop a coordinated program to assess the potential for groundwater contamination" at the French site. I The program discussed included several important steps, some of which were: o Collection and analysis of Riverdale well samples o Evaluation of well results o Development of a more extensive groundwater strategy to more clearly define the existence and extent of groundwater contamination/ the source and assemble information needed for remedial decision-making May 13^ 1981 C\J Air samples taken around French site and analyzed. Low concentration of contaminants were reported. O O July 1981 Emergency Action Plan prepared for the French Ltd* site. August 19, 1981 Acoustic emission monitoring survey conducted to determine dike stability. Results indicated structural stability. August 27, 1931 Water and sludge samples collected by FIT personnel. September 17^ 1981 Residential well samples collected by TDWR. September 18, 1981 FIT repor- on results of 8/26-27/81 sampling and analyses. September 29, 1981 FIT report on "Review of Organic Analyses of Three Sludge Samples from French Ltd. TDD #F-6-8109-32." These were sludge samples collected 8/26-27/81. All three samples contained priority pollutants. All thr^e were negative for PCBs.

B-3 EPA report on PCB analyses of residential well sample* s collected 9/17/81 by TDWR. Reported no PCBs detected. November; 9, 1981 paredRemedia. l Response Fact Sheet for Allocation of Funds is pre- Noveriber_ 23, 198_1 FIT report on monitoring well samples collected at French tantsLtd. . site. Results indicated high levels of organic pollu- CVJ C\J EPA sent a notice letter for remedial action to George r^ Whittmen, owner of French Ltd. of Houston. o O February 22,1982 o bEPe A conducteauthorised d at a thremediae Frencl h investigatioLtd. site.n and feasibility study March 8, 1982 EPA site visit. March 19, 1982 TDWR provides EPA with requested itemized budget breakdown sitefor .site investigation and feasibility study for French Ltd. April 29, 1982 Cooperative agreement for $437,000 awarded to Texas. May 12, 1982 EPA announces that plans are underway to conduct immediate removal actions at site. The removal actions are to include (1) removal of remaining PCB-laden floating sludge mat and shoreline deposits and placing it back in lagoon, and (2) repairing any significant deterioration of the lagoon dike. July 9, 1982 undeEPA r commentthe Cooperativs on TDWR'e Agreements draft . Request for Proposal for work

B-4 Removal action started. August _1_7, 1982 Removal action completed. December 16, 1982 TDWR selects Lockwooc, Andrews and Newman as the candidate tiofor n contracand Feasibilitt negotiatioy Studyn fc. r the French Ltd. Site Investiga-

GNr89 CM K^ O O O

B~5 CVJ ro o o Appendix C o SOIL BORING LOGS ONtuon jo 001

i X o of.- m SOIL o o Oorino NO.: F-2 •tl t. NOTES I Sand, clay, fill material

Black sand, contaminated, odor present Water drilled 1C I

CM ro o L ••

TD 30' -

ur WATf ft i ...id Oi««r.iiio,u OI«I,OM LOG Of" UORING Bob W. Lee I I I

CM o o Appendix D o REMEDIAL SITE INVESTIGATIONS - LOCATIONS, SITE SELECTION RATIONALES, AND LABORATORY TESTING 4-3 Table A Well/Boring Site Selection Rationale French Limited 5i te

Site Number Rationale B001/GW01 Background shallow well upgradient (east) of French Limited. B002/GW02 Deep well south of Gulf Pump Road, downgradient of French Limited. B003/GW03 Shallow well south of Gulf Pump Road, downgradient of French Limited, east of B002. B004/GW04 Shallow well upgradient of BOC2/3, potentially across gradient from French Limited. ao S005/GW05 Shallow well north of U.S. 90, northwest of French Limited, potentially downgradient. B006/GW06 maiDeenp wellagoonl adjacen. t to existing EPA well southeast of B007 Shallow borings to 40 feet along southern French 8008 Limited boundary to define soil characteristics along 8009 potential slurry wall alignment. BOIO Shallow borings to 40 feet along eastern boundary to BOil define soils along potential slurry wall alignment. GW07 Shallow well adjacent to deep well GW02, forming a piezometer cluster downgradient of French Limited, but upgradient from Riverdale Subdivision. GW08 Existing well southeast of Main Lagoon. GW09 Existing well southwest of Main Lagoon. GW10 Composite jroundwater sample from about 5 homes with shallow wells in southern half of Riverdale. GW11 Composite groundwater sample from about 5 homes with shallow wells in northern half of Riverdale. GW12 Residence well at 915 Gulf Pump Road immediately south and downgradient from French Limited. Source: ESE, 1983.

