$EPA
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
Superfund
Record of Decision;
Brio Refining, TX
EPA/ROO/R06-88/031
March 1988
ENVIRONMENTAL
PROTECTION
AGENCY
DALLAS, TEXAS
LIBRARY
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REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R06-88/031
3. Recipient's Accession No.
4. Title and SuMitli
KRFUND RECORD OF DECISION
i
5. Rei
Refining, TX
Remedial Action - Final
7. Authors)
8. Performing Organization Rept. No.
\y
CK
9. Performing Organization Nam* and Address
10. Project/Task/Worfc Unit No.
11. ContracKC) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report A Period Covered
800/000
14.
IS. Supplementary Notes
V
!«. Abstract (Limit: 200 words)
The 58-acre Brio Refining site is located in Harris County, Texas, approximately
20 miles southeast of Houston. The site is broken into two parcels, 49-acre Brio North
and 9-acre Brio South, separated by Drive Farm Road. The site is bprdered by Mud Gully,
a flood control ditch that drains into Clear Creek, Dixie Oil Processors NPL site,
iendswood oil field and the Southbend residential subdivision. Between 1957 and "
the site refined crude oil and styrene tars to produce toluene, ethylbenzene,
solvents, naphthalene, diesel fuel and kerosene. Various owners of the site
stored styrene tars in 24 open pits. Other waste products and sludges were stored in
aboveground tanks. Site investigation indicate that between 500,000-700,000 yd3 of
onsite soil have measurable contamination, and that high levels of VOCs exist in ground
water underlying the site. Primary contaminants of concern affecting the soil and
ground water are VOCs including 1,1-dichloroethane, 1,1,2-trichloroethane, and methylene
cnloride; and base/neutral organic compounds including phenanthrene and fluoranthene.
The selected remedial action for the Brio Refining site includes: excavation and
incineration or biological treatment of all onsite soils, sludges, and liquids found to
be above action levels defined in the Endangerment Assessment, with backfilling of all
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Brio Refining, TX
First Remedial Action - Final
Contaminated Media:- gw, sludge, soil
Key Contaminants: organics, VOCs (DCA, TCE)
b. Tdentlfiers/Open-Endod Terms
Tl Field/Group
Statement
19. Security Class (This Report)
None
20. Security, Class (This Page)
None
21. No. of Pages
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce
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Refining, TX
First Remedial Action - Final
'16. ABSTRACT (continued)
treated material passing the Toxicity Characteristic Leaching Procedure (TCLP). If the
Brio Site Task Force (PRPs) can successfully demonstrate the effectiveness of
aqueous-phase biological treatment it will be considered, otherwise, incineration will
be selected; excavation and treatment of all visual onsite seeps; excavation and removal
of all offsite soils contaminated above background levels; further investigation of Pit
G to locate sludge or contaminated soil underlying the existing onsite wastewater
treatment impoundment; consolidation and disposal of all inert debris and rubble with
ultimate disposition to be determined during remedial design; disposition of Mud Gully,
the flood control ditch, to be determined during remedial design; inplace stabilization
of wastes existing in the wastewater treatment impoundments, backfilling with dike
materials, capping, regrading and vegetating to improve runoff, and installation of a
package wastewater treatment system or route wastewater to a POTW; removal and offsite
disposal of tank contents, and decontamination, dismantling and selling or offsite
disposal of tanks; dismantling of all onsite process equipment; monitoring ambient air;
control of air emission from the treatment processes; venting waste enclosures to an
emission control device; treatment of ground water in the Numerous Sand Channel Zone to
a level to be determined in design; natural attenuation of the Fifty-Foot Sand Aquifer
with monitoring to ensure effectiveness; regrading and vegetating areas outside
ivation boundaries; construction of a stormwater transmission system draining to Mud
Ly; and imposition of deed restrictions as necessary. The estimated present worth
cost of this remedial action is $23,308,000-^23,333,000 for biological treatment or
$22,458,000-^26,598,000 for incineration based on 62,900 yd3 of treatable material.
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BRIO REFINING
RECORD OF DECISION
MARCH 31, 1988
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322
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
ALLIED BANK TOWER AT FOUNTAIN PLACE
1445 ROSS AVENUE
DALLAS. TEXAS 75202
DECLARATION FOR THE RECORD Q£ DECISION
SITE N£M£ AND LOCATION
Brio Refining site, Harris County, Texas
STATEMENT Q£ PURPOSE
This decision document outlines the selected remedial action for
the Brio Refining site in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA) , as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) , and to the extent
practicable, the National Oil and Hazardous Substance Pollution
Contingency Plan, 40 CFR Part 300, November 20, 1985.
The State of Texa*S (through the Texas Water Commission) has been
provided an opportunity to comment on the technology and degree
of treatment proposed by the Record of Decision and has no
objection to the selected remedy (See Appendix G).
QF_ BASIS
This decision is based on the administrative record for the Brio
Refining site (See Appendix F). The attached index identifies
the items which comprise the administrative record.
DESCRIPTION QF_ THE RRMRPY
Upon review of the information contained in the administrative
record, it is EPA's judgment that on-site incineration of wastes
appears to best serve both statutory and selection criteria in
relation to the other solutions evaluated. A detailed
description of this remedy and an explanation of how it meets
statutory requirements is contained in the attached "Summary of
Remedial Alternative Selection."
The Brio Site Task Force (a group of potentially responsible
parties) proposes the use of on-site aqueous-phase biological
treatment. The lack of the demonstrated performance of this
technique on the wastes of concern at the Brio Refining site,
while of concern to EPA, may not prevent favorable consideration
if the Brio Site Task Force can demonstrate that aqueous-phase
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biological treatment can provide the same level of treatment
deemed necessary to protect human health and the environment
This action would include:
Affected materials and soils - Shall be treated using either
incineration or biological treatment. This media shall be
defined as all contaminated sludges and liquids and waste
material found to exist above the action levels defined in the
Endangerment Assessment (EA). This will include those affected
materials and soils existing in pits B, J, H/V, E, Q, and R
(as defined in the EA). Additionally, the Remedial Investigation
identified sludges and liquids in pits F, G, I, K, L, and M;
therefore, these sludges and liquids (and any others found during
remedial action) must also be excavated and treated. The
definition of the boundary between the sludge/soil interface will
be determined prior to remedial action.
Excavations shall be conducted in enclosures, material
transported to the treatment unit(s), and *:ae treated material
backfilled in the pits if it successfully passes the Toxicity
Characteristic Leaching Procedure.
Surface contamination - Attachments 8 and 9 of the Remedial
Investigation Report shall be examined and the site re-evaluated
prior to remedial action, to identify those areas where surf
seeps are visually apparent. These areas will be scraped or
excavated to remove the source of contamination and to prevent
future migration of this material. This source of contamination
will then be consolidated and treated with the affected materials
and soils.
Off-site soil Contamination - Any off-site soil contamination
found during the remedial investigation, or during the remedial
action, shall be removed to background levels. This may require
that special detection limits be used for sampling efforts at the
site boundaries during the remedial action. This activity will
have to be further defined in the remedial design.
Pit fi - Further investigation into this pit area to locate
sludges or liquids may have to be done at the completion of the
remedial action due to the location of this pit beneath the
wastewater treatment surface impoundment. This activity will be
further defined in the remedial design.
Debris and rubble - There is much inert debris and rubble
remaining on the site from past operations. This material may be
consolidated and the ultimate disposition of the material
determined during the remedial design.
Mud Gullv - Contaminants observed in this flood control
and the "bottle neck1* that exists as it passes the Brio site
been a noted concern of the EPA as well as local residents and
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the Harris County Flood Control District. It is apparent that
these problems will have to be corrected as part of any remedy
that is instituted at the site. Initial thoughts would suggest a
low-maintenance approach to resolving this problem where some
type of performance standard would be set in cooperation with the
Harris County Flood Control District. Such actions shall be
further defined in the remedial design.
Wastewater treatment system - In-place stabilization of wastes
existing in the impoundments, backfill impoundments with dike
materials and other uncontaminated materials (if necessary), cap
and cover, grade to promote runoff and minimize infiltration,
install a package wastewater treatment plant or route wastewater
to a POTW. Portions of the existing wastewater treatment system
may be used during remedial action, but will be decommissioned
once the remedial action is completed.
Storage tanks and. drums - Remove tank contents, decontaminate
tanks, dismantle tanks; sell dismantled tanks or transport the
tanks to an EPA approved off-site disposal facility; transport
the tank contents and drums to an EPA approved off-site disposal
facility. If any tanks are used during remedial activities, they
will be dismantled upon completion.
Process equipment - The entire process facility will be
dismantled. If any portion of the existing facility is used during
remedial activities, the structure will be dismantled upon
completion of remedial action.
Monitoring and control of migration pathways - Ambient air
sampling on a semi-annual basis; control air emissions from
treatment processes; excavate in enclosures and vent the
enclosure to an emission control device; eliminate or control
rainfall on construction areas; sample and monitor Mud Gully
sediments; treat the groundwater in the Numerous Sand Channel
Zone to a level to be determined in the remedial design (but to
achieve treatment of the Dense Non-Aqueous Phase Liquids (DNAPLs)
to the satisfaction of EPA) monitor the groundwater for a
timeframe to be determined in the remedial design; allow natural
attenuation (no treatment) of the Fifty-Foot Sand aquifer and
monitor the groundwater in the aquifer to ensure that it is
naturally cleaning itself. Monitoring activities will be
utilized to determine the effectiveness of the actions to be
implemented and shall be detailed in the operation and
maintenance plan of the remedial design. This same data will be
evaluated during the Agency's 5-year review, in accordance with
SARA Section 121(c), to determine if any corrective action is
necessary.
Site management plan - Areas outside the boundaries of
excavation will be regraded and vegetated to promote drainage and
minimize infiltration. A stormwater transmission system draining
to Mud Gully will be constructed in an east/west direction across
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the north and south parcels. All regrading will be covered
6 inches of topsoil, if necessary, to promote vegetative gr
To the maximum extent practicable, the aesthetics of the site
(upon completion of the remedy) shall be enhanced by utilizing
creative design and landscaping techniques with input from local •
residents.
Site control - This remedial action is based on permanent site
control, imposition of necessary deed notices and restrictions
(if possible), and restriction of access to the site by use of a
fence or similar barrier.
USE QE BIOLOGICAL TREATMENT ]Jg LIEU QF_ INCINERATION
All factors considered, EPA has determined that the Brio Site
Task Force's proposal utilizing biotreatment has the potential to
provide for the protection of human health and the environment
comparable to the on-site incineration remedy. The Task Force
(or settling party) must agree to undertake any corrective action
deemed appropriate by EPA in the event of remedy failure, if
biotreatment is used. Pass/fail criteria for use of
biotreatment, rather than incineration, will be developed prior
to the start of remedial action. If biotreatment cannot meet the
pass/fail criteria, then on-site incineration will be
implemented.
DECLARATION
The remedy described above is protective of human health and the
environment, attains Federal and State requirements applicable or
relevant and appropriate and is cost-effective compared to
equally protective alternatives. This remedy satisfies the
preference for treatment that reduces toxicity, mobility or
volume as a principal element. Finally, it is determined that
this solution utilizes permanent solutions and alternative
technologies to the maximum extent practicable.
In
/Date1' / j Robert E. Layton Jr., P.E.
Regional Administrator
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BRIO REFINING
Record of Decision concurrences
The Brio Refining Record of Decision has been reviewed and I
concur:
Allyn M. Davis, Director
Hazardous Waste Management (6H)
At-J
b^rt'E. "Hannesschlarger, P.E., Chief
uoerfund Enforcement Branch (6H-E)
Harry D'.u Wright,
Superfund Enforcement Section (6H-EE)
Bennett Stokes, Chief
Office of Regional Counsel (60C)
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
BRIO REFINING SITE
SOUTHEAST HARRIS COUNTY, TEXAS
MARCH 31, 1988
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TABLE QE CONTENTS
I. SITE LOCATION AND DESCRIPTION Page
1.1 Site History 1
1.2 Geology 4
1.3 Hydrogeology 6
1.4 Remedial Investigation Results 8
1.5 Pilot Studies 11
1.6 Potential Impacts of Site on Human Health .... 13
and Environment
II. ENFORCEMENT 14
III. COMMUNITY RELATIONS HISTORY 14
IV. ALTERNATIVES EVALUATION
4.1 Evaluation Criteria 16
4.2 Descriptions of Alternatives 19
4.3 Evaluation of Alternatives 21
4.4 Operation and Maintenance 25
V. SELECTED REMEDY 26
VI. APPENDICES
A. Tables 1-5
B. Vessel Inventory
C. Site ARARs Evaluation
D. Site Plan
E. Community Relations Responsiveness Summary
F. Administrative Record
G. State Response to Record of Decision
H. Process Facility Dismantling Cost Estimates
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LIST QE TABLES
NO.
