United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-86/012
Sept. 1986
&EPA
Superfund
Record of Decision
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<.
1. REPORT NO.
EPA/ROD/R06-86/012
.. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECIS ION
Geneva Industries, TX
TECHNICAL REPORT DATA
(PlHl~ ntld /,,,,ructions on th~ nv~n~ ~/on com"'~t;nl)
T2. 3. RECIPIENT'S ACCESSION'NO.
15. REPORT DATE
September 18, 1986
6. PERFORMING ORGANIZATION CODE
7. AUTHOR'S)
8. PERFORMING ORGANIZATION REPORT NO.
i. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM E~EMENT NO.
". c;ONTf'AC;T/Gf'ANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
1.. SPONSORING AGENCY CODE
800/00
115. SUPPLEMENTARY NOTES
16. A8STRACT
The Geneva Industries site is a 13.5 acre tract located in Houston, TX, immediately
adjacent to the corporate limits of the City of South Houston. Approximately 35,000
people live within one mile of Geneva. The closest residences are located less than 50
feet from the east and southwest site boundaries, and two businesses are located 300
feet west of the site. Th~ site is currently located in the 100-year floodplain and is
drained by the adjacent flood control channel. Geneva Industries is an abandoned
refinery which manufactured a variety of organic compounds and fuel oils from 1967
through 1978. Surface and subsurface onsite soils havi been contaminated as a result 01
operational spills, leaking drums, tanks, and lagoons, and landfill/land farming
operations. Shallow ground water is'conta~nated onsite; some offsite migration has
occurred east of the site. A planned removal was performed by EPA between OCtober 1983
and February 1984 to close out three onsite lagoons, remove all drummed waste on the
surface, remove all offsite soils containing greater than 50 ppm PCBs, install a cap
over onsite soils containing greater than 50 ppm PCBs, and improve site drainage. OtheI
removal actions to plug abandoned wells onsite and remove storage tank materials were
performed in May and september 1984 respectively. Further studies were conducted to
determine an appropriate permanent site remedy. The primary contaminants of concern
include: VOCs, PAHS, TCE, PCBs, phenols and fuel oils.
. (See Attached Sheet) -
~7,
Ia.
DESCRIPTORS
KEY WORDS AND DOCUMENT ANA~YS'S
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSAT! Field/Group
Record of Decision
Geneva Inustries, TX
Contaminated Media: sw, gw, soils,
Key contaminants: VOCs, PAHs, TCE,
Phenols, Oils, Aromatics
sediment
PCBs,
"
"
18. DISTRI8UTION STATEMENT
19. SECURITY CLASS (Tllis R~pO"1
None
20. SECURITY CL.ASS (Tllis pag~1
None
21. NO. OF PAGES
90
22. PRICE
I
I!'A ,- 2220-1 (R..... .-77)
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"
EPA/ROD/R06-86/012
Geneva Industries,TX
16.
ABSTRACT (continued)
The selected remedial action includes: removal and disposal of surface
structures in an offsite hazardous waste landfill~ excavation of
contaminated soils with greater than 100 ppm of pCBs and all buried drums
onsite~ disposal of excavated soils and drums at an EPA-approved offsite
disposal facility~ construction of a multi-layer surface cap over the site
and a slurry wall tied into the clay below the 30-foot sand around the
perimeter of the site~ recovery of TCE contaminated ground water from the
30- and 100-foot sand, treatment onsite by carbon adsorption, and discharge
into the adjacent flood control channel. The estimated capital cost for
this remedy is $14,990,000 with O&M for years one and two of S532,000/year
and $483,000 for years three through thirty.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site:
Geneva Industries, 9334 Caniff Road, Houston, Texas
DOCUMENTS REVIEWED
I have reviewed the following documents describing the analysis of cost-
effectiveness of remedial alternatives for the Geneva Industries site:
- Geneva Industries Site Investigation Report, IT Corporation, June 1985
- . Geneva Industries Feasibility Study, IT Corporation, April 1986.
- Summary of Remedial Alternative Selection, Geneva Industries, September
)
1986.
- Responsiveness Summary, September 1986.
- Staff summaries and recommendations.
DESCRIPTION OF SELECTED REMEDY
- Remove and dispose of surface structures in an offsite hazardous
waste landfill.
- Excavate soils contaminated with greater than 100 ppm of polychlorinated
biphenyls and all buried drums onsite.
- Dispose of excavated soils and drums at an EPA-approved offsite
. disposal facility.
-, Construct a multi-layer surface cap over the site and a slurry wall
tied into the clay below the 30-foot sand around the perimeter of the
site.
- Recover trichloroethylene contaminated groundwater from the 30 and 100-
foot sand, treat onsite by carbon adsorption, and discharge .into the
adjacent flood control channel.
DECLARATION
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA) and the National Contingency Plan (40
CFR Part 300), I have determined that the selected remedy for the Geneva
Industries site is a cost-effective remedy and provides adequate protection
of public health, welfare, and the environment. The State of Texas has'
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';:;
action will require future operation and maintenance activities to ensure
the continued effectiveness of the remedy. These activities will be
considered part of the approval action and eligible for Trust Fund monies
for a period of one year. I have also determined that the action being
taken is appropriate when balanced against the availability of Trust Fund
monies for use at other sites.
D~t 18 I ~
::Lb
Dick Whittlngton. P.E.
Regional Administrator
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
GENEVA INDUSTRIES
HOUSTON, TEXAS
.
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~
TABLE OF CONTENTS
Background
Site location and Description
1
1
Site History
Current Site Status
1
3
Contaminant Migration Pathways
Target Receptors
8
9
Enf-orcement
Alternatives Evaluation
9
10
Groundwater Alternatives
15
Soils Alternatives
18
Community Relations
Consistency with Other Environmental Laws
20
Recommended Alternative
20
21
Operatio"n and Maintenance
23
24
Schedule
..
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
GENEVA INDUSTRIES
HOUS TON, TEXAS
BACKGROUND
The Geneva Industries site is an abandoned refinery which manufactured a
variety of organic compounds including biphenyl, Polychlorinated biphenyls
(PCBs), Phenyl Phenol, naptha, and Nos. 2 and 6 fuel oils from 1967 through
197B. These products, along with chlorinated hydrocarbon solvents,
volatile organics, and polynuclear aromatic hydrocarbons associated with
the manuf actu ri n 9 P roces ses are the maj or contami nants at Geneva Indus t ri e s.
Site location and Description
The Geneva Industries site is a 13.5 acre tract located at 9334 Caniff
Road in Houston, Texas immediately adjacent to the corporate limits of
the city of South Houston. The site is within one mile of Interstate Highway
45 and within two miles of William P. Hobby Airport. The property is bound
on the north by Caniff Road, on the Southwest by Easthaven Boulevard,
and on the east by a Harris County Flood Control Channel. location and
site maps are shown in Figures 1 and 2.
Approximately 35,000 peop;e live within one mile of Geneva. The closest
residences are located less than 50 feet from the east and southwest site
boundaries, and two businesses are-located 300 feet liest of the site.
The topography in the site vicinitY"is flat with a maximum gradeelevation
of 35 feet above mean sea level (msl). The site is currently located in the
100-year floodplain and is drained by the adjacent flood control channel.
Channel improvements planned for this area are expected to lower the 100.
year floodplain elevation to 31.4 feet msl.
.' .,..".
While several manufacturing units have been removed from the site, a
substantial number of tanks as well as process equipment remain. The
historical plant layout and current site conditions are Illustrated In Figures
. 3 and 4. respectively.
Site Histor~
Prior to 1967, the property was used for petroleum exploration and
Production. Geneva Industries began manufacturing biphenyl by distillation
of toluene dealkylatjon botto~ in June 1967, began prOducing PCBs in~une
1972, and declared bankruptcy in November 1973. Since that time, four
other corporations owned and operated the Geneva facility, including:
Pilot Industries, February 1974 - December 1976
Intercoastal Refining, December 1976 - December 1980
lonestar Fuel Co., December 1980 - May 1982
Fuhrmann Energy, May 1982 - Present.
-
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1lXAS STATE DEPARTMENT OF HIGHWAYS
AND PUBLIC TRANSPOATATJON. TRANSPORTATION
PlANHING DIVISION FILe D-'o. CONTROl-SECTION MAP,
DISTJ1lCT '2 HOUSTON.
lOCATIO,. MAP
Gt'fEVA '"Ousr",u SITE
SITE '"VESflGAflOIi
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Figure 2
GENEVA INDUSTRIES
lOCATION MAP
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D
2
Operation of the facility ceased In September 1978 and was never resumed
by the future owners. The current owner, fuhrmann Energy, has salvaged
much of the equipment onsite for resale.
Records from the Texas Water Quality Board and the Harris County Pollution
Control District indicate that several citations were Issued to the
various owners for unauthorized dlscharges of wastewater into the adjacent
flood control channel. These records also indicate that plant operation
was marked by numerous spills and process leaks and that housekeeping
and disposal practices deteriorated with time. As of 1981, the site
Contained proceSSing tanks, piping, and equipment, three open and one
closed wastewater lagoon, a diked tank area ,several drum storage areas,
a landfill, and possibly a landfarm.
In a preliminary investigation, the U.S. Environmental Protection Agency
(EPA) found onsite soils contaminated with up to 9,DDO parts per million
(ppm) of Pe8s and up to ID4 ppm in sediments In the flood Control channel.
Samples from six monitoring wells installed by the Region VI field Investi-
gation Team indicated that the shallow waterobearing zone (3D-foot sand)
was contaminated with PCBs and other organic compounds.. Based on the
results of this investigation, the site was ranked with the Hazard Ranking
System (HRS score = 59.46) and is currently on the National Priorities
list.
A Planned Removal was performed by EPA during the period from October
1983 to February 1984 to close out three onsite lagoons, remove all
drummed waste on the surface, remove all offsite soils containing greater
than 50 ppm PCBs, install a cap over all on~ite soils Containing greater
than 5D ppm PCBs, and improve site drainage. Approximately 3,4DO cubic
yards of contaminated soils and sludges, 55D drums, and 3D tons pf asbestos
were removed and transported to an approved disposal facility In Emmelle,
Alabama. Other removal actions to plug abandoned wells onslte and remove
storage tank materials were performed In May and September 1984, respectively.
The total cost of removal actions performed to date is $I,748,179,
A Cooperative Agreement for a Remedial Investigation and Feasibility
Study (RIffS) for $63D,DDD was awarded by EPA to the State of Texas In
December 19B3. D'Appolonia. Inc.. now IT Cooperation, In association
with Environmental Research and TeChnology. Inc.. and Rollins Environmental
Services (TX) Inc" was contracted by the State to conduct the RIffS,
The Initial site work was completed In September 1984. at which time It
was determined that additional field work would be required. An amendment
to the grant for $3DD,DDD was awarded in March 1985 to Investigate Possible
aslesmlc faulting at the site. All field work was completed In October 1985.
The Remedial Investigation was Completed In December 1985. The feasibility
Study began In December 1984 and completed in April 1986. The long
feasibility study period was due to the need for the extensive fault
Investigation conducted In September 1985. The detailed development and
~valuatlon of remedial alternatives could not be done until the effects
f Possible faulting across the site could be determined.
. .:,.
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3
Current Site Status
The Geneva Industries site investigation consisted of surficial soil
sampling, soil borings, lagoon borings, trenching, groundwater sampling,
sediment sampling, stormwater/surface water sampling, and air monitoring.
The investigation focused on the identification of the geologic and
hydrologiC characteristics of the site, the wastes present, the migration
pathways, the extent of contamination from the site, and the target
receptors and population at risk.
Site Geology and Hydrology
The shallow stratigraphy at the site is characterized by the following
general horizons (Figure 5):
- A silty clay to clay (Horizon 1) extends from land surface to a
depth of 12 to 19 feet;
- A sandy silt to silty sand (Horizon 2, or 30-foot sand) from
Horizon 1 to a depth of 35 feet;
- A clay layer with Occurrences of silty to sandy clay (Horizon 3)
with a thickness of 13 to 27 feet;
- A well-sorted sandy layer (Horizon 4, or 100-foot sand) containing
zones of coarse sand and gravel, with a measured thickness of 50
to 91 feet;
- A clay (Horizon 5) with a thickness of approximately 100 feet
begins at 107 to 140 feet b~low ground surface.~
The groundwater in the area is supplied by two aquifers, the Chicot and
the Evangeline. The upper unit of the Chicot, a minor water supply in
the area, consists of the 30-foot and 100-foot sands under the site and
extends to a depth of about -160 feet NGVD (National Geodetic Vertical
Datum). The lower unit of the Chicot provides most of the groundwater used
for pub 11 c and i ndust ria 1 water supp ]f.es in southeastern Harri s County,
including the city of South Houston, and Galveston County. The base of
this unit Occurs at approximately -600 feet NGVD. The Evangeline aquifer
lies below the Chicot and is the major Source of groundwater for the city
of Houston. The base of the Evangeline occurs at an elevation of -2500
NGVD. A generalized stratigraphic and hydrologic column for the region
is presented in Figure 6. .
A water well fnventory was conducted fn the vfcinfty of the site. As
shown fn Figure 7 and listed fn Table I, seventeen wells were fdentfffed
wfthfn approximately one mile of the site. The only active municfpal
well, LJ-65-23-707. fs screened below the Chicot aquifer. However. other
municipal wells farther from the sfte are screened at depths of 600 to
700 feet in the Chicot. Also, three prfvate domestic were fdentfffed, at
least one of which is screened in the 100-foot sand approximately 0.2
miles southeast of the site.
Horfzon 2 (3D-foot sand) fs the shallowest water-bearfng zone underlying
the site. Water in this zone Occurs under apparently semi-confined.
conditfons and rfses in monitorfng wells to 5 to 8 feet below land surface.
. .t;
.
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Figure 5
Stratigraphic Zones at Geneva
Industries
---..-. --
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APPROXIMATE
ELEVATION
SYSTEM SERIES UNIT AQUIFER FT. NGVD
BEAUMONT UPPER
FORMATION Ut\JIT
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E S FORMATICt~
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Figure 7
WATER WELLS
WITHIN ONE MILE OF SITE
GENEVA INDUSTRIES SITE
SITE mVE S i IGATION
PREPA RED FOR'
TF. XA$ DEPARTI/iPH OF
WATER RESOURCES
AUSTIN. TEXAS
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Table 1
WATEI WELL INVENTOIlY
ONE MILE RADIUS
GENEVA INDUSTIIES SITE
Well Invento~y F~om City Recordl
Well 10.
Location
Street add~ess
1
6
Ga~ner Mobil Holle Park
Fields Trailer Park
9343 Redfo~d
8302 Hanaen
Well Invento~y f~om USGS Records
Ownersh{p Approx. Depth
I.D. 10. (ft.) Status
LJ-65-23-705 City of So. Houston 795 Inactive
LJ-65-23-706 City of So. Houlton 778 Inactive
LJ-65-23-707 City of So. Houl"ton 1067 Active
LJ-6S-23-708 City of So. Houston 1170 Inactive
LJ-65-23-713 Barris County 620 Destroyed
LJ-6S-23-714 City of So. Houston 600 Destroyed
LJ-65-23-715 Barris County 1200 Des troyed
LJ-6.5-23-716 City of So. Houston 771 Destroyed
LJ-65-23-717 City of So._Houston 668 Destroyed
LJ-65-23-718 City of So.-Houston .- 316 Destroyed
LJ-65-23-719 City of So. Bouston 916 Destroyed
LJ-65-23-720 . City of So. Houston 650 Dest~oyed
LJ-65-23-724 City of So. Houlton 657 Destroyed
LJ-6S-23-725 City of So. Houlton 916 Destroyed
-~ .......,
-, ..".