L. COCK WOOD: AMORCWB fi NCvt/WAM. If C. I Table B Groundwater Chemical Analyst French Limited Site

Site ••>•"" Number Type of Chemical Analysis GW01* GW02 A B C D E F G GW03 A B C D E H I J K GW04 A B C 0 E A ru D t - __•••• GW05 AFt C 0 GW06 t*£ F H I J A B C 0 L> K GW07 A 8 C 0 J K GW08 M E F G A C D E F G H I GW09 A B C D E H I J K G010 A B C 0 F G H I J K GW11 r\A E G GW12 C D E G J _A J_ JL Jl JL K TOTAL SITES 12 12 12 12 12 5 6 5 5 6 6 Duplicate samples. A -- H - PConductivity C Xtractabls D -- TOP K ta]l Or^ anl E - rnv I 9 c Carbon) F -- TOMetalX sTotal Organic Halogen) G -- Total Phenols H -- PC8s (Pesticides) I -- GC/MS (Volatile*) J -- GC/MS (Base Neutral) K -- GC/MS (Acid) Source: ESE, 1983.

LOCK WDOO- 1 *M' INC. I 4-6 Table C Sediment Sample Site Selection Rationale I French Limited Site Site Number Rationale SE01, 02, 03 Waste pit composite samples from east, center, and • west zones. SE04 Composite sample from east pit on French Limited Site. SE05 Composite or samples taken from swamp along cross °' section near U.S. 90 bridge. ^\ KY SE06 Composite of samples taken from swamp along cross o! section near west end of waste pit, o; SE07 Composite of samples taken under U.S. 90 bridge. 'i ; SE08 Sample taken from channel centerline north of U.S. 90 at site to be selected. SE09 Sample from drainage aitch south of Gulf Pump Road and east of Riverdal e. Source: ESE, 1983.

C . A N O K E W 5 4 '4 £ \-. H i. M . INC. Table 0 Sediment Chemical Analysi French Limited Si te

Site Number of Chemical Analysis SEOi* SE02 c D E F G H SE03 c 0 E G H SE04 c D E F G H SE05 c 0 E F G H SE06 c D E G H SE07 c D E F G H SE08 c D E G p SE09 c D E H

Site Nisnber Rationale SWOI Eastern end of waste pit at depths to be selected. SW02 Western end of waste pit at depths to be selected. SW03 Sample from east pit. SW04, OS O Samples from swamp northwest of waste pit. O SW06 Beneath U.S. 90 bridge. i* Survey to determine any stratification of pH or conductivity in waste pit. ; i oBathymetrin waste cpit .Survey to determine water depths over grid • Source: ESE, 1983.

c e •; wn c c.. <. f. c> 4-12 Table F Surface Water Chemical Analysis French Limited Site i Site Number Type of Chemical Analysis "•*~-r — ' • i— •^1^1 i miaiJH,^ •"• ., " '" i .— — . -— -[••ni^^-. i •.wn ft \J ii A B C D SW02 A 8 E F G H I J K ro SW03* M c D E G H A DR c D ri_ - Ki SW04 HA (R5 D G SW05 A B c E F G H r J K fO SIV06 A R c D E G H O -1 **" ** F ~ -• £ 2. i i H I J_ K_ 1o fOTAL SITES 6 6 6 6 O 6 3 6 5 3 3 3 i * Dupl icate samples, A -- pH Conductivity C a xtractdb] 0 Tnr fj°+ tal l ^Or ani e Organics cL. ^v J° 9 'c Carbon) F MetaliOX (Totas l Organic Halogen) G Total Phenols H PCSs (Pesticides) 1 GC/MS (Volatiles) J GC/MS (Base Neutral) K GC/HS (Acid) Source: ESE, 1983,

:00. - L i-. 5 r. 4-13

Table G Soil Sample Site Selection Rationale French Limited Site

Site Number Rationale SOC1 West end of French Limited Site, seek sludge residue. S002 Sludge and/or soils along south site boundary. SOC3 Sludge and/or soils a^ong east site boundary. O SOO^ Sludge and/or soils dbove swamp waterline south of O U.S. 90, O SOC5, 06 watersSoils .north of U.S. 90 in area flooded by past high Site reconnaissance ^k-through survey to determine extenswamp t waterof lsludg inee. residues on soils above prevailing Source: -ESE, 1903.

