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
                                                                 V V r\ ^ '
                                                                   Or i
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                                                                                      iO
    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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