United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5502G)
EPA520-F-93-004
Spring 1993
x> EPA Superfund At Work
Hazardous Waste Cleanup Efforts Nationwide
Site Description:
Former disposal facility located in
Harris County, Texas
Site Size: 22.5 acres
Primary Contaminant:
Volatile organic compounds (VOCs),
phenols, heavy metals, and
polychlorinated biphenyls (PCBs)
Potential Range of Health Risks:
Central nervous system disorders,
liver damage, and cancer upon
direct exposure
Nearby Population Affected:
300 residents within one mile
Year Listed on NPL: 1983
EPA Region: VI
State: Texas
Congressional District: 9
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Flood Spreads Contaminants From French Limited
Petrochemical
dumped in unlined
lagoon
San Jacinto River
floods adjacent land
Flood waters
overfill lagoon
Success In Brief
Innovative Technology Used to
Clean Up French Limited
The U.S. Environmental Protection Agency (EPA) negotiated a
major cleanup at the French Limited site, working with the Texas
Water Commission (TWC) and the French Limited Task Group
(FLTG). EPA's Superfund program:
• Employed an innovative technology to clean up 300,000 cubic
yards of hazardous waste;
• Negotiated an agreement, known as a consent decree, in which
FLTG pays for all cleanup costs and future oversight expenses;
• Ensured the planting and preservation of 23 acres of wetlands
near the site; and
• Awarded the nation's 75th Superfund Technical Assistance Grant
to a local group so that the community is kept informed.
Cooperation between all parties demonstrates how the Superfund
program cleans up hazardous waste sites.
The Site Today
FLTG began cleaning up contaminated soil and water in early 1992
and work continues on schedule. Hazardous contaminants in one-half
of the lagoon have been cleaned
up; the other half should be
completed by August 1993. FLTG
expects to complete cleanup of
the contaminated ground water
by 1996.
An independent quality assur-
ance team has been formed which
reports monthly to EPA, TWC,
and FLTG on the progress being
made, consistent with the terms
Overflow carries
contaminants into wider
area of flood plain
Contaminants migrate
through sandy soil into
ground water
of the consent decree.
Status reports indicate that
FLTG has consistently met all
EPA deadlines.
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Flogr
Chicago, IL 60604-3590
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Superfund At Work
French Limited, Harris County, Texas
Spring 1993
The French Limited site is
a 22.5-acre hazardous waste
site located two miles south-
west of the town of Crosby
in northeast Harris County,
Texas.
This former disposal
facility is located one mile east
of the San Jacinto River, and
lies within the river's flood
plain. The surrounding area is
rural; approximately 300
people live within one mile of
the site. The nearest resident
lives 500 feet from the main
lagoon; a private well is lo-
cated about 1,500 feet from the
site perimeter.
During the 1950s and early
1960s, this site was used for
sandmining operations. The
A Site Snapshot
extraction of sand created the
depressions that would eventu-
ally be filled with petrochemical
waste.
After sandmining operations
ceased, the site was sold and used
The French Limited site
lies within
the flood plain of the
San Jacinto River
by area industries from 1966 to
1972 for disposal of chemical
byproducts. The French Limited
site operated under a permit
issued by the State of Texas until
1973, when the permit was re-
voked for continuing violations,
following extensive public hear-
ings and legal proceedings.
Operations ceased and all
equipment was removed from
the site. The owners subse-
quently deeded the land to the
state.
The sludge, soil, air, ground
water, and surface water are
contaminated with volatile
organic compounds (VOCs),
phenols, heavy metals, and
polychlorinated biphenyls
(PCBs).
Direct exposure to these
contaminants has been linked
to central nervous system
disorders, liver damage, and
cancer. An earlier health assess-
ment for the site found that
area residents have not been
directly exposed to any of these
chemicals.
French Limited
Site Timeline
• FLTG investigation begins
French Limited Trust Group (FLTG) formed
Contaminated sludges removed by EPA
• TWC begins site investigation
• Site added to NPL
Flood-damaged dike repaired
• Superfund enacted \
Protective dike built around lagoon
Site permit revoked
• Operations cease
Petrochemicals improperly
dumped on site
4
1966
1972 1973 1980 1982 1983
1985 1981
Page 2
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Superfund At Work
French Limited, Harris County, Texas
Spring 1993
The French Limited Site:
Treating Contamination In A Flood Plain
While the site operated as a
disposal facility, an estimated
300,000 cubic yards of waste from
area petrochemical facilities were
dumped in an unlined 12-acre
lagoon. Soil, surface water, and
ground water have been polluted
due to migration of the waste.
Over the years, floods have
caused spills and other contain-
ment problems, dispersing
hazardous waste into the sur-
rounding areas.
