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sludges formed a seal on the bottom of the lagoon. This seal effectively
retarded leachate generation. Aeration of the sludges broke the seal,
allowing leachate to contaminate the upper aquifer.
Sludges on the bottom of the lagoon currently provide an effective barrier
against leachate generation. As these sludges are mixed In the lagoon,
some leaching of contaminants to the shallow aquifer may occur. Recovery
and treatment of the shallow aquifer Is necessary to control any groundwater
degradation which may occur during Implementation of the blotreatment remedy.
Based on the results of the study, the estimated implementation time for a
full scale biological treatment remedy is four years. The estimated
present worth cost of the remedy is $47 million.
Evaluation of Alternatives
The degree that the five remedial alternatives meet the nine selection
criteria is shown in Table 6. The following values were assigned to
compare remedial selection criteria:
++ Alternative would greatly exceed a selection criterion when
compared to other alternatives.
+ alternatives would exceed a criterion in comparison to other alternatives
o alternatives can be designed to meet the selection
- special efforts will be necessary in the design of the remedy to
meet the selection criterion
-- alternative would present the most difficulty in achieving a
selection criterion in comparison to other alternatives.
The rationale for the ratings assigned in this table is as follows:
1. Compliance with ARARs (i.e. meets or exceed applicable, or
relelvant, and appropriate Federal and State Requirements).
a. No action was assigned a "--" because it would not
comply with SARA or the National Contingency Plan provisions
to respond to a threat of release which endangers human
health and the environment.
b. Complete Incineration was rated "++M for compliance with all
identified ARARs regarding operation of the thermal
destruction unit. This alternative would also meet the
applicable standards (including water quality standards).
c. Partial Incineration received a "+" rating. A thermal
destruction unit would be operated in compliance with all
applicable requirements. This alternative would also, by
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destruction of the PCB contaminated sludges, fulfill the
disposal requirements of TSCA. The alternative would not,
however, comply with the RCRA requirements for closure in a
100-year floodplain due to the high concentrations of
organics remaining in the subsoil.
d. Containment was rated "-". This alternative would not comply
with the RCRA or TSCA requirements for closure in floodplain.
e. Insitu biodegradation received a "++" rating for compliance.
Reduction of the contaminant concentrations below the health
based criteria, in conjaction with chemical fixation of the
treated residue, would comply with the closure requirements
for the site, ^is alternative would also satisfy the
preference in SARA to significantly reduce the mobility,
toxicity, or volume of the waste.
The compliance of each alternative with ARARs is shown in
Table 7.
2. Reduces Mobility, Toxicity, or Volume
a- Nq_Action received a "" because it would not reduce these
parameters to any extent.
b. Complete Incineration rated a "++" for these parameters since
all of the organic contaminants above the identified health-
based criteria would be eliminated.
c. Partial Incineration was rated "0". The contaminated sludges
would be destroyed and the mobility of the subsoils would be
reduced. However, the toxicity of the subsoils would not be
significantly reduced, while the volume of the soil would be
increased significantly by the addition of the stabilizing
agents. Also, the degree of reduction of mobility will
depend upon the concentration of organics in the soil. Soils
with greater than 2 percent organics may continue to generate
leachate after stabilization.
d. Containment (cap and slurry wall) was rated a "-". The
volume and toxicity would not be affected and mobility of
the waste would only be reduced so long as the integrity of
the slurry wall was maintained.
e. In situ biodegradation' received a "++" rating. Destruction
of tiie contaminated sludges and treatment of the soils will
significantly reduce the toxicity of the waste. Reduction
in the volume of the sludges will be offset somewhat by an
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increase in volume of stabilized residues. The net reduction
in volirne is, however, expected to be significant. A slight,
temporary increase of the mobility of the waste may be expected
during implementation of the remedy. This increase is due
to leachate generation and can easily be controlled by
recovering and treating the groundwater under the site.
3. Short-term Effectiveness
All of the alternatives were rated "0". A potential exists for
the release of volatile organics during site drainage and excavation
activities for alternatives 1, 2, and 3 and during the operation
of alternative 5. This can be reduced by cautious work practices
during implementation, and will have to be addressed during
design. Property boundary air monitoring data generated during
the PRP pilot study indicates that emissions generated by
bioremediation should not consitute a health treat.
4. Long-term Effectiveness and Permanence
Both alternatives 1 and 5 were rated "++" for their abilities
to reduce contaminants to levels below the established health-
based criteria. While biodegradation of PCBs to the criterion (23
ppm) has not been dennonstrated, significant reductions in concen-
tration have been noted. Stabilization of the residue should
provide adequate long-term effectiveness if the PCB criterion is
not achieved through biodegradation. Partial incineration was
rated less highly (+) because of concerns regarding the permanance
of stabilized soils with high concentrations of organics.
Contaia-nent and No Action were rated "" because neither would
contribute to the long-term remediation given the site conditions
of high water table and 100-year floodplain.
5. Implementability
Alternative 1,4, and 5 were rated "++" because they are easily
implementable in a reasonable timeframe. Concerns about air
emission can be overcome with careful design and implementation
considerations. Partial incineration received a "+" rating due
to potential problems with the stabilization of soils with high
organics concentrations. The containment alternative was rated
"+" based on its effectiveness as a short-term solution at the
site.
-------
15
6. Cost
Estimated costs for each alternative are listed In Table 6.
Included In this table are the total present worth and replacement
costs. Total present worth costs consist of capital costs and
operation and maintenance costs through the post-closure period.
Replacement costs are the costs for remediation of the site
should the remedy fall.
The containment, partial Incineration, and no action alternatives
are considered most likely to fall because of the potential for
leachate generation, slurry wall failure, and lateral migration
of the waste. Failure of In situ biotreatment 1s less likely
because the treated soils may be more amenable to solidification.
However, failure costs must also be considered for biotreatment
Replacement costs ark estimated at $120 million, assuming that
onsite incineration is the replacement cleanup technology.
Costs associated with the no action alternative include
groundwater and air monitoring and periodic site inspections.
These costs are considered to be operation and maintenance costs,
not capital costs.
Costs for the containment alternative, $42 million, are primarily
reflective of the construction costs for the cap and slurry wall
and treatment of the lagoon water prior to discharge.
The difference in cost between alternatives 1 and 2 is associated
with the lower volume of material to be treated by incineration.
Alternative 5, biological treatment, offers the lowest cost of
the treatment alternatives. This is attributed to the equipment
and operating costs which are significantly lower for biological
treatment than for thermal destruction.
7. Community Acceptance
The community expressed significant concerns about the
incinerator alternatives. Comments regarding the biological
treatment alternative were mixed, ranging from complete endorsement
to opposition. Those persons opposed to biological treatment
were also opposed to all onsite remedies.
A complete summary of the community relations history and
responses to public comments is presented in Appendix B of this
summary.
8. State Acceptance
The State of Texas (Texas Water Commission) has concurred
with the selected biological treatment remedy.
-------
16
9. Overall Protection of Public Health and the Environment
Complete incineration and j£ situ bioremediation both received
"++" ratings. Incineration offers destruction of all of the
contaminants to levels below the health-based criteria and can
be operated in compliance with applicable requirements. Biode-
gradation has been shown to reduce contaminants, except PCBs, to
levels below the criteria. Stabilization of the treated residue
for disposal onsite will provide adequate protection from any
residual PCB concentrations.
Partial incineration was rated a "+" for the destruction of
contaminated sludges. A higher rating could not be justified
due to the potential for future leachate generation form Inade-
quately stabilized soils. The cap and slurry wall alternative
was rated a "-" because it was considered a short term remedy
for the site. The potential would always exist for failure of
either the cap or the slurry wall allowing for the movement of
unstabilized wastes contained onsite.
The risk involved with leaving untreated waste onsite is the
principal reason that the no action alternative received a rating
of "-".
Recommended Alternative
Based on the evaluation of alternatives discussed in the previous
section, Alternative 5 is recommended for implementation at the French
Limited site. The major components of this alternative include:
1. In situ blodegradation of sludges and contaminated soils;
2. Recover and treat contaminated groundwater until modeling shows that
a reduction in the concentration of volatile organics to a level which
attains the 10 Hunan Health Criteria can be achieved through
natural attenuation in 10 years or less.
3. Discharge surface waters from the lagoon to the San
Jacinto River; treat as necessary to meet surface
water discharge criteria;
4. Stabilize the treated residue and dispose onsite;
5. Backfill the lagoon to grade and conform the site surface
to promote drainage; and
6. Monitor the upper and lower aquifers for a period of 30 years.
-------
17
Operation and Maintenance (0AM)
Operation and maintenance will consist of post closure monitoring of the
upper and lower aquifers as well as surflclal maintenance of the site once
closure is complete. Surflclal maintenance Includes such Items as:
o Fence repair, and
o Fill replacement and regrading.
Due to Its proximity to the French Limited site, groundwater monitoring
in the Riverdale subdivision will be necessary during the post-closure
period. The frequency of sampling will be outlined in a post-closure
operation and maintenance plan. This plan will be developed and
finalized during implementation of the selected remedy.
O&M costs include purchased services such as sampling and laboratory
analysis for groundwater monitoring, administrative costs, taxes, insurance,
labor, and materials. Operation of the groundwater recovery system after
the final closure of the lagoon is also included in this cost. Operation
of this recovery system will continue until modeling shows that a reduction
in the concentration of volatile organics to a level which attains the
10 Hunan Health Criteria can be achieved through natural attenuation in
10 years or less.
Future Actions
No future actions are anticipated at the site. The proposed remedial action
is considered permanent. If, however, significant, unforeseen offsite
migration of contamination occurs as a result of the site, appropriate
remedial measures will be taken. Also, should organic contamination be
detected during any of the residential well sampling events, the need for
an alternate water supply in the subdivision will be evaluated.
Remedial Action Schedule
ROD Signature March 1988
Complete Enforcement Negotiation September 1988
Start Remedial Design September 1988
Complete Remedial Design December 1989
Begin Remedial Action December 1989
Complete Remedial Action December 1993
-------
TEXAS WATER COMMISSION
.
John O. Houchim, Commiuioner vfe'3/ Mfchwl t FJeW, Chief Examiner
B. J. Wynne, III, Commisiioncr ^*+*r
Allen Betake, Executive Director
Mr. Robert E. Layton, Jr., P.E.