Other. Wells Located by Su~vey of Area
Well Mo. Location Reported Depth (ft) Status
1 9310 Tallyho Road 100 Active-
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4
Potentiometric contours, as shown in Figure 8, indicate that the gradient
in this zone under the site is oriented toward the adjacent flood control
channel. The potentiometric data also indicates that some discharge into
the flood control channel is possible on a periodic basis.
Permeability of the silty sand in Horizon 2 has been estimated as ranging
from 10-4 to 10-5 em/sec. The transmissivity of the zone is estimated to
be 2 to 3 square feet per day. This zone is not suitable as a source of
water supply in the site vicinity due to the high Total Dissolved Solids
concentrations (to 10,000 ppm) found during the site investigation. For
comparison, the secondary standard for Total Dissolved Solids in drinking
water. is 250 ppm. .
,
Horizon 4 (IOO-foot sand) is the next shallowest water-bearing zone under
the site. Water in this zone occurs under more confined conditions than
Horizon 2 but is considered to be semi-confined, and rises in monitoring
wells to about 16 to 18 feet below the ground surface. Based upon.
potentiometric data developed during the site investigation, the gradient
.is relatively constant across the site and groundwater flow is toward the
.west and southwest (Figure 9).
The primary surface water features in the vicinity of the site include:
- Harris County Flood Control District channel along the eastern
boundary of the site. The 10-foot deep channel receives all of
the runoff from the site and flows in a northerly direction into
Berry Bayou.
- Berry Bayou is intersected approximately one mile northeast of
the site. Berry Bayou drains into Sims Bayou about two miles
north of the site. Sims Bayou, in turn, flows into the Houston Ship
Channel.
Surface drainage patterns are illustrated in Figure 10. There are three
principal drainage paths at the site, all of which drain into the flood
control channel. These are:
- A drainage ditch along the western boundary of the site flowing
south to north, draining into a roadside ditch west along Caniff
Road into the channel.
A drainage ditch starting south at the center of the site flowing
to the southeast. This path drains the central portion of the site. and
discharges into the flood control channel.
- A drainage ditch running parallel to the southern fence and
discharging into the flood control channel at the southernmost
-------
LEGEND
.
.
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SCALE
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- -'M.." ."."'"'''' .'.25 Figure 8 MAP
~ NTlOM[TAIC
1I.-I814'.!l5I POTEo FOOT SAND TE
43 50 3 - TRIES SI
;'-" .IIEVII ~"v"EUSSTlG"'IOII
- - -- 43.7~" SITE I
. \: ...........
-44.0V A COMMISSION
TEUS ::;T~N. TEXAS.
m fERT/ROLLINS
.25 FEET
A INTERVAL
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Figure 9
POTENTIOMETRIC MAP
~ 100 FOOT SAND
INT ERPRETATIOH I
. <: Gf...rvA ,..OUSTAI(S "lTf
SI If ,..V(STlGATlOII
""£DAOI{D ~DIt
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'Wl.T[;! Qt.~;OllRCES
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Figure 10
/'\. GENERAL SIT
/ G£..(V. IN E Df44INAGE
, OU~f"'£
,- SllrINV£S 5511£
, TOGA flON
V "'rPA"£~ fOR
TE),A5 "f
WII:n:LR ~~~T~E"'TOF
/lUST I I.:UU"(:[5
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m IERT/ROL
-------
~
5
The flood control channel, being the recipient of the site runoff,
is the most likely surface water feature to be impacted by contaminants
from surface soils at Geneva. .
)
Due to the temporary protective cap placed on the site during the 1984
Planned Removal, on-site surface expressions of faulting were not discovered
during the site investigation. However, faulting in the vicinity of
Geneva Industries has been documented by the United States Geologic
Survey. To further define the potential for faulting at the site, an
area survey was conducted to locate surficial expressions of faulting
within 1/2 mile of the site.
One interpretation of the initial fault survey data, shown in Figure 11 ..
and 12, suggested that a surface fault might affect the Geneva site. In an
effort. to confirm or refute the presence of a fault onsite, a detailed
fault investigation was conducted in September 1985. Four borings were
drilled perpendicular to the "Fault of Concern" (Figures .11 and 13) along
the southwest boundary of the site. Based on the logs of these borings,
presented schematically in Figure 14, faulting in the area does not impact
..the Geneva Industries site. Faulting would be indicated by a disconti-
nuity of the markers along the line of borings. It appears that the
"Fault of Concern" terminates about 900 feet southwest of the site
boundary, and is moving horizontally at a rate of 0.03 inch per year.
The current subsidence rate in the vicinity of the site appears to be in
the range of 0.05 to 0.15 feet per year. The rate~of subsidence has been
decreasing gradually over the past several years, primarily due to efforts
by the Harris-Galveston Coastal Subsidence District to control groundwater
withdrawl in areas of previously high pumping rates. Based on projected
continued use of groundwater for industrial and water supply purposes it is
expected that subsidence will continue at a rate of 0.05 to 0.15 feet per
year.. Subsidence across the site is expected to be uniform, based on the
lack of faulting across the site.
The site has been inundated several times in recent years by heavy
precipitation. This inundation is due primarily to inadequate capacity
in the adjacent flood control channel to drain water away from the site.
Modifications to widen and line the channel, currently being planned by
the Harris County Flood Control District, should alleviate inundation
problems at the site. These plans would lower the predicted 100-year
flood elevation to .31.4 feet msl. This is 3.5 feet below the current
site surface evaluation.
Review of the data generated prior to and during the remedial investigation
leads to the following conclusions concerning the characteristics and
extent of contamination from the Geneva site:
- The principal sources of contamination at the site are waste
lagoons and ponds, buried drums, landfarming, surface storage of
-------
.
.
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LEGEND
/
KNOWN SURFICIAL FAULT
(HACHURES INOICATE
OOWNTHROWN SlOE I
,,-'
,
,
PRESUMEO SURFICIAL
FAUL TI NG
REFE~ENCE: U~GS OPENFILE
REPORT NO. 78.797
20(10
L--
2000
----'
SCAlE '" rEET
o
Figure 11
SURFICIAL FAULTING
G("( VA l"OU5T1"£5 5"E
SIf[ ,..V£STlGUIO"
"£'."£0 '011
TEXA~ OEPARTMENT OF
WATER RESOURCES
AUSTIN.TEXAS
':
m /ERT/ROLLINS
).
"
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Figure 12
SURFACE FAULTING SURVEY
STOP LOG POINTS, .
GENEVA mDUSTRIES 511£ ~
51 TE INVEST IGATtON
.
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PREPARED FOR
TEXAS DEPARTltAENT OF
WAT ER RESOURCES
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tigure 13
PROJECTION OF FAULT
<: TO THE SITE
Cl[II[VA INOU5TIII[$ liT!
SIT[ INV£STIGUIOII
""£PAllED fOil
TEXAS WATER COMMISSION
AUSTIN, TEXAS
SeAl[
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HORllONTAl SCALE
240 .
300
360
Fi~ure 14'
CORRELATION OF HORIZONTAL
STRATIGRAPHIC MARkERS
GENEVA INOUST'''ES SITE
SITE INVESTIGATION
"'(1'''''(0 '011
1010
TEXAS WATER COMMISSION
AUSTIN, TE XA S
-------
6
- The principal contaminants are polychlorinated biphenyls (PCBs).
aromatic solvents (benzene). nonaromatic chlorinated solvents
(trichloroethylene). and polynuclear aromatic hydrocarbons (PAHs).
- Surface and subsurface onsite soils have been contaminated as a
result of operational spills. leaking drums. tanks. and lagoons.
and landfill/landfarming operations.
- Offsite soils have not been measurably impacted by site activities.
- Sediments in the adjacent flood control channel have been
contaminated in the past.
- Shallow groundwater (30-foot sand} is contaminated onsite; some
offsite migration has occurred east~of the site.
- Intermediate groundwater (lOO-foot sand) is slightly contaminated
onsite.
50il Contamination
--
. Concentrations of PCBs in surface soils onsite range from less than 1.0
ppm to 1.750 ppm. One sample taken during the 1984 Planned Removal
contained 12.200 ppm PCB. Sample locations and analytical results are
illustrated in Figure 15. The highest concentrations of PCBs were found
in the bi,phenyl chlorination unit area (12,200 ppm) , the landfill/landfarm
area (1.170 ppm) and the diked tank area. Relatively high levels of
contamination (50 ppm to '500 ppm) are associated ~ith lagoons and
containerized storage areas where spills have occurred. Based on the
data presented in Figure 16 and Table 2, dioxins and dibenzofurans do not
represent a threat to human health or the environment at Geneva.
~ "8a:sea on ana Iyt fC;r "=data froin ons1!es01 r 'bar1 ngs-'rnlf'Wencnes, t'~e". ,-.;I -.
highest concentrations o.f PCB are generally within the upper 5-6 feet
of soil. Boring and trench loc~?ions are shown in Figures 17 and 18.
respectively. Analytical data from samples are presented in Tables 3,
~. _4..and .5__As_the_results indicate, contamination in the pond area -------
extends to a depth of at least 13 feet. Ponds provide a source of liquid
waste and the hydraulic head necessary to drive migration downward.
Considering th~ potentiometric data already discussed and vertical driving
force from the ponds, it is possible that contamination in the pond area
extends vertically to the shallow groundwater. .
'.,- .
.. - _r .'
p
~
~--
Volumes of surface and subsurface onsite soils contaminated above various
concentrations of PCB were estimated in the remedial investigation.
These estimates are presented below:
. '.s.-
~
500
100
50
25
1
50il Volume (cubic yard)
9.000
22,500
31,000
42,000
-------
1
}
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-
o
98
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'ROM [~A SA"PL~ 11.0/-01
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Figure 15
PCA CONCtHTRAT
SURFICIAL SO,~ONS IMG/KG)
SAMPLES
Gt'~VA 'NO
SIT[ I"V~~$TT,"'[S 'ITE
GAT 10M
,.r P"RtD FOA
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W:. ~..~ :~TMOIT OF
AU';T' L"2Uqf.E~
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m IERT/ROL-'UNS
-------
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v
X'2
EPA SOIL ~AMPLE LOCATION FOR PCB. !)IOXINS.
Af.O FURANS ANALYSES
MW-4
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MONITOR WELL SA~PLED "OR PCB. DIOXINS,
"'10 FURANS ANALYSES
00 0
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Figure 16
EPA RfMFlT
SAMPLING LOC~TIONS
I;('':f.~
-------
-
Table 2
S1MWIt or KI. 0101111 AIID 'UIAII OATA PION I'A IDIPIT SAMPt.11IC
IAIIfU fIftA CDO()) IIE"A coon)
LOCATI.< I) TOTAL PCIU) .EIITA COD()) IIEIA coo( n OCTA coon) ttT1IA CII'U) nllTA co,U) IDA CDPU) IE"A CDrU) OCT. CDr(])
17 1.]00.0 lID lID lID lID 0.15 '.76 0.28 lID lID 0.28
18 111.0 lID lID 0.07 0.)11 I. ~4 1t.~1 0.4' o.n o.n 1.611
I 16.0 lID liD 0.01 1.04 7.7 ).07 lID 0.04 o.n 0."
I Ift.O lID lID 0.07 O..~ 2.7] 3.07 lID O.U D." 0.47
1tV-6 117.0 lID lID lID 110 lID 0." lID liD lID lID
1tV-6 ]6.0 lID lID lID lID lID o.n 0.0) lID lID lID
. 1tV-4 10,000.0 lID lID lID 0.40 0.116 80.6 14.n 1.01 l.tI '.07
U '.J lID lID 0.06 0.711 '.2 1.21 o.n 0.0' 0.14 . o.n
.. ']0.0 lID lID 0.14 0.66 4.112 ..... 1.74 lID 2,'2 '.31
] 0.6 lID lID lID lID O.H 0.1 0.01 lID 0.02 lID
U 2'.0 lID 110 110 0.02 0.11 o.~, 0.04 lID 0.09 0.21
14 "o.0 0.02 lID lID 0.011 ].14 1ft. 12 lID lID O. tJ I."
U no.o IIA IIA IIA IIA IIA IIA "A IIA M M
II '".0 lID lID lID lID 6.)8 '".95 . 0." 1.18 0.16 I.U
0' 6~.0 lID lID lID 0.7~ 3.22 13.52 lID 0.2' 0.6) 1.15
09 ~8.0 lID lID lID lID 0.19 '.111 0.3' lID lID lID
04 lID lID liD lID 0.02 r 0.12 lID lID lID lID lID
01 810.0 lID lID lID lID 3.5) 1.'11 lID lID lID 0.74
10 lID 110 lID liD lID 0.84 "0 lID lID lID lID
.. . lID lID lID lID lID 0.13 lID lID lID lID 8D
01 0.2 liD lID lID lID 0.27 "0 lID lID lID lID
DUP07 0.]
I' J.I . . lID 0.06 0.)7 2.]] . lID . .
.. . !lot Deteet"
'A . !lot _.1,...
(2) PCI eonc..tr.tlae I. .I~roar... fer Ilt.r 'or ..t.r ....1.. (NV-6 ... NU-4) ... t. 8!llllr... por Iitor 'or ootl ....1.. (.11 oth.r ....10.).
-------
C\
0:
"
%
~
«
...
~
u
.
..
SlfaL:'OW IICIIIIIG t..S StUDY
110"0 IC'IIt:"O T H'S ST\I!)T
.
.
.,
A
SOIL 10111"0 .so rOOT. 1I0IIIT01t wtLL tHIS ~UDT
SOIL 8011'''G .100 rOOT. IIIOIIITOII wtLL THIS STUDT
.SO FOOT. 111011"011 Wt..L. P"(VIOUS stUOT
.'00 root. 1IOIt1T0It wtll/ SOIL .O!tltll p"tYlOUS StooT
00 0
.1':> CJ" ..." I
~ .
..~~:y /'v7" II. M"-I6 .~o:,----.::-;;:~.:;::~\ 1:;31:
~ /" "l ~ I .."."." 0" - \ , .
~....~.,. , '. /,>/MW.3 ~ t ~ fJl \ \ ~Wo".,
.,' : '1"'1-''''/ r P8-~ ,~ ...:. ~ " \ a;;]
. ./ Ji . \. : I I \ I oct'
'7' ;' .:::.:~--~::::.::; I ClIO rI-'J ~ : Q . m.(1 'I'
:;/ 0" /?] MW.4 I. A I I lJ .
~.~ / . Or(~~/I~ MW-: i: W \~~-"f7-_...6MW:~
..' ./ . 8-6 0 1 .B-6 .----
/. MW0V' 0 MW.5 ~' .
&.... .".-19 ,~:'" /-4 () ~@ J 0".-2
on ,t". -." .. __r. . .._~ " .
~-T';;' 00''''''- "0'''' ~... .MW-" --. .MW~-" .MW-"
~... '\. . MW-II
'5(.
f'..-
o
150"
0°
.
~(.ALL
....
"-' -
~.
It.
...
..
u
--
.---
Fi gure 17
SOil BORING / MONITOR
WELL LOCAT:ONS
0[111(-:& l"OUST"'tS SIT!
sin .",(STIGaTlOII
PII£paRto FO"
TEXAS OEf'ARTMENT OF
WATEP ~E5/)lIPCES
AUSTIN, TEXAS
-------
LEGEND
-
TP-' UST -IT 110,1, ClltCUD IlUMftl!II
I " Dt:'TM '" ,aT 0' T[ST PIT
v.Q' ./ :~~. ---,' ..- "'~I
. " I -- " ~ :rrr.:!1
.01-.' /" ",' " ...- ".-:,.- - --',', t..... '~I
~ .',.' , I -" -, ," . . \ . I lal::::8'--J
..... . " I ' r.:1 - \' I L ~ -, ,
,. ! .." ,I '=1 ",.-J dI.'t"; .
