%EPA
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-88/040
September 1988
Superfund
Record of Decision:
1
i
Sol Lynn/ Indutrial Transformers,TX
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REPORT DOCUMENTATION i- «EP°«T NO. 2.
pAQE EP A/ROD/ RO 6 -8 8/0 40
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
1 First Remedial Action - Final
^k Author(s)
1 9. Performing Organization Name and Address
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
3. Recipient's Accession No.
5. Report Oat. Q9/23/BQ
6.
8. Performing Organization Rept. No
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words.) , , j . , c- ^ -,
Trie Sol Lynn site, also known as Industrial Transformers site, is located in Houston,
Texas. The area around the three-quarter-acre site is a mix of residential, commercial,
and light, industrial facilities. Approximately 2,000 residents and 100,000 other people
move within a one-mile radius of the site on a daily basis due to recreational
activities associated with the area. The site operated as an electrical transformer
salvage and recycling company between 1971 and 1978, and as a chemical recycling and
supply company from 1979 through 1980. The first documented investigation of this site
ook place during the fall of 1971 when the City of Houston Water Pollution Control
ivision noted that workers at Industrial Transformers poured oil out of electrical
transformers onto the ground during transformer dismantling. In 1981, strong odors
originating from the site were brought to the attention of the Texas Department of Water
Resources, the predecessor agency of the Texas Water Commission (TWC). Upon inspection,
approximately 75 drums were found scattered about the property. Most of the drums,
labeled "trichloroethylene", were empty and had puncture holes. A technical assessment
of the site, commencing in January 1986, indicated the presence of PCB contamination.
PCB contamination has been confined to the top two feet of soil. The highest
concentrations of PCBs were found in the middle of the site. TCE has migrated deeper
(See Attached Sheet)
Sol Lynn/Industrial Transformer, TX
First Remedial Action - Final
Contaminated Media: gw
Key Contaminants: TCE
b. Identlfien/Open-Ended Terms
c. COSATI Field/Group
Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
50
22. Price
(See ANSI-Z39.18)
See Instruct/on* on Reverse
OPTIONAL FORM 272 (4-77
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R06-83/040
Sol Lynn/Industrial Transformers, TX
Second Remedial Action - Final
16. ABSTRACT (continued)
than the P'^Bs and away from the site. Residual TCE remaining in the surface soil will
be remediated along with the PCB contaminated soils. Any TCE that has migrated into th-
deeper ground water will be addressed in the second operable unit. The primary
contaminants of concern affecting the soil are PCBs.
The selected remedial action for this site includes: excavation of approximately
2,400 yd-3 of PCB-contamir^ted soil and treatment using alkali metal polyethylene
glycolate (APEG) complex dechlorination with onsite disposal of treatment residuals;
effectiveness verification of the dechlorination process through treatability studies;
and pretreatment of liquid by-pro<.".ucts, if necessary, with discharge into a publicly
owned treatment works facility. The estimated present worth cost for this remedial
action is 52,200,000.
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RECORD OF DECISON
FOR
INDUSTRIAL TRANSFORMER SITE
PHASE II
Houston
Harris County, Texas
September 1988
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TABLE OF CONTENTS
I. Declaration by Regional Administrator
II. Decision Summary
A. Site Location and Description 1
Site History
Geology
Remedial Investigation Results
Potential Impacts of the Site on
Human Health and the Environment
B. Enforcement 9
C. Community Relations History 9
D. Evaluation 10
Evaluation Criteria
Description of Alternatives
E. Recommended Remedy 22
III. Attachments
A. Administrative Record Index
B. Community Relations and Responsiveness Summary
C. TWC Letter of Agreement
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LIST OF FIGURES
Figure Page
1 Site Location 2
2 Location of Shallow Monitoring Wells
and Sample Concentration 5
3 Plume Outline in Shallow Zone 6
4 Location of Second Zone Monitoring Wells 8
and Sample Concentrations
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LIST OF TABLES
TABLE PAGE
1 Evaluation of Alternatives 17
2 Applicable or Relevant and 18
Appropriate Federal and
State Laws
3 Cost 21
4 Sensitivity Analysis 23
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DECLARATION OF
RECORD OF DECISION
SITE NAME AND LOCATION
Industrial Transformers Site
Houston, Texas
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the
Industrial Transformers site in Houston, Texas, developed 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 the National Contingency Plan (40 CFR Part 300).
This decision is based on the administrative record for this site. The
attached index identifies the items which comprise the administrative record
upon which the selection of the remedial action is based.
DESCRIPTION OF THE REMEDY
This operable unit is the final action of two operable units for the
site. This operable unit addresses the groundwater contamination. The
remedy addresses the principal threat at the site by treating the
contaminated groundwater and reducing the risks associated with exposure
to the contaminated water. The first operable unit at this site involves
remediation of the contaminated soil.
The major components of the selected groundwater remedy include:
-- Pump and treat, via air stripping, approximately 12 million gallons of
groundwater which exceeds the primary drinking water standard for TCE.
A carbon unit will be used to filter the exhaust air if it does not
meet Texas Air Quality Criteria.
The treated groundwater will be disposed in a sanitary sewer or pumped
back into the waterbearing zone.
DECLARATION
The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable, or relevant
and appropriate to the remedial action, and is cost-effective. This remedy
satisfies the statutory preference for remedies that employ treatment
that reduces toxicity, mobility or volume as a principal element and
utilizes permanent solutions and alternative treatment (or resource
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recovery) technologies to the maximum extent'practicable. Because this
remedy will not result in hazardous substances remaining onsite above
health-based levels, the five year facility review will not apply to this
action.
The State of Texas has been consulted and supports this remedial decision.
Date ' Robert E. Layton Jr.P.E.
Regional Administrator
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Summary of Remedial Alternatives Selection for the
Sol Lynn/Industrial Transformer Site,
Operable Unit II, Houston, Texas
SITE LOCATION AND DESCRIPTION
The Sol Lynn Superfund site, which is approximately three quarters of an
acre in size, (also known as Industrial Transformers (IT)) is located in
Houston, Texas. As shown in Figure 1, the site is located just south of
1-610 and west of Highway 288. There are two buildings on site which
house four retail businesses. The area around the site is a mix of
residential, commercial and light industrial facilities. The light
industrial and commercial business areas are located directly to the east
and south of the site. Astroworld and Astrodome are approximately 3,000
feet to the northwest of the site and a mix of private, single and multi-
family dwellings are approximately 4,000 feet to the north. The residential
population 'in the area is about 2,000 and a maximum daily traffic of
100,000 persons may move within a one mile radius due to recreational
activities associated with the Astrodome and Astroworld.
Surface drainage around the site include shallow ditches that border the
site along Knight and Mansard Streets. These two ditches carry surface
runoff by slightly different routes to Braes Bayou, which empties into
Buffalo Bayou then into the San Jacinto River. The San Jacinto River
ultimately flows into Galveston Bay. The site is above the 100-year
flood plain.