Regional Administrator
U.S. Environmental Protection Agency
Region VI *
1445 Ross Avenue
Dallas, TX 75202-2733
Re: Draft Record of Decision
French Limited Superfund Site
Dear Mr. Lay ton:
We have reviewed the draft Record of Decision (ROD) and
responsiveness summary for the French Limited Superfund Site.
We have no objection to the issuance of a ROD by the
Environmental Protection Agency (EPA).
On a related matter, we would like to comment on the obligation
of State monies for a period of 30 years after the remedial
construction activities are complete. Such a commitment by the
State of Texas may be a violation of Article VIII, Section 6 of
Sincerely yours,
Allen P. Beinke
Executive Director
P O. Box 13087 Capitol Station 1700 North Congrei. Ave. Au«m. T«xa« 78711-3087 Area Cod« 512/463-7830
TOTPL P.09
-------
APPENDIX A
ADMINISTRATIVE RECORD
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i'HCjiJMFV FL Mr, rO
DCir-'lMPNT 'I JTi F-":
IS
09/18/81
018
Michael J. Mi i lie, Ph.D., Director of GC/MS
Services
CaJ J f cirn i* Analytics] Laboratories, Inc.
Dxck Tnscker, Viar & Company
nemo rand urn ana attachment
C'rrj ;>.»-, 5 rr-. Pna ] yue^
19
Or1 ' i\'9/ P. 5
004
Larry K. Lanary, FIT
£'.;. ] ogy 3nc En /i ronment , Region VI
'." n 5 r- 1 cv = '3=i;:c:t, Chief, Compliance Section,
'.. . .: . E . P . M .
j »w -.f organic ana]ysis of three sludge
pie'j f.-on; French Ltd. , TDD #F~6-8103-3£
LOCUmENT DftTL:
r DUMBER OF' FHGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT FLAG CODE:
REFERENCE:
DOCUMENT TITLE:
10/0£/81
OO^t
William D. Langley, Chief, Laboratory
Services Section, Region VI
U.S. E.P.A.
William J. Librirzi, Director, Surveillance
and Analysis Division, U.S. E.P.A.
Lab report analyses
Reports for analyses of monitoring well
samples taken by TDWR at French Ltd.
-------
l&^i--.., §>:v...r-_-riiV;t.':-ii;ai
C V :
DOCUMENT TYPE-:
DOCUMENT F;_MG CODE:
RE-TERENCE:
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DUC;UMcNT DATE:
NUMBER OF PftGES:
OI.ITHQR:
COMPfiNY/flGENCY:
RECIPIENT:
DOCUMENT TYPE;
DOf^'jMEN^' cLAi6' CODE
.
DOCUMENT T:TL.E:
U. ",. R.P.fl.
Si.sr\ ?> Pc-ports f*t Frenr-h Ltd. and Motc-o
Pco'.!£.l ic Emission Monitoring Surveys
10/31/ei
007
Unsvpec-'i f ie-d
U.S. E. P. ft. , Region VI Headquarters
U.S. E. P. ft. Files
Report
c;: Quality fi&5'.'rance RMd G'C Report
DfiTF:
OF PHbLT
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:
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NUMBER OF PflGES:
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REFERENCE:
DOCUMENT TITLE:
31/09/ei
'I'-I'll'
FIT
hriiocy : En-* ironrnerit , Regicn VI
C. i". ? r- 1 e -. Cst-rcs, Cnief, Compl i^ricti' Section,
U.S. E-P.S.
MOM or. 3 nc um
fc-t-j of sample data from French arid Sikes
rno r; i t : r wells; TDD F -6-8 1 1 1 - 1
ii/09/ei
OOc
David Anderson, FIT
Ecology & Environment, Region VI
Charles Gazda, Chief, Compliance Section,
U.S. E. P. ft.
Memorandum
Collection of data for Bikes Pit and French
Ltd.; TDD#F-6-8109-33
-------
NJMBi:.? Or
T TYf-p :
'T Fl CiG CTiDFI
REFERENCE:
DOCUMENT TITLE:
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NUMBER OP POGES:
ftHTHOR:
COKPPN'Y/flGF.N^Y:
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L1 s v i c H r d e r s o r^ FIT
Ecoiocy and CnvirotuVitfi-it, Rc-?yiori
C'^c»r3^s=. P«:rdr\, -Chi^f, Comri] j a^r
:.:.s. K.P.fl.
F^sview of sample aata from French end Bikes
ic>i'.it-:-r wells; TDD F-&-8111-1
1 J/E3/P1
00£
Thornar N. Smith, FIT
Ecology anc' Environnient, Region VI
Cfiarlt3£ G^nda, Chief, Compliance Section,
:_i. 5. E. P. Pi.
M e rn o r a n d u rn arid a 11 a c h merit
Col ] «?ct- ion of date* for areas surrounding
<=.ike? Pit and French Ltd. ; TDD #F-G-8 109-3:
DOCUMENT TVPE:
Dt?CU^ENT F-P5
REFERENCE:
Jr., DirectC'r, Office
WilJiarr. TJ. Ktcerriio-,, Jr., DirectC'r,
'.: f *. 'I'.E r a £ r i r y a nc fterni-c i a 1 Rc-s ponse
'.!. =.. K- P. ft, "
C/-. : si ..-'phe-r Capper, Act i ng fisst.
Qcjn'T.ni^trai.-or, Solid Waste K Efperge?
Rf-'-pc.nsf? Office-, U.S. r.. P. ft
f.emor'and uir
genry
Hut hov'isat ion to proceed with Remedial
Planning at the French Ltd. Disposal Site?
ftct ion Memo rand urn
-------
.ifrn.:.c ' j Y / (jR"
F :'. T,''TF!\n r
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lyjCl'toENT FLAG CODE:
REFERENCE:
DOCUMENT TITLE:
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RECIPIENT:
00.~ljlv.FNT TYPE-":
r»fiCU*lFM'r CLAP CODE.:
REFERENT.;-::
DCir.ijriFNT TIT,.' ;
D ." C 'J r-', EN" v J LJ M 6 E i"' :
c-. _: I e -
ilier-^ Me. ^ .1. n:: Dn -rritcr-. C"*";ic:£ -_-
:- ..i ;: r a 01 s E r. f c r c e rn c.1 r. i;
e, iJ^ S. E-P.ft.
\ a
txpsriait «.u-e of Superfuna rfioriey at French
i-'cc:. , RSCJ iori VI
!="?
Of./ 2 irVBc-.1
001
Char]«?s ft. Bazda, Chief, Emergency Response
Brar-iCf;
U.S. E.P.ft.
U'lliidiii riathaway, ficting C^lief, Super-fund
E-fr an.:*-., U.S. E. P. ft.
1*1*? pi or .si
uro t y Rp] c--t innfi P'jari fc>r the French
tc. Site, Cro-:-»b>, Texas
(-li ITMHR ;
COMPANY /AGF.NC / :
DGCJhENT TYPE;
Di;'(..U(vlENT F_ft5 CODE
REFERENCr.:
DOCUMENT TITLE:
W. :. r*M^r ^njler, Hrt 3 ny Director, Offirp of
I-'??, to Pr"ogrsrn= Pnf or cement
U.'5. F.,F.fl.
U:3.'3sni N. Hg-ciprnan, Jr., Director, Office
o^ Ei.isrcency and RoMedia.i Respo.nse, U.S.
Expenditure of ?uperfund money at the
French Ltd. Site
a
-------
DOC .IM.f iv"1" TYC'£:
i>r!C-.U*FNT Ft.AC-i C'.ODF
TITLE:
i
Dept.
Water
S.
y Assurance Program Plan for the
Ltd. Site
NUMBER
DOCUMENT DftTFT:
NUMBFR OF POJ5ES
fiHTHOR:
COMPflNY/fiGENCY :
RECIPIENT:
FLAP
REFFP^NCE:
iioruxfiNT T:TI.E:
001
Wi3]iarn B. Hathaway, Deputy Director, ftir &
W*=te Management Division
U.S. E.P.fi.
Ruts Uiyer, Acting Director, Hazardous Site
C-'f-itr--oI Division, U.S. E.P.A.
Cover Letter
ty RpJatjons Plans for Rerneclia]
fiction ^.t &i'-'-Ecology and French Limited
K^zfrrdrui. Waste Bites
^Jfip'"!"' OF PMGE^i
I01UMENT TYPE:
DOCUMENT FLAG CODE:
REFERENCE:
DOCUMRNT TJTl.F;
DOCUMENT NUMBER:
DOCUMENT DftTE:
NUMBER OF PftGESi
AUTHOR:
COMPfiNY/ AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT FLAG CODE:
REFERENCE:
DOCUMENT TITLE:
wJ'.J
07/13/fiJE1
>'I'01
Usjlr- am Rhe?a, C'h:pf, Policy and Dp=iQ
Serrt "ion
U.S. E.P.fi.
Eddie l.ee, Acting Director, Office of
Pusiic Affairs, U.S. E. P. A.
L <:: r r e H D o n a e n c e
j ty Relations Plan for French Ltd.
09/03/82
001
R. A. Brunei1, Lt. Commander
U.S. Coast Guard
Sarn Nott, Superfund Enforcement Section,
U.S. E.P.A.
Correspondence
Information request from the U.S. Coast
Guard
-------
::0i. LficA-"'" DiV c-li
S OF Pfr5r
RECIPIENT!
DQOJttENT TY='E:
DOCUMENT ^LftS CODE
REFERENCE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DftTE:
NUMBER CF PftGES :
hiJThOR:
COMPANY /ftGENCY:
RECIPIENT:
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DOCUMENT FLOG CODE:
DOCUMENT T;Ti_E:
DOCUMENT ^'jwiBER:
DnCU^iEf-IT E'HTE :
C 0 iv; p q N Y / p 3 r" N ~. -T :
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT Fi_fiG CQLE
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DfiCUMENT Tj^L.E:
DOCUMENT DATE s
NUMBER OF PfiGES:
«UTHOR:
COMPftNY/ftGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT FLAG CODE:
REFERENCE:
DOCUMENT TITLF:
.'.. A.:'
M.S. F.-P. «.
n. H. Eruti&ll,
?up.c-r-f unr! E>if c-rcefo
Lt . Cornfus rider, U.S. Toast
Cor r
Response to inquiry regarding French Ltd.
OS/I0/85
Olc
S. D&via Ellison, P.E.
Cr;£M Hill
Russell Bart ley, Site Project Officer, U.S.