",'" ./TP-9 :' : : I.~J r;;r" \' \- " I ~ I
,- ,,@! " 1.8 ,'-- I ' ~ -::s:::J ~~
.' . "/ Tp.6 !:ci)- it,,;,.. ..--.: ,L:,~ !~~ \ L__LLI ~C~ 1'1
.'/"// ,,' """fj) . ' ')-~:~;It-=z~'~-~'--, t:>"Jii 0 t \ 0 . rJ "1- ii'
. " " '@ @:k , \ \00 ,- 0-'
~// " TP'9 '£5T.+I~ @:,-J;,i.. '~~-~~;:...-)
/ . , . <1> :~/ " , ~~ ".T~,. ~ {ryr'1JiD CJ i
<~- __0 . ----_t-_. -- -..... ....... ,0 _::!.- - -.-. .----- 0-__0 J
~~,/ ,,~""'u"'" -~ '" ~~(~ ,','
,"'! 0 I!O'T
, a/)<~~j') , ~' / //~'
'"
..
'i
..
..
..
oc 0
c/
, ,r-\
.....
i;"::i-
......
..
...
z
z
.,
u ,
I
7rl.
Figure 18
TEST PIT LOCATIONS
GE!I£VA ''IDUSTfI'£S SITE
~In INvtS11GATION
I'P,:rAI/£!I fI)ll
TE)(A~ :'F.PIHHMfNT O~
W/lTE.R PEc;O'J!>CES
AUSTIN, ,(xIlS
-------
Tabl e 3
SHALLOW BOURG SAMPLE ANALYSES
SITE INVESTIGATION
GENEVA IIDUSTRIES SITE
Sample
Identification(l)
Concentration (ppm)
PCB Total Base-Neutra18(2)
Sample Depth (Ft.)
1.0-2.0
3.0-4.0
. 5.0-6.0
6.5-7.0
32
11
N.D.
N.D.
l-l,C-l
l-l,C-2
l-l,~-3
l-l,C-4
1-2,C-l
1-2,C-3
1-3,C-l
1-3,C-3
0-1.0
2.0-3.0
18
8
1.5-2.5
4.0-5.0
2
2
1~4,C-l
1-4,C-2
1-4,C-3
1.0-2.0
3.0-4.0
5.0-6.0
2
15
N.D.
1-5,5-1
1-5,5-2
1-5,5-4
1-5,5-5
1.0-2.0
3.0-4.0
6.0-7.0
7.0-8.0
364
72
N.A.
N.D.
1-6,C-2
1-6,C-3
1-6, C-4
1.0-2.0
3.0-4.0
4.0-5.0
22
10
6
PB-lA,C-4
PB-IA,C-5
:PB-IA,C-6
PB-1A,C-7
PB-IA,C-8
PI-IA,C-9
8.0-8.5
8.5-9.5
9.5-10.5
10.5-11.5
11.5-12.0
12.0-13.0
2
101
2700
437
387
91
( 3)
N'»'(4)
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
162 .
N.A.
0.75
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
116.2
N.A.
N.A.
N.A.
(1) .See Figure 4-10 for boring location.. See Appendix D for boring logs.
(2) Sum of individual ba.e-neutral organic compound..
Bee Section 5-5 for .pecific compound concentration..
(3) N.D.. Not Detected. .
-------
Table 4
MONITOR WELL SOIL BORING SAMPLE ANALYSES
SITE INVESTIGATION
GENEVA INDUSTIRES SITE
Sample
Identification(1)
Sample Depth (Ft.)
MW-10,ST-1
MW-ll,ST-1
24.5-25.5
.30.0-32.0
MW-12 ,C-5
MW-12 , C-6
MW-12 , C-7
MW-12,ST-1
MW-13,ST-1A
7.0-8.0
9.0-10.0
12.0-13.0
39.5-40.5
37.0-38.0
MW-14,C-1
MW-14,C-3
IN-14,C-4
MW-14,C-9
0-1.0
3.0-4.0
5.0-6.0
13.0-13.5
MW-15 ,5T-3
KW-IS ,5T-6
MW-15,ST-8
MW-15,5T-9
MW-1S,5T-10
MW-16,C-2
MW-16,C-3
MW-16,C-5
MW-16,5T-1
5.5-6.5
11.0-13.0
40.5-41.5
45.0-47.0
108.5-109.5
.'
....".
2.5-3.0
4.5-5.0
12.0-13.0
34 .0-36 .0
Concentration (ppm)
PCB Total B8Ie-Neutral.(2)
N.D. (3)
N.A. (4)
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
4
2
N.A.
2
N.D.
N.A.
N.D.
R.A.
R.D.
7
2
N.D.
2
(1) See ri!,ure 4-10 for horin!, location. See Appendis D
(2) Sum of ha.e-neutral of!,anic compound..
(3) I.D.. Rone Detected.
(4) I.A.. Not Analyzed.
N.A.
N.A.
N.A.
N.A.
R.A.
N.A.
N.A.
N.A.
N.D.
N.A.
N.A
.N.D.
N.A.
N.D.
N.A.
N.A.
'LA.
N.A.
N.A.
-------
TABLE 5
TEST PlT SAMPLE ANALYSES(I)
SITE INVESTIGATION
GENEVA INDUSTRIES SITE
Test Pit Sample Depth Below PCB( 2) Base Neutrals
Number Number Land Surfa~~__{fQ ( mg ! kg) (mg!kg)
TP-1 5-1 0-1 Composite 308 N.D.
S-3 2 Composite N.D. N.A.
5-4 3 Composite N.D. N.A.
S-5 4 Composite N.D. N.A.
TP-2 5-1 0-1 Composite 281 N.A.
5-3 2 .composite 329 N.A.
5-4 3 Composite 402 Total Basp. N{~jrals
. 30
5-5 4 Compos! te 418 N.A.
5-7 2 (West End) 511 N.A.
5-8 3 Grab Sample 519 N.A.
TP-3 5-1 0-1 Composite 23 N.A.
S-) 4 Composite 3 N.A.
TP-4 5-1 0-1 Composite 949 Tot al Base N~~jrals
. 38
5-2 4 Composite .- 2 N.A.
5-3 6 Composite 2 N.A.
TP-5 5-1 0:-1 Composite 1180 N.A.
5-2 2 Composite 710 N.A.
5-) 1 Grab Sanlple 1610 N.A.
TP-6 S-I .. 1 G~~ Sample 1410 H.A.
TP-7 5-1 - 1 Grab Sample 2 N.A.
TP-8 5-1 0-1 Composite N.D. N.A.
5-2 2 Composi te N.D. N.A.
5-3 4 Compod te N.D. N.A.
5-4 6 Compod te N.D. N.A.
TP-9 5-1 0-1 Composite N.D. N.A.
5-2 2 Compod te N.D. N.A.
5-3 4 Compod te N.D. N.A.
5-4 6 Composite N.D. N.A.
-------
7
As seen in Table 6 and Figure 19, PCB concentrations in onsite drainageway
and adjacent flood control channel sediment samples taken during the site
investigation were generally below 1.0 ppm. This is due primarily to the
placement of the temporary cap on the site, which minimized direct contact
between runoff and contaminated surface soils. Runoff carrying contaminated
soil into the.flood control channel had a greater impact on channel sediments
prior to the 1984 Planned Removal. Since minimizing the contaminant load
to the channel by capping, PCBs in the sediments have been diluted and
carried downstream during storm events. Erosion of the thin cap currently
on the site would increase the exposure of contaminated soils to runoff,
thus increasing the risk of channel contamination in the future.
Offsite soils were not found to be contaminated during the remedial
investigation. Because drainage of the site is toward the flood control
channel, migration of waste to the south or west of the site is considered
extremely unlikely. Contamination east of the flood control channel was
not detected in soil samples taken during monitoring well installation.
Drums
.In order to estimate the number of drums buried onsite, a magnetometer
survey of the site was performed. as part of the site investigation.
Probable areas of buried drums were identified as the landfill area, the
southern lagoon, and areas indicating buried metal in the magnetometer
survey. The estimated number of drums in the .~ite investigation report
is 400 to 700 drums. This estimate could increase to as high as 2300
drums if all areas of buried ~ta1, as indicated i.n the survey, contain
drums. .
Groundwater Contamination
Data from the remedial investigation, presented in Table 7" indicate that
elevated concentrations of PCBs are present onsite in the groundwater in
the 30-foot sand. The ~Jghest c~ncentrations were found in MW-3, MW-4,
and MW-5 (Figure 17). A film of oil was also present in MW-4, MW-5, and
MW-12. Measured PCB concentrations in oil/water samples taken during a
pump test in MW-4 were 400 to 600 ppb, indicating that the oil layer
contains elevated concentrations of PCB relative to the groundwater.
-
Significant concentrations of other priority pollutants were detected
in the 30-foot sand. These contaminants were primarily in the. volatile
organic (3.0-S800 ppb) and base-neutral extractables (1.0-1900 ppb)
c1asses of compounds. As seen from the data in Table 7, the highest
concentrations of base-neutral compounds were detected in MW-12, east of
the site. These priority pollutants are more water-soluble than PCBs,
and therefore, one would expect a more extensive contaminant plume (Figure
20).
Contamination in the 100-foot sand is restricted to a small area near MW-9.
Trichloroethylene (TCE) was detected in two samples taken from the well.
Because TCE was detected in an adjacent monitoring well in the 30-foot.
sand, MW-5, a hydraulic interconnection between the two water-bearing
-------
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~#/
~
~\..
.':,:"') -
....
,Loo 0
',/1 ~']
. ;/ :
,. .' L
,1 r' 0- '~r_~=
. /YY /0r.rm- I --_..----:--'- 8 Ci~. ~ 200 0
" ~~ ,-<-'u. ,~,-. --.\..' ,- ~ ~"
/ /'~ ,.,,-::~ - o' 1 !;"~I ~CA-U
,. l!!QI I'" ,oc .
./ c~,., :,'.\ - ~"'t I
. . . ' I '.8 '
.-' ,/ ilim I I \ I : .- ' . .., ~ 0 .
, ./.,' " ~.-' --.-----.' I' \ 0 ~.
~f//" /. -------------, : - , ~ ~--'!1C I --
. ' . '. . I , 0 . ,... 1r1J I
" d" A" u'
:/' .' ,'.' I" I 0" '
)" ~)'/. ~ ; \'98.---i
/; / ...t['84 I ~D <"f-- Ilr
,r "'" ' ,',y ---
""'; ~/ ~ 0
'--~- " fjJ'1 . 0 :
-.--L- .~-. I ~ ',- I
.~~_. . ,,~,,-'1-'-- . Q .' ; ..
., 41 / I "~.- . ....,-..,- - ..J '
. r.;ntND.... ., ., ~ iI= .:', -. --" .,.,.. . "'D'
. "'" """ .,., --~_. - + ,=
~. / I!!ID ~ - ([Q) ~- e,l. - 8,.:",.. :-:---.-.....,
." '",,' N. '" 0= ., =0 -,"-
.-' ..' ~ ~ ~.
,,/ /0> ". . !!?I Figure 19
-/ /) ". . PCB C""''',ATIO'''S (MG/kG)
, (' / 0 TO'" om ."n.'
. v" \ 'N SC ".E '" ".Pl'S LS
-\ ,. ./-,." J' .- ,,,. ...""......
,/ (' ) ~~ ~ '~ ""EPARED ~OA
/ /X> -tv . "" /" /' '''AS O[".'O"TO'
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- ,\" '\.\ AU~TIN,Tf.XAS
, // '\. .
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.685 PC. CONe
EIITItATIOII 11010/.'"
fORA. SAM"lE OF s[0I1oI( NT S
. 4' P~8 CONI:EU'ItA"ON IIIG/.rtn
SEDIMENT '~Ilt ;AIOPl'S
.
-------
, Table 6
STORMWATER SAMPLE ANALYSES
GENEVA INVESTIGATION
Sample No. Location(2) PCB .(uq/l~ TOC ( ua 11 ) Other Analyses(4)
SW-1 South of tank 158 9 PNA'. - None detected
SW-2 South of louth drum S5 47 PNA' s - None detected
.torage building
sw-3 South drainage ditch 6 37 PNA'I - Naphthalene
2 pg/l
sw-4 Site roadway 28 10
~w-S(5) Northeast lite
drainage ditch (1 VOA - None detected
SW-6 Northwest lite
drainage ditch (1 -
lote.
(1)
(2)
(3)
(4)
(5)
Grab samples of Itanding water on next day following evening or
eight Itorm events, except sw-5 (8ee note 5).
General location of Itanding ~ater, lee allo Filu~e 5-4.
PCB concentration in micrograms per liter (u9/l)~
filA - polynuclear aromatics, VOA . volatile organics
Sample of vater leeping into drainageway 24 to 48 hourI following
aton event.
.'
-------
Tab1e 7
nOUtm VATU SAMP1.!! AltO COIfCt18TIATtOtiS
SIT! lMV!STICAT10M
GtM!'A INDUSTI1!S SITI
5a.,18 . Toul ToUI Total Saa. Neutral toul
Identifieatloft(l) toeatioftU) ~("II) 'olatlle. (p,II)(3) Acid tKtraetalll.. (ppll)(3) !Ktraet8bl.. ("b)(3) Of.ante Carbon<../l)
S1tALLOV V!t.LS 1G-rOOT SAIIO
CV-l IN- t 16 11.0.(4) ".0. 4.2 1
GV-2 1111- 2 II 11 M. O. 19 S. 7 S
C\f-3 1111- 3 II SIII.t N.D. 90 1
GV-4 1111-4 82 51107.3 N.D. 275 '"
CV-17 HW-4 714 Pu8p Teat N. A. N.A. N.A. M.A.
GV-20 HW-4 591 r., T.at N.A. N.A. N.A. N.A.
GV- 5 HW-S 29 1167.2 N.D. 488 16
GV-6 1111-6 7 6.1 N.D. 90 16
C\f-12 1111-10 11.0(6) 2.1 N.D. 14 14
GV-Jl IN-IO <10 11.0. M.A. II. O. N.A.
Cv-u(7) HW-l0 N.D. N.A. N.A. N.A. N.A.
GV-IS Iftf-Il N.D. N.D. N.A. H.O. IS
C\f-24(7) HW-U 11.0. 11.0. N.A. N.A. N.A.
GV-311 IN-Il It. D. ".A. N.A. N.A. M.A.
CV-l0 Iftf- 12 '50 ". A. N.A. H.A. ".A.
CV-16 1ftf-12 II.D( 91 N.A. 1908 25
CV-30(7) 1ftf-12 <10 6) 31.8 N.A. 1222 II.A.
CV-J6 1ftf-12 ..0. II. A. N.A. N.A. II.A.
CV-Il IN- 11 11.0. 36.6 M.D. 16 40
GV-25 IN- U II. D. ".0. N.A. 1.2 II.A.
C\f-J4(7) IN- U 11.0. N.A. N.A. II.A. N.A.
GV-IJ 1N-14 2 696.6 N.D. 111 19
C\f-14 1N-16 II.D. 230.6 N.D. 16 J6
GV-2" IN-I7 II. D. II. D. N.A. 7.4 N.A.
cv-J7(1) Iftf-I7 II.D. N.A. N.A. N.A. N.A.
