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Final Remedial Action Master Plan for the French Limited

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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 Jl ••*!- 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 accor- dance 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 migra- tion 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 pro- jects 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 reme- dial 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. 1-2 '"**w«* J l •- r,V*.,« T, >' C ' 3r ^"~ 1 • , - ' v -v^ii-V'V -'• 'ii^M-•yfrqntonai •-!/•i _ u^^-'-• -T" 1 " vr^- " ^ 2Z±£-'rfXV^V /^ rrrt" "I V-''" ,P~Sw M&No.fl • ( \.^i—-^ A'."'..' -- I S'iA a-rr^-^^Kl^» X "^-"J^/JJ rr^f^ FIGURE 1-1. Mquston Area and Site Location. W66101 00 / / . Disposal Pits FRENCH : l-M.-^ue .>*WH»I „' | LIMITED SITE -„-.-..;.—v ./•"•) tf&r-iuH !, / (Approximate Boundaries) • . "(f Scals^z™~e in ™Fee; FIGURE 1-2. 0 t.OOO " 2,000 30Genera0 2 l 3 Vicinit5 y Map and Site Location. 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 dis- cussion 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.
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