E. P. P.
Correspondence and workplan
Cover letter; French Ltd. Work Plan
37
001
"I"ex5=j Depi'. '~'f Water Resources
Car?, ene Chambers,, Project Officer, LI. B,
Correspondence
E.1 L.er and Frencn Ltd. Work Plans
03/0^/83
001
Frieda Beaty
Baytown Sun
Public, Baytown, TX
Newspaper Article
"Sikes Waste Dump Cleanup to Begin Soon"
10
-------
ur-riiMFTv'-' TYPE:
DOCUMENT PL.Hi; CODE;
RZFERENCE: i
DOCUMENT TITLE:
DOCUMENT NUMBERi
DOCUMENT DflTEi
NfJ'^BER OF C'«GES:
AUTHOR:
COMPftNY/flGENCY:
nuCiPIENT:
DOCUMENT TYPE:
DtDrUMENT r..flG CDI'E
REFERENCE:
T TITLF:
I- 1
wori-.plans
40
f.:tp Project
-' -v p. r-r i den <?£ .
G-:
nor' e. letter protests hearings of
r- Site's"
DOC1 IMrN
MUMPER Of7 PPGEb
REFERENCE:
TITL.F:
N^ f-'UMPER:
DCCL'MEr/r DPT1:
KJKSER OF PHGEEr
OUTHCR:
COMPflNY/rtGENCY:
RFCIPIFNT:
DOCUMENT TYPE:
DOCUMENT FLOG COPEi
REFERENCE:
DOCUMENT TITLE:
'-".' 1
r-.::.l: -
N-wr.^ne.- Prt i- : v
"FjsOo w-r-r^' f.t^rtf-d et Cros-by Wa=.te Site"
T&xas E't-pt. of Witter Resources
Sta^e of Texas
t'ub] ic
News Release
Pnnouncement of field investigation at
Sikcs
1J
-------
P.! ". Hi K s
/iOCU^rA" TYP.1
,'.)::f.'l..M:LN'r F'i-.AG CCDE
OCUMENT T:TI.E:
MENT NUMBER:
;JMENT DATE:
NUNBER QP PflGES:
fUTHOR:
COMPANY /AGENCY:
DOCUMFNr T/u'E:
DOCUMFNT FLAG CDDC
ITLE:
rr 3 ; U'---ir'-^e'cit
r.:r-.?r .-.c ,
I "I t 1 "
'-onsj de
W.iter
=.] «t ) on
A A
05/11:3/83
001
c i f i&o
n Sun, Bay town, TX
e^'n oa ner fir t i c 1 e
" h- j fr I d s : D HMD x :. bs C 1 ee
0~ ^M-
yzj*':*-' ';<'-
;j[;i::'ir'!'; -LK
Lin=r'f>c ; f j ed
CH,-'f-' H i 1 "
r-fr' r - c:-1-:-' - f. 31«? Pont »: 3 D i v i ?> 3 -tin, U. S.
Hc/r.itc i c- J. M-tiori Master Plan
PI IT HOW;
Cs>- ::.= Py^rt. f.r.cH J ; rn Car It on
M o 1 1 5 \, o n C n r o n i c 1 e
LN I : i-'uDi ic
DOCUMENT TYPE: Newspaper Article
DOCUMENT FLAG CODE:
REFERENCE:
DOCUMENT TITLE: "EPA Taking Emergency fiction to Clear UP ?
PCS Dumps"
-------
_ M S E r
FLf'ifr CODF.
REFERENCE:
TITLE:
DOCUMENT NUMBER :
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NlV-BER OF PftGESi
flUTHQR:
COMPftNY/flGENCY:
RECIPIENT:
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DOCUMENT NUMBER:
DOCUMENT DftTF :
NLIMJ3E3 OF
fil'~HOR:
L.YiCCJ&C 1 f .-.?.£ i
D? 11 -^r ^orriir.c NPW-
T' ;.i n: i r
N- T> X - p ~< 'J *? r £3 r" t 1 O 113
to Cie^n up Houston ftrea Dumps1'
46
OC/Ofj/65
00 1
Unspeci f ipd
fii.i.stin finiericcm Statesrnari
Pub] ir
* paper ftrt i c i e
" H i 9 n »-' C B L t? v el F o u r C3 s t Bit e? N K a r'- h o u -^ t o r:"
49
<."'f./05/'«'i3
001
l>'ir-pf:.n f D. PCI
E-i-^vl. owri Sun, Ba/tc-wri, TX
fuL-iit:
N'c: w .:; p^ i.ic»- f-Ti; i : .1 -5
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':: '.' r f '' f -H
X 'J r'i E-s E ~: D 7 F1 1- 1 G E S :
DOCUMENT TYPE:
DOCUMENT FLA6 CODE:
REFERENCE:
DOCUMENT TITLE:
50
W i 5 1 1 s f o H a t n a w s y , D e p u t y D i r e c t o r , 0 1 r a n d
I J .> z *; t- f' i * r i .-? i; ems f\ t D i v i -3 1 o r<
i J . S . E . i"' i "; »
Willicin Lihrirsi, Director- flir- anci
^anacjenier.'t Division, U.S. E. P. fi.
Memorandum and attachment
Rornova 1 act i on not i f i cs>t i on
-------
='_A&
-i,-,i-r,:d i-.;--^v', r-r. . ,"'cic.t Fovi rcir:ffi»nt. Writer
i ,*>.., Co.!.. i^r A/'tlCl::'
DOCUMENT TITLF:
DOCUMENT NUMBER:
DUCUMFNT DftTF:
NJttBER OF PHG1-IS:
RUTHCRi
CCMPftNY/fiGENCY:
r C'ollutants Search Expected after
DOCUMENT T
HOC.UMENT F'l.fiG CODE
REFERENCE:
T TITLE:
001
Jirn Car It on
Ho MS t o n Ch r of i i c 1 e
PuDlie
Nswspsper firti c1e
"c: PCB-L aceo ftrpa Dumps Ready
EPA
' NJME-2R :
T DATE!:
G~ PA52S:
-J-J
Of. /'JL'&/8
O'I'l
f.e-»' 3 e-rip C'
s n -' D s ' = i rj n »v
r., Prcg't-rt Officer, Policy
r ': i o r i
, Htr^ri-1 r>nf-ct Tits1 Re?pc>nc'«1
. : '" water' Resource -i
DOCUMENT FLflG CODE
RLIf-EREIMCE:
OC'CUMENT TIT : E:
£!;-'":> c-" of 1=3 te =pecjfic
wor I- pi s-r,--. for ^'rsfich Ltd., Sike^, and
i" i- y x f 3 Cher.i 3 r-fi 3 ? i t- e-vr-
DOCUMENT NUM5ER:
DOCUMENT DATE:
NUMBER GF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DCCUMrNT FLAG CODEE:
REFERENCE:
DOCUMENT TITLE:
001
Rucssell Bart ley, Engineer
U. 5. E. P. A.
RoH Kirnhro, Texas Dept. of Water Resources
Corre = pondence
Fie: Final RAMP for French Lta. Site
-------
:;_;;-:, N.-r.-.T-. ^
!..;::-..>:«::"' 1P£:
Di.^U^E^T fLA2 CODE
SE-ilRtls'CC:
DOCL'MENT TITL.E:
DOCUMF.NT NL^BFR:
NUMBER OF PAGES:
AUTHOR;
COMPANY/flGENCY :
RECIPIENT:
Dnr.UMENT FLA'? CODE
RE-FRANCE :
ri;'.f;uMEMT TJT- F:
Lir'ir.ypr 3 f; pc1
L'"»"^w"!'!:, Andrews ?. Nswnam, Inr,
"l^'xa?; Pent, of .J^te>r-
Frencn !..ta. Suoplenient:a 1 Field Effort
56
3 O/3 3/8?
001
RUSS.&] 1 Bart3e»y, Enrjincser, Operations
Sect ion
U.S. E.P.fi.
U.S. E.P.fi. Fi^£
Fje: Pf-c-'rif-t-i Ltd. F.:te Invest i gat idn Meeting
with State? of Texas
r:Uf".BER
D;Sf\ I.'1. i:.hro£'dfe-> , P. E. , Chief, Solid Waste
DCr:..iMFA
-------
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N'JMBE? OF i--'C;!:E'-:
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DOCUMENT FLfiC- CODE
REFERENCE:
DOCUMENT TITLE:
of
"'"r-cifisroittdl of T&crnniCcil Comments on
Reriiec i a 1 I n vest i c at i on Re port
AO
077
Un=. pacified
Resource Eng i neer i ng
Frenc.i Ltd. T'9«-;k Group
French t.tc. Site Technical Coriunsni;s
Te^chnj ca] C-i'mrnen-t s- CT,
Ir. vn«;t i c?t i^n Rep-trt
f 1
ri:,-;.:^ u-to. £tt-srir,g Cos.Uf1 : t l':-?e
' '.'. t " : '"
U t: \ '. r Re 1st --r-.-
'1 _ :.1 1 ? Ho\'ii.or> Scatemenv French i.irnitec.;
'' =-. .: i- Gr :"-.ip
Resource Engineer i nr;
French Ltd. Task Group'
Report-
h Ltd. Supplementary Investigation
-------
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COMPAN
uftr-i wmt
NJ^.E-ER OF PfiGEH
f- v.~!r.riL- v-'C!f :
f-.i.ip"-' f-ment sry ' nve-=.t j gat iori
&A
08/31/e-V
COS
un 3 pec if i&cl
French i_tc. Task Group
Li. S. F. P. ft. PeQion VI
Informat ion Report
?rv-£-.T-:cr. L.tci. Task Group Infc-rmat ion Report
65
03/or. /?-;
06 I1
Ur,<-pf?n fi Pd
Fe? =.<,..;ree Enc "
Fre-r.ri-, Ltd. Ta:-l-
p rj n r i r t
' t:c.r r: c:e : t-nc- Rea::uic>t r-ry Concepts fo'
'.r;- '"' I a r LV CI o -3- u r e
DCCUMEN'- TYPE:
DUCbMENT FLfiG CODE
REFERENCE:
TITLE:
t -. ft
1. '.' -'£'3' P.'T
Lin; te <.! :-t^tr=i o'f fitter 3 r^, Plaintiff
Le-f er.dant fe
Or^e-r-i i\nd Certificate of Service
Extension of deadline for the Defendants to
answer
7
-------
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::'.<..!=-":.T i!>;::
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REFERENCE:
tOC'JMENT TITLE:
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AUTHOR:
COMPANY /AGENCY:
RECIPIENT:
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Rt.FERr.r.CE:
DnryvCNiT TITLE:
DOCUr'iF.N" NUMBER:
:-|.-.r.-,,-»r- I:. ::. F..-.fi, Sen 5 on VI
: "i ^i i~ H r,.'? <~
Re:; ~.onre to Information Request
68
01/17/85
008
HsreO Hoffman, Esq.