SITE HISTORY
The Industrial Transformer site is the location of a former electrical
transformer salvage and recycler company which operated between 1971 and
1978. A chemical recycling and supply company subsequently operated at
the same location from 1979 through 1980.
The first documented investigation of this site took place during the fall
of 1971 when the City of Houston Water Pollution Control Division noted
that workers at the Industrial Transformer Company poured oil out of
electrical transformers onto the ground as they were being dismantled.
In 1981, strong odors originating from the site were brought to the
attention of the Texas Department of Water Resources, the predecessor
agency of the Texas Water Commission (TWC). Upon inspection it was
revealed that approximately 75 drums were scattered about the property.
Most of the drums, labeled "trichloroethylene", were empty and had puncture
.,noles.
In October 1984 the site was proposed for inclusion on the National
Priorities List. In September 1985, the TWC entered into a Cooperative
Agreement with the Environmental Protection Agency (EPA) to conduct the
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FIGURE 1
INDUSTRIAL TRANSFORMERS SITE
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Remedial Investigation/Feasibility Study (RI/FS) at the site. Utilizing
funds from this cooperative agreement, the TWC contracted with Radian
Corporation on June 30, 1986, for a technical assessment of the site.
In an effort to address the contamination in an expeditious manner, the
site was broken down into parts called operable units. The first operable
unit addressed soil contamination in the Phase I remedial investigation
and feasibility study. The results of this investigation indicated poly-
chlorinated biphenols (PCBs) are isolated in the upper two feet of soil
at concentrations to 350 ppm. Trichloroethene (TCE) was also found in
the soil in concentrations below the health criterion of 160 ppm. Chemical
Dechlorinization was selected as the soil remedy. The remedy selection
is documented in the Record of Decision dated March 25, 1988.
This summary only examines potential remedial alternatives'for the ground-
water operable unit, Phase II.
GEOLOGY
Surface soils at the site and in the vicinity are of the Lake Charles
series. These soils are characterized by somewhat poor drainage and high
available water capacity. When the soil is dry, deep, wide cracks form
on the surface where water can enter rapidly. When the soil is wet the
cracks are sealed and water infiltrates slowly.
Below the surface soil is Beaumont Clay, which is of Pleistocene age.
The lithology of the Beaumont Clay is comprised of unconsolidated clays
and muds or deposits of clayey sands and silts. The clays and muds were
deposited as interdistributary, abandoned channel fill, overbank fluvial
or mud-filled coastal lake or tidal creek muds. The sands and silts
represent alluvium, levee and crevasse splays.
The uppermost aquifer is encountered at a depth of 30-34 feet below ground
surface. This particular aquifer is a water-bearing sand that varies in
thickness from 2 feet to 6 feet, averaging 4 and 1/2 feet. Sand content
increases from west to east across the site, from 50 percent to 70 percent.
Water levels taken at monitoring wells in uppermost zone indicate that the
groundwater flows to the northwest.
The uppermost water-bearing sand is separated from the next lower, or
"second", water-bearing sand by a stiff clay, approximately 45 to 52 feet
thick. The second water-bearing sand is underlain by clay. Water levels
^taken at monitoring wells in the second zone indicate that the groundwater
"-flows to the west.
These aquifers are not used as drinking water supplies. However, these
aquifers have the potential to be drinking water sources, Therefore, they
are Class IIB aquifers in the EPA groundwater classification system.
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'The major aquifers in the Houston area are the Chicot and Evangeline.
These aquifers supplement surface water in supplying the City with drinking
water. In the vicinity of the site the shallowest well for the City of
Houston is screened at 670 feet below the surface.
REMEDIAL INVESTIGATION RESULTS
During the Remedial Investigation (RI) groundwater samples were collected
using monitoring wells and cone penetrameter to determine the nature and
extent of contamination in the groundwater. Soil samples were also
collected as the monitoring wells were installed.
Because information collected previously by TWC indicated the primary
contaminants at the site were polychlorinated biphenyls (PCBs) and
trichloroethylene (TCE), the emphasis for analytical testing was placed
on determining the vertical and areal extent of these contaminants. PCBs
were known to adsorb tightly to soils and were not expected to infiltrate
into the groundwater. The phase I remedial investigation results verified
this, as PCBs were only found in the upper two feet of soil. In addition,
the leaching of PCBs into the groundwater would not be expected and
accordingly, groundwater sampling did not show any PCB contamination. On
the other hand, TCE does not adhere tightly to the soils but will tend to
migrate through the soil. TCE is also quite soluble in water. This
indicates that the potential for TCE to leach into groundwater is high.
Groundwater sampling results indicate that this is the case.
The groundwater was sampled by two different methods. The first method
involved withdrawing water samples from installed monitoring wells. Water
samples were collected twice from six monitoring wells screened in the
uppermost water-bearing zone and analyzed for TCE. The locations of
the wells and TCE concentrations for both sampling events are shown on
Figure 2.
In the second method, a cone penetrometer was advanced into the uppermost
water-bearing sand. A well-screen tip was substituted for the tip of the
cone penetrometer and at a selected depth the sampling sleeve was pulled
up to expose the screen. Twenty samples were obtained and analyzed for
TCE from this method. The cone penetrometer was only used in the upper-
most aquifer.
The results from both methods indicate the highest concentration of TCE
in the groundwater Is directly below the island between the South Loop West
feeder street and South Loop West.
Figure 3 shows contour lines of TCE in the uppermost water-bearing zone
using both the monitoring well water samples and the cone penetrometer
samples. This illustration indicates the plume extends to the north-
northwest.
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Three monitoring wells which were installed in the second water-bearing zone,
were sampled twice. The concentrations of TCE from both sampling events
and the location of the wells are illustrated in Figure 4. Although
these three wells cannot identify the extent of the plume or the volume
of contaminated water in this zone they do indicate: (a) that the TCE has
penetrated down to this water-bearing zone; and (b) that the flow gradient
of this zone is to the west.
Deep soil samples were taken during the installation of monitoring well
#10. These samples were taken at two-foot intervals. The analytical
results indicate that TCE contamination was found as deep as 101 feet.
The highest concentration of TCE in the soil was 600 ppm obtained in a
sample taken at a depth of 18-20 feet. Based on laboratory studies, soil
above the water table will contribute TCE to the groundwater by two
mechanisms. First, as groundwater is pumped from the upper water-bearing zone,
water in the soil above the water table will be drawn into the aquifer.
TCE in the soil will be released in the water-bearing zone as the ground-
water is pumped. Second, TCE will also reach the water table as rainwater
percolates through the soil. Because it is quite soluble and will not
tend to adsorb to the soil particles of the aquifer, TCE is expected to
be quite mobile once it reaches the groundwater, increasing the size of
the plume.
The general water quality was also determined in this investigation. The
analytical results revealed that there are up to 3670 mg/1 of dissolved
solids in the upper aquifer and up to 1650 mg/1 In the second aquifer.