- o ~••: \-.- c C c - A ti c• a -; 4-16

Table H Soils Chemical Analysis French limitad Sits

Site Number Type of Chemical Analysis — "• — - H _ — —— - — . ——— . — — •• —-ill. I"I • •" •— •' - •! 1^.. — _ _ S001 S002 ~ — r D E F H J K C D E Li i S003 wC 1 S004 D E I". r\j 0 uc — J K S005 H J K ri S006* c D E H J K ~ - £ 0 I ™ H C TOTAL SITES :o 006 6 6 1 0 4 n A A o Oupl icate samples. A -- H - PConductivity C - { a £xtractabl D -"- TOrnC r(Tota / T°5l Organi! c Carbon) e Organics cL- ~ - TOX (Total Organic Halogen) C „- Metals G - Total Phenols H - PCBs (Pesticides) I - GC/MS (Volatiles) J - GC/MS (Base Neutral} K - GC/MS (Acid) Source: ESE, 1983.

LOS '•' S (. M C M- K. A M . i •„ I 4-17

Table I Biota Samples Selection Rational Lfrafted Site

bioaccumulats specimeni s beneath u s 9o0n bndK 9-* e analyzed for Source: ESE, 1983. ci o I 4-18 I Table J Fish Tissue Chemical Analysis French Limited Site

Site Number Type of Chemical Analysis FT01-A FTOi-6 FTOi-C TOTAL SITES o Dupl icate samples. ;o A 3 -- Conductivity C -- TOE (Total Extractable Organics D TOC (Total Organic Carbon) L. TOX (Total Organic Halogen) F Metals G Total Phenols H PCBs (Pesticides) I GC/MS (Volatiles) J GC/HS (Base Neutral K GC/MS (Acid) Source: ESE, 1983. I 5-3 Tab^e '< Well/Bering Site Selection Rationale French Limited Site Site Number Rationale SOOl/GWOi LimitedBackgroun. d shallow well upgradient (east) of French 3Q02/6W02 FrencDeep h welLimitedl south. of Gulf Pump Road, downgradient of 3003/GW03 oShallof Frencw h welLimitedl south, easof t Guloff Pum8002p .Road, downgradient 3004/GW04 f gradienShallowt welfrol m upgradienFrench Limitedt i 8002/3. , potentially across o 3005/GW05 o LimitedShallow , welpotentialll north y of downgradientU.S. 90, northwes. t of French 3006/GWQ6 maiDeenp wellagoonl adjacen. t to existing EPA well southeast of = 007 BOOS Shallow borings to 40 feet along southern French 3009 potentiaLimited l boundarslurry walto l definalignmente soil . characteristics along B010 3011 Shallow borings to 40 feet along eastern boundary to define soils along potential slurry wall alignment. Shallow well adjacent to deep well GW02, forming a upgradienpiezometet r clustefrom Riverdalr downgradiene Subdivisiont of Frenc. h Limited, but G*Q8 Existing well southeast of Main Lagoon, GW09 Existing well southwest of Main Lagoon. GW10 Composite groundwater sample from about 5 homes with shallow wells in southern half of Riverdale. GW11 Composite groundwater sample from about 5 homes with shallow wells in northern half of Riverdale. GW12 Residence well at 915 Gulf Pump Road immediately south and downgradient from French Limited. 5-7

Table L Summary of Laboratory Tests for Physical Soil Properties Test Number Moisture Content 60 Dry Density 60 Atterberg Limits 10 Grain Size Analysis 24 Specific Gravity 10 Pemeabil ity 12 o

. AKORCAd fi N C ^ W * M . BQ07^GWQ6

£ TOWfi Monitor Welts • Monitor Wel! -f- Soil Boring -f Boring and Weff Figure 4-2. Sediment Locations