Atlantic Richfield Company
U.S. District Ct. Southern District of TX,
Houston Division
Cover Letter
Fir-^t Stipulation for Extension of Time?
63
01 /£;:/ ftf.
(j ' 0
Tt-;: well, Epv-ircnwentsl Engineer, Super fund
Tt-'^r: f\ i Cc> l ^tJcrtirT'i
.., = . E . P . P .
r>v. l..v?: Di el fi.c\ ":'' III. Lockwc'Od, ftndre^r.. aric
D 0 C U M E ^ T F L & G C H D F£
TITLE:
t e
ftft&r- ri.it ion Report on Rtni&uial fiction
NUMBER OF PAGES: 05-j
AUTHOR: Unspecified
COMPANY/AGENCY: Resource Engineering
RECIPIENT: U.S. E. P. A. , and the Texas Dept. of Water
Resources
DOCUMENT TYPE: work Plan - Response to EPA Request
DOCUMENT FLA3 CODE:
REFERENCE:
DOCUMENT TITLE: French Ltd. Field Activities Work Plan
18
-------
7 :::::::;>:
MtflE-EIR:
DOCUMENT I'ATE:
NUMBER OF PAGES:
PUThOR:
n o c u KI F N ":" N jf'' ?.'-:
NIJMP-: OF Ps?"
nt ITMOR r
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T'.. ' "C'Ti; -vr, t.-. r>- r. "'. P.
_-? r .:,'.' r i: 11.! r.i c\ n :. .r\!; c a..? r n: ^ i.'; ::
Jnt".:irr>i?t 3 on r«?3ai-ivp to thif? Frencn water
w*:?"ki found at the French i,td. s\te;
rfecr-firr.eriaat ion that tne well be completely
ciosod, t\nd niethodclogy for closure of well
7C-.
0-'i/01/65
i&e
LJnspec:i f j G>d
LorUwoori, findrew= * Newnam, Inc.
. £-r"£ u i c.< 1 I n ve r.. i i L, a - i on V: 1 um2 I
-.= -*-:; f led
i-.i-"!-:-.:. ftiiJr'sw- j Newi'i-arn, Inc.
-r.. r-'. "-
.-avexi j ^ 3 Invest } j-at ion Volume II -
ftlJTriORi
CQMPftNY/OGENCY:
KCCIPIENT:
DOCUMENT TYPE:
DOCUMENT FLCiG CODE:
REFERENCE:
DOCUMENT TITLE:
V-M
CM. ,.£. 65
06 b
Frances E. Phillips, Regional
Administrator, Region VI
U.S. E.P.A.
Respondents
Administrative Order on Consent
Administrative Order on Consent to conduct
in accordance with NCP, the additional
remedial investigations to determine fully
the nature and extent of any threat to
pub3ic health or welfare
-------
' .'-LIL-. ; -:: = :
I),:,!' ;',: ,H fiv, ;;.-:.. F. -'. A- fverjijor V
£": r--;' ,- f Cornr;i'. r,'. Cc-4: i ~.-ri
l;£C;.irtrNT TIT;.?::
DJCUMENT DttT":
NUMBER OF PACES!
HUTHOR:
COMPANY /AGENCY:
fcFTJPTENT:
DOCUMENT TYPE:
I'-'C'CJMtlN'T FLS3 CODE:
REFERENCES
rie-.'iGv.i cr tne :>i.-visea Frencn Ltd. QnP;P
7G
C7/ltL/63
043
Franre-F E. Phi ) 1 ips
U. S. E.P.8. Region VI
U. B. E. P. ft.
First flr.ierided ftdnunistra+ ive Order on Consent
Fi>-iic hliiiericec: ficirr.inistrat ive Order on
'''- >-!::e.-'t to cu-'.'i'Ji.ict the additional remedial
r.ve=.t i []«»t ions described in the Work Plan,
.?n-j to prepare a ^inal remedial
T r.vF^t : ric*x' i on report surnrnarir ing the?
re ='.'. 11 =
i'',i'^
"".-t: w. Nu-wv.an. Senior Attorney,
F ! v \ r n n rr, e n t = 1 Enforcement Sect i o n
L1. -.. H. c-. ft. Retjjon VI
H = ::.el p. Hof fw^n, Esq. , Senior Attorney,
fn* ' c-nt. i c: R 3 ch * 3 e 3 d Company
ivi'£f.M'r?''iC'.>" ana Re'.'ise-d Consent Decre?o
F'CrV j =..£: rJ Concent Decree between the
Plaintiff and Certain Defendants
-------
H; :nS7M7 " Y"-T t
.'jr.-N" FLn3 CO;}?
K . :: :?; .' ,';
:.-\:.-: ": ^.': :. "o.:
ch U. S, E. P, Fi.
o>-i aesp a Q Mirier be ION the French
DOC JMTNT NUMBER :
DOCUMENT DPlTE :
NUMBER OF
fiUTHOP:
m~ HIP IF. NT:
DOCJMENT TYPE:
T Fu-flG lOD
NUMBER OP Pp,3E=, :
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DCCLT'itfJ" TvPE:
DfjilU^lINT F_n3 CO
RUFF FENCE:
DOCUMENT TITi F:
OOCUNEN" NUMBER:
?Viri.lMFK'T DftTF:
NUMSEP OF PP-3E: :
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT FLAG CODE!
REFERENCE:
DOCUMENT TITLE:
79
12/16/85
070
I in? per i f i ed
Unspeci f i«d
U. ^ E.P. ft.
x - Qfif-
cix for Quality fissurarice Program
i.'»-i?f..et: i f iiari
R e = o i.'. r'"::t E n g i n e? e r- 1 n g
L.£-. ;-". P. H. , eir-c! the Texas ^Jater Cornrnisc ion
1 '?£'? F i * 3 cj ] nve-st : gat i on Report
35-+
w'rispec: i f i&cJ
Resource Engineering
U. S. £. P. A. , and the Texas Water- Commission
Report
Field Investigation Report Appendices
£1
-------
Ml'"' ~if|£-
1M c p !\- Y / P i
Ji'.t'~',
..c.:
r!t Decrrefc tttwsevi tr.e Plaintiff
UMF M7 DPTF :
NUMBFR OF PP6F5:
AUTHOR?
CCMPfiNY/fiBFNCY:
RECIPIENT:
TVp;-:;
047 Cm/ 86
00 1
Brur-e Plane hard; Director Office of
Environmental Project Review
U. E. Dept. of Interior
Gsfie Htcero, Director, Office of Wa-ste
Prcyr-ai.!^ fc'nforceMent, U.S. E. P. A.
ftf e i '.:> ran d'-'f r
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F urvpy
rjj^e^:? 0
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". P ;: > p >s n d : c e »
= ion
R^r'ic-c i ;t i I r'ive'£,-c i gat i on Report Append i cer
« . .
NUMBER OF PAGrlS:
COMPANY /AGENCY :
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT FLAS CODE:
REFERENCE:
DOCUMENT TITLE:
04/30/fife
J £3 -
OOl»
Lir;i-pe>t-i f j ed
Resource Engineering
U.S. E.P.A., and the Texas Mater Commission
Report Appendices
Remedial Investigation Report Appendices
Vo 1 urne 11
-------
COPF:
ITLE:
DOCJi»,£NT NUMBER:
DOCUMENT DATE:
NUMBER OF PfiGES:
OlITHORx
COIPP^Y/AGFNCY:
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DuCUflllNT TYPE:
DOCUMENT F...RS CCUEi
REFERENCE:
N U % 5 E ' OF P1 H 3 ~. r. :
TYPe:
FLPG CODE
DOCUMENT N-J
DOCUMENT PATE;
NUMBER DC pftGES:
AUTHOR:
COMOflNY/flGENCY:
RECIPIENT:
DOCUMENT TYPE:
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REFERENCE:
TITLE:
Rcl'.l . ''{'' <.. : .if ,u 1 i'ltf
l\ ?. s. , P, A. , f*n
'-f t. c:
*; Watf?r Coronu r/PJ on
Rernc-'Cial Investigation Report Appendices
volume III
87
05/08/86
001
V. Peter Wynne, Chairman, French Ltd, Task.
Group
At 3 ant i r Richfield Company
Robert Hanneschlager, Chief, Superfunc
Enforcement Branch, U. B. E. P. A.
Merocrancium
G r o u n d w & t e r s a rn p ?. e s 3 o «^
88
fv._r.iert E. Hsnnetch layer, P. E. , Cnief,
5 v D Z - ~ i. , '-. C3 E r'i f O r C ? '(1 S f ', t Ei ^
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«t ion
CjCJMENT NUMBER:
L'PCUMENT DATE:
NJIBBER OF PAGES:
OiJTHOR:
CGMPflNY/RGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT ~L.n& COD
nF.~E PENCE:
0£7
Resource Eng ineer Inr;
I1. F. P.P. ft. Rerjion VJ, «nd the Te?xas Water
iii'S'T i on
Labor- 1, t ory Evalyat ion of Biodeyradat ion at
1 1 j e ?-" r' ench Ltd. site
3IJTHCK1:
'I j.^i'-'prsj'V/Aijil'-j." r'
L-C'TL ''*"£'/'" T rr-',~
3ivv 3 9
188
; f i
rc' 1 <: cy fis^ociat ion, Inc.
Tc««. : Groun, and ARCO
L)Gf:SJl*»ENT Till E:
Report
COMPANY /flGEMY:
RECIPIENT:
DOCUKKN^ TYPE:
DOCUMENT FLOG CODE:
REFERENCE:
DOCUMENT TITLE:
03
H :.- > t C . C 1 ark, Sen i or Pro j ect Manager
E3T - A Resource Engineering Co.
R. L. Sloan, ARCO Chemical Co.
Memorandum and attachment
Final ERT comments? on draft Endangerment
Assessment
-------
. : f-f
. v-c *. *"!<:->?> i. r"!f: i. -.nin.y. i-'iy
RE-ER-.NCE :
.'.nri.-'J^iEMT "I *:_£:
DOCUMENT NUMBER;
iJOriJMir.NT DATF:
N'UMpr^ OF C'HGF.3:
fllJTHOR*
COMPftNY/PGENCY:
DOCUMENT TiCPE:
D'J.^'JP'ENT FLAG CCDE
r:
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AUTHOR:
COMPONY/fiCENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT FLflP CODE:
REFERENCE:
TITLE:
."r;c.i.> qe ioont .£'iL.s£. csmerit Report
915:.