1 Highest Compound Concentrations For Pit Soil
and Subsoil Samples
2 Organic Compound Concentrations in the Numerous
Sand Channel Zone
3 Comparison of Remedial Alternatives
4 Estimated Amount of Waste Requiring Treatment
on the Brio Superfund Site
ii
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LIST QF FIGURES
FIGURE NO. TITLE
1 Site Location Map
2 Site Location Map
3 Generalized Stratigraphic Column
4 Site Lithologic Units
5 Wastewater System
6 Schematic of Water Flow Through
Wastewater System
111
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1.0 SITE LOCATION AND DESCRIPTION
The Brio Refining site is located approximately 20 miles
southeast of Houston, Texas, in Harris County (Figure 1). The
site occupies approximately 58.1 acres. Portions of the site
occur both north and south of Dixie Farm Road and are designated
as Brio North and Brio South. Brio North occupies 48.8 acres and
Brio South covers 9.3 acres.
Mud Gully, a flood control ditch and local tributary of Clear
Creek, runs along the western boundary of the Brio site. The
Dixie Oil Processors site borders Brio South to the southwest.
The Southbend Subdivision borders the Brio property to the
northwest and Beamer Road borders to the northeast. The
Friendswood Oil Field borders the remaining areas (Figure 2).
1.1 SITE HISTORY
Past ownership and operations as obtained from the Brio
Refining/Dixie Oil Processors Feasibility Report and Summary
Report prepared for the Brio Site Task Force by IT Corporation
are summarized below:
0 1957-1969
O 1969 -1972
O 1972-1975
Hard Lowe Co. operations included regeneration
of copper catalysts, recovery of ethylbenzene
from styrene tars and recovery of chemicals
from vinyl chloride bottoms. The company
changed names in 1959 to Hard Lowe Chemical
Company and again in 1963 to Lowe Chemical Co.
In 1963 operations included reclamation of
chemicals/petrochemicals from phenol heavy
ends, chlorinated hydrocarbons, cresylic acid
and ethylene glycol.
Chemical Pollution Control Corp. took over
operations and the name of the facility was
changed to Phoenix Chemical Company.
Production of ethylbenzene, toluene, aromatic
solvents and styrene pitch occurred. Archem
Corporation leased Brio North from Phoenix to
produce cresylic acid, sodium sulfide and
sodium cresyllite. They also stored spent
caustic on site. Phoenix assumed operations
of Archem in 1971.
Phoenix Chemical Corporation lost control of
the site and its operations in 1972. The
facility was purchased and operated by the
Lowe Chemical Company.
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VICINITY MAP
LOCATP*
NOTE INFORMATION OBTAINED FROM THE
IT CORPORATION FEASIBILITY STUDY
BRJOREfNERY
RECORD Of DEC6ON
SITE LOCATION MAP
PROJECT NO.
TC3621-23
DATE
2-18-8S
FIGURE NO,
1
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NOTE. INFORMATION OBTAINED FROM THE
IT CORPORATION FEASIBILITY STUDY
8RJO REFINERY
RECORD OF DECSCN
SfTE LOCATION MAP
PROJECT MO.
TC3621-23
DATE
2 18 «8
FIGURE NO
2
Tfc
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o 1975-1978 In 1975, JOC Oil Aromatics, Inc. controlled
the site and production included toluene,
ethylbenzene, cumene, aromatic oil and fuel
oil.
o 1978 Friendswood Processing Inc. , a wholly owned
subsidiary of the Brio Petroleum Corporation,
purchased the facility and converted it to a
crude oil topping unit for jet fuel
production.
o 1978-1981 Facility changed names to Friendswood Refining
Inc. and onsite production of diesel fuel,
residual oil, naphtha, kerosene and fuel gas
occurred.
o 1981-1982 The facility changed names to Brio Refining,
Inc. and operations changed to the production
of jet fuel. Operations closed in 1982 after
Brio Refining filed for bankruptcy.
Between 1957 and 1960, Hard Lowe Chemical Co. constructed several
pits to support the styrene tar processing operations. The
majority of the pits were built from 1964 through 1970. Due to
the lack of processing capacity, styrene tars were stored in four
large impoundments on Brio North.
The first pit closure activities were conducted in 1969 and 1970
with some pit materials left in place. Closures were reportedly
accomplished by removing the stored material from the pit and
backfilling with a mixture of soil, calcined clay and pit
residue. Soil cover was then placed over the stabilized pit
material. Approximately seven additional pits were closed from
1972 through 1975 while under the ownership of the Lowe Chemical
Company.
JOC Oil Aromatics, Inc. (JOC) stored styrene tars in open pits on
the site from 1975 to 1978. Four of the open pits were closed in
1976 and 1977. One new pit was constructed by JOC.
The final pit closure occurred in 1979-80 by Friendswood Refining
Inc. Operations closed down in December 1982 (with the
declaration of bankruptcy by Brio Refining, Inc.) and the Brio
site has remained inactive.
1.2 SITE GEOLOGY
The Brio site is located within the Pleistocene Deltaic Plain of
the Brazos River, known as the Alameda Delta. The site is
underlain with Pleistocene and Pliocene deposits to a depth of
approximately 2400.0 feet as shown on Figure 3. The aquifers
used to supply water for domestic, industrial and agricultural
purposes are the Lower Chicot and Evangeline, which are confined
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BROREHNERY
RECORDOFDECGCN
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DATE
2 11 II
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aquifers isolated from surface recharge. The groundwater flow in
the Lower Chicot and the Evangeline is to the southeast.
The Friendswood Oil Field borders the site and is an extensively
explored oil and gas field. The Oligocene Age Brio Formation of
the Texas Gulf Coast Region is the oil producing zone with wells
from 4000.0 to 7000.0 feet deep.
The site specific geology that was under investigation during the
Remedial Investigation/Feasibility Study (RI/FS) was the Beaumont
Formation as shown in Figure 4. The results from the Feasibility
Study and Summary Report are given in the following paragraphs.
The Beaumont Formation is separated into five major units (Figure
4). The Upper Clay Unit is composed of clay and silty clay. The
unit is continuous across the site and ranges in depth from 14.0
to 32.0 feet. The Numerous Sand Channels Zone (NSCZ) is the next
unit and is comprised of interbedded sands, sandy silts, silty
sands, clayey silts and silty clays. The thickness of the NSCZ
varies across the site from less than 10 feet to over 20 feet.
The NSCZ is the upper water bearing unit with well yields less
than 10 gpm. The Middle Clay Unit is next and is composed of
silty clay/clayey silt. The thickness ranges-from 8.0 to 20.0
feet. The Middle Clay separates the NSCZ from the lower aquifer
and forms a confining layer over the lower unit. The Fifty-Foot
Sand is the fourth unit and occurs between 52.0 and 61.5 feet
below ground surface. The thickness varies from 35.0 to 45.0
feet. The Fifty-Foot Sand Unit has a reasonably high well yield.
The fifth and last unit is the Lower Clay Unit, a silty clay
approximately 100.0 to 120.0 feet thick. The unit extends to at
least 200.0 feet below ground surface.
A salt dome fault is located in the western part of the Brio
site. According to Dr. Carl Norman of the University of Houston,
the ground movement north of the fault has been downward in
relation to the ground south of the fault. The fault could cause
a slight reduction in lateral groundwater flow for various units
across the fault. At this time, there is no evidence to support
a vertical hydraulic connection between the units along the
fault.
1.3 SITE HYDROGEOLOGY
The NSCZ and the Fifty-Foot Sand are the two water bearing units
investigated at the Brio site. The NSCZ potentiometric surface
indicates that the groundwater flow is towards Mud Gully and will
either run parallel to the gully or discharge into the gully.
The groundwater flow volumes range from 6.6 to 102.0 gallons per
year per square foot of cross-sectional area. The velocity of
the groundwater ranged from 2.9 to 68.0 feet per year.
The potentiometric surface of the Fifty-Foot Sand showed a
hydraulic gradient of 0.0001 in the south-southeast direction.
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Flow would be towards the Gulf Coast. Lateral groundwater flow
volumes range from 1.2 to 12.0 gallons per year per sq. ft. of
cross sectional area. The average groundwater velocities were
3.9 to 58.0 feet per year.
The Middle Clay Unit has an upward hydraulic gradient thereby
minimizing the potential for groundwater movement between the
NSCZ and the Fifty-Foot Sand over most of the site.
1.4 REMEDIAL AND SUPPLEMENTAL REMEDIAL INVESTIGATION RESULTS
Five different types of wastes were sampled at the Brio Superfund
Site. Those included sewage sludge, wastewater treatment system
sludge and liquid, above ground storage tank sludge and liquid,
closed impoundment (pit) soils, and groundwater as described in
the following paragraphs.
At some time when the Brio refinery was active, processed sewage
sludge was brought in for odor control. T-?re are numerous piles
of sludge on the northwest section of the ." te. After testing,
this material was found not to be RCRA hazardous by
characteristic, but could be intermingled with hazardous
substances, pollutants or contaminants inherent to the site.
The wastewater treatment plant for the Brio site has been tested
and the discharge was found to be within the limits of its old
NPDES permit. Testing was also done on the sludge and water in
the impoundments and sumps, and the results indicated that these
wastes are also not RCRA hazardous by characteristic, but are
considered hazardous substances, pollutants or contaminants.
Various sludges and liquids are stored in vessels and tanks on
the site (reference Appendix B). All but six tanks are within
earthen or concrete berms. The six uncontained tanks would drain
into the wastewater treatment plants impoundments (Figures 5 and
6 ). There are 1,757 drums on the site, most of which were
generated during the Remedial and Supplemental Remedial
Investigations.
The major sources of possible contamination are the closed
impoundments (pits) on the site and the contamination these pits
have caused to the shallowest aquifer.
There are approximately 200,000 cubic yards of contaminated pit
and subsurface soils on the site, associated with 24 different
pits. But, the site investigations indicated that there is
between 500,000 and 700,000 cubic yards of soils with measureable
amounts of contamination. The pits are identified as A through
X. Numerous discrete interval and composite samples were
collected from each pit and the subsoil around each pit. Table 1
shows the compounds with the highest concentrations detected in
the pit and subsurface soil samples. 1,2-dichloroethane had the
highest concentration (245,000 mg/kg) of any of the volatile
8
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•EVAPORATION
DISCHARGE
MUD
GULLY
UT*LL
SLUDGE
RECYCLE
CLARIFIER
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GRAVITY
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{EVAPORATION
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SEPARATOR
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RUNOFF
WASTEWATER
PROCESS
UNIT
NOT IN OPERATION
RESOURCE ENGINEERING
INVWOMKNTAl. CONSULTANTS
•TOM. «t«*f
FIGURE
SCHEMATIC OF WATER FLOW
BRIO REFINING SITE
FRIENDiWOOD, TEXAS
ONAWM |T
•H
1 OATC.
11-10-16
|mo«C
TNO.. 351-
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organics detected in the pit soils, while phenanthrene had the
highest concentration (6,670 mg/kg) of any of the base neutral
organics found in the pit soils. In the subsoils around the pits
l,1,2-trichloroethane had the highest concentration (918 mg/kg)
of any of the volatile organics found and fluoranthene had the
highest concentration (29.5 mg/kg) of the base neutral organics
detected.
Over twenty wells were installed in the shallowest aquifer (known
as the NSCZ) to test it for contamination, and five more were
drilled into the next aquifer (known as the Fifty-Foot Sand
aquifer). Table 2 shows the highest concentrations of
contaminants detected in the groundwater samples from the
site. The analyses of these samples indicates that the pits are
sources or potential sources of groundwater contamination.