Suspended solids are visually noted in both aquifers. While the suspended
and dissolved solids are high in both aquifers they are still within the
potential drinking water range. The EPA identifies a potential drinking
water source as having less than 10,000 mg/1 dissolved solids. These
aquifers could be classified as Class IIB aquifers. They are not currently
used as a resource, but could be used as a future supplemental source of
water.
These observations indicate the following:
o TCE contamination is observed in the soil on site from the surface
to a depth of 101 feet;
o TCE contaminates both the uppermost and the second water-bearing
zones. The highest concentrations of TCE (790 ppm; cone penetrometer
number 13) in the uppermost aquifer was observed off site underneath
the median strip between 1-610 South Loop West and the southern
feeder street. The volume of contaminated water in the uppermost
aquifer is estimated at 3.2 million gallons;
o Although a volume cannot be defined for the second water-bearing
zone because of the westerly gradient; it appears the Phase II
investigation has identified the northern boundary of the plume.
Further definition of the plume will be required in the remedial
design portion of this project.
o TCE is the only identfied contaminant in the groundwater.
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Potential Impacts of the Site on Human Health and the Environment
As part of the remedial investigation, an assessment of the health threat
created by the current site conditions was conducted. Factors included
in this risk assessment were the identified target receptors, the maximum
concentrations of TCE, and the degree of exposure to the hazards from the
site. Target receptors identified in the assessment included anyone who
utilizes or comes in contact with the contaminated groundwater.
The results of the risk assessment indicate that the highest concentration
of TCE found in the groundwater presents greater than a 10"^ (one in ten)
lifetime cancer risk. This level represents the threat that would be
posed by the site conditions if no remedy were implemented and the groundwater
utilized. This assessment assumes a 70 kg person consumes 2 liters of
contaminated water each day. The major pathways of exposure are inhalation
and ingestion.
Levels of cleanup are based on a comparison of the contaminant concentration
found at the site to either 1) existing health based standards or criteria;
or 2) concentrations that would represent a 10 to 10 lifetime cancer
risk. Because a standard exists, it is not necessary to calculate a
concentration representing the risk range. The health-based criterion
for TCE in contaminated water is .005 mg/1 (Safe Drinking Water Act of
December 1974 as amended in 1986).
II. ENFORCEMENT
The goal of the EPA is to have those parties responsible for contamination
of the site perform the cleanup. There are two identified potentially
responsible parties (PRPs) for the IT site. These parties will be given
the opportunity to conduct or participate in the remedial action selected
for the site. If they refuse, EPA may order the parties to perform the
remedial design and if they continue to refuse, proceed against them
for cost recovery after EPA has funded and implemented the proposed remedy.
III. COMMUNITY RELATIONS HISTORY
The Industrial Transformer Superfund site was proposed for the National
Priorities List (NPL) in October 1984. In February 1985 the U.S.
Environmental Protection Agency (EPA) and the Texas Water Commission
(TWC) held a public meeting in Houston for residents near the site to
discuss site conditions and the Superfund Program/Process. Approximately
15 people attended the meeting. On October 3, 1985, EPA issued a news
release announcing that funds to study the site had been awarded to the
TWC.
Initiation of studies on the Industrial Transformer site was announced by
TWC at a public meeting in Houston on September 24, 1986. Evaluation of
the site was divided into two separate studies: 1) surface soil contamination;
2) groundwater contamination. The study addressing surface soil contamination
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IV.
10
was completed in December 1987. On January 21, 1988, EPA announced to
the public via a news release that a public meeting would be held on
February 2, 1988, to discuss the proposed remedy for surface contamination
at the site.
An EPA prepared fact sheet which described alternative remedial actions
for the soil contamination along with the EPA preferred alternative was
sent to the interested and affected public shortly after the public
meeting was announced. EPA and TWC conducted the 7:00 p.m. public meeting
at the Astro Village Hotel on February 2, 1988. Approximately 35 people
attended the public meeting.
On August 8, 1988, a news release announced that a public comment period
on the groundwater study would begin on August 10, 1988, and end on
September 9, 1988. The news release also announced that a public meeting
would be held on August 25, 1988, at the Astro Village Hotel, Houston, Texas
An EPA prepared fact sheet describing the alternative remedial actions for
the groundwater study along with the EPA preferred alternative was sent
to the site mailing list shortly after the meeting and comment period was
announced. EPA and TWC conducted the 7:00 p.m. public meeting on August 25,
1988. Approximately 15 people attended the meeting. Only two
questions were asked and no comments were made during the public meeting.
Further details on community relations are contained in Attachment B.
EVALUATION
A. Evaluation Criteria
1. SARA Requirements - Section 121(a) through (f) of SARA contains three
factors which EPA must consider in selecting a remedy.
a. Protection of Human Health and the Environment
The alternative must provide adequate protection of human health
and the environment.
b. Cost Effectiveness
Cost effectiveness includes an evaluation of the following criteria:
i. 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:
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magnitude of residual risks in terms of amounts and concen-
trations of waste remaining following implementation of a
remedial action, considering the persistence, toxicity,
mobility, and propensity to bioaccumulate of such hazardous
substances and their constituents;
type and degree of long-term management required, including
monitoring and operation maintenance;
long-term reliability of the engineering and institutional
controls, including uncertainties associated with land
disposal of untreated wastes and residuals.
ii . Short-term Effectiveness
The short-term effectiveness of alternatives must be assessed
considering appropriate factors among the following:
0 magnitude of reduction of existing risks;
short-term risks that might be posed to the community,
workers, or the environment during implementation of an
alternative including potential threats to human health
and the environment associated with evacuation, trans-
portation, and redisposal or containment;
0 time until full protection is achieved;
potential need for replacement remedy;
potential for exposure of human and the environmental
receptors for remaining waste considering the potential
threat to human health and the environment associated
with excavation, transportation, redisposal or containment.
iii. Implementability
The ease or difficulty of implementing the alternatives are
assessed by considering the following types of factors:
degree of difficulty associated with constructing the
technology;
expected operational reliability of the technology;
need to coordinate with and obtain necessary approvals and
permits (e.g. NPDES, Dredge and Fill Permits for off-site
actions) from other offices and agencies;
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availability of necessary equipment and specialists;
0 available capacity and location of needed treatment,
storage, and disposal services;
compatibility with existing future land use;
need to respond to other sites.
iv. Cost
The types of costs that should be assessed include the following:
t capital cost;
operational and maintenance costs;
cost of five-year reviews, where required;
net present value of capital and O&M costs;
potential future remedial action costs.
c. Compliance with Applicable or Relevant and Appropriate Federal
and State Regulations
In determining appropriate remedial actions at Superfund sites,
consideration must be given to the requirements of other Federal
and State laws. Alternatives should be assessed as to whether
they attain legally applicable or relevant and appropriate require-
ments of other Federal and State public health environmental laws.
Requirements under Federal and State laws that specifically address
the circumstances at a Superfund site are considered applicable.
Relevant and appropriate requirements, while not applicable to a
Superfund site, address situations which are sufficiently similar
to those existing at the site.