543
L'n^pec: i f i ed
uockwooc, Andrews & Newnani, Inc.
L1. E-. E. P. A.
Report
Fef-r-i bi ] : ty Fturiy Report - French Limited
^upcrf"i.r-cj 9i-fce, Harris County, Texas
if.
02/J1/67
C'i.r.
*- r-sricc?j3. E. Pn i 111 DE , Reci i ona 1
florni mstrst :T", Recicir! VI
U.S. F.P,p
on C on-J"c?ri'i'
^cci. 3 r:i i^fift i ve Orcier :-n Consent to conauct
a c ior-2'oecjis.t ion stu^y to stucy tne
," r.-;.- -:: c: i 1 i t y : v tst ing D i orerned i at i on as a
possible? ror.ioHy, and to prepare a final
report rff-1? rri bj nrj resu]t<^ of the ^tudy
37
Oi/l&/S7
001
Carl E. Edlund, Chief, Superfund Section
U.S. E. P. fi.
Bryan Dixon, Texas Water Commission
Memorandum
Request for concurrence with preferred
rewedi a1 act i on
-------
f.t'^t W. T-vv;r. -'.f-. . -'r".-
"fl F:
DOCUMENT
;;rcuME:NT DATE:
NUMBER OF PAGES:
ftUTHOR:
COMPflNY/AGENCY:
RECIPIENT:
DOCUMENT TVPE:
nOCUMc:MT F'.AP CODFi
REFERENCE:
rommentK on the ERT Eridangerrnerit
Report
03/;-.0/ft7
£70
Unspecified
ERT - ft Resource Engineering Co.
U.S. £.".. P. ft. , and trie Texas Water Cormni se i on
Report
G'Hpr.'; In-Situ Pa odegradat j on Demonstration
D HC L ''* tl N T F L M b C 2 L1 E".:
PE-£FFNC£:
nOCUMENT TI~u.E:
DOCUMENT NUMBER:
1" '.CUMETNT DPTF :
NUMBER OF C'fif;p:=s
ftUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT FLAG CODE:
REFERENCE:
DOCUMENT TITLE:
0 *,.: 1/67
C'JS
Un- f 'f-c-5 * J ed
an.-.,-
Ena _> ri L, e r-rner it fti; ses srne nt
L.'nspec: i f led
U.S. E.P.A.
Public
Siaperfund Fact Sheet
Remedial Investigat ion/Fea^ibi1ity Study,
Public Meeting - French Ltd. Site, Crosby,
Texas
£f.
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fi r ; v -;. , ' fit ";'.'' ;. .'* |-"' .'
s. ""ri^i-: - -<» " ~<'n<
n< -\ «. f-. i nv
,:'1-.:. Dorec: In-5i t u B : ocegr scat iovi
Dcf.v.-nstr^t ion - P!i5.-5O III - Rev. 5
NUMBER OF PPG=:S
.0 n c -j f< rr r-j ~
OjC!jr'L:.KT
^ v r < z. r
' -AS CODE
OA/07/P7
005
R. L. F]of*n, Special Projects Manager
PRCO Chenijcal Company
R. E. Hanneschlager, Chief, Superfund
Enf -i-rceu-ient Branch, U.S. E. P. fi.
d attacnrnent
Rpvjssons tc« wor^plan fc.r the P'Y-'opon.
Tri-Sit'j Pioderjredc-t ior, D<=rn:-n-5tr?t j.on,
':>--rnc-ri ; jrojtec S)te - C'h«-<5e JIJ;
5. 04 <:?/87
/] 4 8?
?
-:?.: 3 f i c-n
" - P P»s-ii.i.r-':*=i Eng in<=<=ring Company
p'-: rt
REFERENCE!
DOCUMENT TITLE:
f-::eJa Evaluation of Eiodegradat ion (Phase
T T
DOCUMENT NUMBER:
nfCUMF.NT DPTF :
NUMBER OF PAGES:
PIJTHPR:
COMPflNY/ftGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOnUMF.NT FLP& CODE:
REFERENCE:
DOCUMENT TITLE:
1 05
04/15/87
001
R. L. Sloan, Special Project Manager
PRCO Chemical Co.
Robert E. Hanneschlager, Chief, Superfund
Enforcement Branch, U.S. E.P.ft.
Memorandum
Transmittal of Quality fissurance Project
Plan Report of 03/30/87
-------
i" ~-t udy t o st u.dy
; r-ip f e*v> in; 1 i t y of u«r ing b J oreT.ieri i fit j on as
z ni'<-,^a \ z .1. action, arid to prepare a report
f £;<. err 3 b J nri t he resu 3 1 s.
107
04/c'0/S7
O'l' 2
FMte'lc:-n ET.. EstE'inb&crn, Senersl Counsel
ftM--TMCan ~oi.'nc:l or t-duc-at ion
Tnf orrn^t i on Feq'.ie^
C _ r.V'i .!' i c ^ 1 i or-'.: ->%.; v'; :: 1st ions, of t^tat'Jt e«r-
f" <= rn i c w- 1 '" c- rn :: 3 n y
F".
U. 5. F . f. ft.
NUMBER OF PflGES:
niJTHOR:
C-DMPANY/ftGENCY:
RECIPIENT:
DOCUNENT TYPE i
DOCUMENT FLAK CODE:
REFERENCE:
I'lQCllMENT TITuF:
Ar'ijcp'i-yfrt tc F'-cr,cri Ltd. Site Quality
H =.' jv a. n.":« Pr-je-t Plan
1 OS
00 1
Harold Scarlett, Post Environment Writer
Trie houiit Z'tt Post
Public
Newspaper firticlr
"Group to Give EPA Site- Cleanup Ideas"
-------
"= rr- r-t-r^- .
i * . j i. i j »,. -
-.^a± t:i P1 an Phase III,
OF
TYPE;
05/0;./67
liMf.peri f led
ERT - ft Resource? Engineer* ing Company
U.S. E. P. 0. , s.r>d' th-:= Texas Water Commits ion
Report
vT TJTI.F:
:? 0 3 ' J f< E N' T N '. / ^ B F R ;
r or-.(c ec! F'e-ss j b J 1 11 y Bt udy
; i s
r.?/r; /ft?
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'..T spec i f !-?._
L'.i. E. -'. A. Rt:'L|ior VI
T r-. ,, ; : -1 p':
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DOCUMENT NUMBER :
ruLUMENT DnT^:
rR OP POG.1E:
COMPflNY/rtSENCY:
DOCUMFNT TYPE:
DOCUMENT FLAG C
REFERENCE:
DOCUMENT TITLE:
- French Ltd.
Ror.ert E. Lciyton, Jr., Regional .
Hrir-jinistrator, Region VI -. . . ; -"
u.s. E. P.fl. - - -v-rr.. - - --;"-^-
Respondents : , . -- V*S-'--=- V " " ~ " "\I~i^I
First flrnended "Administrative Oi-derJ'ph
* " '
£
First Amended ftdministj^at ive Order:>on. -- \7.;.i;.._
Consent to add four additional respondents
-------
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'<<:. t : He' .'L-:
FCIS,
& Seicei Law
. A.
:;'jr.UM~M"r T3Ti.E:
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DOCUMENT DATE:
NLVBER OF PA6ES:
AUTHOR:
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RECIPIENT:
DOCUMENT TYPE:
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REFERENCE:
DOCUMENT TITLE:
DOCUMENT NUKBER:
DQCUMLNT DflT= :
\"JMBER OP PPiSE'^:
fil.iTHOR:
KLC Jf-'IFNT;
DOCUMENT T>PE:
DOCUMENT FLftG CODE:
REFERENCE :
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY /AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT FLAP CODE:
REFERENCE:
DOCUMENT TITLE:
Fre»nrri Ltd. FOIA re-quest
07/10/87
160
Unspecified
ERT - A Resource Engineering Company
U. S. E. P. A.
Report
Revised Field Evaluation of Biodegradat ion
at the Frencn Ltc. Site (Pnase II) Volume I
n 10, 1987; Revised 07/10/87)
07 / £0/87
001
Larry Thomas, Ph. D.
U. S." E. P. A.
fi~,r : r-t 3 ne McCT i nrr-, P*?te?r?.on, Ross, 8ch 3 oerta
to FOIA request
117
13 /£J./B7
01 4
Unspecified
ERT - A Resource Engineering Company
U.S. E. P. A. , and the Texas Water Commission
Report
Biodegradation Equipment Evaluation Phase
IV French Ltd. Site (October, 1987;
Rsvised 11/23/87)
io
-------
' '*". 'T "
^p; rer-n-nr Company
*s 2?r, ''.. S. F. P. O.
-'L_:"iG CCEI:
lr:-Si*'.i Bioaes»"tscj3t ion Demonstration Report
I, E^xerutivc? Summary (October 30,
Revised I?/ 15/67)
NUMBER:
r>QCUMEMT BATE;
NUMBER OF PAGES:
RUTHOR :
COMPANY /AGENCY:
RECIPIENT:
DOCUMENT TYPE:
FLAP CODF.
T
119
!;=/?£/ 67
OS 1
R. L. Sloan, Special Projects Manager
ARCO Chemical Company
R. E. Hsnneschlage-r, U.S. E. P. A.
Memorandum and attachment
Workjrilan describing the installation of
five.- s-ioilow aquifier monitor wells,
_:ja-3 gnec to allow sampling and analysis of
SDciIlow groundwatsr downgradient from the
French Ltd. Site
ft; ITHOR:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT FL.H& CODE:
REFERENCE:
DOCUMENT T]TLE.:
r f 03 /: 3 /&&
'"JE?.: 010
H.:.> t C. Clark, 9.pn).c>r Project Manager
~.\: EPT - >~: Resource Engineering Company
R. L. Sloan, ARCO Chemical Company
rar.ai.tm and attachment
pjfc-r f-eerionse romrnents to EPA memo regarding
FP£ comment?; on the French Ltd.
b j i-idegradat ion Air Monitoring Study
-------
TfJX .?-- !">,-!-
f? ^ n o f 'l;
TITLE:
Wor!< Plen Volume:- I Project fictivity and
S am pi ivia P'lan
T NUMBER;
T DftT :
NUMBER 0~ PftGES:
COMPANY /PGEN^Y:
ENT TYPE:
DOCUMENT FL.AG CODE:
DEFERENCE:
N.'T Ni JMFER:
009
Un«.peci fieri
ERT - A Resource Engineering Company
L1. S. E. P. ft.