GV- 27 IN-l1 ".D. 3.2 N.A. ". O. W.A.
cv-n(7) IN-l1 11.0(6) I.A. I. A. N.A. N.A.
GV- 29 IN-l' <10 II. o. N.A. M.D. M.A.
CV-40( 1) IN-19 ".0. I.A. M.A. M.A. I.A.
cu-:1Z 1N-20 M. D. 3.4 N.A. 18.0. M.A.
O!!. WLU lOG-rOOT SAND
CV-33(1) IN-ZO W.D. II.A. N.A. II.A. II.A.
cv-t8 IN-' II. A. (5) 8.' 11.0. 2.2 I.A.
. CV-7 IN-1 II.A. 11.0. H.O. 11.0. 10
cv-U IN-7 It. D. N.D. N.A. N.A. II.A.
CV-II IN-8 11.0. "4.3 H.O. 11.0. IS
C\f- 22 IN-II ".0. ".0. M.A. 1.2 N.A.
-------
I
\
I
i
oc 0
: ," ,/'-,(Al, r'\ '
; '//7'.o'.J \'=> /' /\~"-'!!. g,~~~~I~A::'o~==:J~~ \
: j' /', . :/ ,.' ..,.---'- -~--, <=~ i
.; /' . / !'" . /~;;:,~\ ,'"~-. ~\ loj t' .-. nl I
... ///,..., . . / : : GJ ' \..J. -9 .::i;;'1 . I
~"/" / d:;-'~ (" ..-~ \\ .'.:' ~ ,,' ~~~ ~ Ii I,
//., / ' ". "..--", --- I' ..-,
~ ./'/ / /~:-. -----~;;:; -'\ h go O.8~5; r (; . ~ ~l il! )~ I
'- .~// I .. 0:'/' --~ ".L ~ .9-6 \,~,~~~-- ...;,.J il I
-----='" (._,-/~' .y.-~.- \ .; . I' .-,.' ,. ey,:-,or, 1\
~-~.. 7- - .=- '~1:::' _-!... c' "'J ~-.t"
~./ ~~~~~~~;,~~::'"/~,-"- ~'3 ~~'\- -. .::" . '" ..' -~ fJ r ", \
~ . " ,..,,' -, ' 1
. (' / ,,' .. '~ , - - ~. .Figure 20 I
,~, . ",' .."..,,, w,...
. .. ..'" . . ,,'" ,... '" :0.,'.'."'0.
o ~ ~ .(",-va ,..ou~,ltt£S ~I".[
~ ' !lot 1£ '"V£ S! !aaT '0"
, . . . . '- ~,..". '"' \'
, . . ,,' /,\', . 'I;:~,;f';~';'~.~:':''''
. " . '\. ..-; - ~ AU'''., ".'S-" !
. m /ERT/ROLLINS I
j
-------
8
No contamination was found in ~ny offsite domestic wells screened in the
100 foot sand. Also, no contamination was found in samples taken from
the 2S0-foot, 600-foot, and lOO-foot sands onsite. These deeper sands
represent a portion of the municipal water supply for the clty of South
Houston.
Contaminant Migration Pathways
Ai r
Air quality monitoring during the remedial investigation indicated that
PCBs are not currently being transported by wind and do not pose an
immediate threat to the public. This is primarily due to the temporary
clay cover on the site. However, significant disturbance of the site or
.1ack of maintenance of a protective cover could cause future air quality
degrad~tion in the vicinity of the site.
Surface Water
Data collected during the 1984 Planned Removal and the remedial investigation
. . indicate that contaminated soil is 'carried offsite via surface runoff.
This soil at least partially settles out in the flood control channel.
Consequently, surface waters on and near the site represent a potential
migration pathway. $oi1 particles that have settled out could be
re-suspended and carried downstream and/or consumed by biota in the
channel.
Currently, the temporary cap onsite minimizes the~contact between precipi-
tation and contaminated soils. As a result, particulate matter in the
runoff is not contaminated.. This is cohfirmed by comparing the sediment
sample data from the Planned Removal with sample data from the site
investigation. Lack of maintenance of the current cover would cause a
reversal of the current conditions in the channel (i.e., contamination in
the ch~nne1 would increase).
.'
'.
.--"",
Groundwater
The primary migration route via the groundwater pathway is horizontal
migration in the 3D-foot sand. It is probable that liquids from the
lagoons were driven downward by hydraulic head and were in direct contact
with the groundwater. PCBs and most polynuclear aromatic hydrocarbons
exhibit relatively low mobility, low water-solubility, and a high affinity
for adsorption to soi 1. Ch 1 ori nated solvents are much more mobile and - .
soluble in water and would be expected to migrate farther in the g.roundwater.
Free phase oil, found in MW-4 and MW-5, will increase the mobility of the
less water-soluble organics, particularly the PCBs. The current migration -
rate in the 3D-foot sand was estimated from values of transmissivity and
-------
9
flow rate in this zone is less than S feet per year. Because of the
effects of adsorption and dispersion, migration of the contaminants will
probably be less, except for contaminants carried in the free oil phase.
Migration of contaminants in the 30-foot sand is particularly important
because of the relationship between this sand zone and the flood control
channel. As mentioned previously, it is possible that the shallow water-
bearing zone could discharge into the channel. Concentrated PCBs in the
oil phase would then be transported downstream, providing a possible
human exposure route.
)
Vertical migration from the 30-foot sand to the lOa-foot sand is of
concern via two pathways. First, the potential exists for migration
directly through the intervening aquitard. Second, a potential exists
for migration through an improperly plugged oil well onsite.TCE has
been detected in the lOa-foot sand and directly above in the 30-foot sand.
Based on this data, some hydraulic connection between the two sands has
existed or currently exists. Concentrated trichloroethylene can react
with clay soils to increase the permeability; this may have been the case
at Geneva. It is also possible that an improperly plugged oil well,
. .since plugged by EPA in 1984, provided the migration route. However, the
conclusion that plugging the abandoned well has eliminated the vertical
migration route may not be drawn with 100% certainty.
Horizontal migration routes in the lOa-foot sand have been estimated in
the remedial investigation at about 2S feet per ye~_r. The direction of
flow, based on potentiometric ~ata, is to the west and southwest. One
active water well reported to be screened in the lOa-foot sand is located
0.2 mile southwest of the site. .Samples taken from this well were not
found to be contaminated.
Target Receptors
The following target rec~ptors ware identified in the remedial investigation:
- Children and adults walking, playing, or working in the adjacent
flood control channel;
- Persons consuming fish and crawfish from the flood control channel;
- Persons consuming water from the lOa-foot sand;
- Residents in nearby houses, trailers, and apartments, and employees.
in nearby commercial facilities who could be affected by future.
airborne contaminant migration from the site.
Enforcement
As noted previously, operations at Geneva Industries had been marked by
frequent spills, leaks and unauthorized discharges. Past owners have
been cited twice by regulatory authorities for improper activities at the
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10
EPA has identified ten Potentially Responsible Parties (PRPs) for the
site. Notice letters and information requests were sent to all known
PRPs in February and May of 1983. PRPs have also been given the opportunity
to participate in all actions that have been taken at the site to date.
Pilot Industries of Texas, Inc., offered $150,000 to pay for a portion of the
1984 Planned Removal in exchange for a total release of liability. This
offer was not accepted by EPA.
During a June 1983 removal action, the current owner refused to give EPA
access to the site unless he received a "hold harmless" statement from
EPA to free him of any liabilities from Federal response actions. Work
was delayed for two days, until EPA issued an Administrative Order
requiring him to grant EPA access to the site.
A second Administrative Order was issued on August 28, 1984, to Lawrence
Fuhrmann; Pilot Industries of Texas, Inc.; Winston Petroleum Company;
Intercoastal Refining; Herbert Koen, doing business as Fox Vacuum Service;
and Texaco, Inc. This order was issued for the removal of tank contents
and onsite asbestos insulation, and the plugging of an abandoned onsite
water well. In September that same year, EPA issued a withdrawal of this
. Order to Texaco and instead entered into a Consent Decree which required
Texaco to remove the contents of three of the storage tanks onsite.
Due to the current fin~ncial conditions of the parties involved with
Geneva Industries, remedial action may not be implemented in a ~imely
fashion through PRP involvement. However, the PRPs will be offered the
opportunity to part.icipate in.the implementation ,.of the selected remedy.
ALTERNATIVES EVALUATION
The Feasibility Study (FS) for the Geneva Industries site was performed .to
determine what actions, if any, would be appropriate as part of a permanent
remedy for the site. Several alternative remedial methods were developed
by the. IT Corporation, Environmental Research and Technology, Inc., and
Rollins Environmental Services (TX) team. The ultimate objective of the
feasibility study was to develop alternatives to cost-effectively mitigate'
damage to. and provide adequate protection of public health. welfare. and
the environment ftom past and potential releases of contaminants currently
onsite.
The major threats to public health and the environment attributed to the
site are: '
- . Direct contamination of groundwater by leaching from the soil and
possible deterioration of buried drums; , ,
- Contamination of surface waters by runoff from the site or possible
discharge of shallow groundwater to the flood control channel;
-------
10
EPA has identified ten Potentially Responsible Parties (PRPs) for the
site. Notice letters and information requests were sent to all known
PRPs in February and May of 1983. PRPs have also been given the opportunity
to participate in all actions that have been taken at the site to date.
Pilot Industries of Texas, Inc., offered $150,000 to pay for a portion of the
1984 Planned Removal in exchange for a total release of liability. This
offer was not accepted by EPA.
During a June 1983 removal action, the current owner refused to give EPA
access to the site unless he received a "hold harmless" statement from
EPA to free him of any liabilities from Federal response actions. Work
was delayed for two days, until EPA issued an Administrative Order
requiring him to grant EPA access to the site.
A second Administrative Order was issued on August 28, 1984, to Lawrence
Fuhrmann; Pilot Industries of Texas, Inc.; Winston Petroleum Company;
Intercoastal Refining; Herbert Koen, doing business as Fox Vacuum Service;
and Texaco, Inc. This order was issued for the removal of tank contents
and onsite asbestos insulation, and the plugging of an abandoned onsite
water well. In September that same "year, EPA issued a withdrawal of this
" "Order to Texaco and instead entered into a Consent Decree which required
Texaco to remove the contents of three of the storage tanks onsite.
Due to the current financial conditions of the parties involved with
Geneva Industries, remedial action may not be implemented in a timely
fashion through PRP involvement. However, the PRPs will be offered the
opportunity to participate in the implementation of the selected remedy.
ALTERNATIVES EVALUATION
. The Feasibility Study (FS) for the Ge'neva Industries site was' performed to
determine what actions, if any, would be appropriate as part of a permanent
remedy for the site. Several alternative remedial methods were developed
by the IT Corporation, Environmental Research and Technology, Inc., and
Roll"ins Environmental Se'rvices -rtX) team. The ultimate objective of the
feasibility study was to develop alternatives to cost-effectively mitigate
damage to, and provide adequate protection of public health, welfare, and
the environment f~om past and potential releases of contaminants currently
onsite.
The major threats to public health and the environment attributed to the
site are: .
Direct contamination of groundwater by leaching from the soil and
possible deterioration of buried drums;
- Contamination of surface waters by runoff from the site or possible
discharge of shallow groundwater to the flood control channel;
" -
-------
11
.
Remedial Objectives
The remedial action objectives developed in the feasibility study include:
- Prevent future contamination to the adjacent flood control channel;
- Minimize direct contact with contaminated soils onsite;
- Prevent degradation of offsite soils;
..
Prevent further degradation of offsite groundwater in the 3D-foot
sand. and reduce the risk of degradation of deeper sands;
- Reduce contamination in the 100-foot sand;
Criteria to measure the accomplishment of these objectives were established
based on:
. - Published criteria and regulatory standards. advisories. or guidance;
- Risk assessment performed as part of the feasibility study.
In accordance with the National Contingency Plan (NCP). the requirements of
Federal environmental regulations. guidances, and advisories are appropriate
in determining the extent of re~edial action at a ~ite. Alternatives
should be developed that meet~ exceed, and do not attain appropriate and
relevant Federal standards. .
,.. -_.:~-:,,..
The following criteria were.selected for each migration pathway at the
Geneyl--si~''''.~'_.l.: -.- - --- ---.- .. --- ---.~ -
---.- .
Pathway
Offsite soil
Criteria
Onsite soil
PCB < 25 ppm in the industrial area
PCB < 10 ppm in residential area
PCB concentration of 25 ppm, 50 ppm, 100 ppm
Surface water
Minimal PCB in runoff « 1.0 ppb)
Groundwater:
3D-foot sand
Existing concentration offsite
TCE < 1.0 ppb onsite
Groundwater:
lOO-foot sand
TCE < 1.0 ppb
The selected remedial action objectives and criteria are specific to the
Geneva Industries site and provide the basis for identifying and evaluating
possible remedial action alternatives for the site. A more complete
discussion of the objectives and criteria identification and screening
-------
12
The process by which potential remedial alternatives are developed is
outlined in Section 300.68 of the NCP. The NCP, 40 CFR 300.68 (f)(l),
states:
liTo the extent that i t- is both poss i b 1 e and appropri ate,
at least one remedial alternative shall be developed as
part of the feasibility study (FS) in each of the
following categories:
\
,....
~.........-"~7
a.
Alternatives for treatment or disposal in an off-
site facility, as appropriate;
b.
Alternatives that attain applicable or relevant and
appropriate Federal public health and environmental
requirements;
c.
As appropriate, alternatives that exceed applicable or
relevant and appropriate public health and
environmental requirements;
d.
As appropriate, alternatives that do not attain
applicable or relev~nt and appropriate public health
and environmental requirements but will reduce the
likelihood of present or future threat from the
hazardous substances and that provide significant
protection to public health and welfare and
environment. ._This-must include an alternative that
closely approaches the level of protection provided
by the applicable or relevant and appropriate
requirements.
~e-. A~tio 'action alternat1ve~----'--
.-:..,""""~~.
..--';;;:~.-
--=.
Identification and Screening of Technologies
.~.. - . - .,..
The fi rst step in the a 1 ternat he development process J s the i de.nt ifi cat ion ---
and screening of potentially applicable technologies. Screening was done by
applying the following criteria:
- Capabi11tyof satisfying remedial objectives;
~_..
- Reliability based on prior performance under similar conditions;
- Consistency 'with environmental limitations associated with the site.
Technologies which have not been proven effective under similar site
conditions and contaminant concentrations were eliminated. Also,
technologies judged incapable of satisfying the remedial objectives were
eliminated. A summary of the identification and screening of potentially
-------
Table 8
SUMMARY OF REVIEW OF TECHNOLOGIES
FEASIBILITY STUDY
GENEVA INDUSTRIES SITE
Technology
Capping
Applicability (1)
A
Comments
Dust Control
Grading
a
Combination clay/synthetic membrane cap preferred.
Applicable with capping, excavation and grading.
a
Applicable with excavation and capping.
Applicable with other technologies.
Revegetation
a
Diversion and
Collection Systems
a
Channels and dikes may have applicability for
intercepting runoff or runon when used in combination
with other technologies.
Soil bentonite wall preferred for a long term
containment. For dewatering of deep excavation, a
cement bentonite wall or sheet piles preferred.
Containment Barriers
A
Groundwater Pumping,
We 11 Systems
A
Groundwater pumping depends on level or remediation
necessary to prevent long tenm risk to water supply
aquifers. Groundwater recovery wells with submersible
pumps potentially applicable to lOO-foot sand. Recr
wells for pumping groundwater and/or oil are pOtent1
applicable to the 30-foot sand. Treatment with dischargE
of treated groundwa'ter or offsite disposal are
pQtentially applicable with pumping.