EPA Stabilizes the Site
With the enactment of Super-
fund in 1980, the state requested
EPA's involvement with the
French Limited site. The Super-
fund program undertakes emer-
gency measures to
stabilize hazardous
waste sites like French
Limited until those
responsible for
the site's con-
tamination agree
to conduct the work.
In 1982, the Superfund
team consolidated the wastes
found on the site and constructed
a large dike around the lagoon
to prevent the spread of contami-
nation.
Later that year, flooding
caused the dike to break and the
lagoon to overflow, discharging
contaminated sludge. EPA re-
paired the dike and pumped the
contaminated sludge back into
French Limited
Harris County, Texas
the lagoon. Some of the sludge
was removed to an EPA-
approved landfill.
Enlisting the
support of the
state, EPA made
federal funds
available to the
Texas Department
of Water Resources,
now the Texas Water
Commission (TWC), to
start investigations of the French
Limited site. TWC's objective was
to determine the nature and
extent of contamination and to
develop cleanup alternatives.
Based upon the extent of environ-
mental damage, EPA added the
continued on page 4
FLTG studies feasibility of innovative technology
Bioremediation selected for ground and surface water
San Jacinto River floods site
Bottled water supplied
FLTG builds wall around lagoon
FLTG agrees to perform cleanup
FLTG removes contaminated soil from ditch
m- • Construction begins
y • Site cleanup begins
Wetlands agreement signed
TAG awarded
Lagoon cleanup complete (planned)
Ground water cleanup
complete (planned)
1987 1988 1989 1990 1991 1992 1993
1996
Page 3
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Superfund At Work
French Limited, Harris County, Texas
Spring 1993
continued from page 3
French Limited site to the Na-
tional Priorities List (NPL) in
October 1983. The NPL is EPA's
roster of the most serious uncon-
trolled or abandoned hazardous
waste sites that are eligible for
cleanup under the federal Super-
fund program.
Waste Contributors Clean Up
Having been identified as
potentially liable to clean up the
site, approximately 90 parties
which disposed of the hazardous
waste formed the French Limited
Task Group (FLTG) in 1985. This
group was organized to oversee
the cleanup efforts at the site and
to conduct negotiations with EPA
and the State of Texas.
That same year, FLTG negoti-
ated an agreement with EPA to
perform field investigations of the
site's contamination. TWC com-
pleted its own investigation
which showed that the surface
water and sludges in the lagoon
and the soil beneath it were
contaminated with PCBs, other
hazardous organic compounds,
and metals.
Based on these findings, EPA
proposed in 1987 that on-site
incineration be used to destroy
the contaminants at the French
Limited site. Subsequently, FLTG
suggested a new technology,
called bioremediation, for treating
the waste (see page 5). EPA
agreed to select the final clean-
up remedy following the results
of the bioremediation test in
October 1987
Lagoon Water Treatment at the French Limited site included dredging operations to
reach contaminated sludges resting on the lagoon bottom. The sludges are mixed with
lagoon water to facilitate bioremediation.
Cleanup Remedy Selected
EPA evaluated the results of
the test and concluded that biore-
mediation offered a number of
advantages over incineration.
Within a similar time frame, the
bioremediation technique could
destroy almost as much waste as
incineration, at a better cost.
In March 1988, following a
period for public comments, EPA
selected bioremediation as the
remedy for treating the hazard-
French Limited
was the first use of
bioremediation technology
at a Superfund site
ous material contained in the
lagoon. Ground water and sur-
face water also were slated to be
biologically treated to reduce
contaminants to safe levels.
This was the first application of
bioremediation as an innovative
technology at a Superfund site.
EPA announced a back-up plan of
incineration if the selected rem-
edy proved to be unsuccessful.
————— Page 4 —————
EPA Responds to Flood
Shortly after bioremediation
was selected as the remedy, the
San Jacinto River flooded the site
in May 1989. An EPA Emergency
Response Team quickly collected
samples, but found no spread of
contamination. As a precaution-
ary measure, EPA provided
bottled drinking water to con-
cerned area residents.
FLTG to Reimburse EPA,
Pay All Future Costs
Following negotiations with
EPA and the State, FLTG agreed
in August 1989 to conduct the
cleanup valued at $88 million.
The FLTG also agreed to reim-
burse TWC and EPA for investi-
gations and past cleanup actions
totaling $1,275,000.
While the agreement was
awaiting the approval of a federal
court, FLTG took interim actions
to secure the site. In the fall of
1988, FLTG spent almost $6
million erecting a wall made of
60-foot interconnected metal
pieces buried 20 feet below the
surface of the lagoon perimeter.
continued on page 5
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Superfund At Work • French Limited, Harris County, Texas • Spring 1993
Treating Contamination In A Flood Plain
continued from page 4
This interim action was to prevent
any spillage from the lagoon.