Re DOT-t
rneri :' s 3 Obj oct i ve? and A ] t ernat i ves
Undated
F;oya 1 J. Nc-aeau, Ph.D., Environmental
Faepoiiss Team
U.S. E. P. -:.
i1. ?. ?:. r-1. N. S(?3 on v:
c: PENCE:
DOCUMENT TIT_E
fin investigation of tne French Limited
no ;ir,o3 hajarcous W;'.^te Site - Crosby,
NUMBER OF
ftlJTHGR:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT FLP.G CODE:
REFERENCE:
DOCUMENT TITLE:
,7.
Undated
00 \
Unspeci f led
U.S. E.P.A.
U.S. E.P.A. Files
Site History
Historical overview of French Ltd.
-------
& of ?*
T DAT?:
OF PAGL
TYPE:
T)!-|-.iimF\'T -LflG
REFEr'ENCEr
/PGENCY
DOCUMfTNT NUMBER:
DOCUMFNT PflTF. :
PUTHOR:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT FLAG CODE
REFERENCE:
DOCUMENT TITLE:
Una at eo
OC 1
i\Uf. Corporat iori
M^ 1 1 i burt on Company
U.S. Efi.P.A. Region VI
French Ltd. Summary Letter
Sur.-unary Letter
l£7
Undated
i*\im) H
NUB Corporation
Ha 11;burt on Company
I1. B. E. P. P. Reg 3 on VI
Sumfiisrv Letter
i. ijMiii^r v Let ter
Undated
OOrJ
NUB C o r p o r f" t i o n
Us i i i CD' ir c ori Company
U. 5. E£. P. 0. Region VI
Summary Letter
Summary Letter
-------
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£ -CUMEi^ T NuM&t R :
NwVBER CF PfiGEC:
fii.lTHOR:
COMPflNY/ftGENCY:
RECIPIENT:
DOCUMENT TYPE:
rscL'MENT =Lne CODE:
REFERENCE:
liOnUMENT TITLE:
DOCUMENT NJMBER:
WlCl.iMEtJT DfiTrs
NUMBER O?7 PPGF=. :
DuCu^'EN"1" TYPE
I'UC L'Pt^NT F; H^
RE~iv. FENCE:
DOCUMENT NUMBER:
nrjr.uttENT :)ftTH :
NUMBER OF Pfii^E'r. :
DOCUMENT TYPE:
DOCUMENT FLftG CODE:
REFERENCE:
DOCUMENT TITLE:
".' ..'V .".'". i -T '
.- ', . ": Cl-i^iV.
'' !.i r i) ''> e » y L. s 1 1 e r
1 30
ML!? Corporation
Ha Hi bur t on Company
U.S. E. P. ft. Region VI
Summary Letter
& u rn r.1 & r y Letter
131
Unosted
0'1'i-.'
MU? Corpc.fat i cin
H a 1 1 \ b i.«. r t o n C o rn p a n y
L1. S. :!. P. f-',. Region VI
£ i.t ni rn a r y i_ e 11 e r
L p 11 e r
Undated
OOr.'
N U S C o r p o r s t i o n
H a 11 i b «.i r t o n C o rn f j a n y
U.S. E. P. P). Region VI
Summary Lot t er
Summary Let t er
-------
\", " .7.!' «. "^*L»i". a
L'X'L^.M' ~:.T_h: ~---^:.r,^^- 11 "-'^ c.or-v.i6?r.ti. of Xay, 1966;
Vr:.i;ir-^:. corn.".::fir, ttarc-i, 1936
}f!Ciii»!r\'T H
N'.WBE^ OF PfiGEBi 0^3
<»; i""'-iOR: Unp ppc 3 f i ed
COMPftNY/PGF.NCV: We = t Coa-st Tpchnira.1. Service, Inc.
TCCIPJENT: L:. E. E. T1. A.
DDCJfENT "YPI: Sample Report
rDCJPlENT F'LHu C-C'Dt.;
q-pr-Tj.-,r%r-.
\)rif.! T-i-NT > I'.[": Cr-rjfr-ij c-r- Prie>3yK3«; Hat a Sheets, and Chain of
I'I'U =t od -' f-rCrTii^
-------
APPENDIX B
COMMUNITY RELATIONS AND RESPONSIVENESS SUMMARY
-------
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY FOR FRENCH LIMITED SUPERFUND SITE
This community relations responsiveness summary is divided into two sections:
Section I: Background on Community Involvement and Concern
This section provides a brief history of community interest and
concern raised during the remedial planning activities.
Section II: Summary of Major Comments Received During the Public Comment
Period and EPA Responses.
Both written and spoken comments are categorized by topics. EPA
responses to these topics are also presented.
I. Background on Community Involvement
The French Limited site was proposed for the National Priorities List
(NPL) in December 1982. On April 13, 1983, the Texas Department of Water
Resources, now the Texas Water Commission (TWC), announced the receipt of
funding from the U.S. Environmental Protection Agency (EPA) for the purpose
of investigating the French Limited abandoned hazardous waste site in north-
east Harris County. In June 1983 high waters caused the holding pond at
French to overflow and PCB-laced sludge escaped. An EPA emergency response
team removed 25 truckloads of sludge from the site. TWC conducted the
Remedial Investigation/Feasibility Studies (RI/FS) on the site. The studies
were completed in the Spring of 1987.
On April 28, 1987, EPA announced through a press release and fact sheet
that the RI/FS has been completed on the site. The announcement also advised
that public meeting would be held on May 21, 1987, at the Crosby High School,
Crosby, Texas to discuss the EPA preferred remedy of incineration and a proposed
remedy of biological treatment by the French Limited Task Group. The infor-
mation release provided that written comments on the proposal would be accepted
beginning May 11, 1987, through June 1, 1987, and that a decision would be
made by the end of year.
EPA conducted the public meeting on the proposed remedies on May 21, 1987.
About 70 people attended. Citizens mainly commented that the waste should be
taken to an offsite disposal facility rather than incineration onslte.
During 1983, a group of companies identified as having used the site for
disposal, referred to as "Potentially Responsible Parties" (PRPs), formed the
French Limited Task Group to fund independent studies on potential remedies
for the site. On March 11, 1987, EPA signed an enforcement agreement referred
to as an Administrative Order (AO) with the French Limited Task Group which
allowed the group to undertake a pilot scale testing of biological treatment
systems on the site. This study was to be completed by the end of October
1987 and clearly demonstrate that biological treatment would be as effective
and timely as incineration and meet all applicableor, relevant and appro-
priate state and federal requirements. The PRPs would also be allowed to
conduct community relations activities with EPA oversight.
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In May 1987 the Task Group initiated a community relations program to
provide communications channels to residents and other interested parties
about site activities. On May 13, 1987, the French Limited Task Group held
a public meeting in Crosby, Texas, to advise the community about the bio-
degradation pilot project. EPA Superfund project managers attended the
meeting and provided updated information on EPA studies. The Group also
announced the establishment of a Community Information Line for residents
seeking additional information on the site. Community leaders were invited
to attended a meeting on May 19 to learn more about the site status.
The French Limited Task Group held additional community leaders meetings
for the purpose of providing site activities status reports on June 11, 1987,
July 21, 1987, August 12, 1987, September 29, 1987, October 28, 1987,
November 18, 1987, December 17, 1987, January 22, 1988 and February 17, 1988.
EPA representatives attended these meetings and provided EPA site status
reports.
On August 18, 1987, the French Limited Task Group held a community
meeting for Riverdale residents. About 50 people attended the meeting and
received the site updates from the Group and EPA representatives. A similar
meeting was held in Barrett Station on August 19 and about 65 residents
attended.
The Task Group held additional community meetings to provide site status
updates in Barrett Station on October 27 and in Riverdale on October 28.
About 112 people attended the meeting in Barrett Station and about 60 people
attended the Riverdale meeting. EPA representatives were also present.
In November 1987, public misunderstandings arose about possible contami-
nation from the French and Sikes sites in several drinking water wells. This
confusion was the result of a meeting held on November 14 scheduled by residents
and attended by an ATSDR official. Although data from the wells gave no
indication of contamination from the sites, EPA agreed to sample wells of
seven residents and a monitoring well. The sampling took place on December
15, 1987. Also, EPA representatives agreed to attend a community meeting on
December 14 in order to clarify the water well data and to further assure
residents that there was no indication of well contamination resulting from
French or Sikes. However, on December 9, 1987, when an EPA representative
called the community leaders to confirm the date and location of the meeting,
she was advised that the residents would not meet with EPA and the meeting
was cancelled.
On January 4, 1988, J. Winston Porter, Assistant Administrator, Office
of Solid Waste and Emergency Response, EPA, Washington, D.C. held a community
meeting to discuss the status of Superfund sites in the Houston area. The
meeting was held at the Crosby Library, Crosby, Texas. About 75 people attended
and requested more detailed information on the water well matter. Through the
news media and telephone calls to interested residents, EPA announced that the
follow-up public meeting would be held January 28, 1988 at the Crosby Library.
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On January 21, 19S8, EPA announced through the news media that the Task
Group pilot study for bioremediation had been reviewed by EPA and that a public
comment period on the new EPA preferred remedy would begin on January 25, 1988,
and conclude on February 23, 1988. Also this announcement Included details
about a public meeting to receive comments on the proposal to be held on
February 11 at the Crosby High School, Crosby, Texas. A listing of the
repositories, where all studies/investigations and other documents concerning
the French Limited site could be reviewed, was Included in the press release.
The press release was mailed to the area news media and the French Limited
site mailing list. Announcement of a proposed actions appeared in the Houston
Chronicle on January 22, 1988, the Houston Post on January 23, 1988, and the
Community News January 27, 1988. Also, on January 22, 1988, the EPA representative
attending the Task Group Community leaders luncheon announced the February 11
public meeting, the public comment period timeframe and he left copies of the
new release for public dissemination. A four page fact sheet on the proposed
remedy was mailed to residents and the media following the press release
mailing. Copies of all documents relative to the pilot study were placed in
the site repositories on January 22, 1988, per the AO.