In ground water samples from the NSCZ bis-(2-chloroethyl) ether
had the highest concentration (38 mg/1) of the base neutral
organic compounds detected while 1,2-dich:.;;roethane had the
highest concentration (3,580 mg/1) of volatile organics found.
The highest concentration of contaminants in the Fifty-Foot Sand
were limited to volatile organics including 1,1,2-trichloroethane
(0.02 mg/l), 1,2-dichloroethane (0.055 mg/1) and methylene
chloride (0.018 mg/1).
The most frequently detected volatile organic compounds in the
pit and subsoil samples were methylene chloride and 1,1,2-
trichloroethane. Fluoranthene and phenanthrene were the most
frequently detected base neutral organic compounds, found in pit
and subsoil compounds. The most frequently detected compound in
the groundwater samples was methylene chloride.
1.5 PILOT STUDIES
While generally available information will give an indication as
to the potential applicability of a given remedial technology,
performance of actual field tests using site-specific materials
under site-specific conditions is often the best method for
determining the appropriateness of a remedial technology. For
this reason, treatability studies were performed at the Brio
site. The studies were undertaken to obtain an in-depth analysis
of the applicability of two remedial technologies (1) infrared
incineration; and (2) solid and aqueous phase biological
treatment.
The incineration testing was performed by Shirco Infrared
Systems. In this treatability study, a pilot-scale size portable
unit was mobilized on the Brio site. Soil and material samples
from pits B, I, J and M were incinerated utilizing the infrared
process. The objectives of the test program were:
o To determine the incinerator ash chemical composition;
11
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o to demonstrate that the incinerator feed system
provide a continuous, blended feed which could be
to the furnace in a uniform manner;
o to demonstrate that the incineration system can meet the
RCRA requirement of 99.99% destruction efficiency
removal; and
o to provide design information and economic data required
to evaluate the feasibility of incinerating certain
Brio site pit wastes.
The results of the studies indicated that these objectives were
accomplished and the results are summarized below:
Incinerator Ash
All compounds detected in the feed were reduced substantially in
concentration.
Incinerator Feed System
The material processed from each pit required-preparation prior
to being place in the feed conveyer hopper. Some materials
required delumping and screening.. These results indicated that
some type of materials handling techniques would have to be
utilized during remedial action to improve the manageability
the waste.
Destruction Efficiency
Emissions sampling found that the destruction and removal
efficiency of the system was greater than 99.9997% for each of
the test conditions (differing residence times).
Design Data and Economics
The analysis concluded that using the currently available size
mobile system 45,000 tons per year could be processed at an
estimated cost of $143 per ton. Using the largest mobile system
that may be built, at the time of the study, a total o.f 67,000
tons per year could be processed at a cost of $119 per ton. The
accuracy of the cost estimate is ± 25 percent. This estimate did
not include feed excavation, preparation, interest and taxes.
A preliminary assessment of remedial technologies indicated that
biodegradation might be a suitable technology for destroying a
portion of the organic constituents present in the soil at the
Brio site. In early 1987, a solid-phase biodegradation pilot
study was initiated at the Brio site. Pit 0 was selected as
pit which could best test this hypothesis.
Ecova Corporation conducted an evaluation of the amenability of
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the organic constituents in Pit 0 to solid-phase biodegradation.
As part of this evaluation, Ecova defined the types of organic
constituents present in Pit 0 soil; defined the level of
microbial activity; demonstrated destruction of organics at a
bench-scale level; demonstrated destruction of organics using an
on-site pilot-scale application; and evaluated potential full-
scale systems capable of removing or destroying organic compounds
in contaminated material.
The results of these studies are summarized as follows:
o A solid-phase treatment process can be used for removing
or destroying the contaminants detected in Pit 0;
o the process removes organic compounds by air stripping
and destroys semi-volatile organic compounds by
biodegradation;
o although such a facility would be effective in reducing
concentrations of volatile and semi-volatile organic
compounds, the time required to treat affected materials
and soils by a solid-phase treatment process might be
unacceptably long; and
o an aqueous-phase biodegradation process would increase
the rate of removal of organic compounds.
This last point is in the process of being verified by the Brio
Site Task Force. This group of PRPs have been conducting their
own aqueous-phase biodegradation studies during late 1987/early
1988, not only to confirm the above referenced findings, but to
support their own recommendation for remedial action (as
discussed in Section V, under "Selected Remedy").
1.6 POTENTIAL IMPACTS Q£ TJifi SIZE QH HUMAN HEALTH AND
ENVIRONMENT
The assessment of risk posed by the Brio Refining site was
evaluated in the Brio Refining/Dixie Oil Processors Endangerment
Assessment. This assessment examined the amount, concentration,
properties, and environmental fate and transport of chemical
found at the site; the populations and environments potentially
at risk; exposure pathways; and potential exposure events.
EPA has concluded that the site potentially poses four major
risks to human health and the environment. These risks would
result from:
o Ingestion of contaminated soils on the site;
o direct contact with contaminated soils on site;
o inhalation of contaminated dust from the site;
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o ingestion of contaminated shallow groundwater from
the site; and
o air emissions of organic fumes from the site
(resulting from soil disturbance activities).
Many of the chemicals found on the site are carcinogens (1,1,2
trichloroethane and methylene chloride) or toxic to the central
nervous system, liver, or respiratory system (toluene and
chlorobenzene).
The populations identified as being potentially at risk are
several subdivisions, including Southbend, a junior college,
an elementary school, and a hospital. Each is located within
one-half mile of the site. The 1985 population residing within
one mile is estimated at 5,751. Approximately 71,000 people
reside within a four-mile radius.
Using a trespass exposure scenario, which "ssumed that the site
would remain a secured industrial facility, target removal and
treatment levels for selected chemicals were developed. These
target levels were based on a 10 increased cancer risk for
carcinogens and on an acceptable chronic daily intake for non-
carcinogens. The endangerment assessment also examined an
unrestricted access exposure scenario which indicated that
greater volumes of affected materials and soil would have to b
treated should exposure to the site increase.
II. ENFORCEMENT
9
Approximately 100 potential responsible parties (PRPs) have been
identified. To this group, 74, 104(e) information requests were
sent, with 28 follow-up letters. EPA received 49 responses (many
of the companies identified are no longer in business). The
Agency also sent 28 Notice Letters to these parties.
EPA will continue its enforcement activities and send Special
Notice Letters to PRPs prior to the initiation of the remedial
design. Should the PRPs decline to conduct future remedial
activities, EPA will provide funding for such activities, but
will retain its right to seek cost recovery for all EPA-funded
response actions from the above referenced PRPs.
III. COMMUNITY RELATIONS
The Brio Refining site was proposed for the National Priorities
List in October 1984. Funds were approved in the Spring of 1985
for EPA to conduct a Remedial Investigation and Feasibility Study
at the Brio site. Prior to the initiation of the studies a
of companies, identified through the Agency's enforcement
as PRPs, formed the Brio Site Task Force in an effort to work
with EPA in assessing the nature and extent of the contamination
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at the site.
On May 16, 1985, EPA announced that the terms of an
Administrative Order (signed in June 1985) had been agreed upon
with the Task Force enabling them to undertake the investigations
and studies necessary to determine the solution to the
contamination problems at the Brio site. Included in the
Administrative Order was the stipulation that, with EPA
oversight, the Task Force would initiate and implement a
comprehensive community relations program for interested
citizens. EPA representatives would also participate in the
community relations effort.
The Task Force held its first community leaders meeting on May
16, 1985, in order to discuss the Administrative Order and
present a timeframe for the site investigation. A community
meeting was held by the Task Force on July 2, 1985, to announce
the initiation of water-quality sampling and odor abatement
programs. The results of the water tests were announced at a
community meeting on September 26, 1985.
Field activities were completed in November 1985. Upon
completion of the first phase of the site investigation (and
review of the information by EPA), the Task Force held a
community meeting on April 30, 1986, to share the results of
their initial efforts. On September 4, 1986, a community meeting
was held to discuss any issues or concerns the local residents
may have regarding the site studies. Status reports were also
provided through newsletters.
On February 2, 1987, the Task Force held a community meeting on
various treatment techniques that may be employed during remedial
actions at a typical Superfund site. A community leaders meeting
was held on April 2, 1987, to provide an update on site
activities. A meeting to discuss the preliminary results of the
Endangerment Assessment was held with the community leaders on
June 18, 1987.
On January 21, 1988, EPA announced through a press release that
studies were completed on the Brio site. The announcement also
advised the public that EPA would be accepting comments on the
proposed remedy for the site from February 1 to March 1, 1988,
and that the Agency would hold a public meeting on February 9,
1988. An EPA prepared fact sheet describing various alternatives
evaluated was mailed to interested citizens. EPA held a
community leaders meeting on January 25, 1988, to brief the
members of the group on the solutions proposed for the site. On
the following night, January 26, 1988, the Brio Site Task Force
held a community meeting to discuss the overall results of the
site investigations, the findings of the Endangerment Assessment.
An EPA representative announced the scheduled public meeting to
discuss remedial alternatives. EPA's public meeting was held on
February 9, 1988, at the Weber Elementary School. Approximately
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350 people attended the meeting. The community expressed greaj
concern that remedial action would address only partial
remediation of the site. A summary of the public response t
solutions proposed by EPA at this meeting, can be found in the
Responsiveness Summary (See Appendix E). On February 22, EPA met/
with the Friendswood City Council to discuss the proposed
alternative solutions that the Agency had outlined in its public
meeting on February 9.
Again, it should be noted that EPA was an active participant in
all of the community or community leaders meetings discussed
above. These activities were carried-out in cooperation with the
Brio Site Task Force in accordance with the terms outlined in the
above mentioned Brio Refining/Dixie Oil Processors Administrative
Order on Consent.
IV. ALTERNATIVE EVALUATION
4.1 EVALUATION CRITERIA
Section I21(a), (b), and (d) of the Superfund Amendments and
Reauthorization Act (SARA) contains nine factors which EPA must
consider in selecting a remedy for a Superfund site. These items
are summarized below:
1. Consistency with Other Environmental Laws ^^
In determining appropriate remedial actions at Superfund
sites, consideration must be given to the requirements of
other Federal and State environmental laws, in addition
to CERCLA as amended by SARA. Primary consideration is
given to attaining applicable or relevant and appropriate
Federal and State public health and environmental laws
and regulations and standards. Not all Federal and state
environmental laws and regulations are applicable to each
Superfund response action. The compliance of each
remedial alternative with all applicable or relevant and
appropriate environmental laws is discussed in
Appendix C.
2. Reduction of Toxicitv. Mobility or Volume
The degree to which alternatives employ treatment that
reduces toxicity, mobility or volume must be assessed.
Relevant factors include:
o The treatment processes the proposed solutions
employed and materials they treat;
o the amount of contaminated materials that will
be destroyed or treated;
o the degree of expected reduction in toxicity,
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mobility, or volume;
o the degree to which the treatment is irreversible; and
o the residuals that will remain following treatment,
considering the persistence, toxicity, mobility, and
propensity for bio-accumulation of such hazardous
substances and their constituents.
3. Short-term Effectiveness
The short-term effectiveness of an alternative must be
assessed considering the following:
o Magnitude of reduction of existing risks; and
o short-term risks that might be posed to the community,
workers, or the environment during the implementation
of an alternative including potential threats to human
health or the environment associated with excavation,
transportation, and redisposal or containment.
4. Long-term Effectiveness and Permanence
Alternatives are assessed for the long-term effectiveness
and permanence they afford along with the degree of
certainty that the remedy will prove successful. Factors
considered are:
o Magnitude of residual risks in terms of amounts and
concentrations of wastes remaining following
implementation of a remedial action, considering the
persistence, toxicity, mobility, and propensity for
bio-accumulation of such hazardous substances and
their constituents;
o type and degree of long-term management required,
including monitoring and operation and maintenance;
o potential for exposure of human and environmental
receptors to remaining waste considering the potential
threat to human health and the environment associated
with excavation, transportation, redisposal, or
containment;
o long-term reliability of the engineering and
institutional controls, including uncertainties
associated with the land disposal of untreated wastes
and residuals; and
o potential need for replacement of the remedy.