.
.J(e11 d' ~l ~9.giti..ng_~.~.c!
~an onmen
.-- .. -=' a
. -----
AppJ.!~.~~.l ~-r~~.2:.,,~~~,_monJto~tlls _:~~n.- ~~.!ir use-i~_.'!~...
longer necessary. . -
Applicable to the monitor wells then their use is no
..'hanger necessary.
Deep Well Injection
a
tIiiror.-~, -. '0.- .
Subsurface
Collection Drains
NA
_.
Not applicable for groundwater recovery due to depth
and trench stability considerations. Could be
applicable if recovery of oil from the 3D-foot sand
but not the contaminated water is required.
- ..- --.----- ..- .
(1) A = Applicable major technology
a = Applicable minor technology used in conjunction with major technologies.
-------
Table 8
SUMMARY OF REVIEW OF TECHNOLOGIES
" (Continued)
Technology
Permeable
,Treatment Bed
Appl i cabi 1 ity
Comments
Gas Collection
and/or Recovery
NA
Not applicable due to potential plugging problems,
potential channeling within the bed, difficulty of
replacing treatment media, and absence of proven
application for similar contaminants.
Subsurface conditions and waste characteristics
are not conducive to subsurface gas collection.
In addition, technologies that control waste and
groundwater migration should control subsurface gas.
NA
Drum/Tank/Surface
Facilities"Removal
)
a
Excavation of buried drums is potentially
applicable. Removal of surface tanks, process
equipment and foundations is applicable prior to
surface capping or excavation.
Incineration
A
Pumping of runoff from wastes temporarily exposed
during remediation is potentially applicable.
Rotary-kiln incinerator can destroy both PCB contaminated
liquids and solids; whereas, the liquid injection
incinerator can destroy PCB contaminated liquids only.
Liquid Removal
a
idificaton
a
. .. "
Applicable with excavation and landfill technologies.
C€ment-based, lime-based, thermoplastic, vitrification
and self-cementing technologies offer best potential
for applicability. Solidification can eliminate free
moisture, increase ignition temperature and reduce
leachability of the waste.-
";...r . --------. '-'~~. ." .- -~'.--._- -.-. ':=--....o.J::'':-- "~-_.....-~.":"-. -~. . -- .
:;..-. ._- ..- ---~:.-.- ~ .
".,,-"
"\
Biological land application is infeasible due to
tne large volume of contaminated soil and the limited
surface area available.
Biological
A
Chemical Treat-
ment of water
NA
" - .
Not generally applicable to site contamination.
Liquid-liquid extraction is potentially applicable
for the free oil phase if sufficient volumes are
treated. Chemical dechlorination is potentially
applicable to the PCBs and dibenzofurans in oils.
These methods are applicable with groundwater
pumping.
) A = Applicable major technology.
a = Applicable minor technology used in conjunction with major technologies.
-------
Table 8
'SUMMARY OF REVIEW OF TECHNOLOGIES
(Continued)
Technology
Physical Treat-
ment of Water
App1icabi1ity(1)
Comments
a
Applicable with groundwater pumping. F10cculation/
precipitation/sedimentation filtration/oil-water
separators are potentially applicable pretreatment
schemes for suspended solids or oil removal from
pumped groundwater. Carbon adsorption is potentially
applicable for treatment of the dissolved organics.
Air or stream stripping are potentially applicable for
the volatile organics present.
Not generally applicable due to waste characteristics.
Could be applicable if only reducing the concentration
of some contaminants is necessary.
In-Situ
Treatment of Water
NA
Offsite Wastewater
a
NA
NA
NA .
NA'
Applicable only for disposal of water already treated
to remove PCBs. Also limited by economics of transport,
Potentially applicable in combination with excavation,
soldification and other technologies.
Onsite Landfill
Excavation
Applicable in combination with other technologies that
treat or dispose of excavated waste~ -
Technologies that control waste and groundwater
-contamination wi11~protect water and sewer lines.
Water & Sewer
Line Protection
Alternate Drinking
Water Supply
Offsite Landfill
Disposal of Soil/
Surface Facilities
A
Drinking water supplies not Water Supply currently
contamiflated or at immediate risk. Applicable
only if long term risk is demonstrated.
In combination with excavation, solidification (as.
required) and other technologies, offsite landfill
disposal is potentially applicable.
(1) A = Applicable major technology.
a = Applicable minor technology used in conjunction with major technologies.
-------
Tab'e 9'
StMCAKY OF VIABLE REM!DlAL ACTIONS
Removal of Surface Facilities
Thi. i. a preliminary act ion common to all. act ion alternat ives.
these facilities is an associated activity.
Disposal of
Plugging and Abandonment of Monitor Wells/Piezometers
Thi. i. a preliminary action common to all action alternatives.
Excavation
This is a major action for all alternatives requiring removal of contaminated
) .oil. ~sociated actions include:
o
o
o
o
o
o
o
grading/backfilling
revegetation
liquid removal requiring disposal
possibly solidification (in limited
diversion/collection systems
disposal of loil
capping
volumes)
Capping
This i. a major. action which can occur with or without prior excavation of
.oil. Associated actions include the fol,lowing:
o
o
o
grading
revegetation. ..,
pressure relief veils
Containment Barrier
This is , ..jor ac:tion wic:h is common to ,U ac:tions whic:h do not include
around vater rec:overy option (3). A pre8lure relief vell .ystem is an
..soc:iated ac:tion.
PreS8ure Relief Well System
Thil act ion is common to a11 act ions involving a containment barrier and
-------
~1fab'e 9
Summary of Viable Remedial Actions
(Continued)
Disposal of Contaminated Water
This 15 an action common to all actions including ground water recovery (or
pressure relief wells) or excavation. Disposal can occur by the following
lIeans:
o
o
offsite deep well injection
onsite treatment with subsequent discharge
Disposal of Contaminated Soil/Surface Faciliti~s
This action is common to all excavation actions and to the removal of surface
facilities.
Disposal can occur by the following means:
o
o
o
o
offsite landfill
onsite landfill
incineration, onsite
incineration, offsite.
Ground Water Recovery Well Systems (Optional)
This action is optional and would supplement oJ replace the containment
barrier and capping actions. Three optional systems are possible to meet the
objectives.
-------
13
Development and Screening of Alternatives
The potential technologies were grouped into remedial methods and a matrix
combining the operable units into alternative remedial plans was developed.
Combinations which were duplicates or essentially equivalent to other
combinations were eliminated. Incompatible or noncomplimentary combinations
were also eliminated.
A "No Action" alternative was included in order to assess the worst case
conditions. Evaluation of the "No Action" alternative is required in
Section 300.68(f)(1) of the NCP. This alternative is carried through the
full screening process.
Section 300.68(g) states that the following b~oad criteria should be used
in-the ~creening of alternative plans:
(1) Cost. For each alternative, the cost of implementing the
remedrar-action must be considered, including operation and maintenance
costs. An alternative that far exceeds the costs of other alternatives
evaluated and that does not provide substantially greater public health
or environmental protection or technical reliability shall usually
be excluded from further consideration. For purposes of this paragraph,
an alternative that meets or exceeds applicable or relevant and
appropriate Federal public health and environmental requirements
provides substantially greater protection than do alternatives that
do not meet such requirements.
- ~
(2) Acceptable Engineering Practices. Alternative must be feasible
for the location and conditions of the release, applicable to the
problem, and represent a reliable means of addressing the problem.
(3) Effectiveness. Those alternatives that do not effectively
contribute to the protection of public health and welfare and
the environment shall not be considered further. If an alternative
has significant adverse effects, and very limited environmental
benefits, it shall also be excluded from further consideration.
Prior to the implementation of major remedial activities, certain actions
common to all alternatives must take place. These actions are listed in
Table 10. The costs associated with these actions are also common to all
of the remedial alternatives.
Detailed Evaluation of Alternatives
Alternatives retained from the initial screening and the "No Actio~"
alternative were evaluated to assess their relative effectiveness in
protecting public health and the environment. Conceptual plans for each
alternative were prepared consisting of:
- Facility designs including cross sectional and plan review;
-------
Table 10
RESPONSE ACTIONS COMMON TO ALL ALTERNATIVES
Removal of remaining onsite structures*
.- Slurry wall*
- Plugging and abandonment of monitoring wells and piezomters
- Groundwater monitoring
- Offsite soil sampling*
* Except "No Action" alternative
-~
..'~
-------
14
A summary of the retained source control alternatives. and components of
these alternatives is presented in Table 11. The conceptual plans for
these alternatives are illustrated in Section 6 of the feasibility study.
The detailed evaluation included:
- Detailed refinement and specifications;
- Assessment of extent of public health and environmental protection;
- Analysis of adverse environmental impacts;
- Construction sequence and implementation schedules;
- Detailed cost estimates. including operation and maintenance and net
present values;
- 'Implementation. reliability. and constructability.
The final evaluation consisted of a comparison of the relative levels of
protection and costs of each alternative. Total remedial costs. in terms
of net present worth. were compared with other considerations for each
alternative. These considerations included:
- Ability to meet remedial criteria;
~ Long term reliability;
- Imp1ementabi1ity;
- Operation and maintenance requirements;
- Net health and environmental benefits.
Brief discussions of each alternative. inc1uding'ihe results of the
evaluations. are given below. An in-depth discussion of the detailed
evaluation can be found in Section 6 of the feasibility study. Remedial
activities involving removal of surface facilities. groundwater monitoring.
and plugging monitoring wells are common to a" of the source control
alternatives. Construction of a slurry wall barrier and a ,pressure relief
well system is also required unless a complete groundwater re~toration was
implemented. For comparative purposes. the estimated costs of these
methods are included in the total remedial alternative estimates.
, Removal of Surface Structures
Removal of surface structures (buildings. tanks. and process equipment)
is necessary to construct a reliable long-term cap over the site. Waste
materials from the facilities have been addressed during previous removal
actions. Therefore. the structures may be disposed of in a hazardous
waste landfill.
Foundations would be demolished and disposed of where necessary for
excavation. Where excavation is not required the foundations would be
covered by the onsite cap.
-------
REMAINING
AL TERNATI VES
A
B
c
D
E
Fl, F2, F3
Table 11
SUMMARY OF INITIAL EVALUATION OF ALTERNATIVES
FEASIBILITY STUDY
GENEVA INDUSTRIES SITE
DESCRI PTION
No Action
Containment: Removal and disposal of surface facilities,
plugging and abandonment of monitor wells, capping, slurry
wall and pressure relief well system, disposal of
contaminated water.
Removal and disposal of surface facilities, plugging and
abandonment of monitor wells, excavation of soil with PCB>
100 ppm, capping, slurry wall and pressure relief well system,
disposal of contaminated water and disposal of contaminated
soil at an offsite landfill, or by offsite or onsite
incineration.
Removal and disposal of surface facilities, plugging and
abandonment of monitor wells, excavation of soil with PCB>
50 ppm, capping, slurry wall and pressure relief well
system, disposal of contaminated~water and disposal of
contaminated soil at an offsite landfill or by offsite
or onsite incineration. ~
Removal and disposal. of surface facilities, plugging and
abandonment of monitor wells, excavation of soil with PCB>
25 ppm, capping, slurry wall and pressure relief well
system, disposal of contaminated water and disposal of
contaminated soil at an offsite landfill or by offsite
or onsite incineration.
Removal and disposal of surface facilities, plugging and
abandonment of monitor wells, excavation of soil, stockpiling
of soil onsite with disposal of remaining soil at an offsite
1andfjll, construction of an onsite RCRA landfill with
placement of the stockpiled soil in the landfill, slurry wall
and pressure relief well system, and disposal of contaminated
water. Soil excavation is to the following criteria:
o Fl PCB >25 ppm,
o F2 PCB >50 ppm, and
o F3 PCB >100 ppm.
-------
15
Groundwater Monitoring
Groundwater monitoring in both the 3D-foot and 100-foot sand will be
necessary to demonstrate that the selecteq source control action is meeting
the objectives. For compliance with the post-closure requirements of
the Resource Conservation and Recovery Act (RCRA), monitoring for a
period of at least 30 years will be required.
Plugging and Abandonment of Monitoring Wells
The existing monitoring wells and piezometers that are not included in
t~e groundwater monitoring system would be plugged prior to implementing
major construction activities onsite. Plugging is necessary to eliminate
any potential vertical migration pathways through the 3D-foot or 100-foot
sands.' The plugging procedure will include:
- Flushing out the bottom of the well;
- Filling the well with a low shrink cement-bentonite grout;
- Cut the surface casing and mark the location of the well.
'Construction of the Slurry Well Barrier
Construction of a soil-bentonite slurry wall would be necessary in
conjunction with all source control remedies unless complete restoration
of the 3D-foot sand was implemented. The slurry wall would be built
around the inside perimeter of the site (linear distance of about 3,250
feet) and keyed into the aquitatd underlying the 30~foot sand. The wall
would be about 2.5 feet thick, -and average 35 feet'-deep.
In conjunction with the slurry wall, a pressure relief well system would
be installed onsite. The purpose of tHe relief system ;s to keep the'
water table onsite wall lower than the water table offsite. By doing so,
the hydraulic gradient across the wall will drive any seepage through the
slurry wall onto the site, preventing offsite migration of contaminated
groundwater. .
Sampling and Analysis of Offsite Soil
This activity is included to demonstrate whether or not PCBs have been
transported offsite by runoff or wind dispersion since completion of the
remedial investigation. Analytical results will be compared with the
established remedial criteria for offsite soils and appropriate remedial
actions will be taken.
Groundwater Alternatives
Three groundwater recovery systems were developed and evaluated in the
feasibility study. These alternatives address different levels of
remediation, and were ~eveloped to be implemented in combination with the
-------
16
Option 1 - Recover offsite contamination in the 30-foot sand.
Option 1 would be implemented in conjunction with the slurry wall barrier,
and provide for the recovery of contaminated groundwater outside the
wall. The system would require the installation of twelve recovery wells
and use an onsite carbon adsorption unit for groundwater treatment.
Treated groundwater would be discharged into the adjacent flood control
channel. Estimated capital costs are $265,760; operation and maintenance
(O&M) costs are estimated to be $410,500 per year until recovery of the
offsite contamination is completed.
Option 2 - Recovery of onsite trichloroethylene (TCE) contaminated
. groundwater for the 30-foot sand and 100-foot sand.
This alternative would involve the recovery of TCE contamination in the
vicinity of MW-5 in the 30-foot sand and MW-9 in the 100-foot sand. This
alternative would also be used in conjunction with a slurry wall, and
would require four new recovery wells and an onsite carbon adsorption
treatment unit. Capital costs are estimated to be $92,000 and O&M
costs are estimated to be $426,000 per year until remediation of the 100-
'foot sand has been completed. The annual O&M cost will then be reduced
to $375,000 until remediation of the TCE plume in the 30-foot sand has
been completed.
Option 3 - Complete Recovery of Groundwater Contamination.
Option 3 provides for both onsi~e and offsite recovery of contaminated
groundwater in the 30-foot sand and recovery of the TCE plume near the
MW-9 in the 100-foot sand. The system would include 25 new recovery wells
in the 30-foot sand plus recovery from MW-9. Onsite carbon adsorption
and subsequent discharge into the adjacent flood control channel would be
required. Total capital costs for the system are estimated at $382,880..
O&M costs would be approximately $652,200 for 2 years and $507,700 for
years 3 through 30.
. .Summary descriptions and costs for the three groundwater alternatives are
given in Table 12. For comparative purposes, costs are presented as net
present worth. The O&M costs have been discounted at 10% for 30 years
to calculate present worth.