2. SARA Preferences. The EPA is also directed by SARA to give preference
to remedial actions which reduce the toxicity, mobility or volume of the
waste. Relevant factors are:
the treatment processes the remedies employ and materials
they will treat;
the amount of hazardous material that will be destroyed
or treated;
the degree of expected reduction in toxicity, mobility, or
volume;
the degree to which the treatment is irreversible;
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the residuals that will remain following treatment, considering
the persistence, toxicity, mobility, and propensity for
bioaccumulation of such hazardous substances and their
constituents.
3. EPA Guioelines. It is EPA policy to consider other factors in selection
of a remedy.These include:
a. Community Reaction
This assessment should look at:
components of the alternatives which the community supports;
features of the alternatives about which the community has
reservations;
elements of the alternatives which the community strongly
opposes.
b. State Acceptance
Evaluation factors include assessments of:
components of the alternatives the State supports;
features of the alternatives about which the State has
reservations;
elements of the alternatives- under consideration that the
State strongly opposes.
B. Description of Alternatives
In accordance with the NCR, an initial set of remedial approaches were
screened to determine whether they might be appropriate for this site.
From these possible remedies, five remedial alternatives were chosen for
more detailed evaluation and comparison with the remedy selection criteria
outlined above. Two discharge alternatives are also identified.
All the action alternatives include pumping the contaminated groundwater
to the surface. The recovery system consists of placing a number of
wells on and around the site and extracting the groundwater. For cost
estimating purposes it was assumed that ten wells would be installed 30
feet deep. These wells would pump a total of 3500 gallons per day. The
recovery system will extract the 3.2 million gallons of contaminated
groundwater currently estimated at the site. An additional volume of
groundwater will be pumped and treated as TCE is released from the soil
particles in the water-bearing zones. Water percolating through the
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unsaturated zone will also add to the total volume of groundwater to be
treated. The total volume may approach 12 million gallons of water from
the upper waterbearing zone. This recovery system will require approximately^
10 years to remove 12 million gallons of water.
Alternative 1, No Action - No additional remedial actions would be conducted.
The selected soil remedy would be conducted without treatment of the con-
taminated groundwater. However, annual environmental monitoring would be
required to assess the horizontal and vertical migration of the TCE. In
addition, a review to occur every five years would be budgeted into
the total costs. A five year review is necessary on any site if wastes
above health-based levels remain at the site. The present worth of this
alternative is estimated to be $400,000.
Alternative 2 - Collection and Off site Deep Well Injection - This alternative
requires that the contaminated groundwater would be pumped and stored in
tanks on site. The water would then be shipped via a vacuum tank truck
to a deep well injection facility in compliance with EPA regulations.
The deep well facility would provide injection, isolation and monitoring
of the contaminated water. Generally, these facilities will use deep
clay and shale formations to confine the waste. In the Gulf Coast region,
the injection depths for these wells typically range from 7,000 to 8,000
feet.
The site would be monitored during and after remediation for evaluation
of the effectiveness of the alternative.
This alternative is not a treatment alternative and therefore does not
destroy the TCE. Deep well injection would provide measures for permanent
isolation and containment of the contaminated groundwater. This alternative
is estimated to cost $4.8 million.
Alternative 3 - Collection, On site Carbon Adsorption and Discharge - In
this alternative the contaminated water would be pumped, as previously
described, to a storage tank where the solids would be settled. From
this settling tank the water would be piped to a carbon adsorption system.
The most applicable carbon adsorption unit is the downflow fixed dual
bed granular activated carbon adsorption system. Water would flow, by
gravity, down through the column and the TCE would bind to adsorption
sites on the activated carbon. Once the adsorption sites became filled
with contaminants, the carbon will need to be replaced or regenerated.
The treated water will be tested. If the TCE levels are below the discharge
criterion, the water will be discharged using one of the options discussed
below. If the concentrations are above the criterion, the water will run
through the secondary carbon bed for polishing.
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The spent carbon from the adsorption would be shipped off site for regener-
ation or disposal. The settled solids in the settling tank will be
periodically cleaned out and analyzed for TCE. If the solids do not contain
TCE they will be shipped off site. If they do contain TCE they will be
air stripped and then shipped off site.
This alternative will require a treatability study to select the carbon
and design the system. However, this is a routine study and easily done.
This alternative does not destroy TCE, however, it does reduce the volume
of TCE contaminated material and would remove the contaminants from the
groundwater, concentrating them on the activated carbon which would be
disposed in accordance with appropriate regulations. This alternative is
estimated to cost $1.8 million.
Alternative 4 - Collection, On site Air Stripping and Discharge - In
this alternative the recovery wells will discharge into settling tanks.
The water would then be pumped to an air stripping system.
The counter-current packed tower configuration has been chosen for its
effectiveness and adaptability. Air stripping works by pushing air
through the contaminated water forcing the volatile chemical contaminants
such as TCE to mix with the air and evaporate.
As with Alternative 3, the treated water will be sampled. If it meets
the established criterion it will be discharged, if not it will be run
through the system again.
The air emissions will be monitored to ensure that there is no threat to
human health and the environment. If the air meets all emission standards
it will be released into the atmosphere. If it does not meet the emission
standards an activated carbon unit will be added to the air stripper. This
will be determined during the design portion of the site remediation.
A treatability study will be required to provide design parameters for
the air stripping tower. However, this is a routine study and easily
performed.
This alternative does not destroy TCE but will remove it from the water
and concentrate it on activated carbon. The TCE may be destroyed during
the disposal or regeneration of the carbon. The present worth of this
alternative is estimated at $2.2 million.
Alternative 5 - Collection, On site Catalytic Dehydrochlorination and Discharge
As with the previous two alternatives, the water is withdrawn and stored in a
settling tank.
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The contaminated water will be pumped into a batch dehydrochlorination
reactor. This alternative will destroy the TCE through a chemical reaction,
removing the chlorine atoms from the TCE molecule. The residuals from
this reaction would include off-gas and brine, both of which could require
additional treatment or disposal. A carbon adsorption column will be
used for the treatment of the gases. The brine will be stored and shipped
off-site for disposal via deep well injection.
A treatability study would be performed prior to implementation of this
alternative to determine reactor size, flow rate and other design parameters,
The estimated present worth of this alternative is $6.3 million.
After the cleanup criteria are met, two discharge options will be considered
for Alternatives 3,4, and 5. These are (a) reinjection and (b) discharging
into publicly owned treatment works (POTW). Reinjection involves pumping
the treated water back into the water bearing zone. This option may
increase the recovery rate of the contaminated water. Discharging into a
treatment plant would require obtaining permission from the City of
Houston Public Works Department and TWC before releasing the treated
water into the wastewater system. This option would also require that
the standards of the National Pollution Discharge Elimination System
(NPDES) be met. Reinjection is estimated to cost $93,650 and discharging
into a POTW is estimated to cost $212,860.
Evaluation of Alternatives
An evaluation of the alternatives is shown on Table 1. The following
values were assigned to compare remedial selection criteria:
+ Alternative would exceed a criterion in comparison to other alternatives.