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5. Implementabi1 i ty
The ease or difficulty of implementing the alternatives
are assessed by considering the following factors:
o Degree of difficulty associated with constructing
the solution;
o expected operational reliability of the treatment
technology;
o need to coordinate with and obtain necessary approvals
and permits (or meet the intent of any permit in the
case of Superfund actions);
o availability of necessary equipment and specialists;
and
o available capacity and location of needed treatment,
storage, and disposal services.
6. Costs
The types of costs that should be assessed include the
following:
o Capital costs;
•
o operation and maintenance costs;
o net present value of capital and operation and
maintenance cost; and
o potential future remedial action costs.
7. Cpmnuinity Acceptance
This assessment should evaluate:
o Components of remedial alternatives that the community
supports;
o features of the alternatives about which the community
has reservations; and
o elements of the alternatives which the community
strongly opposes.
8. state Acceptance (through the Texas Water Commission)
Evaluation includes assessment of:
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o Components of remedial alternatives that the State
supports ;
o features of the alternatives about which the State has
reservations; and
o elements of the alternatives which the State strongly
opposes.
9. Overall Protection of Human. Health and the Environment
Following the analysis of the remedial options against
individual evaluation criteria, the alternatives are
assessed from the standpoint of whether they provide
adequate protection of human health and the environment.
EPA is also directed by Superfund law (SARA) to give
preference to solutions that utilize treatment to remove
contaminants from the environment. Offsite transport and
disposal without treatment is the least preferred option
where practicable treatment technologies are available.
4.2 DESCRIPTION 0_f_ ALTERNATIVES . -
In conformance with the National Contingency Plan (NCP), initial
remedial approaches were screened to determine which might be
appropriate for this site (see the Brio Refining/Dixie Oil
Processors Feasibility study for details of this evaluation).
From these possible remedies, four were chosen for more detailed
evaluation and comparison with the remedy selection criteria
outlined above. Two other alternatives, No Action and Offsite
Disposal were also evaluated to comply with the requirements of
the NCP. Each remedy is summarized below, common elements of
all the plans include:
o Implementing the Site Management Plan. Areas of the
site which are not treated by one of the four remedies
would be regraded and revegetated to promote rainwater
drainage into Mud Gully and to minimize infiltration.
o Monitoring the 15 existing wells on the site. There
are ten in the shallowest aquifer (the NSCZ) and five
in the next deeper aquifer (the Fifty-Foot Sand).
o Monitoring Mud Gully in three locations for any
increased contaminated runoff.
o All the sludge in the wastewater treatment plant will
be stabilized in place and the impoundments will then
be backfilled.
o All tank contents will be removed and properly disposed,
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There will be semi-annual air monitoring of the sit
o There are two lenses of DNALP (Denser than Water Non-
Aqueous Phase Liquid) trapped on the top of the
Middle Clay Unit. The lenses are beneath pits J and
0. This liquid would be collected by two well nests
and disposed.
o Site control through the use of the existing site
security fence and the imposition of deed notices and
restrictions (if necessary).
The cost estimates provided below for each alternative do not
include the cost of dismantling the existing process facility.
The cost of this effort has been estimated to be $500,000 as
illustrated in Appendix H.
Alternative jj_ No Action All of the items summarized above as
common elements to all alternatives would .- included in this
remedy. The approximate cost of this action is $3,266,000.
Alternative jjjLi Cap and Cover This remedy consists of three main
phases. First all on-site liquids and flowable organics will be
stabilized in place. Any work which might release VOC fumes will
be done inside portable buildings connected to a fume
incinerator/scrubber. Next the pits would be closed by
constructing compacted clay caps over them. These caps would
have a venting system to trap any volatile organic compound (VOC)
fumes released later by the unstabilized materials (such as
untreated contaminated soils) in the pits. The vents will be
connected to carbon canisters to control any VOC emissions, if
necessary. The estimated cost of this alternative is
$13,333,000 (plus $500,000 for dismantling the process facility).
Alternative 3* Vault This remedy would place all affected
materials in an on-site vault. Affected materials would-be drum
contents, surface and subsurface soil contaminated at or above
action levels, and any liquids and flowable solids. Any liquids
or flowable solids will be stabilized first, and then put in the
vault. Any work which might release VOC fumes would be done in
portable building, and the fumes collected and incinerated.
After the vault was filled it would be capped and covered. As in
the Cap and cover alternative, a venting system for VOC fumes
would be installed. Tank liquids and drums with liquids would be
disposed of off site. All tanks but one would be dismantled and
buried in the vault along with all drums of solids. One tank
would be used to equalize the flow to a package wastewater
treatment plant. This plant would treat the vault's leachate.
The estimated cost of this alternative is $20,723,000 (plus
$500,000 for dismantling the process facility).
Alternative 4; Biological Treatment This remedy would use
either a solid phase or aqueous phase biological system to treat
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-1- -' '- -
.
all affected materials and soils. After treatment, the solid
residues from either process would be sufficiently decontaminated
for use as direct backfill of the areas from which they were
removed (cover soil and vegetative growth also placed in these
areas). All excavation would be enclosed in a portable structure
which would vent to a fume incinerator/scrubber system* The
estimated cost of this alternative is $22,808,000 (aqueous phase)
and $22,833,000 (solid phase - plus $800,000 for dismantling the
process facility).
*.itL«rn*^y« JLL Qn«-sifc« incineration the only difference between
this remedy and Alternative 3 is that the affected- materials
would be incinerated. The decontaminated ash would be used to
backfill the excavations. These areas would then be covered with
top soil and vegetation. The estimated cost of this alternative
is $21,958,005 to $26,098,000 (depending on the type of
incinerator used - plus $500,000 for dismantling the process
facility).
Alternately* $j. Qff-ait« Piapaaal This solution would include
excavation inside portable buildings connected to a fume
incinerator/scrubber. The -pits would then be backfilled with
clean soil. The excavated material would be placed in trucks,
specially equipped for hauling hasardous substances, and
transported to SA off-site disposal facility. The estimated cost
of this alternative is $84,283,000 (plus $500,000 for dismantling
the process facility).
QL
The degree to which the remedial alternatives meet the nine
selection criteria is contained in Table 3.' The following values
were assigned to compare remedy selection criteria:
++ Alternative would oreativ exceed a selection criterion
when compared to other alternatives.
+ Alternative would exceed a criterion in comparison
to other alternatives.
0 Alternative can be designed to meet the selection
criterion.
Special efforts will be necessary in the design of
the remedy to meet the selection criterion.
In comparison to the other remedies, these
alternatives would present most difficulty in
achieving a selection criterion.
The rational* for the ratings assigned in this table is as follows;
1. compiles vith &BAJ& (i.e. meets or exceeds
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Applicable, or Relevant and Appropriate Federal
State Requirements).
No Action is assigned a "—" because it violates the
intent of SARA Section 121 regarding the selection of
a remedy that is protective of human health and the
environment.
All other alternatives are rated "0" since they all
can be designed to meet any ARARs as discussed in
Appendix C.
2. Reduces; Toxicity. Mobility, and Volume
No Action and Off-site Disposal are rated "—"
because they do not reduce any of these parameters.
Cap and Cover was rated differently for each of these
parameters.
o Toxicity was rated "-" since none of the
organic contamination would be removed from
the site except for possible air emissions.
o Mobility was rated "0" since the plan could
be designed to meet the selection
o Volume was rated "-" since the addition of
stabilizing agents would increase the
amount of material.
Vault was rated differently for each of these parameters
o Toxicity was rated "-" since none of the
organic contamination would be removed from
the site.
o Mobility was rated "+" since the leachate
from the vault would be contained and
treated before discharge.
o Volume was rated "-" since the addition of
stabilizing agents would increase the
amount of material.
Biological Treatment and Incineration were both rated
"++" since both remedies would remove organic
components in the waste materials thus reducing all
parameters.
Short-Term Effectiveness
Off-site Disposal is rated H-M because the
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transportation of waste poses additional
environmental risks.
No Action is rated "0", but only in the short-term
(less than one year) as long as site access is
restricted and direct contact with site contaminants
is prevented.
All other alternatives were rated "0" since any
excavation or stabilization would be done in portable
buildings. These buildings would vent to a fume
incinerator, thus minimizing any VOC fume releases
during the clean up.
4. Long-Term Effectiveness and. Permanence
No Action was rated "—" because of the potential
human health and environmental risks involved in
leaving untreated wastes at a site where long-term
site control can not be insured.
The rating of "+" were given to Biological Treatment
and Incineration since these remedies would entail
the destruction of most of the'organic contamination
on the site. The Vault remedy was rated "0" and Cap
and Cover was rated "-" since they would involve more
long term monitoring and maintenance.
Off-site Disposal rated "-" due to the potential
threat involved in the long-term transport of wastes
from the site and the problems associated with
redisposal of the wastes.
5. Implementabi lity '
The Cap and Cover and Vault remedies were
rated "+" since these remedies could be easily
implemented. Biological Treatment was rated "0"
since it is more complex but is still easy to
construct and implement. Incineration was rated "-"
since it is the most complex alternative which
requires a significant amount of testing prior to
start-up. Off-site Disposal received a rating of "-"
due to potential transportation problems.
6. Cost
Estimated costs for each remedial action alternative
are summarized in Table 5. Included in this table
are total capital and present worth costs. Operation
and maintenance costs were factored into each line
item. Replacement costs have been evaluated as the
cost involved in remediation should the alternative
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fail. With the exception of No Action, the potential
for failure was determined to be greatest with t
Cap and Cover solution, since there would remain
potential for contaminants to leach from stabilized
wastes without some direct means of capturing the
leachate (as used in the Vault).
The Vault alternative would rank second to Cap and
Cover with regard for the probability of failure
because these structures have been known to leak
(over the long-term) even with the leachate
collection devices they provide. Biological
Treatment and Incineration would have the lowest
probability of failure because they would be treating
certain amounts of contaminated materials to levels
that should not cause future problems if used as
backfill for the site. However, to differing
degrees, all solutions will leave contaminated soils
on site property, therefore, a'l solutions will
include a cost for an estimated cost for corrective
action should the remedy fail. In this case, we will
assume that incineration will be the replacement
treatment and that $21 million will be the cost of
replacement.
The No Action alternative has the lowest present
worth cost of the various alternatives followed by
Cap and Cover, Vault, Biological Treatment,
Incineration and Off-site Disposal (in increasing
order of cost). The line items accounting for the
greatest cost were treatment of affected materials
and soils, air emission controls and monitoring,
groundwater treatment and monitoring, and the site
management plan. Transportation costs are the
primary reason for the vast difference in cost
between any of the on-site remedies and Off-site
Disposal.
7. Community Acceptance
Comments from local residents received at the public
meeting on February 9, 1988, and during the public
comment period have one central theme, there is
general agreement among local residents that all
measurable amounts of affected soils found on the
site should be treated. EPA has proposed to treat
only affected materials and soils that would pose a
health threat. Thus, some measurable amounts of
contaminants will remain on site, however, deed
restrictions will be imposed and site access will be
controlled. Another major concern of the public is
the potential adverse impact that this Super fund
will have on their property values and on the
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economic development of the area.
Community members have also expressed concern over
the need to widen Mud Gully (a flood control ditch
located on the western boundary of the site) to
prevent a "bottle neck" in the ditch. Additionally,
they would like to see the tanks and process
equipment dismantled as part of any remedy.
Off-site Disposal was the only solution which the
public appeared to favor, but they wanted all
measurable amounts of contaminants excavated and
disposed offsite. Therefore, all alternatives in
this Record of Decision were rated "-" due to the
lack of support from the community.
To address the concerns mentioned above, EPA will
request that any settling party (as part of the
selected remedy) investigate creative design and
landscaping ideas, in cooperation with the local
residents, that might reduce any adverse economic
impact the site might have on the area and enhance
the aesthetics of the site. Additionally, any remedy
will have to address the problem associated with Mud
Gully to the satisfaction of the local Flood Control
District and include dismantling the above ground
storage tanks and process equipment. For further
detail refer to Section V, entitled "Selected
Remedy." Further discussion concerning EPA's
response to public comments can be found in Appendix
E, "Community Relations Responsiveness Summary."
8. State Acceptance
The State (through the Texas Water commission) has
been provided an opportunity to comment on the Record
of Decision. They have indicated that they have no
objection to the proposed remedy (See Appendix G).
Therefore, on-site incineration and on-site
biological treatment have been rated "+" while all
other alternatives were rated H0".