Option 1 was eliminated as a viable groundwater alternative primarily
because of other, naturally occurring, conditions in the 30-foot sand.
This water-bearing zone has never been used as a water supply for any
purpose due to the high total dissolved solids concentrations in the
water (2,000 to 10,000 mg/l). The EPA Secondary Drinking Water Criteria
is 250 mg/l. Recovery'of the small offsite organic plume would have
virtually no effect on the overall suitability of the 30-foot sand as a
groundwater resource. Also, Option 1 would have no effect on the
100-foot sand, a documented water supply zone. Therefore, Option 1 ;s
-------
8
Comment #18:
The ash from the incinerator is still considered to be a
hazardous material. Will this material be used as backfill at
Geneva?
Response:
Yes. The ash from the incineration of waste from Geneva will be
sampled and analyzed on a random basis. If the analytical results
indicate that the contaminants of concern are not present in
significant concentrations, the ash may be considered non-hazardous.
This ash may then be used as backfill at Geneva Industries.
Comment #19:
Can and will EPA guarantee that there will be no groundwater con-
tamination as a result of any process associated with incineration,
similar to the problems currently at the Rollins facility in
Baton Rouge, La?
A properly designed and maintained cap and slurry wall at
Geneva Industries will minimize the amount of leachate generated
during the post-closure period. Operation of the pressure -.
relief system will insure that any leakage through the slurry
wall will move toward the site. Also, a groundwater monitoring
program will be in place to detect any groundwater problems
long before a significant health threat would exist.
Response:
- Comment #20:
Two commentors believed that the cap and slurry wall should b~
the selected alternative, suggesting that 1) the Fund may not~
provide much more than $5,000,000 for a remedy at Geneva, and
2) the buried drums may be deteriorated and their contents
adsorbed onto the subsurface s011s.
Response:
Superfund does not ~ave a pre-set maximum cost of a remedy for a
site.- That remedy which provides adequate protection of public'
health and the environment is considered to be cost-effective.
The drums-buried at Geneva Industries may have deteriorated.
However, EPA cannot be sure that all of the dru~s, or even most
of the drums have deteriorated. Therefore, EPA must consider
proper disposal of the drums and possible contents.
Comment #21:
Solids cannot be fed into an incinerator under the same
steady state conditions as liquids can. Batch feeding of
solids result in temperature variations, uneven combustion,
and increased probability of the emission of hazardous
constituents.
Response:
While solids may be batch fed into an incinerator, the rate of
heat input to the unit, in BTU/hour, is constant and close to .
steady state. For incinerating the solids at Geneva. the source
of heat would be auxiliary fuel, not the contaminated solids. .
Since the auxi1 iary fuel can be fed at a constant rate, temperature
variations due to changes in the solids feed should be minimized. .
Also, the incinerator would be operated at a temperature of at
least 2012°F. Because the heat value of the soil is already
,extremely low, it is unlikely that changes in the soils feed
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9
Response:
Changes in waste composition, moisture, particle size will
have an effect on the operation of the incinerator.
Shredding the solids can reduce the particle size of the solids
to an efficient level. The release of volatile organics can be
controlled by using a totally enclosed shredder, such as the
shredder at the ENSCO facility in Arkansas. The effects of soil
moisture variations can be overcome by reducing the soils feed
rate during rainy periods, thereby maintaining the desired total
heat input on a BTU/hour basis.
Coment #22:
)
Response:
Monitoring carbon dioxide and carbon monoxide in the flue gas
may not be adequate to detect incomplete combustion quickly
enough to prevent incomplete combustion of wastes. If a
shutdown occurs due to high CO or low oxygen, then unburned
material in the incinerator wi]l create additional problems.
Changes in carbon monoxide concentrations are reliable indicators
of combustion upset as excess air is lowered toward stoichiometric
conditions and combustion temperature is lowered. The maximum
allowable carbon monoxide concentration set in a permit is
usually the maximum concentration reported from the trial burn
demonstrating commpliance with the performance standards for
PCB incineration. By setting the maximum CO concentration in
this manner, CO monitoring can be an effective indicator of
incinerator performance.
Corrment 123:
When a shutdown occurs due to upsets such as excessive CO in
the stack, the temperature in the incinerator is still sufficiently
high for combustion Qf the waste to occur. The shutdown causes
the feeding of PCB materials to stop. Auxiliary fuel would
still be fed to the unit.
Comment #24: What kind of track record have incinerators had in the past?
Response:
Based on previous inspection reports from the Rollins and ENSCO
incinerators, no major problems have occurred from the operation
of PCB units,n RegioJt VI.
Comment #25: One commentor was concerned that the contractor conducting the
remedial action woul~ be granted special concessions and be
allowed to contribute to pollution in the Houston area.
Response:
By regulation, all on-site remedial actions must be able to
comply with the technical requirements of any permits that.
would be applicable to the type of operation being implemented.
No special concessions would be granted through Superfund.
Comment #26: One commentor was concerned about the possibility of dioxin and.
dibenzofuran formation as a result of a 1983 grass fire at the
-------
Response:
Comment #27:
. R~sponse:
10
On November 19 and 20. 1985. EPA took 23 surface soil and three
groundwater samples' to be analyzed for dioxins and dibenzofurans.
The analytical results from these samples were included in the
remedial investigation report. and submitted to the staff at the
Centers for Disease Control in Atlanta. Georgia for review.
Based on this review the staff at the Center concluded that the
concentrations of dioxins found at Geneva Industries do not
represent a chronic health threat.
During the installation of shallow monitoring well. PCB 1232
was detected in a core sample at a concentration of 1500 ppm
at a depth of 34-36 feet. However. this is not being considered
during the remedial action.
This sample was taken during the installation of a monitoring
well. in a tight clay six feet below a contaminated water-bearing
zone. No PCBs were detected in other s011 samples taken during
this depth at other well locations onsite. EPA does not believe
that the PCBs detected in the core samples in question were.
actually at that depth (35 feet). but were inadvertently carried
down with soils from a lesser depth during the installation
procedure.
. Comment #28: Three commentors expressed concern over a Housing and Urban
Development housing project near the site. and the effect the
site has had on the citizens living there.
EPA forwarded information to the Housing and Urban Development
staff in 1983 indicating that Geneva Industries would not pose
an immediate threat .~o "the senior citiz~ns living in the project.
This assessment has since been substantiated by the remedial
investigation. No soil contamination was detected within several
hundred yards of the site and groundwater contamination has not
migrated offsite. EPA still believes that the' housing project
is a safe place to live. EPA would also not recommend or select
a remedy that would pose a health threat to the citizens in the
project.
Comment #29: Several commentors suggested that more public participation was
needed in the remedial investigation and decision-making process.
Response:
Response:
Comment #30:
Response:
EPA believes that the current community relations regulations set
forth in the National Contingency Plan provide for adequate
public participation in the Superfund program.
One commentor expressed concern about the drinking water aquifer
not being addressed in the remedial investigation. . .
The drinking water aquifers were not investigated in the remedial
investigation because EPA and the Texas Water Commission did
not find PCBs in the 100-foot sand during investigations prior
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11
PCBs would have migrated vertically to the 600-foot sand zone
and not be detected in the upper zones.
Comment #31:
One commentor expressed a concern about permitting of incinerators
or requirements to dismantle an incinerator after a remedial action
is completed at a Superfund site. .
Pennits are not required for onsite remedial actions at
Superfund sites. However, the technical and performance
requirements that would be included in an applicable permit
must be met. An incinerator placed at Geneva Industries would
be dismantled upon completion of the remedial action. .
Response:
Comment #32: What data was used to assess faulting in the vicinity of the site?
Response:
Several maps and diagrams were presented in the remedial investi-
gation and fault study documents to support the conclusion that
faulting in the vicinity of Geneva Industries will not have an
effect on migration of the contaminants from the site.
Comment #33:
Several commentors suggested that methods of thermal destruction
other than rotary-kiln incineration exist. .
This is true. Rotary-kiln incineration was used in the feasibility
study as a concept for the purpose of developing a cost estimate
for comparison with other categories of technologies. It was
also used because the two mobile incinerators in Region VI
currently permitted for PCB destruction are rotary-kiln units.
Durins the aesign of the remedy, any permitted thermal destruction
unit would be evaluated, and any unit meeting the required
performance criteria for PCB destruction would be eligible to
bid on the remedial action contract.
Response:
Comment #34: Two commentors questioned the lack of detailed evaluation of
biodegradation in the feasibility study. .
Response:
Biodegradation as a possible reme~ was eliminated during the
initial screening of alternatives. Data exists in research
literature and in field work to suggest that biodegradation of
PCBs in liquid media is possible. Several people have done
work with both batch and continuous flow aeration basins and
reported varying degrees of success. However, 1andfarming or
land treatment of PCB-contaminated soils has not been documented
in research literature.
I
~
One company has presented data indicating a reduction in PCB
concentrations in a mixture of transformer oil, sludge, water
and soil in a batch reactor aeration unit pilot study. This . ~
technology is not considered feasible at Geneva Industries for
. several reasons. First, no data was developed to show what effects
the other contaminants at Geneva m~ have on biodegradation,
such as toxicity to highly specialized microorganisms. Second,
a bioreactor would have to be very large in order to address
-------
12
study, the contaminated mixt~re would have to be a liquid for
proper aeration and mixing, resulting in a much larger volume of
material to be handled during remedial action. This in turn may
lead to problems of: 1) dewatering the basin material prior to
ultimate disposal, and 2) ensuring that any effluent from the
reactor would meet discharge requirements. Treatment of the
effluent may be required prior to discharge.
Site constraints would have an effect on the size of a reactor
that could be built onsite and still provide a reasonable time
in which to complete the remedial actions. Data from one pilot
study indicated that about 4 months were required for degradation
of one ton of material. While a larger basin may permit treatment
of larger volumes, a balance between the size of the reactor and
the size of the site would be required.
Application of a microbial population directly to contaminated
soils in-situ would present several problems. First, the clay
soils at Geneva may have an inhibitory effect on biodegradation.
Dense clays may inhibit the dispersion of microbial suspensions
applied to the soils unless accompanied by soil tilling. Soil
tilling is limited by depth; excavat10n of s011 to a treatment
cell would be necessary, as would some stockpiling of contaminated
soils. land treatment would be done under much dryer conditions
than bioreactor degradation. The low soil moisture in a land.
treatment/landform would allow for more exposure of microbes
to sudden and wide variations in climate conditions. Also, low
soil moisture content would inhibit the dilution of products of
metabolism which may be toxic themselves.
- . .
Comment #35:. How will EPA address the asbestos present at Geneva?
Response: The asbestos at Geneva Indu~tries was removed from the site as
part of a removal action in September 1984. The material, used
as insulation for the process equipment, was placed in plastic
bags and transported to a hazardous waste landfill. Asbestos
introduced into the incinerator would be captured by the wet
scrubbers in the stacks. A minimal amount of particulate may
escape, but it would not be anticipated that this amount would
pose a ~ign1ficant health threat.
Comment #36: How will scrubbers be cleansed? What will be done with toxic
materials found?
Response:
Water from the scrubbers will be neutralized and analyzed for.
PCBs. Scrubber water containing no PCBs is discharged from the
site. If PCB's are detected, water would be treated by carbon
adsorption prior to discharge from the site.
Comment #37:
Health effects from the transportation of wastes to potential
land disposal sites in Alabama or Nevada can be expected to
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13
Response:
No studies have been done, to EPAls knowledge, comparing transpor-
tation related health effects to on-site remedial alternative
health effects. EPA therefore cannot adequately comment on such
a relationship or comparision.
Comnent #38:
Criteria for quantatively evaluating options for their potential
to minimize health impacts should be more fully developed in
the feasibility study.
Response: Any remedial alternative must comply with applicable Federal
environmental regulations and will adequately protect human health
and the environment and minimize health and welfare impacts.
)
Respons,e:
Particulates from the flue gases are toxic and must be
permanently contained. The particulates could be stabilized
in a block matrix.
The specific design of the pollution control equipment is beyond
the scope of the feasibility study. Pollution control equipment
for an incinerator will be designed such that all applicable'
Federal and State regulations and guidelines will be met.
COl1l1lent #39:
The performance standards for particulate emissions set forth in
the Resource Conservation and Recovery Act and the Toxic Substances
Control Act provide adequate protection of health and the environ-
ment. The disposal of particulate material captured by the
stack scrub6ers is a consideration to be addressed in the design
of the remedial alternative.
Response:
.-
No mobile incineratQrs are adequately_equipped with process
controls and emission controls including a bag house.
Mobile incinerators that have been granted operating permits are
equipped with adequate controls to comply with current Federal
performance standards. Bag houses may be retro-fitted to existing
permitted units for additional particulate control. .
Comment #40:
Comment #41: Municipal refuse should be used as an auxi1lary fuel for the
i nci nerator. .
Response: Because-research has shown that municipal refuse may contribute
to the formation of chlorinated dioxins when used as a fuel,
refuse will not be used at Geneva Industries.
Comment #42: One commentor submitted data for consideration in setting
emission standards for incinerator units.
'-
Response:
Emissions standards are set to minimize impacts on human health
."
and the environment. As toxicological assessments become more'
refined, adjustments may be made to the regulations setting
-------
Comment #43:
Response:
Comment #44:
Response:
Comment #45:
.Response:
Comment #46:
Response:
Comment #47:
Response:
14
One commentor suggested that the property should be usable
after the remedial action is completed.
EPA is bound by regulation to implement the most cost-effective
remedy which adequately protects public health and the environment.
Potential future land use is generally not a consideration in
selecting a remedy although current land use may be considered.
One commentor suggested that solidification and/or stabilization
of the soils may be a viable remedy for the site.
Solidification/stabilization of waste was eliminated during the
initial evaluation of technologies in the feasibility study.
Major drawbacks to this technology, as applied to Geneva Industries,
include: 1) possible problems due to organic content of the
waste and silt/clay content of the soil; and 2) possible high.
energy cost involved in some of the solidification methods such
as vitrification or micro-encapsulation. .
What effect will changes in soil moisture have on incinerator
performance?
Extremely wet soils will be fed into the incinerator more slowly
than dry soils. This will maintain the overall BTU/hr feed at
the design rate. Standing water i~ ~he excavated areas will be .
treated by granular activated carbon and discharged into the
adjacent flood control channel.
Several people demanded that a new feasibility study be done
. for Geneva Industries.
EPA believes that the feasibility study that has, been completed
is adequate. No second feasibility study is necessary.
What would be the short-term and long-term liability for
damages sustained as a result of onsite incineration at
Geneva if such damages were to occur? Who would be liable?
The concern seems to be that people in the vicinity of the
Geneva site, who may be in a position of possible contamination
by hazardous emissions from a malfunctioning incinerator, might
experience injuries not immediately discoverable; i.e., cancer.
Under tort law, the statute of limitations for damages under the
circumstances described would begin~o run when the injury is .
discovered. Liability would attach to the party or parties. .
proximately responsible for any injury. The Federal Tort Claims . ~
Act provides that its general waiver of sovereign immunity is
not applicable to circumstances in which a federal agency ;s
-------
.
.
Comment #48:
Response:
C Ollll'le n t #49:
Response:
15
EPA should assist in the establishment of permanent facilities
for the disposal of hazardous waste.
EPA is not in the 'business of commercial hazardous waste disposal.
The Agency prefers to let private enterprise handle the disposal.
EPA should limit testimony to scientists and affected citizens.
EPAls regulations and policies do not allow us to prevent anyone
from making a statement at a public meeting. These regulations
and policies were created to ensure that every citizen of the
United States would be represented by the Agency in its endeavor
to protect human health and the environment.