EPA representatives held the January 28, 1988, community meeting to
announce the results of the water well sampling and to clarify other areas of
concern. Prior to the meeting at the Crosby Library, EPA and ATSDR represen-
tatives delivered copies of the water well data to the residents whose wells
were sampled and explained that none of the contaminants from the French
Limited or Sikes sites were found in the wells. About 150 residents attended
the evening community meeting.
During the afternoon of February 11, 1988, EPA representatives briefed
state elected officials on the preferred remedy. EPA conducted the public
meeting on the proposed remedy on the evening of February 11, at the Crosby
High School. Citizens reiterated their comments from the May public meeting
that the waste should be disposed offsite. About 150 people attended the
meeting.
II. Summary of Public Comments
This section is divided into two parts. Part A includes comments
received during the public comment period from January 25 to February 23, 1988,
including the public meeting held on February 11, 1988. Part B includes
comments received at a community meeting held on January 28, 1988. EPA
responses to comments received during the comment period held from May 11
to June 1, 1987, regarding the originally proposed incineration remedy,
have been incorporated into the Administrative Record for French Limited.
PART A: Summary of Comments Received During the Public Comment Period
and Agency Responses from January 25 to February 23, 1988.
Comment #1
The available PCB data has confirmed that over 90% of the PCBs originally
present in the demonstration area were destroyed.
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EPA Response to Comment #1
EPA disagrees. Analytical results from the demonstration indicate that the
concentrations of PCBs decreased during the demonstration. No data was pre-
sented to show what portion of the decrease is specifically attributable to
degradation.
Comment 12
It is not necessary that bioremediation equal or exceed the effectiveness of
incineration.
EPA Response to Comment 12
EPA disagrees. Bioremediation must meet or exceed the cleanup criteria
established for the contaminated soils and sludges at the site. Biological
treatment must also work as quickly as onsite incineration.
Comment 13
A final decision on the need for residue solidification can only be made
after the results of residue testing are available.
EPA Response to Comment #3
EPA disagrees. Based on the results of the pilot study, the health-based
criteria for PCBs was not attained. Therefore, stabilization of the
residue is a necessary component of the remedy.
Comment 14
The post-closure monitoring period should be reduced from 30 years to 5
years.
EPA Response to Comment #4
EPA disagrees. A 30-year post-closure monitoring period is required under
40 CFR Part 264.117(a)(l). EPA deems the period appropriate, particularly
given the proximity of the Riverdale residential subdivision to the site.
Comment 15
The cleanup criterion for PCBs at the site should be increased from 23 ppm to
50 ppm because both concentrations would provide equivalent levels of pro-
tection.
EPA Response to Comment 15
EPA disagrees. The cleanup criteria were established based on an endangerment
assessment conducted in April 1987. Five criteria were identified in the
assessment and were subsequently used to estimate the volume of sludge and
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soil requiring treatment. Increasing the PCB criterion from 23 ppm to 50 ppm
could possibly decrease the volume of material to be treated. The effect of
this change would be to allow higher concentrations of other, more mobile
contaminants to remain in the soil. This would increase the possibility of
continued contamination of the upper aquifer. EPA believes, therefore, that
the 23 ppm PCB criterion is appropriate.
Comment 16
The surface water discharge criteria for the lagoon water should be set at a
combined chemical and biological oxygen demand level of 10 ppm.
EPA Response to Comment 16
EPA disagrees. Discharge standards based on the specific contaminants
found at the site would be more appropriate.
Comment #1
Would it be possible to build a tank onsite as a biological treatment unit.
EPA Response to Comment 17
It may be possible, but is not necessary. The current conceptual design
of isolating 2.5 acres of the lagoon with sheet piles is essentially the
equivalent of a separate reactor. Waste treatment in the lagoon would also
minimize excavation of the waste, reducing air emissions during
remediation.
Comment 18
Will waste from other sites be brought into French Limited?
EPA Response to Comment 18
No. Wastes from other sites will not be brought to French Limited.
Comment 19
How will the residue from the biological treatment system be handled?
EPA Response to Comment 19
The treatment residue will be dewatered, stabilized, and used as fill
material in the lagoon. The residue will be tested to show that the
stabilized mass will not generate leachate that will contaminate the upper
aquifer. The specific methods for residue handling will be developed during
remedial design.
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Comment
What volatile organic compounds were found at the site? What were the
concentrations found?
EPA Response to Comment 110
The concentration ranges for contaminants found at French Limited are
listed In Table 1-2 of the Feasibility Study written by Lockwood,
Andrews, and Newnam.
Comment 111
Biological treatment will result in a significant increase 1n air pollution
in the vicinity of the site.
EPA Response to Comment 111
Some air emissions will occur during biological treatment. However, air
monitoring performed during the pilot study indicated that the emissions,
1% to 5% of the threshold limit values for the volatile compounds onsite,
would not constitute a public health threat.
Comment 112
Offsite disposal was not considered as an alternative.
EPA Response to Comment 112
Offsite disposal was eliminated during the initial phases of the feasibility
study for the following reasons: Section 121 of the Superfund Amendments
and Reauthorization Act clearly states a preference for onsite remedies involving
waste treatment. Section 121 goes on to state that these remedies shall be
selected to the maximum extent practiceable. Also, recently enacted land
disposal restrictions require significant treatment of the waste prior to
disposal in a landfill .
Comment 113
Is the soil in the Riverdale subdivision contaminated?
EPA Response to Comment 113
Based on surface soil samples taken during the remedial investigation, no
contamination was found in the subdivision.
Comment 114
Biological treatment was rejected at Sikes because it was untested. Why is
it being recommended for French Ltd., which has similar types of waste?
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EPA Response to Comment 114
Remedies are selected on a site-specific basis. It Is applicable to
French Limited because It can be Implemented In the lagoon where the wastes
are located with few construction and materials handling considerations. At
Sikes a treatment unit would have to be built onsite. The land area available
for construction would limit the size of the basin to be built, potentially
legthening the time required to implement the remedy. Excavation and transport
of the waste, spread over 185 acres, would also be required. These
considerations make biodegradation unattractive at Sikes.
Comment 115
How will the property values in the area be affected by the site?
EPA Response to Comment 115
EPA does not know how property values may be affected by the site.
Comment 116
Signs warning of possible contamination in the fishing hole and north slough
should be posted along U.S. Highway 90.
EPA Response to Comment
EPA is currently looking into posting signs along Highway 90.
Comment 117
Have chemicals from French or Sikes contaminated the drinking water in
Riverdale?
EPA Response to Comment 117
Analytical results of samples taken from the shallow wells in Riverdale in
December 1987 indicate that the drinking water has not been contaminated from
either site.
Comment 118
Does biological treatment really work and is it safe?
EPA Response to Comment 118
Yes, biological treatment does work. Data generated in the pilot study
indicates that the organic contaminants, with the exception of the PCBs, are
reduced to concentrations below the cleanup criteria. The PCBs and arsenic
can be controlled by stabilization of the treatment residue.
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8
Comment 119
What Is the relationship of the Potentially Responsible Parties at French to
the EPA?
EPA Response to Comment 119
All of the work performed by the Potentially Responsible Parties was
done under an Administrative Order issued by EPA. EPA reviews the plans and
reports generated under the Order and oversees the onsite activities
conducted by the PRPs.
Comment 120
Was the dike around the lagoon at French built with contaminated soil from
Sikes?
EPA Response to Comment 120
No. Samples of the sand used in the dike were taken prior to construction.
The analytical results indicated that the sand was not contaminated.
Comment 121
How many studies were conducted and how much money has been spent on French
Ltd.?
EPA Response to Comment #21
Three studies have been conducted. The remedial investigation and feasibility
study conducted by EPA and the TWC cost about $1.5 million. The French
Limited Task Group spent almost $5 million on the pilot study. The Task Group
has also reimbursed Superfund for $965,000 for removal actions conducted at
the site.
Comment 122
EPA did not consider relocation of the residents as part of any remedial
alternative.
EPA Response to Comment 122
EPA does not believe that relocation is an appropriate component of the
remedy at French Ltd. Relocation is authorized when implementation of
a remedy would not provide adequate protection of public health or when
buildings are located on land necessary for implementation of a remedy.
Neither of these conditions exists at French.
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Comment #23
EPA should consider a health monitoring program as part of the selected
remedy.
EPA Response to Comment 123
After review, EPA has determined that a health monitoring program would
provide no additional protection from the hazards from French Limited.
Data generated in the remedial investigation shows that the contaminants
from the site have not migrated to drinking water supplies and are not
currently contaminating the air. Groundwater monitoring will be conducted
after completion of the remedy to ensure that drinking water supplies in
the vicinity of the site are safe.
The Agency for Toxic Substances and Disease Registry has expressed a
willingness to assist the public in developing a private health monitoring
program, should a citizens' group wish to pursue such a program on its own.
Comment 124
Table 4 in the draft "Summary of Remedial Alternatives" should be revised to
indicate that onsite incineration is "an effective alternative," not the
"most effective alternative. The rationale for this alternative should also
indicate that air emissions risks may exist and that implementation is
"complex" not "simple."
EPA Response to Comment 124
Onsite incineration of sludges and soils (Alternative 1) is considered the
most effective alternative evaluated. This is based on the complete
destruction of the organic contaminants onsite. Performance standards for
air emissions from incinerators would be met, minimizing the risk from these
emissions. EPA considers the implementation of an incinerator to be
relatively simple in comparison to the other alternatives evaluated in the
summary. EPA believes that the ratings given to the alternatives in
this table are appropriate.
Comment 125
The Federal Government should have a facility to dispose of these types
of wastes.
EPA Response to Comment 125
As a governmental agency, EPA is not and should not be in the business of
handling and disposing of wastes. EPA believes that these functions,
including the ownership and operation of offsite disposal facilities, .is
best left to the private sector.
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10
PART B: Summary of Community Meeting Held on January 28, 1988.
ATTENDEES: o Approximately 150 area residents and other concerned citizens.
o Representatives of the Environmental Protection Agency (EPA),
Agency for Toxic Substances and Disease Registry (ATSDR), and
Texas Water Commission (TWC).
PURPOSE: This informal meeting was held at the request of residents of Crosby,
the Riverdale subdivision, the Rogge subdivision and the Barrett Station
subdivision to discuss hazardous waste pollution at the French Ltd. and
Sikes Super fund sites, as well as other possible hazardous waste problems
in the area. This was a followup meeting to a January 4, 1988, meeting
between Dr. J. Winston Porter (EPA's Assistant Administrator for the
Office of Solid Waste and Emergency Response) and community leaders in the
area. Since citizen concerns covered a wide range of environmental issues,
an effort was made to have all the key federal and state officials avail-
able to respond to questions. This record was prepared to summarize the
response to issues raised at the January 28 meeting.