9. Overall Protection o_f Human Health and the Environment
No Action receives a rating of "—" because it does
not provide adequate protection from the potential
risks involved with leaving untreated wastes onsite.
Off-site Disposal is rated "-" because the solution
does not utilize treatment and the problem is. merely
transferred from one location to another.
Furthermore, there is potential for exposure or
release during transportation, and most importantly
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it is the least preferred alternative where
practicable treatment technologies are available.
The Vault and Cap and Cover rated "+" because they
utilize treatment (stabilization) and do provide
overall protection of human health and the
environment. Biological Treatment and Incineration
both rated "++" because they provide the best means
of treatment (i.e., destruction of organics) and they
do provide overall protection of human health and the
environment.
4.4 OPERATION AND MAINTENANCE
The need for future operation and maintenance will be minimized
since the primary sources of contamination will be removed
through treatment. Site operation and maintenance will include a
monitoring program for sampling groundwater wells, ambient air,
and Mud Gully sediments. This sampling program will monitor the
effectiveness of the selected remedy and provide the data
necessary to trigger future corrective action, if necessary.
Additional site maintenance would include, but not necessarily be
limited to, inspections of surface vegetation,- ensuring proper
drainage, proper operation of any actions such as groundwater
treatment which may extend beyond the time required for the
source control remedy,.and periodic fence (or barrier) repair.
The details of this activity will be defined in the Operation
Maintenance Plan of the remedial design.
V. SELECTED REMEDY
Based on the information provided in the administrative record
and the results of the evaluation of alternatives (Section 4.3),
the final remedy has been selected.
It is EPA's judgment that on-site incineration of affected
materials and soils best serves both statutory and selection
criteria in relation to the other solutions evaluated in this
document. However, the Brio Site Task Force proposes the use of
aqueous-phase biological treatment. The lack of the demonstrated
performance of this technique on the affected materials and soils
at the Brio Refining site, while of concern to EPA, may not
prevent favorable consideration if the Brio Task Force can
demonstrate that aqueous-phase biological treatment can provide
the same level of treatment deemed necessary to protect public
health and the environment.
EPA has determined that if adequate demonstration is provided
prior to remedial action, the Brio Site Task Force's proposal has
the potential to provide protection of human health and the
environment comparable to the on-site incineration remedy.
this determination has been made with the understanding that
the remedy (aqueous-phase biological treatment) should fail the
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Task Force (or settling party) would have to undertake any
corrective action deemed appropriate by EPA. Pass/fail criteria
for use of biotreatment rather than incineration will be
developed prior to the start of remedial action. If biotreatment
cannot meet the pass/fail criteria, then on-site incineration
win be implemented.
The final remedy is summarized as follows:
Affected materials and soils - Shall be treated using either
incineration or biological treatment. This media shall be
defined as all contaminated sludges and liquids and waste
material found to exist a±>ove the action levels defined in the
Endangerment Assessment (EA). This will include those affected
materials and soils existing in pits B, J, H/V, E, Q, and R
(as defined in the EA). Additionally, the Remedial Investigation
identified sludges and liquids in pits F, G, I, K, L, and M;
therefore, these sludges and liquids (and any others found during
remedial action) must also be excavated an , treated. The
definition of the boundary between the sluoje/soil interface will
be determined prior to remedial action.
Excavations shall be conducted in enclosures, material
transported to the treatment unit(s), and the treated material
backfilled in the pits if it successfully passes the Toxicity
Characteristic Leaching Procedure.
Surface contamination - Attachments 8 and 9 of the Remedial
Investigation Report shall be examined and the site re-evaluated
prior to remedial action, to identify those areas where surface
seeps are visually apparent. These areas will be scraped or
excavated to remove the source of contamination and to prevent
future migration of this material. This source of contamination
will then be consolidated and treated with the affected materials
and soils.
Off-site soil contamination - Any off-site soil contamination
found during the remedial investigation, or during the remedial
action, shall be removed to background levels. This may require
that special detection limits be used for sampling efforts at the
site boundaries during the remedial action. This activity will
have to be further defined in the remedial design.
Pit fi - Further investigation into this pit area to locate
sludges or liquids may have to be done at the completion of the
remedial action due to the location of this pit beneath the
wastewater treatment surface impoundment. This activity will be
further defined in the remedial design.
Debris and rubble - There is much inert debris and rubble
remaining on the site from past operations. This material may be
consolidated and the ultimate disposition of the material
determined during the remedial design.
27
-------
h^s
- Contaminants observed in this flood control ditcl
and the "bottle neck" that exists as it passes the Brio site
been a noted concern of the EPA as well as local residents and
the Harris County Flood Control District. It is apparent that
these problems will have to be corrected as part of any remedy
that is instituted at the site. Initial thoughts would suggest a
low-maintenance approach to resolving this problem where some
type of performance standard would be set in cooperation with the
Harris County Flood Control District. Such actions shall be
further defined in the remedial design.
Wastewater treatment system - In-place stabilization of wastes
existing in the impoundments, backfill impoundments with dike
materials and other uncontaminated materials (if necessary), cap
and cover, grade to promote runoff and minimize infiltration,
install a package wastewater treatment plant or route wastewater
to a POTW. Portions of the existing wastewater treatment system
may be used during remedial action, but will be decommissioned
once the remedial action is completed.
Storage tanks and drums - Remove tank contents, decontaminate
tanks, dismantle tanks; sell dismantled tanks or transport the
tanks to an EPA approved off-site disposal facility; transport
the tank contents and drums to an EPA approved off-site disposal
facility. If any tanks are used during remedial activities, t
will be dismantled upon completion.
b^^
Process equipment - The entire process facility will be
dismantled. If any portion of the existing facility is used during
remedial activities, the structure will be dismantled upon
completion of remedial action.
Monitoring and control of migration pathways - Ambient air
sampling on a semi-annual basis; control air emissions from
treatment processes; excavate in enclosures and vent the
•enclosure to an emission control device; eliminate or control
rainfall on construction areas; sample and monitor Mud Gully
sediments; treat the groundwater in the Numerous Sand Channel
Zone to a level to be determined in the remedial design (but to
achieve treatment of the Dense Non-Aqueous Phase Liquids (DNAFLs)
to the satisfaction of EPA) monitor the groundwater for a
timeframe to be determined in the remedial design; allow natural
attenuation (no treatment) of the Fifty-Foot Sand aquifer and
monitor the groundwater in the aquifer to ensure that it is
naturally cleaning itself. Monitoring activities will be
utilized to determine the effectiveness of the actions to be
implemented and shall be detailed in the operation and
maintenance plan of the remedial design. This same data will be
evaluated during the Agency's 5-year review, in accordance with
SARA Section I2l(c), to determine if any corrective action is
necessary.
28
-------
Site management plan - Areas outside the boundaries of
excavation will be regraded and vegetated to promote drainage and
minimize infiltration. A stormwater transmission system draining
to Mud Gully will be constructed in an east/west direction across
the north and south parcels. All regrading will be covered with'
6 inches of topsoil, if necessary, to promote vegetative growth.
To the maximum extent practicable, the aesthetics of the site
(upon completion of the remedy) shall be enhanced by utilizing
creative design and landscaping techniques with input from local
residents.
Site control - This remedial action is based on permanent site
control, imposition of necessary deed notices and restrictions
(if possible), and restriction of access to the site by use of a
fence or similar barrier.
29
-------
APPENDIX A
-------
TABLE 1
HIGHEST COMPOUND CONCENTRATIONS FOR PIT SOIL AND SUBSOIL SAMPLES
Highest Concentration of
Volatile Organic Compounds
(mg/kg)
Pit Compound Pit Soil Subsoil
A Vinyl Chloride 0.074 ND
B 1,2 Dichloroethane 245,000 515
C Methylene Chloride 0.037 0.050
D 1,2 Dichloroethane 0.0245 ND
E 1,1,2 Trichloroethane 12,500 36.1
F 1,1,2 Trichloroethane 728 0.50
G Methylene Chloride 0.50 ' 0.01
'H 1,2 Dichloroethane 32,000 ND
•
I 1,1,2 Trichloroethane 3,980 ND
J 1,2 Dichloroethane 179,000 159
K Ethylbenzene 328 ND
L Methylene Chloride 392 ND
M 1,2 Dichloroethane 121 9.97
N 1,1,2 Trichloroethane 23 .1.19
O Ethylbenzene 340 ND
P 1,1,2 Trichloroethane 0.934 91.0
Q 1,1,2 Trichloroethane 65,700 472
R Ethylbenzene 588 21.1
S None Detected
T Methylene Chloride 0.19 ND
U Methylene Chloride 0.054 ND
V Methylene Chloride 1000 ND
X None Detected
-------
TABLE 1 (Cont.)
HIGHEST COMPOUND CONCENTRATIONS FOR PIT SOIL AND SUBSOIL SAMPLES
Highest Concentrations of
Base Neutral Organic Compounds
(mg/kg)
Pit Compound Pit Soil Subsoil
A Fluoranthene 0.074 16.1
B Bis (2 chloroethyl) 3,040 ND
ether
C None Detected
D None Detected
E Phenanthrene 838 "ND"
F Phenanthrene .411 ND
G Phenanthrene 91.5 ND
H Pyrene 762 ND
I Phenanthrene 6,670 ND
J Phenanthrene 2,910 ND
K Phenanthrene 740 ND
L Phenanthrene 120 ND
M Phenanthrene 62.6 ND
N Phenanthrene 111 ND
0 Phenanthrene 29 ND
P Anthracene 86.5 NO
Q Bis (2 chloroethyl) 1,810 ND
ether
R Phenanthrene 758 ND
S None Detected
T None Detected
U Phenanthrene 2.18 ND
V None Detected
X None Detected
-------
TABLE 2
ORGANIC COMPOUND CONCENTRATIONS IN THE NSCZ
Well
BMW1A
BMW2A
BMW3A
BMW4A
BMW6A
BMW7A
BMW8A
BMW9A
BMW 10A
BMW 11A
BMW 12A
BMW13A
BMW 14A
. BMW 15A
BMW 16A
BMW17A
BMW 18A
BMW 26A
BMW 27A
BMW 28A
BMW 30A
BMW31A
BMW - Brio Monitoring Well
A » Well monitors the NSCZ aquifer.
• » Only Methylene Chloride detected.
Concentration is the sum of
the concentrations of: Vinyl Chloride
Dichloroethane
Trichloroethane
Methylene Chloride
Bis (2 chloroethyl) ether
Concentration (mg/h
ND
ND
2.41
3.21
664
4165
4.89
13.2
.51
1.25
.02
829
ND
5.99
.02'
73
1756
.02*
.04
38.4
1.83
37.2
-------
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-------
TABLE 4
ESTIMATED AMOUNT OF AFFECTED MATERIALS AND SOILS
REQUIRING TREATMENT
AT THE BRIO REFINING SITE
Pit
Location
B
E
H/V
J
Q
R
Volume (cu.vd.)
6,319
7,870
15,020
11,636
16,889
5 .022
Pit
Location
F
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K
L
M
Total 62,756
Surface Contamination 0 - 50,000 cu. yd.
Volume (cu.vd.
3,918
3,759
10,415
4,478
3,176
2.333
24,320
Contaminated Liquids
Liquids in Tanks 104,225 gals.
Denser than water
non-aqueous phase liquid
--Total
66 ,000 gals.
170,225 gals.
Drums
Generated during Remedial Investigation 1,674
Generated by Past Operators 34
Generated by Pilot Studies A2
Total 1,757
-------
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-------
APPENDIX C
-------
1.7 REGULATORY COMPLIANCE
1.7.1 General Background
Section 121(d) of CERCLA, as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), describes the types of standards that a
remedial action is required to meet. Those standards must be met by any
remedial action proposed by this Feasibility Study for the Brio site. Section
121(d) mandates that the remedial action selected must be protective of public
health and the environment and the types of control in place and the levels of
the hazardous substances, pollutants, or contaminants at the site must meet
those standards, requirements, criteria, or limitations under any Federal
environmental law, or any more stringent state standard, that are "legally
applicable" or "relevant and appropriate". To obtain compliance with this
general standard, and in recognition of the USEPA " July 9, 1987 memorandum
"Interim Guidance on Compliance with Applicable and Relevant and Appropriate—'
Requirements", all remedial action plans were evaluated to determine what
standard and appropriate technologies would be adequately protective of public
health and the environment.