-~
-------
.
Attachment A
Community Relations Activities
Conducted at the Geneva Industries Sites
Community relations activities conducted at the Geneva Industries site to
date include the following:
o An EPA press release of June 2, 1983, announced immediate action to
fence the Geneva site.
o Congressman Andrews held a town meeting on July 6, 1983, to discuss
the Geneva site. EPA representatives were speakers at this meeting.
o Geneva was added to the NPL in Septemeber of 1983.
o EPA press release of September 15, 1983. announced a public meeting
to discuss the planned removal. Th~meeting was held October 6. 1983,
and 63 persons attended, including media.
o In Janaury 1984. TWC announced the approval of the Cooperative Agree-
ment for Geneva.
o On February 3, 1984, EPA announced the completion of the surface
cleanup.
o The TWC announced the selection of a contractor to begin the RIfFS on
April 9, 1984.
o
TWC conducted community interviews wit~ local officals and interested
residents and finalized the Community Relations Plan 1n M~ 1984.
o Information repostiories were estabilshedat the City Secretary's
office in Houston; Houston Public Library; University of Houston
M. D. Anderson Library; Rice University Fondren Library; South Houston
Branch Library; Houston-Galveston Area Council; and the Texas Water
Commission offices in Deer Park and Austin.
o EPA issued a press release on June 29, 1984, announcing that an aban-
doned oil well had been plugged.
o The Feasibility Study was released for public review and comment in
~1~
o EPA held a public meeting at the South Houston Community Center in
South Houston to describe the RIfFS reports and to respond to citi-
zens' questions. 397 people registered at the public meeting on '
May 22, 1986. '
o The transcript of the public meeting was sent to the arearepositor1e$
on June 5. 1986.
o The public comment period closed on June 10, 1986.
o This Responsiveness Summary was provided to all speakers at the
public meeting on May 22 and all citizens who commented during the
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17
TABLE 12
SUMMARY OF GROUNDWATER ALTERNATIVES
Option
Description
Net Present Worth
1
Recover Offsite Contamination in
30-Foot Sand
$3,303,000
2
Recover TCE in 30-Foot and
100 foot Sand
$3,820,000
3
Recover all Offsite and Onsite
Contamination
$17,298,000
Option 3 was also eliminated as a viable alternative. The net present
worth of this alternative is considerably higher than the costs of Option
.1 or 2 ($17,298.000 vs. $3,303,000 and $3,820,000. respectively). However,
this alternative does not provide a commensurate increase in health and
environmental benefits. Option 3 would provide some additional benefits
to the 30-foot sand in comparison to Option 1 by recovering all of the
contamination. However. the high total dissolved solids concentrations
occurring naturally in this zone would still preclude its use as a resource
after completion of the remedial.action.
Currently, the only potential exposure routes associated with the
contamination in the 30-foot sand are the flood control channel and the
lOO-foot sand. The 30-foot sand may, periodically, provide a base flow
for the flood control channel. The construction of a slurry'wall barrier
and pressure relief system would effectively prevent any contamination,
including the free oil phase, from impacting the flood control channel.
The cost of the slurry wall system, $378.560, is significantly lower than
1 year of O&M costs for Option 3, while providing the same benefit to the flood
control channel. The slurry wall is therefore considered to be the most
cost-effective method of controlling contamination in the 30-foot sand
and protecting the flood control channel.
Option 2 provides a level of protection to potential users of the 100-foot
sand equivalent to the level of a protection afforded by Option 3. The
primary contaminant of concern regarding the 100-foot sand is trichloro-
ethylene. Recovering the TCE from both sands would minimize the threat
of further contamination of the 100-foot sand and potential exposure to
current or future human receptors. Although contamination would remain
in the 30-foot sand in the form of PCBs and base neutrals, these contaminants
are not expected to impact the 100-foot zone. PCBs are not very water-
soluble and will adsorb onto the soil in the upper water-bearing zone.
-------
o
d
18
The base-neutral compounds are more water-soluble than PCBs, but will not
effect the permeability of the aquitard. Therefore, base-neutrals will
tend to migrate horizontally with the flow in the 30-foot sand.
The recommended alternative for groundwater remediation at Geneva is
Option 2 implemented in conjunction with a slurry wall barrier around the
Recovering the TCE would effectively protect the groundwater supply in
the 100-foot sand by reducing concentrations below the 10-6 health
risk level (2.8 ppb). The slurry wall would offer two benefits:
site.
- Prevent migration of contaminants in the 30-foot sand offsite and
.possib1e exposure of the flood control channel to a free phase
PCB-contaminated oil;
- Increase the efficiency of the recovery system by minimizing the amount
of uncontaminated water pumped through the recovery system from the
30-foot sand.
As mentioned previously, the capital cost of this alternative is $91,470;
O&M costs are $426,000 for 2 years, then $375,500 for years 3 through 7.
'This alternative would be implemented with a slurry wall, a pressure
relief system, and a source control (soils) remedial action. The source
control alternatives developed in the feasibility study are discussed below.,
Soils Alternatives
Alternative A - No Action
Section 300.68(f) of the NCP specifies that the "No A~tion" alternative
be evaluated. Under this alternative, no remedial action would be implemented
at Geneva Industries. Section 300.68(g)(3) states: '
"Those alternatives that do not effectively contribute to the
protection of public health and welfare and the environment shall not
be considered further." ,
The absence of remedial action would allow for long term erosion of the
site due to wind, precipitation, and possible flooding as erosion continues.
Exposure of soils contaminated with up to PCBs to 12,000 ppm would occur.
The following threats to public health and the environment would be posed
if no remedy was implemented at the site:
- Direct contact with surface soils;
- Migration due to surface water runoff;
Fugitive dust migration offsite;
Migration due to leaching and subsequent
- Consumption of contaminated groundwater.
The only activities associated with the site under the "No Action"
would be groundwater monitoring and periodic inspections. Because the
risks to public health and the environment associated with the "No Action"
alternative are unacceptable, this alternative is eliminated.
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19
Alternative B - Containment by Cap and Slurry Wall
Alternative B involves leaving all contaminated soils in place and the
construction of a multi-layer cap across the site. The cap would be
designed in accordance with performance standards in the Resource
Conservation and Recovery Act (RCRA). Containment of the contamination
would be completed by the construction of a slurry wall barrier around
the site perimeter and a pressure relief system to control infiltration
into the containment cell. Net present .worth of this alternative is
$4,459,000.
. \
Alternative C, D, E - Partial Excavation and Disposal
Alternatives C, D, and E all involve excavation of contaminated soils and
buried drums and disposal of these materials. Three methods of disposal
were "evaluated in detail in the feasibility study: offsite landfill,
offsite incineration, and onsite incineration. The differences among the
three alternatives are associated with the extent of excavation as defined
by the concentrations of PCB in soils remaining onsite. Alternatives C,
D, and E require excavation of soil with PCB greater than 100 ppm, 50 ppm
and 25 ppm, respectively. The net present worth of these alternatives is
presented below:
Offsite Onsite Offsite
Alternative Landfi1~ Incineration Incineration
C $15,867,000 $21,406,000 $32,100,000
D $20,184,000 $26,175,000 . $43,000,000
E $25,695,000 $32,273,000 $57,000,000
Net present worth includes capital cost and operation and maintenance
(O&M) costs. O&M costs are discounted using a discount rate of 10%
for 30 years. .
Alternative F - Partial Excavation and Disposal in Onsite Landfill
Alternative F has three options defined by levels of excavation.
Alternatives F1, F2, and F3 refer to excavation soils contaminated with
greater than 25 ppm, 50 ppm, and 100 ppm of PCBs, respectively. .A slurry
wall would also be constructed to prevent migration of contamination via
the shallow groundwater. Construction of the vault would be consistent
with the performance requirements for landfills outlined in RCRA.
. ~
The vault would primarily be an above ground facility. Due to the limited
-------
20
disposal would be required during construction. Total excavation and
offsite disposal soil volumes for the landfill alternative are greater
than for Alternatives C, 0, And E.
The net present worth of the on-site landfill alternatives are:
F1
F2
$36,903,000
$34,251,000
F3
$31,472,000
Community Relations
Public interest in Geneva Industries during the initial phases of the
project was moderate. Informational meetings were held in South Houston
prior to the Planned Removal and the site investigation. Approximately
55 people attended these meetings.
Public interest in the site increased significantly upon completion of
the feasibility study. The two-week public notice period began on May 3,
1986. This was followed by a public comment period which closed on June
10, 1986. The comment period was extended one week in response to the
extensive interest shown at the May 22, 1986, public meeting to present
the results of the. feasibility study. Approximately 450 people attended
the meeting to express opposition to onsite incineration as a disposal
method for the contaminated soils. Responses to the,Lomments received
during the comment period are outlined in the "Community Relations
Responsiveness Summaryllattached to this Record of Decision.
Consistency with Other Environmental Laws
The Environmental Protection Agency's policy is to select a remedial
action that attains or exceeds applicable or relevant and appropriate
Federal environmental and public health requirements. Other Federal criteria
and advisories and State standards may also be used, with adjustments
for site-specific circumstances. The Federal regulations which will have
an impact on the proposed remedy for the Geneva Industies site include:
2.
The Resource Conservation and Recovery Act (RCRA), 40 CFR Part 264:
technical requirements for the surface cap, incinerators, and landfills; .
The Toxic Substances Control Act (TSCA), 40 CFR Part 761: disposal
requirements for PCB-contaminated materials; technical standards for
landfills and incinerators.
. -.c.'
1.
Offsite facilities used for the disposal of hazardous materials from a
Superfund site must be in compliance with the requirements of the
applicable and relevant environmental laws, including all appropriate
permits and authorizations. Also, wastes may not be taken to an offs~te .
facility if the receiving Regional Administrator determines that the facility
-------
21
The regulation set forth in RCRA and TSCA were reviewed to determine if
the recommended alternative (Alternative C) meets these requirements.
This alternative will be designed to meet the design standards for a
surfac cap in RCRA. Free liquids found in drums excavated from the site
will be solidified prior to disposal in order to comply with the free
liquid land disposal ban. Also, it is anticipated that the excavation
and disposal activities can be completed prior to November 8, 1988, the
effective date of the ban on land disposal of solvents, should this apply
to the soils at Geneva Industries.
)
This alternative also meets the technical requirements for the disposal
of materials contaminated with greater than 50 ppm of PCBs. Offsite
facilities used for the disposal of these materials will be permitted for
PCB disposal under TSCA and will be compliant with the offsite disposal -
policy under Superfund. TSCA staff has been consulted and a clean-up
level of 100 ppm onsite with a surface cap is considered acceptable.
The recommended alternative will include a groundwater monitoring program
to determine if future conditions warrant additional remedial action. This
program will continue for at least 30 years. If it found that the remedy
did not correct the problems associated with the site,-further remedial
- actions will be evaluated.
Recommended Alternative
Section 300.68(i) of the NCP states that "The appropriate extent of remedy
shall be determined by the lead agency.s selection of a cost effective
remedial alternative that effectively mitigates and minimizes threats to
and provides adequate protection of pUblic health-and welfare and the
environment." To this end, Alternative C in combination with groundwater
Option 2 is the recommended remedial action for the Geneva Industries
site. The components of this alternative are as follows:
- Remove and dispose of all surface facilities;
- Plug and abandon unnecessary monitoring wells;
- Excavation of 22,500 cubic yards of soils contaminated with greater than
~. -~
100 ppm PCBs; . -
- Excavation of all buried drums onsite;
- Disposal of excavated material in an EPA-approved offsite facility;
- Construction of a slurry wall barrier around the site with a pressure
relief well system;
- Construction of a permanent protective cap across the site surface;
- Recovery of the TCE contaminated groundwater in both the 30-foot and
100-foot sands. .
- .
The areas of soil and groundwater contamination addressed by the recommended
alternative are illustrated in Figures 21 and 22. Figure 23 is a cross- - ~
sectional view of the soil excavation and surface cap. The rationale for
the selection of Alternative C and offsite landfill disposal is outlined
-------
M.JOIt AAUS OF PC8
CONTAMINATION> 100""18
u
~
()
D
liMITED TO I' DEPTH
LIMITED TO 'I.' DEPTH
IlUAIED CONTAMINATION TO D!PTH INDICATED.
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Figure 21
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-------
LEGEND
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FiQure 22
OPTION e21
GAOUND WATER RECOYER'
GENEya "'O'15T"'E' SITE
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Figure 23
CROSS.5EcnONAl VI(W
ALTERNATIvE C
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22
Alternative B (cap and slurry wall) was eliminated because adequate
protection of public health and the environment would not be provided.
While direct contact with and migration of contaminated soil would be
eliminated, protection of the 30-foot sand would not be afforded. The
contents of the buried drums, if allowed to remain onsite, could leak
and migrate vertically into the 30-foot and possibly the 100-foot sand,
then horizontally offsite.
Alternatives 0 and E were eliminated because the excavation of additional
soil would not provide a commensurate increase in protection of public
health and the environment. As long as the surface cap is properly
maintained, direct contact and contaminant migration by runoff and wind
will be prevented. Therefore, Alternative C offers the same level of
protection as Alternatives 0 and E at substantially lower costs, even
though the concentration of PCBs in the soil under the cap are higher
with Alternative C. .
" )
Alternatives Fl, F2, and F3 were eliminated for several reasons. First,
a landfill at Geneva Industries would not comply with the siting require-
ments set forth in the Toxic Substances Control Act (TSCA). These
requirements state that the water table must be at least 50 feet below
"the bottom of the landfill. The water at Geneva has been measured at
15 feet below the ground surface, and the first water-bearing zone
is 30 feet below the ground surface. A variance to the TSCA requirement
would be necessary in o~der to construct a landfill onsite.
The second reason for eliminating the onsite landfiJ1 options involves
site constraints associated with landfill construction. A landfill would
take up the entire site area, leavfng no place for temporary storage of
contaminated soils excavated during installation of the bottom landfill
liners. This would result in approximately 50,000 cubic yards of soils
requiring disposal at an EPA-approved offsite landfill. This volume is
higher than the volume considered in the remedy (22,500 cu. yd.). The.
additional disposal volume is not considered to provide additional benefits
and therefore is not a cost-effective alternative.
The third reason for eliminating Alternatives fl, f2, and F3 is a result
" of the required offsite disposal. Transport and offsite disposal of
soil increases the cost of the these alternatives by almost $10,000,000
compared to the corresponding offsite landfill alternatives. Again,
the increased cost is not justified by a commensurate increase in
protection.
Of the three disposal methods evaluated for Alternative C, removal of wastes
offsite for land disposal or incineration was selected over onsite".
incineration. Significant public concern was voiced regarding the safety
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~
ct
23
official comment period. It is the Environmental Protection Agency's
position - backed by a great amount of operating data from other locations
- that incinerators can be designed, constructed, and operated in a manner
that is environmentally sound and protective of public health. Incineration
also destroys organic contaminants and removes them from the environment.
However, since all of the disposal methods evaluated under Alternative C
offer the same level of protection for public health and the environment
and since onsite incineration was found to generally cost more than
offsite remedies, offsite disposal has been selected as the remedy for
this site.
Currently, offsite incineration has limitations in terms of its cost and
the availability of facilities. Only three commercial, non-transportable
incinerators now exist which are permitted for PCB disposal. These inciner-
ators are operating at very close to full capacity. The high cost is a .
direct result of the limited number of facilities currently available.
These limitations are expected to become less of an obstacle in the near
future as additional incinerators are designed and permitted.