FLTG also removed contami-
nated sediment and dirt from a
nearby ditch and placed them into
the lagoon for treatment with the
rest of the contaminated materials.
The technical design and
construction of the bioremedia-
tion facilities were completed in
December 1991, and contaminant
destruction began in January 1992.
Pumps are being used to mix
the thick sludges from the lagoon
bottom with the liquids. The
bottom sludge is first broken up,
then the contaminated soil be-
neath the sludge is dredged and
mixed with the lagoon liquids.
After all the material in the entire
lagoon is treated, lagoon water
will be passed through the on-site
water treatment facility.
Clean fill will be mixed with
the treated soil to pack the lagoon.
The surface will then be seeded
for vegetation.
Surface and ground water
treatment also started in January
1992. Ground water will be
treated until the concentration of
VOCs has been substantially
reduced. All surface water and
ground water from the site will be
treated to meet Texas water
quality standards, and then
discharged into the San Jacinto
River. FLTG has 10 years to bring
the contaminated shallow ground
water up to federal drinking
water standards.
Ground water will be closely
monitored for 30 years to ensure
that cleanup standards are main-
tained. The state, EPA, and re-
sponsible parties are conducting
discussions with regard to future
potential site use.
Wetlands to be Planted
As part of the site cleanup,
FLTG will plant and maintain 23
acres of new wetlands near the
site to compensate for damaged
area habitat. Nearby wetlands
had been fouled by spillage from
the lagoons containing hazardous
waste.
In 1992, the Department of
Interior, the National Oceanic and
Atmospheric Administration, the
State of Texas, and FLTG signed a
natural resource mitigation
settlement. In March 1993, a
natural resource mitigation
consent decree was entered into
Federal District Court.
The wetlands plan requires the
purchase of adjacent land, plant-
ing a wide diversity of vegetation,
and supplanting fish, birds, and
other wildlife to compatible
habitat. These actions are ex-
pected to cost FLTG approxi-
mately $10 million.
Throughout the entire cleanup
process, FLTG has consistently
met EPA deadlines and require-
ments. FLTG maintains a consci-
entious approach to the cleanup,
as well as regular communication
with members of the EPA team.
Bioremediation At French Limited Site
Bacteria r—
cultures V^v
injected into \\
contaminated \\
soil \Y
•*--—f+i
Nutrients and other elements added to
soil to increase bacteria growth
Bacteria "eat" contaminants in
soil, decomposing the chemicals
through biological activity
Decomposed
contaminants
mineralized into CO2 and water
Bioremediation Technology
The remedy selected for the French
Limited site is in-situ (in-place) bioreme-
diation of contaminated sludge and soil
in the lagoon. The process uses micro-
organisms already present in the lagoon
to neutralize the hazardous waste.
Nutrients, similar to fertilizer, are added
to the lagoon. The micro-organisms
"eaf' the nutrients and contaminants
and break them down into non-hazard-
ous materials. Oxygen is pumped into
the lagoon to speed up the process.
Page 5
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Superfund At Work
French Limited, Harris County, Texas
Spring 1993
Grant to Local Community Group
Boosts Public Involvement
In March 1992, the Superfund
program awarded a Technical
Assistance Grant (TAG) to the
Barrett-Crosby Civic League
because of their interest in the
French Limited site cleanup.
A TAG provides a community
group up to $50,000 to hire inde-
pendent advisors who help local
citizens gain a better understand-
ing of technical issues at Super-
fund sites.
With the grant, the group is
currently in the process of procur-
ing a technical advisor. Local
citizens will be able to better
express their concerns and offer
comments on site cleanup activities.
The French Limited TAG
marks the 75th grant awarded
nationwide, demonstrating EPA's
commitment to keeping citizens
informed at Superfund sites.
The Technical Assistance Grant for
the French Limited site was the 75th
such grant nationwide.
If you wish to be added to our mailing list or to comment on this bulletin's content, length
or format, please call (703) 603-8984 or send a letter to Superfund At Work (5502G),
401 M Street SW, Washington, DC 20460.
Success at
French
Limited
Cleanup of the French
limited site is expected to be
c0fhpleted by 1996. Monitor-
ing of ground water will
continue for 30 years to ensure
that safety-standards are
maintained.
EPA Superfund staff, the
French Limited Task Group
(FLTG), and the State of Texas
have cooperated to achieve
full financing of an $88 million
cleanup by the FLTG.
Their efforts included use
of an innovative technology,
planting wetland habitat,
and community education
and involvement.
For additional copies of this or other Superfund At Work updates, contact the National Technical Information Service,
U.S. Department of Commerce, 5285 Port Royal Road, Springfield, VA 22161, telephone (703) 487-4650.
xv EPA
United States Environmental Protection Agency
5502G
Washington, D.C. 20460
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