The universe of environmental standards and controls was reviewed to determine
which of them had a bearing on remedial action at the site, Table 1-8. The
results of that evaluation are summarized in Table 1-9 which specifies
controls and standards deemed appropriate during remediation on the basis of a
best engineering judgement evaluation.
At the completion of remediation the only standards that Bust be complied with
are those that describe the level at which a hazardous substance, pollutant or
contaminant should be found in the environment or those standards that specify
a means of controlling releases of hazardous substances, pollutants or
contaminants.
For those standards that describe a level or type of control, these
requirements need only be net if they are "legally applicable" or "relevant
and appropriate". These terms are not defined in the amended CERCLA. The
EPA's Interim Guidance defines "applicable requirements" as "those cleanup
standards, standards of control, and other substantive environmental
U-11
-------
TABLE H-8
STANDARDS, REQUIREMENTS, CRITERIA, OR LIMITATIONS EVALUATED
FOR ARARs DETERMINATION
Safe Drinking Water Act
Clean Water Act
Solid Waste Disposal Act
Occupational Safety and Health Act
Hazardous Materials Transportation Act
National Historic Preservation Act
Archeological and Historical Preservation Act
Historic Sites, Buildings and Antiquities Act
Fish and Wildlife Coordination Act
Endangered Species Act
Rivers and Harbors Act of 1899
Wilderness Act
Scenic River Act
Coastal Zone Management Act
Texas Clean Air Act
Texas Solid Waste Disposal Act
Texas Water Code
BRO/FS-FN-S4TrO6)
BRO/FS-FN-S*4Tr(l6)
-------
TABLE 4-9
STANDAflDS AND CONTROL TECHNOLOGY
UTILIZED DURING REMEDIATION AS
SPECIFIED BY BEST ENGINEERING
JUDGEMENT TO PROTECT PUBLIC HEALTH
AND THE ENVIRONMENT
A. AIR EMISSIONS
1. Excavation/stabilization performed in enclosure and air emissions
collected and routed to fume incinerator with scrubber (all
remedial options).
2. Any stockpiles of feedstock for treatment (biological or
incineration) maintained in enclosure with air emissions collected
and routed to scrubber equipped fume incinerator.
3. Biological treatment (solid or aqueous) performed in an enclosure
with air emissions collected and routed to a scrubber equipped fume
incinerator.
4. Incinerator equipped with high-temperature" secondary combustion
chamber and wet scrubber designed to meet particulate, HC1 and
destruction removal efficiency limitations specified in MO CFR Part
264, Subpart 0.
B. SURFACE AND CROUNDWATER
1. Process water and potentially contaminated stormwater collected
and routed to a package activated sludge treatment system equipped
with carbon polishing and discharged to Mud Gully or routed to a
POTW for treatment (all remedial options).
2. Discharge from package treatment system consistent with NPDES
permit limitations, and 40 CFR Part 125.
3. Any groundwater subject to treatment would be treated in the
package treatment system prior to discharge.
BRO/FS-FN-S4Tr(12)
1 Since excavation/stabilization, stockpiling and any treatment will take
place in enclosures such that potentially contaminated storowater would
not be generated, the only areas subject to stomwater collection would
be the transfer areas between pit excavation and stockpile and stockpile
and treatment.
-------
TABLE 4-9
[Continued)
C. AFFECTED SOIL AND MATERIAL
1. Compliance with substantive portions of 40 CFR Part 264, Subpart J,
relating to tanks (aqueous biological treatment), including:
a. 40 CFR § 264.191 (shell strength)
b. 40 CFR $ 264.192 (prevent overfilling)
2. Compliance with substantive portions of 40 CFR Part 264, Subpart L,
relating to covered storage piles (all remedial options),
including:
a. 40 CFR 5 264.250(c) (covered waste pile)
3. Compliance with substantive portions of "0 CFR Part 264, Subpart M,
relating to land treatment (solid phase :.odegradation), including:
a. 40 CFR § 264.273 (maximize degradation)
b. 40 CFR § 264.278 (unsaturated zone monitoring)
D. GENERAL
1. OSHA Health and Safety Regulations as provided for in 20 CFR Part
1910, Subpart H.
BRO/FS-FN-S4Tr(13)
-------
protection requirements, criteria, or limitations promulgated under Federal or
State law that specifically address a hazardous substance pollutant,
contaminant, remedial action, location or other circumstance at a CERCLA
site." The guidance also notes that to be "applicable" implies that the
remedial action or circumstance satisfy all the Jurisdictional prerequisites
of a requirement.
The Interim Guidance defines "relevant and appropriate" requirements as "those
cleanup standards, standards of control, and other substantive environmental
protection requirements, criteria, or limitations promulgated under Federal
and State law that, while not 'applicable' to a hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance at a
CERCLA site, address problems or situations sufficiently similar to those
encountered at the CEPCLA site that their use is well suited to the particular
site."
Section 121 also provides that on-site remedies are not required to obtain
Federal, State, or local permits. This permit exemption covers Federal, State
or potentially responsible party response actions being taken on site under
the authority of CERCLA Sections 104, 106 or 122. Therefore, these remedies
must comply with the substantive requirements which specify a level or means
of control, but do not need to comply with administrative and procedural
requirements associated with the permitting process. "On-site" includes the
areal extent of contamination and all suitable areas in reasonable proximity
to the contamination necessary for implementation of the response action.
ARARs must be determined on a site specific basis. Therefore, with this
general understanding of the requirements of $ 121(d), the following is an
assessment by environmental media of compliance of the proposed remedial
actions with the standards found to be either "legally applicable" or
"relevant and appropriate".
4.7.2 Air Emissions
Based on a review of all potentially applicable air emission-related
regulations and standards, the only "legally applicable or relevant and
appropriate requirement" for air emissions at the completion of remediation la
-------
specified in Section 4.01 of the Texas Clean Air Act, which provides that "no
person may cause, suffer, allow or permit the emission of air contaminants or
the performance of any activity which causes or contributes to, or which will
cause or contribute to, a condition of air pollution". "Air pollution" is
defined "as the presence in the atmosphere of one or more air contaminants or
a combination thereof, in such concentration and of such duration as are of
may tend to be injurious to or to adversely affect human health or the
environment, animal life, vegetation or property, or as to interfere with the
normal use and enjoyment of animal life, vegetation, or property."
To assure compliance with this standard, each of the proposed remedial action
plans contains provisions for semiannual ambient monitoring to verify that
site conditions existing at the completion of remediation are not causing or
contributing to a condition of air pollution. All of the remedial actions are
designed to insure .that emissions are in compliance this ARAR. Specif ic^_>*
measures to control air emissions during remediation- have been incorporated
into each remedial action plan and are outlined in Table 4-9.
•
4.7.3 Surface and Ground Water
4.7.3.1 Discharges to Surface Water
Mud Cully runs through the site and will be impacted from both point and non-
point sources of water discharges from the site. The point sources will
/
consist of water generated by remedial activities as well as storm water
flows. At the completion of remediation, there will be no point source
discharge.
However, at the completion of remediation Hud Cully may be impacted by a non-
point source discharge, namely ground water flow from the NSCZ. The only
standards that could be "legally applicable or relevant and appropriate" to
discharges from the NSCZ would be state' water quality standards or federal
water quality criteria.
State water quality standards are the legally enforceable counterpart to
federal water quality criteria. In Texas, the state water quality standards
are set forth in Chapters 319 and 333, of the rules and regulations of the
4-43
-------
Texas Water Conr.ission. Those standards establish certain numerical criteria
which are legally applicable to Mud Gully. All remedial action plans satisfy
the requirements of 31 TAG §§3^9.21 - 29, 333.17 - .19 for the discharge of
water from the NSC2 to Mud Gully.
While these requirements are ARARs, those portions of the state's standards
and the federal water quality criteria that relate to use of surface waters as
a source of drinking water (because the surface water directly supplies water
to a public drinking water supply system or recharges an aquifer used for that
purpose) are not applicable or relevant and appropriate, because Hud Gully
does not supply water to a potable water supply system nor does it recharge an
aquifer used for that purpose.
4.7.3.2 Ground Water
The EPA's ground water protection strategy is based on the "differential-—'
protection" of ground water (i.e., ground water protection as it relates to a
specific classification of an aquifer). Under the strategy ground waters are
classified as follows:
«
• Class I - ground waters that are highly vulnerable and
either an irreplaceable source of drinking water or
ecologically vital;
• Class II - ground water currently used or potentially
available for drinking water or other beneficial use;
and
• Class III - ground waters are not a potential source of
drinking water and of limited beneficial use.
For Class I and Class II ground waters MCLs established under The Safe
Drinking Water Act would be applicable for ground water which qualifies as a
public water system or a community water system. MCLs aay also be relevant
and appropriate to ground water that would not currently qualify as such
systems but could potential so qualify in the future. Similarly, where the
State has established drinking water standards are more stringent than the
Federal MCL, these may be applicable or relevant and appropriate.
-------
There are two water-bearing zones underlying the site which appear to have
been impacted by on-site activities. The uppermost zone is the NSCZ. The
next zone, which is separated from the NSCZ by an aquitard referred to as the
Middle Clay Unit, is the Fifty-Foot Sand. As discussed in this FS, the NSCZ
is neither an existing nor potential drinking water supply because of the poor
yield of that zone and therefore is a Class III aquifer under the EPA
Groundwater Protection Strategy. As such MCLs are neither applicable nor are
they relevant and appropriate to the NSCZ. As outlined above, however, NSCZ
ground water quality will be maintained such that its discharge does not
represent a threat to aquatic life in Mud Gully.
While the Fifty-Foot Sand might be a "potential" drinking water source,
demograpnic data, land use, and projected water supply plans for the area
clearly indicate that this aquifer is not likely to be used for drinking water
supply purposes.
Even if it is used as a drinking water supply it is not likely to serve as a
public water system or even a community water system. Therefore, MCLs would
not* be legally applicable to the Fifty-Foot sand. However, because of its
status as a potential drinking water source these standards may be considered
•
relevant. Given that any potential use is unlikely in the near future, and
indeed may never occur, immediate application of MCL is not appropriate.
Instead, it is more appropriate to monitor this zone and let natural
attenuation, which will eventually allow any affected ground water in the
Fifty-Foot Sand to achieve MCL levels, take its course since there is not
current or projected threat of exposure. Furthermore, any subsequent
application of MCLs would apply to concentrations at the point of use and not
at the source.
U.7.U Affected Material and Soils
The primary standards of criteria that could be legally applicable to the
storage, treatment or disposal of affected material and soils are those
developed under the authority of RCRA. RCRA requirements would be "legally
applicable" to "hazardous waste" which includes: (1) wastes which exhibit one
of four characteristics (ignitability, reactivity, corrosivity, or toxicity)
or (2) are listed in the RCRA regulations as hazardous waste or (3) are
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TABLE U-10
BRIO/DOP APPLICABLE OR
RELEVANT AND APPROPRIATE REQUIREMENTS
1.- Section M.01 of Texas Clean Air Act (applicable).
2. Sections 329.U1-.U9, 333.17-.19 of Chapter 31 of Texas Administrative
Code Relating to State Water Quality Standards as applied to Mud Gully
(applicable).
3. Federal Water Quality Criteria for Fresh Water Aquatic Life Protection
as applied to Mud Gully (relevant and appropriate).
4. Safe Drinking Water Act Primary and Secondary Maximum Contaminant
Levels (MCLs) as applied to Fifty-Foot Sand (relevant and appropriate).
5. RCRA requirements contained in MO CFR, Part 264, consisting of the
following (by remedial action plan) (relevant and appropriate).
a. Car and Cover (40 CFR Part 264, Subpart N}
(1) Eliminate Free Liquids.
(2) Stabilize to a bearing capacity sufficient to support final
cover.
(3) Cover designed to:
(a) provide long term minimization of migration of liquids
through closed area;
(b) function with minimum maintenance;
(c) promote drainage and minimize erosion;
(d) accommodate settling and subsidence so that cover
integrity maintained; and
(e) have a permeability less than or equal to permeability of
my bottom liner system or natural subsoil.