The availability of more permitted thermal destruction facilities in the
near future may lower the costs associated with the technology. EPA
'plans to design the onsite logistics and construction activities associated
with Alternative C, and evaluate the availability and costs of offsite
landfills and incinerators at 70% completion of the remedial design.
Based on the results of the evaluation, the offsite disposal method will
be selected, and the remedial design completed.
Cost of Selected Alternative
The estimated capital 'cost of Alternative C, with offsite land disposal
of soils and drums, is estimated to be $14.9 million. Disposal of the
excavated material by offsite incineration would increase the estimated
capital costs to $32.1 million. Operation and maintenance costs are
estimated to be $107,000 per year for 30 years. Groundwater Option 2
increases the capital cost of the remedial action by $92,000 and the
operation and maintenance cost by $425,000 for years 1 and 2, and by
$376,000 for years 3 through completion of the groundwater remedy.
Operation and Maintenance
Operation and maintenance (O&M) activities are required during implemen-
tation of the remedy and during the post-closure period. The major O&M
during implementation are associated with the groundwater recovery
system of Groundwater Option 2. This includes replacement of pumps,
wells, and spent carbon and electricity and labor required to operate the
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24
inspection and repair of the surface cap, operation of the pressure
relief and leachate collection systems, and semi-annual groundwater
monitoring. A detailed operation and maintenance plan will be written as
part of the remedial design.
The Trust Fund is available for O&M costs for the selected remedy for a
period of up to one year after completion of construction of the remedy.
For the trichloroethylene recovery system, O&M begins when groundwater
recovery begins. The State of Texas will be responsible for the operation
and maintenance of the system through the completion of the groundwater
remedy.
)
Operation and maintenance of the cap and slurry wall and the pressure
reljef system and post-closure groundwater monitoring will become the
responsibility of the State after completion of the remedial construction
and continue for a period of at least 30 years. If significant offsite
contamination is detected during the post-closure period, additional
corrective measures will be evaluated.
Schedule
The schedule for the remedial design 'and construction of the remedy at
Geneva Industries is currently dependent upon reauthorization of
Superfund. The design Rhase of the project will begin as soon as funding
becomes available, either through reauthorization or a continuing
resolution. When funding becomes available, the design of the remedy will
take an estimated 12 to 18 months to complete. Remedial construction will
begin as soon as possible after ~Qmpletion of the d~5ign, and take
approximately 18 to 24 months to complete, depending on the disposal method
selected.
"
.
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,D
TEXAS WATER COMMISSION
'aul Hopkins, Chairman
.alph Roming, Commissioner
John 0, Houchins, Commissioner
September 10, 1986
Mr. Dick Whittington, P.E.
Regional Administrator
u. S. Environmental Protection
Region VI
1201 Elm Street
Dallas, Texas 75270
Agency
Dear Mr. whittington:
Re:
Geneva Proposed Record of Decision
Larry R. Soward, Executive Director
Mary Ann Hefner, Chief Clerk
James K. Rourke, Jr., General Counsel
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We have reviewed the proposed Record of Decision (ROD) for the
Geneva Industries Superfund Site. We have no objection to the
selected remedy. as described in the proposed ROD of disposal of
contaminated soils with greater than 100 ppm of PCB's at an
EPA-approved off-site land disposal facility. We would like to
note, however, that the obligation of State monies for a period
of 30 years after the remedial construction activities are
complete may be a violation of Article VIII, Section 6 of the
Texas Constitution which addresses the appropriation of money
beyond a two year period.
Skt.~
Larry R. Soward
Executive Director
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
1201 ELM STREET
DALLAS. TEXAS 75270
Geneva Industries, Houston, Texas
Responsiveness Summary
This community relations responsiveness summary 1s divided into the
following sections:
Section I. Overview. This section discusses EPAls preferred alternatives
for remedial action, and the public's response.
Section II. Background on Community Involvement and Concerns. This section
provides a brief history of community interest and concerns raised during
the'remedial planning activities at the Geneva Industries site.
)
. I. OVERVIEW
At the time of the public comment period, EPA announced several alterna-
tives for corrective action at the Geneva site.
.
EPA's recommended plan included excavating approximately 22,500 cubic yards
of contaminated soil throughout the site. EPA considered three disposal
options for the excavated soils:. 'offsite land dispO'sal, onsite incineration,
and offsite incineration. The excavations, ranging in depth from one foot
to approximately twelve feet, would affect about half of the 13-acre site.
The excavated areas would be backfilled, graded, and replanted.
A slurry wall, averaging 35 feet deep, would be built around the site.
The entire site would be covered with a seven foot thick cap consisting of
three feet of clay, a .24-inch thick plastic liner, two feet of sand, two
feet of topsoil, and new vegetation. The multi-layered cap would eliminate
direct contact with the remaining contaminants and prevent them from being
carried offsite in ~tormwater runoff.
EPA also proposed to pump groundwater from sands at 30 feet and 100 feet
and decontaminate it through the process of carbon adsorption. The decon-
taminated water would be discharged into the flood control ditch adjacent
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"~
t)
2
The estimated cost of the cleanup ranged from $15,000,000 to $28,000,000,
depending on the disposal method selection. Ground water monitoring, cap
rep~ir and the cost of onsite incineration, offsite incineration, and
landfilling are comparable. Erosion control for thirty years would cost
an additional $4,461,000.
Judging from the comments received during the public comment period,
the public is opposed to and will protest if onsite incineration is the
selected remedy for the Geneva site.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT
Pre-Superfund (1971-1982) community involvement at the Geneva site has
historically centered around numerous public hearings to solicit comments
from interested parties prior to the issuance or amendment of the facili-
ty's wastewater discharge permit. The general public was notified of each
hearing"through a notice published in the local newspaper; in addition,
local governmental groups, and other affected state agencies were also
notified.
With the onset of Superfund activities at the site, community involvement
and awareness increased significantly. On July 6, 1983, a town meeting,
sponsored by U. S. Representative Michael A. Andrews (25th Congressional
District), was held at the City Cafe in South Houston. Approximately 100
people were in attendance, including State Representative Ralph Wallace,
South Houston Mayor Lyn Brashe~, South Houston Cit~ Aldenmen Homer Roades
and J. B. Anthony, and various residents of the area. .
.-
On October 6, 1983, a public meeting was held by EPA at the South Houston
Intenmediate School to explain the plan~ed removal action to -mitigate the
immediate surface hazards at. the Geneva site. Approximately 60 residents
were present as well as representatives from the EPA, Texas Department of
Water Resources (now the Texas Water Commission), Railroad Commission of
Texas, the Centers for gisease-Oentrol in Atlanta, and local city officials.
Frequent and substantive communication, both oral and written, continued
between the Texas Water Commission (TWC) and the officials of the City of
South Houston.
Early discussions with area residents revealed that the most significant
concern of the South Houston community was the impact of the Geneva site on
the area's drinking water supply. The City of South Houston relies entirely
on ground water wells for drinking water. Officials and residents of the city
expressed their fear that contamination from the site might seep down old oil-
wells in the area and contaminate water taken from sand layers 600 to 1,300
feet deep. Of particular concern was the existence of a City of South Houston-
water well located approximately 1,300 feet away from the site. Residents also
expressed concern with regard to children playing in drainage ditches which
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3
III. SUMMARY OF PUBLIC COMMENT DURING THE PUBLIC COMMENT PERIOD
Comments/questions raised during the Geneva Industries site public comment
period are summarized briefly. The pres~ release announcing the public
comment period and public meeting was issued on May 2, 1986. The comment
period began on May 16 and ended on June 10, 1986. The public meeting to
outline the results of the remedial investigation and feasibility study was
held May 22, 1986, at the South Houston Community Center in South Houston.
397 people registered at the meeting with 37 people making oral statements
or asking questions. Twenty-three written comments or questions were
received during the comment period as well as petitions opposed to
on-site incineration containing 523 signatures, and resolutions from
the City Councils of Houston and South Houston. .
. )
During the public comment period, there were comments/questions regarding:
Comme~t.#1:
Response:
Comment #2:
Response:
Why is the incineration of PCBs suspended during an air
stagnation advisory?
Incineration of PCBs is suspended in order to prevent the
accumulation of stack emissions in the immediate vicinity of
the incinerator.
Has EPA studied the quantities of dioxins and dibenzofurans
created when incineration of PCBs is shut down?
Yes. During the trial burns conducted for the permitting of the
Rollins incinerator i-n.Deer Park, Texas~and ENSCO incinerator
in El Dorado, Arkansas, sampling was perf-ormed to assess the
emission of dioxins and dibenzofurans. The incinerators were
tested while burning: 1) waste fuel; 2) waste fuel and PCBs;
and 3) clean fuel and PCBs. Under the last two conditions, the
incinerators were operated at temperatures of greater than.
1200°C. The results of the tests indicated that 1.8 x 10-11
grams of dioxin per cubic foot of emission air were produced
while incinerating a mixture of waste fuel and PCBs at the
Rollins facility. Also, 2.8 x 10-11 grams of dibenzofurans
per cubic meter were produced. The results of the test burn
using a mixture of clean fuel and PCBs indicate that 2.4 x
10-11 grams of dibenzofurans cubic foot of emission air were
produced and that no detectable dioxins were produced.
Research has also shown that PCBs can be completely destroyed
at temperatures of 1475°F - 1830°F. The specific minimum
operating temperature would be set in the design stage of
the project.
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!;
4
<)
Comment #3:
Will the toxicities of emissions and effluents from an incinerator
be tested? Under what conditions? Will it be done prior to
incineration at Geneva?
Response:
Yes. The toxicities of emissions will be tested during the trial
burn and periodically thereafter. However, in cases where public
concern over the incineration of PCBs exists, an environmental
assessment of the incinerator operation may be performed. This
assessment would include air pollution and risk assessment modelling
to determine more site-specifically the input and effect of emissions
on the surrounding environment. Such an assessment was done for
the Rollins incinerator permit, and could be done for Geneva
Industries.
Prior to conducting the test burn for an incinerator, a test burn
plan must be written and approved by the Regional Administrator. .
Part of the plan should identify a ~~nge of operating conditions
within which the incinerator can ac leve the required level of
performance. Testing of the incinerator would be performed over
the entire range of operating parameters, including carbon monoxide,
waste feed rate, thermal input rate, temperature, and combustion
gas flow rate. Based on the results of the test burn, the range
of operating conditions would be set in the permit.
Testing of the incinerator would be performed prior to transporting
the unit to the site. Once operation of the incinerator onsite
began, monitoring and inspection schedules as set in 40 CFR 761.70
and the incinerator_permit would be instituted.
Comment #4:
Will EPA guarantee that fugitive emissions and accidental spills
will not release as much or more toxic material to the environment
than direct emissions?
Response:
The incinerator would be designed to minimize fugitive emissions
by maintaining a negative atmospheric pressure inside the unit.
This is part of the technical requirement an incinerator contract.
Also, daily visual inspections of the incinerator must be performed.
Any leaks of solid waste material from the incinerator would be
detected and corrected prior to continued operation of the unit.
An accidental spill of material at Geneva would not have a
significant immediate consequence, since the contaminated
material is soil and would not migrate if spilled. Also, PCBs
will remain absorbed on the soil particles in the event of a
spill, and would not contribute to a significant degradation of.
air quality. ..
Comment #5:
Will analysis of emissions be expanded to include all chemicals
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Response:
j
5
No. The selection of compounds for analysh is based on the
Principal Organic Hazardous Constituents (POHCs) in the waste to
be treated by incineration. The selection is based on the
constituents of the waste which are the most difficult to destroy
or in the highest concentration. Chemicals in the waste which
are less difficult to destroy and less abundant in the waste are
considered to be sufficiently removed by the incinerator.
The test burn plan should identify the procedures used for
sampling and analyzing the waste feed, the incinerator stock
gas, and incineration residues. Sampling and analysis methods
that are not standard EPA procedures should be documented.
However, the EPA approved procedures in "Test Methods for
Evaluating Solid Waste: Physical/Chemical Methods (SW-846,
Second Edition, July 1982) and "Sampling and Analysis Methods
for Hazardous Waste Incineration (SW-846 Addendum, First Edition
1982) should be used where possible. This would assure the
validity of the analytical techniques used.
Comment #6: Will EPA quantify the types and amounts of emissions from a PCB
incinerator at Geneva with the PCB incinerator at Rollins,
Deer Park?
Response:
Comment #7:
Response:
The effects of the Rollins incinerator would not be measurable
at Geneva Industries, and quantifying the two incinerators would
not be feasible because of the vari~ty of materials routinely
incinerated at the Rollins facility.
Have any previous risk assessments been performed for the
emissions from PCB incinerators?
Yes. With the assistance of the EPA Caricinogen Assessment Group,
an upper limit risk assessment was developed fot the Rollins
and ENSCO incinerators. The assessment was based on a "worst
casel! exposure scenario for the toxicology associated with
dioxins and dibenzafurans and the ambient air concentrations
discussed in'the prevrous comment. The resulting individual
risk for the Rollins unit was found to be less than 1 increased
cancer case in 50.000 exposed persons. For the ENSCO facility
the value was less than one additional case per 2,500,000 people.
The numbers do not represent an estimate of the actual individual
risk from operation of the incinerators, but are an estimate of
the upper level of risk possible if all the worst case assumptions
occurred. Such an occurrence is virtually not possible. .
Comment #8: Will emissions be monitored after the initial test burn?
What will be monitored and why? How often? .
Response:
Yes. Monitoring of the following parameters would be performed
continuously during the operation of an incinerator: oxygen and
carbon monoxide in the stack emissions and combustion temperature.
Periodic monitoring (at least once every 24 hours) will be
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o
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u
Comment #9:
Response:
Comment #10:
Response:
Comment Ill:
Response:
Comment #12:
Response:
6
nitrogen in the stack emissions. Periodic sampling and analysis
of the waste and exhaust emissions may be carried out, at the
request of the Regional Administrator, to verify that the operating
requirements established in the permit achieve the required
performance standards. This would involve monitoring the POHCs
and calculating destruction and removal efficiencies on a periodic
basis.
Performance monitoring is done by the incinerator operator.
On a periodic basis, a private contractor makes unannounced
inspection visits and reports on the overall condition of the
incinerator and reviews the monitoring records of the facility
for compliance with the permit specifications. The contractor
monitors the incinerator 5 times per month at varied intervals.
A verbal report of each monitoring event is given to the EPA
Project Officer as soon as possible. A full written report on
several visits is prepared every 90 days.
Will the public be informed as to the results of monitoring?
How and when will the information be made public?
Yes. Monitoring data will be shared with the public. The
specific details of how and when the public is informed would
be developed as part of the "Remedial Action Community Relations
Plan." A bulletin would be published on a monthly basis.
Will monitoring specifically be conducted for dioxin and
dibenzofurans emissions?
Yes, during the trial burn for the incinerator. However, based
on data developed during the trial burns for the Rollins and ENSCO
incineration permits, these compounds were not detected when a
combination of clean fuel and PCBs were incinerated at 2190°F.
Air quality monitoring and risk assessments were also performed
indicated that the emissions from an incinerator permitted in
accordance with PCB regulations will not present an unreasonable
risk of injury to health or the environment. Therefore,
monitoring specifically for dioxins and dibenzofurans would
not be necessary.
One commentor offered a proposal to ship the excavated materials
overseas for disposal.
Such an alternative was not to be evaluated in the feasibility
study becau~e sufficient technology exists in the United States.
to handle PCB-contaminated materials. Also, it was not possible
to assess the potential risks to citizens in other countries.
One commentor suggested that a bias exists in Superfund
regulations and guidance toward containment and incineration
remedies.
The National Contingency Plan (40 CFR Part 300) and the Superfund
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