0 Alternative can be designed to meet the selection criterion.
- In comparison to other remedies, this alternative will present difficulty
in achieving a selection criterion.
1. Complies with ARARs - (meets or exceeds Applicable, or Relevant and
Appropriate Federal and State Requirements.) Table 2 delineates the
Federal and State statutes which are applicable or relevant and
appropriate (ARARs). In all instances where the regulation is
considered applicable or relevant and appropriate, those requirements
will be met. The maximum contaminant level (MCL) for TCE is considered
the appropriate cleanup criteria because these are considered Class
IIB aquifers.
2. Reduces Toxicity, Mobility and Volume - The "No Action" alternatives
was rated 0 in reducing toxicity and mobility because it does nothing
to reduce these parameters. The volume will continue to increase as
the plume spreads. Therefore, it was rated "-" for volume reduction.
Natural flushing will occur; however, due to the low transmissivity
it will take generations as compared with a decade using any of the
other alternative. Deep well injection was rated "0" for toxicity
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20
and volume reduction because it does nothing to reduce these parameters.
Deep well injection does reduce the mobility of waste, however, not
as permanently as the three treatment alternatives; therefore, it
rated a "0" for mobility reduction. The three other alternatives all
rated a "+" for toxicity, volume and mobility reduction because they
removed the hazardous compound from the site and reduced the volume.
In the ultimate disposal of the by-products the TCE may be destroyed
(i.e., through the incineration of the carbon).
3. Short Term Effectiveness - The "No action" was rated "-" in relation
to all other treatment alternatives because of the relative differences
in time between the natural flushing action of the aquifer versus the
pumping associated with the other alternatives; however, since no one
is using this aquifer it does not pose a short-term health risk.
Deep well injection rated a "0" because it requires transporting the
wastes off site which may pose a threat to the community or the
environment during implementation of the alternative if a spill
occurred. The other pumping alternatives rated "+" because they pose
little threat to the community and the environment and they return
the aquifer to a potentially useable water source in a short time
compared to the "No Action" alternative.
4. Long Term Effectiveness - "No Action" does nothing to remediate the
effect of the contamination on site; therefore, it was rated a "-".
The action alternatives do alleviate the health threat and return
the aquifer to useable water source. Therefore, they all rated a "+".
5. Implementability - The "No Action" and air stripping alternatives are.
. the most easily implementable alternatives, therefore, they rated a
"+". Deep well injection may be more difficult to implement because
the possibility exists that a deep well injection facility may not be
available to receive all of the fluid withdrawn over the life of the
remedy. For this reason deep well injection rated a "0". Carbon
adsorption is well proven and generally easily implemented. However,
the groundwater has an abundance of dissolved solids which may decrease
the life of the carbon, therefore, it rated a "0". Catalytic Dehydro-
chlorination is an innovative technology and will require a more
extensive treatability study than the other alternatives. Specialists
will be needed to set up and run the treatability studies and teach
the operators about the system, so it was also rated "0".
6. Cost - Estimated costs for each remedial action alternative are
summarized on Table 3. Included in this table are capital
costs, annual operations and maintenance cost, present worth of
operation and maintenance cost and total present worth.
Because the plume in the second water bearing zone is not defined, a
sensitivity analysis was performed relating the volume of water to
cost. Scenario A assumes ten wells would be installed. Each well
would pump 350 gallons per day for ten years (12 million gallons).
Scenario B assumes 50 wells will be installed, with each well pumping
-------
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-------
22
at a rate of 350 gallons/day over a ten year period (64 million
gallons). As the volume of water pumped increases, the cost per
gallon decreases for carbon adsorption and air stripping. Air
stripping becomes the most cost effective.
The results of the sensitivity analysis are summarized on
Table 4.
7. Community Reaction - The public comment period began August 10, 1988,
and ended September 10, 1988. The meeting was held August 24. Two
comments were received during the public meeting and several throughout
the comment period. All the comments and the Agency's responses are
provided in Attachment B.
8. State Acceptance - The State of Texas has been consulted and
supports this remedy.
9. Overall Protection of Human Health and the Environment - All pumping
alternatives can potentially reduce groundwater contamination and
thereby be protective of human health and the environment, therefore
they rated a."+" while the "No Action" was rated a "-" because it
does nothing to protect human health and the environment.
RECOMMENDED REMEDY: Air Stripping
Treatability studies will be conducted during the design phase of the
project. Additional hydrogeological studies will also be conducted during
the design stage to define the extent of the plume in the second water-
bearing zone. The contaminated groundwater will be recovered and the
suspended solids allowed to settle. The water will be pumped into a
packed air column, sprayed onto the packing coming in contact with the
air. The TCE will evaporate as it comes in contact with the air. The
air will be monitored as it is released out of the column. If the released
air does not meet Texas Air Control Board air quality criteria, a carbon
adsorption unit will be added to the air stripping column. After the
concentration of TCE in the water is reduced below .005 ppm, the water
will be discharged into the Houston sanitary sewer system or reinjected
into the water-bearing zones.
The groundwater will be sampled and analyzed while the remedy is in
operation. EPA anticipates that the concentration of TCE in the
recovered groundwater will decrease over time. Should the sampling
results indicate that the concentration of TCE is not decreasing, the
feasibility of achieving the remedial criteria in a reasonable period
of time and the possibility of revising or terminating the remedial
action will be evaluated.
Rationale
As previously stated, based on the information available to evaluate the
five remedial options against these nine criteria, the EPA has concluded
that Alternative 4, Air Stripping, is the Agency's preferred alternative.
-------
TABLE 4
SENSITIVITY ANALYSIS OF ALTERNATIVES
PRESENT WORTH COSTS
SCENARIO
ALTERNATIVE
1. No Action
2. Deep Well Injection
3. Carbon Adsorption
4. Air Stripping
5. Catalytic Dehydro-
chlorination
A
$411,248
$4,789,955
$1,885,424
$2,204,890
$6,332,267
B.
$411,248
$20,960,117
$3,951,900
$3,077,547
$14,001,398
23
-------
24
This alternative is more easily implemented than carbon adsorption
because of the dissolved solids in the aquifer. There will also be less
materials handling required for the air stripping alternative than the
carbon adsorption alternative. This alternative is protective of human
health and the environment, attains all applicable or relevant and appropriate
Federal and State requirements and is cost-effective. This alternative
also satisfies SARA's preference for a remedy which employs treatment as
the principal element to reduce toxicity, mobility, or volume.
Operation and Maintenance (O&M)
The site will be monitored during and after remediation for evaluation of
effectiveness of the alternative. The monitoring will be accomplished by
sampling the groundwater on a selected interval and analyzing for TCE to
determine if remediation is continuing as planned.
Future Actions
No future actions are anticipated for the groundwater. The selected remedial
action will afford a high degree of permanence.