(4) Post-Closure Designed to:
(a) maintain integrity and effectiveness of cover;
(b) maintain groundwater monitoring system;
BRO/FS-FN-S4Tr(1H)
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TABLE 4-10
(Continued)
(c) prevent run-on and run-off from eroding or otherwise
damaging final cover; and
(d) prevent disturbance of cover.
b. Vault (40 CFR Part 264, Subpart N)
(1) Constructed with two liners and a leachate collection system.
(2) Lower liner at least 3 feet thick constructed of recompacted
clay with a permeability of no more than 1 x 10"' cm/a.
(3) Maintain a run-on control system to prevent flow into active
portion of landfill.
(U) Maintain a run-off control system tc -allect and control water
volume from active portions resulting from a 24-hour, 100 year
storm.
(5) Manage wind dispersal of particulates.
(6) Stabilize materials sufficiently such that no free liquids are
placed into vault.
(7) Cap construction consistent with 5a, above.
(8) Post-closure consistent with 5a, above.
6. RCRA requirements contained in 40 CFR Parts 262 and 263 to the extent
that a remedial alternative involves off-site transportation of
materials (applicable). Additionally, 49 CFR Parts 107, 174-177
relating to Hazardous Materials Transportation would be applicable.
7. RCRA requirements contained in 40 CFR Part 264, Subpart B, related to
general facility standards (applicable), consisting of:
a. 40 CFR $ 264.14 (site security).
b. 40 CFR $ 264.17 (incompatible waste).
8. RCRA requirements contained in 40 CFR Part 265, Subpart G (relevant and
appropriate), consisting of:
a. 40 CFR $ 264.114 (equipment decontamination).
b. 40 CFR $ 264.117 (monitoring).
9. Executive Order 11988 - Flood Plain Management
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Additionally, all remedial action plans that involve the off site transport
for disposal would be managed in a manner consistent with UO CFR Part 262,
including disposal at a RCRA approved facility.
JJ.7.5 Land Ban Requirements
Waste banned pursuant to the Hazardous and Solid Waste Amendments of 1984
(HSWA) cannot be placed in or on the land unless they have been first treated
to levels achieving by best demonstrated available technology (BOAT) for each
hazardous constituent in the waste. "Placement" triggers the land disposal
requirements and this only occurs when disposal occurs. Therefore, for
placement to occur, hazardous waste must be picked-up and moved across the
boundary of RCRA "unit area of contamination". Applying this definition to
the Brio/DOP sites, it is clear that "placement" does not occur when waste is
consolidated within an area of contamination, capped in place (including
grading prior to capping) or treated in-situ.
Therefore, since the Brio/DOP sites are each considered an "area of
contamination", for the reasons discussed above, "placement" does not occur
during any of the proposed remedial actions. Therefore, the land disposal
requirement is not "applicable" nor is it considered "relevant and
appropriate".
J4.8 SUMMARY OF DETAILED ANALYSIS
M.8.1 Introduction
At this stage, remedial investigations and endangeroent assessment of the
Brio/DOP site have been completed. Utilizing data developed in the RI and
SRI, the EA concluded that existing conditions at the Brio/DOP site do not in
and of themselves represent unacceptable risks to public health and the
environment. The EA further concluded that exposure scenarios reflecting
reasonably anticipated future changes to site conditions can be developed
which, were they to occur, would result in unacceptable risks to human health
and the environment. The identified areas containing Materials that exceed
the cleanup levels developed in the EA include materials and soils in Pits B,
E, J, Q and H/V. The exposures of concern include long tern inhalation of
volatilized compound from these areas or direct ingestion of these affected
soils and materials.
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To remediate these affected areas, four surviving remedial action plans were
refined in the beginning of this chapter (Section 4.3). Each plan was t
evaluated in relation to its technical feasibility (Section 4.4),
effectiveness in achieving health and environmental goals (Section 4.5), cost
(Section 4.6) and regulatory compliance (Section 4.7). The purpose of this
section is to summarize the results of these earlier analyses.
4.8.2 Cap and Cover
Technical Evaluation - Stabilization followed by cap
and cover is a feasible and commonly practiced remedial
approach. It is applicable, practical and proven.
Some long term monitoring and maintenance of cap
conditions would be required.
Public Health Environmental Evaluation - Stabilization,
cap and cover and venting will isolate affected soils
from human contact. Cap and cover in combination with
the site management plan will minimize the potential
for migration via infiltration or runoff. Cap and
cover in combination with long term venting system will
eliminate potential air emissions.
Regulatory Compliance - Cap and cover complies with all
legally applicable or relevant and appropriate federal
and state standards, requirements, criteria or
limitations.
Cost -.Total cost of cap and cover is $13,481,000. Net
present cost of cap and cover is $11,700,000. Cap and
cover is the most cost effective remedial action plan.
4-48
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Vault
• Technical Evaluation - The vault is a feasible and
readily constructable remedial approach. Equipment
manpower and materials for vault construction are
readily available. Some uncertainty regarding the
effectiveness of stabilization remains. Some long-term
maintenance would be required.
• Public Health/Environmental Evaluation -Stabilization
and vaulting of affected soils and materials will
isolate the materials from direct human contact. Vault
construction in combination with the site management
plan will minimize the potential for migration via
infiltration or runoff. The secure cap and cover
installed on the vault will eliminate potential air
emissions.
• Regulatory Compliance - Stabilization and vaulting of
affected soils and materials complies with all legally
applicable or relevant and appropriate federal and
stare standards, requirements, criteria or limitations.
• Cost - Total vault costs are $20,871,000. Net present
costs of the vault are $17,300,000.
.8.4 Biological Treatment
Technical Evaluation - Biological destruction of
organic compounds is applicable, practical, and
proven. Field testing on site specific materials has
yielded further positive results for degradation of
PNAs and removal of volatiles. Basic process
configurations- (solid or aqueous phase) are easily
constructable and implementable.
Public Health/Environmental Evaluation - Biological
treatment of affected soils and Materials will
significantly reduce constituent concentrations for
both PNAs and volatiles. This destructive technology
will result in the production of soils that can be
backfilled to the pit areas with no need for further
treatment effectively eliminating the ingestion and
runoff issues. Cap and cover on other site areas will
further isolate materials from potential contact or
transport.
Regulatory Compliance - Biological treatment compiles
with all legally applicable or relevant and appropriate
federal and state standards, requirements, criteria or
limitations. Further substantial reductions in
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mobility, toxicity and volume of affected soils and
materials are achieved.
Cost - Total costs for biological treatment are
$22,956,000 (aqueous phase) and $22,981,000 (solid
phase). Net present costs are $19,920,000 (aqueous
phase) and $19,930,000 (solid phase).
4.8.5 Incineration
• Technical Evaluation - Destruction of organic compounds
through incineration is applicable and a proven
technology for remediation of affected soils and
materials. Field testing of high temperature
incineration on site specific soils indicated
successful destruction of organic constituents.
Mobile/transportable incinerators are available from
various vendors. Application of incineration, however,
will be more complex than other alternatives.
• Public Health/Environmental Evaluation - Incineration
will eliminate potential public health/environmental
impacts by elimination of organic compounds in affected
soils and materials. Air emissions would be controlled
with conventional scrubber technology. Constituent
destruction eliminates future concerns regarding
ingestion, inhalation and off site transport. Cap and
cover on other site areas will further isolate
materials on site from potential contact or transport.
• Regulatory Compliance - Incineration complies with all
legally applicable or relevant and appropriate federal
and state standards, requirements, criteria or
limitations. Further, substantial reductions in
mobility, toxicity and volume of affected soils and
materials are achieved.
• Cost - Total costs for incineration are $22,271,000
(Rotary Kiln) and $22,131.000 (Infrared). Net present
costs are $21,780,000 (Rotary Kiln) and $17,540,000
(Infrared).
M.S. 6 Comparative Evaluation
All remedial action plans are technically imp lenient able and construe table.
Both aqueous phase and solid phase biological treatment systems will be acre
complex to implement than the containment options (cap and cover and vault)
because of the fact that complete nodular units are not available.
U-50
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the process itself is not complex. All technologies are field-proven although
certainty concerning performance is variable.
All remedial action plans achieve compliance with the specified remedial
objectives. The containment options isolate affected materials and soils from
human contact. While subject to prior stabilization, affected soils and
materials remain on site in the cap and cover and vault alternatives. The
treatment alternatives (biological and incineration) reduce or destroy organic
constituents down to trace levels to the extent that future concerns regarding
inhalation, ingestion or off site transport are eliminated.
All remedial action plans achieve compliance will all legally applicable or
relevant and appropriate federal and state standards, requirements, criteria
or limitations. Both treatment options achieve an additional reduction in
mobility, toxicity and volume of affected soils and materials.
Cap and cover is the most cost effective containment options. The treatment
option costs are essentially equivalent given the accuracy of the cost
estimation.
Table 4-11 summarizes this comparison of alternatives.
BRO/FS-R3-S4
4-51
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APPENDIX D
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APPENDIX E
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BRIO REFINING SITE
SOUTHEAST HARRIS COUNTY, TEXAS
RESPONSIVENESS SUMMARY
This community relations responsiveness summary is divided into
two sections:
SECTION I: BACKGROUND OJJ COMMUNITY INVOLVEMENT Aiffi CONCERN
This section provides a brief history of community
interest and concern raised during the planning
activities at the Brio Refining Superfund site.
Section II: SUMMARY QF MAJOR COMMENTS RECEIVED DURING T_H£ PUBLIC
COMMENT PERIOD AND THE EPA'S RESPONSE IP THE COMMENTS
Both written and oral comments are presented. EPA's
responses to these relevant topi"~ are also
presented.
I. BACKGROUND QN COMMUNITY INVOLVEMENT
The Brio Refining site was proposed for the. National Priorities
List in October 1984. Funds were approved in the Spring of 1985
for EPA to conduct a Remedial Investigation and Feasibility Study
at the Brio site. Prior to the initiation of the studies a group
of companies, identified through the Agency's enforcement efforts
as potentially responsible parties (PRPs), formed the Brio Site
Task Force in an effort to work with EPA in assessing the nature
and extent of the contamination at the site.
On May 16, 1985, EPA announced that the terms of an
Administrative Order (signed in June 1985) had been agreed upon
with the Task Force enabling them to undertake the investigations
and studies necessary to determine the solution to the
contamination problems at the Brio site. Included in the '
Administrative Order was the stipulation that, with EPA
oversight, the Task Force would initiate and implement a
comprehensive community relations program for interested
citizens. EPA representatives would also participate in and
conduct oversight on the community relations effort.
The Task Force held its first community leaders meeting on May
16, 1985, in order to discuss the Administrative Order and
present a timeframe for the site investigation. A community
meeting was held by the Task Force on July 2, 1985, to announce
the initiation of water-quality sampling and odor abatement
programs. The results of the water tests were announced at a
community meeting on September 26, 1985.
Field activities were completed in November 1985. Upon
completion of the first phase of the site investigation (and
review of the information by EPA) , the Task Force held a
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community meeting on April 30, 1986, to share the results of
their initial efforts. On September 4, 1986, a community meetin
was held to discuss any issues or concerns the local residents
may have regarding the site studies. Status reports were also
provided through newsletters.
On February 2, 1987, the Task Force held a community meeting on
various treatment techniques that may be employed during remedial
actions at a typical Superfund site. A community leaders meeting
was held on April 2, 1987, to provide an update on site
activities. A meeting to discuss the preliminary results of the
Endangerment Assessment was held with the community leaders on
June 18, 1987.
On January 21, 1988, EPA announced through a press release that
studies were completed on the Brio site. The announcement also
advised the public that EPA would be accepting comments on the
proposed remedy for the site from February 1 to March 1, 1988,
and that the Agency would hold a public meeting on February 9,
1988. An EPA prepared fact sheet describing various alternatives
evaluated was mailed to interested citizens. EPA held a
community leaders meeting on January 25, 1988, to brief the
members of the group on the solutions proposed for the site. On
the following night, January 26, 1988, the Brio Site Task Force
held a community meeting to discuss the overall results of the
site investigations, the findings of the Endangerment Assessment.
An .EPA representative attended and announced the scheduled publ
meeting to discuss remedial alternatives. EPA's public meeting
was held on February 9, 1988, at the Weber Elementary School.