000341 ure4-3. Surface Water Locations Figure^. Composite Soil andFfeh

-OJQQ 3 4 3 Site -Schedule of Major Aclivilj Texas tment of Water Resources PS Task Series DateCompEellos n Figure 3-t 100 Sertes Fcst Actual! 1983- Gala Search A^y Sept I Oct Surveying 228 Well fnveniory 1-3* Plans '2-7s 200 Series , SO, S£ Sampfes I UfflllfKJ 3 18 ZJ Samples mi(;j! Analysis 3-25 Ql )f[ -?s )rl 300 Series f^57 •o* Cr Her id C/25 Alfornalives >, Detailed Analysis 2 Cos! Fsifmales '/i§ i Dralt Report Ftnal Report Notes: " Sfectfic Delivery Dales s s :x> J... 20«1fW0l *-> - Final fleporl Ctunpteiion OVJIL- ASSI«:M;S 'JO Day T(JW(t Compledon Dates A m J Stirics Hevicw of (>ei(j I w T( rt,v» -J ———— -—————————__ -^ HAVH rif-vic-w ti( n.a I

O Appendix E o REMEDIAL INVESTIGATIONS/FEASIBILITY STUDY SCHEDULE OF MAJOR ACTIVITIES E *;?;:• ~

COMMUNITY RELATIONS PLAN for Remedial Action at the French Limited Hazardous Waste Site Crosby, Texas

o o o

Revised February, 1983

Abandoned Site Response Unit Texas Department of Water Resources 1700 North Congress Avenue Austin, Texas I I

COMMUNITY RELATIONS PLAN for Remedial Action at the French Limited Hazardous Waste Site Crosby, Texas CO

O O O

-y Act of 1980. onse, Compensation and Grant Number: CX-810196-Q1-2 Grant Manager: Gary D. Schroeder, P.E. Texas Department of Water Resources