MEETING SUMMARY: Mr. Edlund opened the meeting at 6:30 pm and indicated that
a record of the meeting would be prepared for attendees and other
interested persons. Because of the wide range of topics, it is being
entered in the records of both the Sikes and French Ltd. Superfund sites.
Numerous comments regarding hazardous waste had appeared on January 27, 1988,
in the The Community News, a local newspaper. In addition, questions were
compiled and presented to EPA by Mr, David Shade of the Rogge subdivision a
few minutes before the meeting began. The questions contained in these
documents were addressed in sequence by the federal and state representatives.
A. "The Community New" "article entitled "Whiddon Fed up with 'Double Talk'/
Whiddon wants facts" by Robert Vanya dated 1/27/88
1. Question; "Have chemicals from the dumps contaminated the drinking
water?"
Response: No. EPA found no correlation between contaminants in
the Riverdale residential water wells sampled on December 15, 1987,
and contaminants found in the French Limited and Sikes sites.
Contaminants found were those commonly associated with analytical
laboratory equipment and PVC pipe used in water well construction.
2. Question; "Is bioremediation (the cleanup method being used at
French Limited) really working and is it really safe?"
Response; Yes, to both questions. EPA believes bioremediation will
be effective if combined with treatment of the groundwater, and
solidification of the residue. For this reason EPA proposed this
approach for the French Ltd. site. A public meeting to discuss the
French remedy was scheduled for February 11, 1988. Mr. Edlund
asked that detailed questions regarding the French remedy be deferred
to that forum.
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11
3. Question; "Is bioremediation causing harmful air emissions?
Response; No, EPA does not believe harmful levels are or will
be produced. This conclusion is based on the data gathered by
the French Task Force at the _in situ biological remediation pilot
project.
4. Question; When will incineration start at the Sikes site?
Response; EPA anticipates that incineration will start in about
two years.
5. Question; "What will the effects of incineration of wastes at
the Sikes dump be?"
Response; EPA does not anticipate any detrimental results or
effects of incinerating Sikes waste. Incineration at Sikes will
take place after the Remedial Design. The Design will be made
available for review and comments. This fall we will post the
list of requirements for the design which will address noise and
air emissions.
6. Question; "Why is there no protective fence around the Sikes
site"?
Response; A fence was proposed in June 1986, to be erected as
part of the incineration project. Until EPA received the recent
comments about the frequency of illegal trespassing on the site,
no urgency was given to this aspect of the remedy. Based on the
citizen concerns voiced in December 1987 and January 1988, EPA
announced that a fence would be erected in the near future to
prevent access to the waste on the Sikes site.
In follow-up discussions by attendees two related questions were
asked: a) will EPA post "no fishing" and/or "no trespassing
signs", and b) will EPA erect the fence across the private access
road that traverses the French site? EPA agreed to look into
erecting signs but indicated that blocking the road was not
planned because there was no evidence that the road itself is a
hazard. Also EPA did not have any evidence that the sand hauled
in the trucks is contaminated.
UPDATE; EPA began fence construction on March 7, 1988.
B. "Proposed Questions for EPA Representatives" - A list of 26 questions
compiled by Mr. David Shea was presented to the representative at the
beginning of the meeting (Attachment 13). Responses to questions
discussed at the meeting are summarized below (the numbering matches
that in the attachment). Written responses to questions that were not
explicitly addressed are contained in Section D.
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12
7. Question; "Why has there been so many cancer related deaths and
people with nerve disorders and lung disease in this area?"
- and -
8. Question; "We feel someone should have done a health survey in
our community. With these dangerous chemicals in our area,
why wasn't one conducted? (There appears to have been numerous
cancer related deaths in our community)."
Response; While some statistical suntnaries show relatively
high incidents of cancer in Harris County, the federal and
state agencies were not aware of any data for the Crosby area.
Any information of this nature would be gladly reviewed by
health advisory agencies such as ATSDR and the State Depart-
ment of Health.
EPA does not take action at hazardous waste sites based on health
studies for two reasons:
a. Timing - chemicals that cause cancer often take many years to
have an affect (e.g. mesothelioma, an incurable lung cancer
caused by asbestos/ takes 20 to 30 years to develop after
asbestos ingestion). It would be poor public policy to defer
action at a hazardous waste site pending a study lasting
several decades.
b. Ambiguity of results - Because chronic disease, such as cancer
can be caused by a wide variety of factors acting singly, or
in combination and often over periods of years, a health study
could never determine the extent that the hazardous waste
sites in question harmed anyone in the area. Exposure of area
residents to former levels of pollution from the sites is
unquantified as is their exposure to other chemicals in the
home or at work. While some factors that contribute to cancer
(such as tobacco use, diet, and possibly heredity) might be
able to be documented, the unquantified factors plus other, as
yet undiscovered causes of disease, would render the results
ambiguous.
Instead of performing site by site health studies before acting.
EPA uses all the scientific information know about the contaminants
to determine if a site poses a potential risk to human health as
the basis for cleanup.
Questions 9-13 restate the issues posed in the newspaper article. EPA's
reponses to these questions are summarized above.
9. Question; Have chemicals from the dumps contaminated our drinking
water?"
10. Question; Is bioremediation causing harmful air emissions?"
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13
11. Question; When will incineration start at the Sikes Dump?
12. Question; What will the effects of incineration of wastes at the
Sikes Dump be?
13. Question; Why is there no protective fence around the Sikes site?
14. Question; Where is well GW-25? Where are the test results on this
well that Larry Thomas took in December?
Response; GW-25 is located along Gulf Pump Road between the Sikes
Disposal Pits and the Riverdale subdivision. The analytical
results from the samples taken on December 15, 1987, can be found
in the reposities.
15. Question; Is the sand contaminated, like it shows on your research,
if so why was the public allowed to purchase this sand?
Response; Samples taken from areas where sand was sold were not
contaminated.
16. Question; How do we clean up the sand that was hauled to the Public
Library/ Post Office, our Schools, and Little League Ball Parks?
Response; EPA does not know if the sand is contaminated in these
areas. We will pursue the sampling and take action if deemed
necessary.
17. Question; What danger are our children in when they have played
in the sand that now shows to be contaminated?
Response; This is difficult to assess because the effects are long
term and the frequency of exposure and concentrations of contami-
nants are not known.
18. Question; "Why was the road, across Sikes Chemical Dump, allowed
to stay open, although the research states there is danger from
spreading the chemicals on the general public using Highway 90?"
Response; The private road, composed of clean fill, is not in and
of itself hazardous. This road is laid over contaminated soils
however, which will be excavated for incineration in the future.
At that time this road may be closed.
The "research" cited was explained to be the Sikes Site RI/K
reports prepared for TWC by Lockwood, Andrews, and Newnam.
19. Question; "Is there some connection between one of the Respon-
sible Parties at French Limited and the EPA?"
Response; No.
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14
19. Question; "Is there sane connection between one of the Respon-
sible Parties at French Limited and the EPA?"
Response; No.
20. Question; "We believe that one of the responsible parties at the
French Limited also owns a large track of land behind Sikes Dump
and otherwise would not have access to their property. Can you
comment on this?"
Response; This may be true. However, EPA data indicates that
the land and access road in question are not contaminated. EPA
has no authority, therefore, to prevent the current business
from operating.
21. Question; How do you go about establishing the safe drinking
water standards? Does your research consider the bathing, cooking,
and drinking, in the anount that the consider safe for human
consumption? What is the normal in-take per child or per adult?
Response; EPA considers all these factors and more in setting
cleanup standards for Superfund sites. EPA looks at all regula-
tions published to date at the State and federal level. We also
check with other health agencies such as ATSDR and we employ
health specialist also.
22. Question; "Why was the dike"at French Limited built with contami-
nated soil from Sikes Dumps? Is that not against the Superfund
Laws?"
Response; Contaminated soil was not used to build the dike
around French Limited.
23. Question; "How many studies have been done on these Superfund Toxic
Waste Sites?"
Response; Three.
24. Question; "How much money has been spent on these studies?"
Response; See Part Af comment 121.
25. Question; "Have you sampled the water and sediments in the swamp
north and south of Highway 90?"
Response; Yes. Sampling was done as part of the remedial investi-
gation at French.
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15
27. Question; "What position is French Limited on the National
Priorities List?"
- and -
Question; "What position is Sikes Site on the National Priorities
List?11
Response; The position (rank) of a site on the list is incon-
sequential. Once a site is on the National Priorities List it is
eligible for funding.
C. Additional Verbal Questions asked at the Meeting
28. Question; Why have you not looked at the alternative of relocating
residents? That might be more cost effective.
Response; Relocation of residents is considered when their health is
immediately threatened or in cases where this is physically necessary
to implement a remedy. While French and Sikes represent potential,
long term health risks there is no immediate health posed by the sites
and the remedies for the sites can be implemented without moving people.
29. Question; Who pays for the guard at Sikes?
Response; Federal funding to the State.
30. Question; Why don't you take the waste offsite by barge or railroad?
Response; Offsite removal was considered at Sikes, the Agency must
give preference to remedies conducted on site.
31. Question; Why can't I take my barrels to French?
Response; We don't even want clean trash at French.
32. Question; Why don't you want responsible parties at Sikes?
Response; EPA is very interested in pursuing Potentially Responsible
Parties at all Superfund sites and will evaluate any information
concerning PRPs.
*
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16
33. Question; Be clear with the citizens that lab tests of well water
can go only so far.
Response (by EPA & TWC); When we tested the water wells it did not
appear that contaminants from the sites are contaminating the wells.
Further analysis is being conducted by the Texas Department of Health
regarding bacteria and sodium. The levels for which we have drinking
water standards were not exceeded. Also phalates were found in the
samples which can result from pipe or lab. These levels were well
below the health advisory. We cannot measure zero although the Agency
goal is zero. We have sampled enough wells and nave thorough data
to show the movement of the groundwater is slow. We do not see any
cause for alarm and the contamination is not related to the Super fund
sites. At French Limited we are proposiny to treat the groundwater.
Sikes groundwater contamination will diffuse and restore itself.
Response (by ATSDR); We have reviewed the type of exposure routes
from the water wells and provided consultation on the Sikes site.
There are 7 homes in the are that use the aquifer and we have recom-
mended that these wells be monitored again.
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