-------
Tentative Remedial Action Schedule
Approval Remedial Action (Sign ROD) September 1988
Complete Enforcement Negotiation Febuary 1989
Award Cooperative Agreement Amendment
for Design of Approved Remedy September 1989
Start Design September 1989
Complete Design October 1990
Award Remedial Cooperative November 1990
Agreement Amendment for Construction
of Approved Remedy
Start Construction May 1991
Complete Remediation July 2001
-------
ATTACHMENT A
-------
SITE NAMEi
SITE NUMBER.
ADMINISTRATIVE RECORD INDEX
ADDENDUM
Sol Lynn Phase II
TXD 980873327
DOCUMENT NUMBER:
DOCUMENT DATEi
NUMBER OF PAGES:
AUTHOR
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE.
DOCUMENT TITLE:
123
02/02/88
001
Arthur Talley
Texas Water Commission
Sherry Fuerst, U.S. EPA Region VI
Record of Communication
Acccess agreement for groundwater sample
for Sol Lynn
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
124
03/30/88
001
Sharon E. Fuerst, Regional Project Manager
U.S. EPA Region VI
Robert Rountree, Texas Water Commission
Correspondence
Transmittal of EPA's final comments for the
Industrial Transformer Remedial
Investigation and Feasibility Study Reports
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
.*
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
125
04/04/88
014
Carl R. Hickam, R.S., Senior Regional
Representative
Agency for Toxic Substance and Disease
Registry/ROHR-Region VI
Carl Edlund, Chief, Superfund Program
Branch
Correspondence and Attachment
Draft Health Assessment for the Industrial
Transformers site; provides findings and
recommendations regarding public health
issues and or concerns for this site and
adjacent areas
A-l
-------
SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
Sol Lynn Phase II
TXD 980873327
DOCUMENT NUMBER:
DOCUMENT DATE.
NUMBER OF PAGES:
AUTHORt
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
126
04/06/88
001
Robin Gelston-Walls, Texas State
Coordinator, State Programs Section
U.S. EPA Region VI
David H. Sorrells, Texas Water Commission
Correspondence w/o referenced enclosures
Transmittal of signed copies of Record of
Decisions, including the Industrial
Transformer/Sol Lynn site
DOCUMENT NUMBER«
DOCUMENT DATE.
NUMBER OF PAGES:
AUTHOR.
COMPANY/AGENCY:.
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
127
04/07/88
002
John Fleeter for Robert E. Layton Jr.,
P.E., Regional Administrator
U.S. EPA Region VI
Honorable Martin Frost, Member, United
States House of Representatives
Correspondence
Explanation of involvement of Sol Lynn
DOCUMENT NUMBER:
DOCUMENT DATE.
NUMBER OF PAGES.
AUTHOR:
COMPANY/AGENCY.
RECIPIENT.
DOCUMENT TYPE.
DOCUMENT TITLE.
128
04/14/88
001
Greg Tipple for David H. Sorrells, P.E.,
Chief,"Superfund Section, Hazardous and
Solid Waste Div.
Texas Water Commission
Lawrence M. Kagan, Kagan-Edelman
Enterprises
Correspondence
Industrial Transformer Superfund Site;
request that the right-of-entry to property
for access to monitoring well not be
terminated
A-2
-------
SITE NAME:
SITE NUMBER.
ADMINISTRATIVE RECORD INDEX
ADDENDUM
Sol Lynn Phase II
TXD 980873327
DOCUMENT NUMBERt
DOCUMENT DATE i
NUMBER OF PAGES.
AUTHORi
COMPANY/AGENCY:
RECIPIENT.
DOCUMENT TYPEi
DOCUMENT TITLE:
129
04/15/88
001
Julie T. Cadogan
U.S. EPA Region VI
Sherry Fuerst, U.S. EPA Region VI
Record of Communication
Air Stripper regulations
DOCUMENT NUMBER.
DOCUMENT DATE.
NUMBER OF PAGES.
AUTHORi
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT
DOCUMENT
TYPE.
TITLE.
13C
04/26/88
001
Robert Rountree, Remedial Investigation
Unit, Superfund Section, Hazardous and
Solid Waste Division
Texas Water Commission
Thomas W. Hoskings, Ph.D., P.E., Department
Head, Radian Corporation
Correspondence
Confirmation of conversation on 04/15/88
which discussed the Objective and Criteria
for the Industrial Transformer site
DOCUMENT NUMBER:
DOCUMENT DATE.
NUMBER OF PAGES;
AUTHOR:
COMPANY/AGENCY.
RECIPIENT:
DOCUMENT
DOCUMENT
TYPE:
TITLE.
131
05/24/88
003
Carl E. Edlund, Chief, Superfund Program
Branch
U.S. EPA Region VI
Carl Hickam, RS, Senior Regional
Representative, ATSDR/ROHR-Region VI
Memorandum and Attachment
Comments on Draft Health Assessment for the
Industrial Transformers Site
A-3
-------
SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
Sol Lynn Phase II
TXD 980873327
DOCUMENT NUMBER.
DOCUMENT DATE:
NUMBER OF PAGES<
AUTHOR.
COMPANY/AGENCY.
RECIPIENT.
DOCUMENT TYPE.
DOCUMENT TITLE:
132
07/08/88
001
Jon Rauscher
U.S. EPA Region VI
Sherry Fuerst, U.S. EPA Region VI
Memorandum
Comment on the excess cancer risk from
exposure to trichloroethylene at the
Industrial Transformer Superfund Site
DOCUMENT NUMBER.
DOCUMENT DATE.
NUMBER OF PAGES:
AUTHOR.
COMPANY/AGENCY:
RECIPIENT.
DOCUMENT TYPE.
DOCUMENT TITLE.
133
07/12/88
005
Robert Rountree, Remedial Investigation
Unit
Texas Water Commission
Texas Water Commission Files
Memorandum and Attachments
Industrial Transformers-Meeting with Bill
Chadick, ERT & Jim Mutch, Gulf States
Utilities, Date. 07/07/88; meeting to
discuss the results of the groundwater
analyses
DOCUMENT NUMBER.
DOCUMENT DATE.
NUMBER OF PAGES.
AUTHOR.
COMPANY/AGENCY.
RECIPIENT.
DOCUMENT TYPE.
DOCUMENT TITLE.
134
07/19/88
013
Sherry Fuerst, Texas Remedial Section
U.S. EPA Region VI
Robert Rountree, Texas Water Commission
Correspondence and Attachments
EPA's comments based on review of the Site
Investigation, Feasibility Study and
Quality Assurance/Quality Control Reports
A-4
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SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
Sol Lynn Phase II
TXD 980873327
DOCUMENT NUMBERi
DOCUMENT DATEi
NUMBER OF PAGES>
AUTHORi
COMPANY/AGENCYi
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
135
07/20/88
007
Robert Rountree, Remedial Investigation
Unit, Superfund Section, Hazadous and Solid
Waste Division
Texas Water Commission
Tom Hoskings, Radian Corporation
Correspondence
Remedial Investigation/Feasibility Study
Phase II Comments as discussed in the
meeting held 06/30/88
DOCUMENT NUMBER.
DOCUMENT DATE.