e S project s hould French Limited H«ardous Waste Site Chris Lippe Abandoned Site Response Unit TSoli d Waste and Spill ResponsPtl0e Section n Austin, Texas 78711 TABLE OF CONTENTS ii Statement of Qbjecti ve...... 1 i A. Site Background and History of Comt.iunity Involvement at the French Limited Site...... 1 i B. Specific Objectives of the Community Relations Program at the French Limited Site...... 3 C. Community Relations Techniques and Objectives...... 3 i D. Workplan and Schedule...... 5 o o E. Budget and Staffing Plan...... 6 APPENDICES A. Interested Groups and Individuals B. Site Location Map COMMUNITY RELATIONS PLAN I for Remedial Action at the French Limited Hazardous Waste Site Crosby, Texas I July 1982 - March 1983 This 1 ti or community relations plan (CRP) outlines the anticipated community rela- in C i program for the continuing stages of remedial action at the Trench site resp •ssby, Texas. Under a Cooperative Agreement with the £PA, the TDWR is 1 si te .isible for implementing the community relations program at the French 1 A. .'TE BACKGROUND AND HISTORY OF COMMUNITY INVOLVEMENT AT THE FRENCH SITE Site Background o The French Limited of Houston, ire. site is south of U.S. IP, Highway 90 on Gulf Pump Road, approximate y le west of the r^i harrisectiosn Countyof Far. m to Market Road 2iOO and U S Highway 90 in northeast O O This site began in 1965 or earlier, as a sand pit owned by Sandy o Sands, Inc., a corporation operated by a Mr. B. G. Burton. In 1966, the files indicate French Limited, a Texas corporation, was disposing i waste materials into this pit. French Limited was purchased by French Limited of Houston, Inc. in December of 1966. French Limited of Houston, Inc. (herein after referred to as French) purchased the disposal pit from Sandy Sands, Inc. in June of 1967. For the next six years this site was the largest known off-site disposal facility in wastthe e Houstoper nyear area. , handling an estimated 100,000 barrels of industrial During operations at this site, the facility held permits or orders from the Texas Air Control Board, the Texas Railroad Commission and the Texas Water Quality Board. The site was a continual source of complaints due to odors, fire, surface discharges and ground water problems. These complaints, coupled with French's inability to meet permit/order requirements, eventually led to the cancellation of these various permits and to litigation in 1971 between Harris County (with fother violatioTexas Waten ro f Qualitenvironmentay Boardl anregulationsd State a.s intervenors) and French In September 1973, French's attorney stated his clients intent to file bankruptcy and in October of 1973 a final judgement was entered. This judgement required French to close two breaches in the dike, strength- en and level the dikes, remove all buildings, tanks, etc., pay Harris CountLand y Office$20,90. 0 and deed the property to the State of Texas General This site is in the floodplain of the San Jacinto River and was flooded in ^969, 1973 and 1979. The flood in June 1973 followed 18 months of litigation. This litigation accomplished the removal of oil from the site, the neutralization of the 1.4 pH with 1,000 twenty-ton loads of cement flue dust and the initiation of aeration in the pond. The flood flushed highly contaminated si:e water to the San Jacinto I River, with no known or recorded occurre^ce .of damage. The flood in 1979 caused a breach in the north dike of the pit allowing the discharge of contaminated sludges. In August 1980, a 311 action was initiated at this site to collect end retjrn some of the sludges outside of the diked area to the impoundment. During this action the levees were restructed. The pit itself covers approximately 5 sur-ace acres and ranges from 2 to 30 feet in depth. Contaminated sludges, which were discharged during flood condition, have been found in adjacent drainage areas and in the marsh area immediately west of the pond. The pit is believed to be stratified with a fairly good quality of water at the surface. Approximately 200 people (53 houses) with shallow wells could eventually be impacted by contaminated ground water, although testing to date has indicated no contaminants in the drinking wells closest to the site. Monitor wells installed by the State on site indicate sandy soils from the surface to 30 feet (depth of borings). Ground water from these wells contain notable concentrations of several heavy metals and organic compounds. Ca The major environmental problems at this site are; o a. Shallow ground water contamination is occurring at the site. There are families in the area using shallow ground water for drinking purposes but no contamination has been found in any drinking wells to date. b. Low levels of contaminants have been measured in the air in the immediate vicinity of the waste areas. c. Some contaminants, including PCBs, have been recorded in adjacent marsh areas which eventually drain to the San Jacinto River. Of "particular concern is the potential uptake of bioaccumulative toxics into the aquatic community. 2. Community Involvement at the Site As noted above, the site was a continual source of citizen complaints during site operations. More recently, in the fall of 1981, a group of 50 Riverdale citizens participated in a public meeting along with EPA and TOWR representatives regarding this site. Mr. Melvin Whiddon acted as spokesman for these citizens. The safety of the drinking water was the major concern expressed at this meeting. Community involvement will likely increase as remedial actions proceed at the site. B. SPECIFIC OBJECTIVES OF THE COMMUNITY RELATIONS PROGRAM AT FRENCH p 1. During the remedial Investigation, feasibility study, and beyond,

DOO 3 5 4 I E. 5'JDGET AND STAFFING PLAN Date Activity Staff Responsibility Hours I 6/10 32 Revise and Submit CRP Primary: S. Ferguson 24 Coordinate: R. Kimbro 2 T. Milligan 2 C. Chambers (EPA) Week 1 Contract Awarded Week 2-3 Prepare Press Release Primary: S. Ferguson 6 Coordinate: R. Kimbro 1 T. Milligan 1 Week 2-3 Prepare Briefing for Primary: S. Ferguson 6 Officials Coordinate: R. Kimbro 1 in T, Milligan 1 \r\ ro Week 4-5 Contact Officials Primary: C. Lippe 12 o Coordinate: R. Kimbro 1 o C. Chambers o Week 6 Issue Press Release Primary: C. Lippe Coordinate: R. Kimbro T. Mi 11igan C. Chambers Continuous Develop Status Reports Primary: C. Lippe 10 R. Natek 10 Coordinate: Project Mgr. 1 T. Milligan R. Kimbro Ji Week 36 Final Investigation Report from Contractor Week 37-39 Public Consultations Primary: C. Lippe Coordinate: R. Kimbro T. Milligan C. Chambers Week 40 Interim Report Primary: C. Linpe 6 Coordinate: R. Kiriibro 1 T. Milligan 1 Week 41 Revise CRP Primary: C. Lippe 6 Coordinate; R. Kir.uro 1 T. Mllligan 1 Continuous Respond to Media/Citizen °rimary: C. Lippe 12 Calls Coordinate: T. Milligan I