Approximately 350 people attended the meeting. The* community
voiced great concern that the remedial action would not be
complete. A summary of the public response to the solutions
proposed by EPA at this meeting, can be found in the
Responsiveness Summary (Appendix E). On February 22, EPA met
with the Friendswood city Council to discuss the proposed
alternative solutions that the Agency had outlined in its public
meeting on February 9.
Again, It should be noted that EPA was an active participant in
all of the community or community leaders meetings discussed
above and provided oversight on a comprehensive program. These
activities were carried-out in cooperation with the Brio Site
Task Force in accordance with the terms outlined in the above
mentioned Brio Refining/Dixie Oil Processors Administrative Order
on Consent.
II. SUMMARY Q_F_ PUBLIC COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND AGENCY RESPONSES
The public comment period on the Feasibility Study for the Brio
Refining Superfund site opened on February 1, 1988 and closed on
March 1, 1988. A public meeting was held February 9, 1988, at
the Weber Elementary School with approximately 350 people in
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attendance. The EPA received many comments regarding all aspects
of the Superfund actions taken at this site. This Responsiveness
Summary is written to summarize the publics response to EPA's
proposal for remediation at the Brio Refining and Dixie Oil
Processors sites. Therefore, the Agency has focused its
attention on summarizing and responding only comments concerning
the Brio Refining and Dixie Oil Processors Feasibility Study and
the remedial alternatives being evaluated. This summary is
provided below:
Comment 1
EPA misrepresented what was meant by "cleanup" of the site (i.e.,
partial versus complete treatment).
EPA Response to Comment 1
The EPA agrees that, in general, the term "cleanup" is misused in
certain situations. However, the Agency's representatives for
this particular site have been very careful as to not mislead the
local residents during the many public meetings that have been
held throughout the past few years. Experience has shown us that
very few sites are ever returned to a naturally "clean" state;
therefore, we are very careful about the message that we
communicate to the public. It is our opinion that this
misconception is a result of the publics own belief that an
eventual remedial action would mean treating all measurable
amounts of contaminated materials and soils enabling the site to
be used for commercial or recreational purposes.
Comment 2
The proposed remedy does not provide maximum health protection to
nearby residences, schools, and hospitals.
EPA' Response to Comment 2.
It is EPA's opinion that the proposed remedy provides what EPA
considers to be adequate protection of human health and the
environment. This message is discussed in great detail in the
Brio Refining and Dixie Oil Processors Endangerment Assessment.
This document provided EPA with the information necessary to make
this determination. Additionally, the calculations made in the
assessment are very conservative thus providing the Agency with
added certainty for protection of public health.
EPA has proposed to excavate and treat all affected materials and
soils that have a potential for creating an unacceptable risk to
human health or the environment. Once this activity is
completed, site controls will be enforced to restrict access to
the site thus reducing the probability of exposure to any low
level contaminants that may remain upon completion of
remediation.
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Comment 1
The deed restrictions and restricted access associated with the
proposed remedy win promote a negative perception of the
community and win adversely affect property values.
EPA Response to Comment 1
EPA in conducting its environmental mandate, must balance a large
number of factors before determining the best approach to
addressing problems at Superfund sites. The Superfund Amendments
and Reauthorization Act (SARA) specifies that EPA shall
"... select a remedial action that is protective of human health
and the environment ..." The statute also states that EPA shall
"... select appropriate remedial actions determined to be
necessary to be carried out ... which provide for cost-effective
response." These laws are developed by our c vernmental leaders
and EPA must use them as a guide in conductir.* its business.
EPA believes that the proposed plan of action at the Brio and
Dixie Oil Processors (OOP) sites comply to the maximum extent
practicable, with the provisions of SARA. The first priority of
the Agency is the protection of human health and the environment
and the proposed solutions serve this purpose very well. An
increased degree of treatment at either site would result in very,
little added protection relative to the incremental increase in
cost that would result. Furthermore, the appearance of the sites
upon completion of the remedial action is a consideration of the
final Record of Decision. Appearance will also be a factor in
all discussions on conducting and funding of remedial actions by
potentially responsible parties. It is believed that the parties
will be interested in investigating, in concert with local
homeowners, various creative landscaping ideas that will result
in an acceptable solution.
Implementing solutions which account for local property values
and economic development is outside the jurisdiction of EPA.
Local residents have the State courts available to them to
resolve these issues or they can request that their State
government intervene on their behalf. State governments have the
opportunity to request for and pay the additional costs
attributed to meeting any such standard they may deem necessary.
This would include a request for treating all measurable
quantities of waste at a Superfund site. Additionally, the State
would then become a signatory to the Consent Decree and actively
participate in negotiations, the remedial design, and remedial
action.
Comment A
Bioremediation should be evaluated further as a potential
at the site.
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EPA Response £o Comment 4.
It is EPA's judgment that on-site incineration of wastes would
best serve both statutory and selection criteria in relation to
the other solutions evaluated. On the other hand, the Brio
Site Task Force has proposed the use of on-site aqueous-phase
biological treatment. The EPA had some concerns over the lack
of demonstrated performance of this technique on the wastes at
the site. However, this win not prevent EPA from favorably
considering the proposal of the Task Force if they can
demonstrate that biological treatment can provide the same
level of treatment deemed necessary by the Agency. Pass/fail
criteria for use of biological treatment rather than
incineration will be developed prior to the start of remedial
action. If biological treatment cannot meet the pass/fail
criteria, then on-site incineration will be implemented.
Comment 5.
On-site incineration is not a practical alternative given the
lengthiness of its treatment.
EPA Response to Comment i
The'six alternatives evaluated in the Brio Refining and Dixie Oil
Processors Feasibility Study and there associated remedial action
(actual construction) time requirements arc as follows:
No Action
Cap & Cover
Vault
Incineration
Biotreatment
Offsite Disposal
- +30
2
3
- 3-4
- 3.3
4
years
years
years
years
years
years
All of these plans assume that 62,000 cubic yards of contaminated
soils will be treated and site controls are implemented. As you can
see there is not a great deal of difference in the length of
actual construction time involved in any of the alternatives with
the exception of No Action which would involve sampling 'and
monitoring for an indefinite time.
Comment &
Complete incineration of waste would allow productive use of the
land — athletic fields or other similar use after it is
completed.
EPA Response to Comment £.
See EPA's response to comments tl and t3.
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Comment 7.
Given the current restricted access of the site, the Mud Gully
must be widened to allow the flood control system in the South
Belt area to work properly.
EPA Response ££ Comment
The EPA shares the same concern as the commenters with regard to
Mud Gully. This problem is addressed in the Record of Decision
for both the Brio Refining and Dixie Oil Processors sites. As
part of any solution, some type of low maintenance approach to
resolving the problem, in cooperation with the Harris County
Flood Control District, will be implemented.
Comment £
There is great concern about the lack of plans to dismantle and
remove all storage facilities.
EPA Response to Comment
Based on the public response to this situation, as part of any
remedy, all storage tanks, surface vessels, drums, and process
equipment will be dismantled and either sold ( after proper
decontamination) or disposed according to EPA regulations.
Comment 2.
The ash from the incinerator is going to be harmful to our
health.
EPA Response to Comment 9_ /
If. incineration is used for treatment of affected materials and
soils all of the ash resulting from the thermal treatment
operations will have to pass specific tests before it would be
allowed to be placed back into the ground. These tests will
provide EPA with the confidence that this material will not
result in a future problem. Additionally, this material will
remain onsite and site access will be restricted.
Additionally, our incineration tests showed us that we could
achieve a 99.997% reduction in contaminants. These results
suggest that minimal amounts of contamination, if any, will
remain after treatment.
Comment 10
Identify the methods of control for odors in the incineration
process.
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EPA Response to Comment 10
The most likely cause of odors during the remedial action would
result from volatile contaminants being released during
excavation activities. As outlined in the Brio Refining and
Dixie Oil Processors Feasibility Study, all excavations (during
the construction of the solution) will be performed in portable
enclosures. The enclosures will trap the volatile compounds.
The air in the enclosures will then be treated to remove these
compounds. This practice should reduce, to the maximum extent
practicable, any odors resulting from soil disturbance
activities.
Comment li
Describe the regulations and standards that will be in place
after the cleanup is completed that will ensure the protection of
the publics health and safety.
EPA Response to Comment 1.1
This remedial action is based on permanent site controls. This
will include the imposition of deed notices and restrictions to
ensure that the site is never used in such a way as to increase
exposure to contaminants that will remain on site and a security
fence or similar barrier will be maintained to prevent trespass
and potential exposure to contaminants left onsite.
In addition to these activities, the ambient air, groundwater and
Mud Gully sediments will be sampled and monitored to provide
information for evaluation of the effectiveness of the solution.
This program will be conducted indefinitely or until such time
that EPA feels that such efforts are no longer necessary. Also
any remedial action where EPA leaves contaminants at the site
(upon completion of the remedy), the Agency must review such
actions no less than five years after the initiation of such
remedial action to assure that human health and the environment
are being protected.
Comment 12
In screening the remedial alternatives, the offsite disposal
option was quickly dismissed in the Feasibility Study. This
conclusion is not reached in a logical and well documented
manner.
EPA Response to Comment 12
The Superfund law, specifically SARA Section 121 (b) state that
"... offsite transport and disposal of hazardous substances or
contaminated materials without such treatment should be the least
favored alternative remedial action where practicable treatment
technologies are available ... shall conduct an assessment of
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permanent solutions and alternative technologies ... that, in
whole or in part, will result in a permanent and significant
decrease in toxicity, mobility, or volume of hazardous substances
dismissal of.Offsite Disposal as a viable alternative.
Comment 1J
It was suggested that the estimates in the Feasibility Study for
waste volumes of the on-site pits were ball-park figures; heavily
contaminated areas could have been missed by soil borings; the
shallow groundwater contamination was not well defined; and the
cost analysis lacked sufficient support.
EPA^ Response to. Comment jj
The EPA feels that the field work conducted as part of the
Remedial Investigation and Supplemental Investigation was more
than sufficient to characterize the magnitude and extent of
contamination. This effort will be further refined during the
actual remedial action where all contaminated sludges and liquids
will be excavated and treated. The Feasibility Study identified
pits B, J, Q, R, H/V, and E as needing remediation based on the
findings of the Endangerment Assessment. As part of the Record
of Decision pits F, G, I, K, L, and M will require examination
during remedial action for removal of all sludges and liquids.
Additionally, all surface contamination (in the form of tars)
will be scraped and consolidated for treatment. Regarding the
comment on cost estimates, the Feasibility Study contained
sufficient information to evaluate each conceptual design.
Comment 14
Some comments were received concerning the question of off-site
contamination which originated from the Brio Refining site.
EPA Response to Comment J.4
This information has been turned over to EPA's Site Assessment
section for further investigation. Those individuals who have
commented in this fashion will be contacted by this group
following their evaluation of the matter.
Comment 15
Explain what pits will be excavated.
EPA Response to Commejit J,5
See EPA's response to Comment f!3.
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APPENDIX F
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APPENDIX G
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TEXAS WATER COMMISSION
P»ul Hopfcini, Chairman fV 7^ &9 J ° Hti>dl G«n«ral Counse!
John O. Houchins, Commu$T>r
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APPENDIX H
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RIMCO DISMANTLING 1331 Lomar, Suite U59
Houston, Texas 77010
713/739-0388
August 2, 1985
Brio Task-Force
0. £. Gonjchinietz
c/o Monsanto Company
P.O. Box 711
Alvin, Texas 77511
Gentlemen:
The following costs are for the cleaning and dismantling of the Brio Refinery Inc. site 05
requested by Mr. Donald E. Ganschinietz:
• -
I_A. $90,000.00 Flushing and Steam Cleaning Ref^ery Area
1B. $220,000,00 Dismantle Refinery Area.
• 7.J-
2A. $40,000.00 Flushing and Steam Cleaning Dixie Chemical Area.
2B. $60,000*00 Dismantle Dixie Chemical Area.
•3. $50,000.00 Dismantle Site Building.
4. $38,000.00 All Other Equipment On Site.
5. $150,000.00 Remove All Concrete.
6. Revenue Sharing Plan 70% for Contractor
N 30% for Brio Task Force
7. Decontamination Work: Cost Plus
10% Overhead
20% Profit '
Thank you for the opportunity to estimate this work.
•
Very truly yours,
J. R. Brown
JRB:oh
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