NUMBER OF PAGES.
AUTHOR.
COMPANY/ AGENCY:
RECIPIENT.
DOCUMENT
DOCUMENT
TYPE.
TITLE.
136
07/21/88
177
Riaz Ahmed, Program Manager, Thomas
Hoskings, Project Director, and Mary
McGill, Geologist
Radian Corporation
Sherry Fuerst, Remedial Project Manager,
U.S. EPA Region VI
Correspondence and Final Draft Report
Investigation Report, Phase II Groundwater
Contamination, Industrial Transformer
Superfund Site, Houston, Texas; objective
is to assess extent of contamination in
water-bearing zones
DOCUMENT NUMBER.
DOCUMENT DATE.
NUMBER OF PAGES:
AVTHOR.
COMPANY/AGENCY.
RECIPIENT.
DOCUMENT TYPE.
DOCUMENT TITLE.
137
07/21/88
235
Riaz Ahmed, Program Manager, Thomas
Hoskings, Project Director, Karen Miller
and Mark Colonna, Engrs
Radian Corporation
Sherry Fuerst, Remedial Project Manager,
U.S. EPA Region VI
Correspondence and Final Draft Report
Feasibility Study, Phase II, Groundwater
Contamination, Industrial Transformer
Superfund Site, Houston, Texas; objective
is to document findings of TCE
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SITE
SITE
NAME:
NUMBER:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
Sol Lynn Phase II
TXD 980873327
DOCUMENT NUMBERt
DOCUMENT DATE*
NUMBER OF PAGESi
AUTHORt
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPEi
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATEi
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
138
07/21/88
038
Riaz Ahmed, Ph.D., P.E., Program Manager,
and Thomas Hoskings, Ph.D., P.E., Project
Director
Radian Corporation
Sherry Fuerst, Remedial Project Manager,
U.S. EPA Region VI
Correspondence and Final Draft Report
Phase II Quality Assurance and Quality
Control Report, Industrial Transformer
Superfund Site; a system of checks which
enables documentation of data reliability
139
08/10/88
003
Jon Rauscher
U.S. EPA Region VI
Sherry Fuerst, U.S. EPA Region VI
Memorandum
Comment on the Health Assessment for the
Industrial Transformer Superfund site
DOCUMENT NUMBER:
DOCUMENT DATEi
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
140
08/10/88
001
Community Relations Staff
U.S. EPA Region VI
Public
Public Notice
Notice of Public Availability announcing
the availability of the Administrative
Record for the Industrial Transformer
Superfund Site
A-6
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f
SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
Sol Lynn Phase II
TXD 980873327
DOCUMENT NUMBER.
DOCUMENT DATE:
NUMBER OF PAGES>
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT
DOCUMENT
TYPE:
TITLE:
141
08/12/88
001
John S. Reese, P.E., General Manager
NEPCCO
Carl Edlund, Chief, Superfund Program
Branch, U.S. EPA Region VI
Correspondence
Comments on possible remedies for
groundwater contamination
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHORi
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT'TYPE:
DOCUMENT TITLE:
142
08/16/88
002
Lawrence M. Kagan
Kagan-Edelman Enterprises
Carl Edlund, Chief, Superfund Program
Branch, U.S. EPA Region VI
Correspondence
Industrial Transformer Site; Houston,
Texas, comments on EPA's proposed remedial
plan to remedy groundwater contamination
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLEi
143
08/25/88
029
Mary Kay Hendricks, CSR
A Better Court Reporting Service
U.S. EPA Region VI
Public Meeting Transcript
Transcript of Proceedings for the
Industrial Transformer (Sol Lynn) Superfund
Site Public Meeting held August 25, 1988
A-7
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME: Sol Lynn Phase II
SITE NUMBER: TXD 980873327
DOCUMENT NUMBER. 144
DOCUMENT DATEi 09/09/88
NUMBER OF PAGESi 006
AUTHOR. Patrick R. Cowlishaw
COMPANY/AGENCYi Cohan, Simpson, Cowlishaw, Aranza & Wulff
RECIPIENT! Carl Edlund, Chief, Superfund Program
Branch, U.S. EPA Region VI
DOCUMENT TYPEi Correspondence
DOCUMENT TITLE: Industrial Transformer (Sol Lynn) Site;
comments prepared by ERT regarding the
Phase II Remedial Investigation Report and
Feasibility Study prepared by Radian
Corporation
A-8
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ATTACHMENT B
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Sol Lynn
Houston, Texas
Responsiveness Summary
This community relations responsiveness summary is divided into two sections:
Section I: Background on Community Involvement and Concern
This section provides a brief history of community interest and
concerns raised during the remedial planning activities at the
Sol Lynn Superfund site.
Section II: Summary of Public Comments Received During the Public Comment
Period and the EPA Responses to Comments
Both the written and spoken comments are categorized by topics.
EPA responses to these relevant major topics are also presented.
I. Background on Community Involvement
Initiation of studies on Industrial Transformer was announced by TWC at a
public meeting in Houston on September 24, 1986. Evaluation of the site
was divided into two separate studies: 1) surface soil contamination; 2)
groundwater contamination. The study addressing surface soil contamination
was completed in December 1987. On January 21, 1988, a news release was
issued stating that a public meeting would be held on February 2, 1988,
to discuss the proposed remedy for surface contamination at the site.
An EPA prepared fact sheet which described alternative remedial actions
for the soil contamination along with the EPA preferred alternative was
sent to the interested and affected public shortly after the public
meeting was announced. EPA and TWC conducted the 7:00 pm public meeting
at the Astro Village Hotel on February 2, 1988. Approximately 35 people
attended the public meeting.
On August 8, 1988, a news release announced that a public comment period
on the groundwater study would begin on August 10, 1988 and end on
September 9, 1988. The news release also announced that a public meeting
would be held on August 25, 1988, at the Astro Village Hotel, Houston, Texas,
An EPA prepared fact sheet describing the alternative remedial actions
for the groundwater study along with the EPA preferred alternative was
sent to the site mailing list shortly after the meeting and comment
period was announced. EPA and TWC conducted the 7:00 p.m. public meeting
on August 25. Approximately 15 people attended the meeting. Only two
questions were asked and no comments were made during the public meeting.
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II. Summary of Public Comment Received During Public Comment Period and
Agency Responses
This section gives the EPA's responses to the comments received during
the public comment period. There were two verbal comments made at the
public meeting and nine written comments received by the EPA
during public comment.
A. Comments at the public meeting
i. By Ray McMullen on behalf of a landowner.
Comment #1
Who is responsible for the fence, barrels and other debris on the
land next to the contaminated area?
Response
The property owner signed an access agreement with the Texas Water
Commission. This access agreement gave the Texas Water Commission
the right to use the land. The Texas Water Commission is responsible
for removing the fence, barrels and any other material generated
during its investigation.
Comment #2
The name I've seen associated with the cause of the contamination is
Sol Lynn. What happened to h-im and is he paying for any of the
cleanup or is it only being funded by the Superfund?