LO r^ o o o APPENDIX A Interested Groups and Individuals I t of w Fec~ral 1 n Honorable Jc*i G. Tower United States Senate Honorable Jack Fields 1 Washington, 3 •C. 20510 House of Representative Honorable LlojGovernor of Texas Austin, Taxas 78711 Honorable Tom Craddick, Chairman TexaResources Housse Committee on Natural i 3108 Stanolind' Honorable lindon Williams, Jr. Midland, Texas 79701 O Texas Senate O P. 0. Box 9816 Honorable Tati Santiesteban, ChairmafP Houston, Texas 77015 74Texa7 s SaSenatn Antonioe Natura, *10l Resourc0 e Committee Honorable Tony Polumbo El Paso, Texas 79901 85Texa5 s UvaldHouse e Roaof d Representatives Honorable Fred Agnich, Chairman i Houston, Texas 77015 TexaAffairs Houss e Committee en Environmental Room G61 P. 0. Box 2910 Austin, Texas 78769 Loca?_ Mr. Richard Bianchi Chamber of Commerce 506 Church Street Jaraes Font Crosby, Texas 77532 713/338-3571 Houston, Texas 77002 Mr. Jack Steele, Executive Director Houston-Galveston Area Council Honorable Jon Lindsay P. 0. Box 22777 Harris County J Houston, Texas 77027 '001 Preston udge Crosby Municipal Utility District Houston, Texas 77002 5521 Avenue B Mr. A!], 'son Peirce Crosby, Texas r 713/328-4242 Pasadena, Texas 77506 [nc-viduals and Concerned Rrn..pc RiverdalMr. Melvie n Whiddon Adj3cent Property Owners (wi'l be listed when identified) Citizen'1 Ma^n sPlaz Environmentaa #1016 l Coalition Toxic Substances Task Force Houston, Texas 77002 1 Main Plaza #1016 Houston, Texas 77002 Sierra Club Conservation Committee Audobon Society 1 Main Plaza #1016 5409 Braedurn Houston, Texas 7700? Bellaire, Texas 77401 League of Women Voters 00 5426 John Dreaper Houston, Texas 77056 SoutheasTexas Watet r SectioPollution n Control Assoc,J 1834 Cheshire ° Houston, Texas 77018 O Media o The Houston Post KNUZ Radio Attn: Harold Scarlett Attn: Lea Foxe Houston, Texas 77001 P. 0. Box 188 Houston, Texas 77001 The Houston Chronicle Attn: Carlos Byars KPRC Radio Attn: Harry Schultz Houston, Texas 77002 P. 0. Box 2222 Houston, Texas 77001 The Highlands Star Attn: Editor KTRH Radio P. 0. Box 485 Attn: Ben Baldwin Highlands, Texas 77562 P. 0. Box 1520 Houston, Texas 77006 The Baytown Sun Attn: Editor KHGU-TV Attn: Jerry Levin Baytown, Texas 77520 P. 0. Box 11 Houston, Texas 77001 Houston Community Newspapers Attn: Patrick Smith KHTV-TV P. 0. Box 280 Attn: Nancy Paul P. 0. Box 1439 Channelvit*, Texas 77530 Houston, Texas 77001 KIKK Radio Attn: Chuck Wolf KPRC-TV 6306 Gulfton Attn: Mike Casserly P. 0. Box 2222 Houston, Texas 77091 Houston, Texas 77001 I <:LT Radio Attn: Jim Carola KTRK-TV -"0 Lovett Blvd. Attn; Walter Hawver Houston, Texas 77006 P. 0. Box 13 Houston, Texas 77001 I E.'A - Region Vf Mr. William Hathaway Oeouty Director Libri i I rector 22 I Ms. Carlene Chambers Texas Project Officer Sutjerfund Branch Mr. Charlie Gazda 2M/767-9091 * Branch Mr. Randall Sabine m Office of Intergovernmental and r^ o o I I I I o I o I APPENDIX B I Site Location Map

•w* French Limited,. Inc. - Abandoned Hazardous, Waste SlCe

00036 !„._.___.