Response
The Environmental Protection Agency has been in contact with
Mr. Lynn and other potentially responsible parties to try to recoup
the expenses of the remedial actions which have occurred and which
are scheduled to occur at the site.
ii. Comments by Steve Hupp of the Harris County Pollution Control.
Comment #3
What is the anticipated total amount of TCE emitted into the air during
the life of this project? What air cleaning equipment was considered to
eliminate the TCE emissions into the atmosphere? What is the odor
threshold for TCE?
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Response
We estimate 50 pounds per year of TCE will be emitted into the air
if no emission control devices are used and less than 10 pounds per
year if any are used.
The carbon adsorption canister was the only emissions control device
considered during the feasibility study.
The lowest reported odor threshold limit is 1.134 mg/m^.
B. Written Comments
i. Lawrence Kagen of Kagen-Edelman Enterprises, an adjacent landowner:
Comment #4
I am concerned about the subsidence danger to my property caused by
the EPA withdrawing groundwater from the property. Who will be
responsible for the damage caused to my property by the settling and
possible flooding caused by the lower ground elevation caused by the
withdrawal of the groundwater?
Response
The City of Houston is experiencing subsidence problems from
groundwater pumpage. The majority of this subsidence problem is
from pumping of municipal wells. These wells can pump up to one
million gallons of water per day. The system discussed in the
Record of Decision for the remediation of the TCE contaminated
groundwater would pump about 3.2 million gallons over a 10 year
period. We estimate the subsidence to be less than'one inch for
the ten year life of the system. The subsidenece will be less if
the treated groundwater is reinjected into the ground than if
it is discharged into publicly owned treatment works. The discharge
options will be evaluated in the remedial design stage of the project.
ii. Prepared by ERT, an engineering company, for the law firm of Cohan,
Simpson, Cowlishaw, Aranz and Wulff, representing Gulf States
Utilities, a potentially responsible party.
Comment #5
" The volume of tricholorethylene contaminated water in the uppermost water-
bearing unit may be overstated. The hydrocone testing determines
groundwater quality very crudely and the data should be viewed with caution,
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Response
The EPA tries to be "cautious" with our estimates erring on the side
of conservatism. A sensitivity analysis was done comparing the effect
of volume changes on the cost of each alternative. This analysis was
considered in the alternative selection. This analysis indicated
that air stripping becomes more cost effective as the volume of treated
water increases.
The cone penetrometer is one of many techniques that can be utilized to
trace groundwater contamination. Like most other techniques it has
its limitations. .Yet when evaluating its effectiveness versus cost,
it proved to be a useful technique for this investigation.
Comment #6
The three monitoring wells completed in the intermediate zone are
inadequate to determine the extent of contamination, the flow
direction or any aquifer parameters.
Response
As stated on page 7 of the Record of Decision, these three wells were
not used to define the extent of contamination. We believe three
monitoring wells adequately indicate the flow direction and many
other aquifer parameters. The extent of contamination will be
determined during the design phase of the project.
Comment # 7
There is a probability the intermediate water-bearing unit
contamination came from poor monitor well construction or from the
on site groundwater production well.
Response
We disagree. Monitoring wells were installed according to approved
specifications. Care was taken to avoid cross-contamination by double
casing each well.
The on site groundwater production well may have contributed to the
contamination by producing a vertical channel for the movement of the
TCE. All wells on site not used in remediation or for postclosure
monitoring will be plugged.
Comment #8
Both the upper and intermediate water-bearing units are not usable
potable water supply sources because of low yield and high Total
Dissolved Solids,
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Response
The Total Dissolved Solids in the upper water-bearing zone ranges
from about 2300 mg/1 -to 3700 mg/1 and in the second water-bearing
zone from 1000 to 1650 mg/1. Although these are higher than the
secondary drinking water standard of 500 mg/1 according to Chemical
Analysis of Public Water Supply by the Texas Department of Health,
1983, there are numerous water supplies in Harris County and throughout
the State that are within these ranges. As stated on page 7 of the
Record of Decision, the EPA identifies a potential drinking water
supply as any body of water under 10,000 mg/1 Total Dissolved Solids;
therefore, the groundwater at Industrial Transformers could not be
eliminated as a potential water supply. The yield is low in these
water-bearing zones, but they do provide enough water to be considered
potential water supplies.
Comment #9
ERT disputes the application of drinking water standard to water
bearing zones not usable for potable purposes.
Response
As stated in response to comment #8, the groundwater at Industrial
Transformers is considered a potential water supply. As such, drinking
water standards apply in defining the extent of remediation.
Comment
The impacts of groundwater remediation need to be studied before a
recovery system is proposed. This includes water bearing unit yield
and the potential for subsidence adversely impacting the adjacent 610
Highway.
Response
See comment #4.
Comment 111
The EPA inappropriately eliminated directly discharging groundwater
to a Publicly Owned Treatment Works (POTW).
Response
As stated in the Record of Decision on pages 16 and 23, the method of
discharge has not been determined. In alternatives 3, 4, and 5
discharging into a POTW and reinjection into the groundwater zone are
still being considered. This decision will be made during design.
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Response
As stated in the Record of Decision on pages 16 and 23, the method of
discharge has not been determined. In alternatives 3, 4, and 5
discharging into a POTW and reinjection into the groundwater zone are
still being considered. This decision will be made during design.
Comment #12
There is no basis for selecting air stripping over direct activated
carbon treatment.
Response
The EPA disagrees. The air stripping system, as described in the
Record of Decision, provides many advantages over direct carbon
adsorption. The high total dissolved solids in the groundwater make
carbon adsorption less effective than air stripping; other organics
will compete with the TCE for adsorption sites. The high suspended
solids also cause the carbon unit to clog, drastically reducing the
effectiveness of the treatment process. The cost effectiveness
increases with air stripping as the volume of groundwater to be treated
increases. This becomes important since the volume of contaminated
groundwater in the second water-bearing zone will be defined during
the design phase.
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ATTACHMENT C
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TEXAS WATER COMMISSION
B. J. Wynne, III, Chairman
Paul Hopkins, Commissioner
John O. Houchins, Commissioner
J. D.
MW^r
Karen A. PKHfips,
J Counsel
i,Jv; ^
Allen Beinke, Executive Director
September 19, 1988
Allyn M. Davis, Ph.D., Director
Hazardous Waste Management Division
U. S. Environmental Protection Agency
Region VI
1445 Ross Avenue
Dallas, Texas 75202-2733
Re: Industrial Transformers Superfund Site
Draft Record of Decision
Dear Dr. Davis:
We have reviewed the proposed Record of Decision (ROD) for the
Industrial Transformers Site. We have no objection to the
selected remedy of collection, on-site air stripping, and
discharge (Alternative 4) as described in the draft ROD of
September 14, 1988.
Sincerely,
Allen P. Beinke
Executive Director
. Tf
P 0. Box 13087 Capitol Station 1700 North Congress Ave. Austin, Texas 78711-3087 Area Code 512/463-7830
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