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San Jacinto River Waste Pits TCRA

All POL/SITREP's for this site San Jacinto River Waste Pits TCRA
Channelview, TX - EPA Region VI
POLREP #6
Landside placement of E. Cell begins
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
San Jacinto River Waste Pits TCRA - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region VI

Subject: POLREP #6
Landside placement of E. Cell begins
San Jacinto River Waste Pits TCRA
06ZQ
Channelview, TX
Latitude: 29.7944000 Longitude: -95.0625000


To:
From: Valmichael Leos, RPM
Date: 3/30/2011
Reporting Period: 03/09 - 03/30/11

1. Introduction
  1.1 Background
   
Site Number: 06ZQ    Contract Number:  
D.O. Number:      Action Memo Date: 4/2/2010
Response Authority: CERCLA    Response Type: PRP Oversight
Response Lead: PRP    Incident Category: Removal Action
NPL Status: NPL    Operable Unit:
Mobilization Date: 12/8/2010    Start Date: 12/8/2010
Demob Date:      Completion Date:  
CERCLIS ID: TXN000606611    RCRIS ID:
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:

1.1.1 Incident Category

RP lead CERCLA time critical removal action

1.1.2 Site Description

The site encompasses approximately 25 acres. The removal action is to stabilize the site by designing and constructing a physical protective barrier surrounding waste ponds 1 and 2 that temporarily abates the release of polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (and possibly PCBs) into the San Jacinto River, until the site is fully characterized and a remedy is selected.

1.1.2.1 Location

The Site is in Harris County in the State of Texas. The Site itself has no specific street address. The Site is comprised of two waste ponds with three surface impoundments built in the 1960's. The ponds and impoundments are situated on a partially submerged 20-acre parcel of real property. The Site is located on the western bank of the San Jacinto River, in Harris County, Texas, immediately north of the Interstate Highway 10 (1-10) bridge over the San Jacinto River. Available information indicates the two waste ponds were built during 1965 by constructing berms within the estuarine area just north of what was then Texas State Highway 73 and is now 1-10, west of the main river channel, east of the City of Houston, between two unincorporated areas known as Channelview and Highlands.

1.1.2.2 Description of Threat

The waste paper sludge was placed in the two ponds on the Site. Waste pond 1 is located on the western portion of the Site totaling 132,386 square feet. Waste pond 2 which consists of two surface impoundments are on the eastern portion of the Site totaling 46,182 square feet and 188,641 square feet respectively. Currently, the Site is inactive and approximately half of the Site's surface area, including the abandoned waste disposal ponds, is now submerged below the adjacent San Jacinto River's water surface. Waste pond I with one impoundment is partially submerged and waste pond 2 with the two impoundments is completely submerged in the San Jacinto River.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results


The primary hazardous substances documented at the Site are polychlorinated dibenzo-pdioxins and polychlorinated dibenzofurans. At the time of the signing of the Action Memo, dioxin concentrations as high as 41,300 parts per trillion have been found in sediment samples collected from the Site's disposal pond areas and in the river sediments near the Site. Sediments contaminated with high levels of dioxin have been found in the San Jacinto River both upstream and downstream from the Site due to tidal influences. Additional sediment samples were collected in compliance with the Action Memo, dioxin concentrations as high as 360,000 parts per trillion organic carbon normalized have been found in sediment samples collected from the submerged portion of the waste disposal ponds as well as dioxin concentrations as high as 3,660 parts per trillion action level in sediment samples collected outside the original 1966 berm placement for the two waste ponds indicating the release of dioxin from the original location of the waste ponds.




2. Current Activities
  2.1 Operations Section
   

 

 

 

 

 

 

 

 

 

 

 

 

2.1.1 Narrative

In accordance with the statement of work (SOW), in the EPA Administrative Order on Consent (AOC), Respondents International Paper Company Inc. (IP) and McGinnes Industrial Maintenance Corporation (MIMC) have 30 calendar days to begin construction for the time critical removal action.  On November 8, 2010 the EPA finalized a work plan that details the construction of a temporary cap that will stabilize the release or threat of release of hazardous substances into the San Jacinto River.

 

 

 

 

 

 

 

 

 

2.1.2 Response Actions to Date

On January 5, 2011, EPA remedial project manager (RPM) Leos conducted a site inspection and documented that all on site field activities at the site have stopped not in accordance with the Work Plan or the Work Plan Schedule.  The Respondents resumed some on site field activities on February 1, 2011 in preparation for implementing the time critical removal action. 

On February 17, 2011, the respondents began the waterside placement of armor cap D rock on top of the eastern waste pit cell.  The eastern cell is under approximately 4 feet of water (during low tide) so placement of rock is being completed via barges stationed in the water alongside the eastern pit. Access road improvements along the Texas Department of Transportation (TxDOT) Right-of-Way (ROW) adjacent to the waste pits continue, preparation of office trailers for onsite project management is completed, and as of March 28, 2011 approximately 14,668 tons of Armor Cap D rock has been placed in the eastern cell.

On February 23, 2011, the respondents began the clearing and grubbing of the western cell in preparation for cap placement.  The clearing and grubbing involves the use of an excavator that is removing large trees, shrubs, and vegetative debris that has grown on top of the western cell.  All debris that may be potentially contaminated will be temporarily staged on top of the western cell.  Any off site disposal of vegetative debris with visible contamination will be first sampled for disposal analysis and sent to the appropriate EPA approved subtitle C or subtitle D hazardous waste landfill.

On March 16, 2011, the respondents began the waterside placement of armor cap C on top of the eastern waste pit cell. As of March 28, 2011, approximately 3,000 tons of armor cap C has been placed.

On March 18, 2011, the respondents began the landside placement of armor cap A and B/C on top of the eastern cell.  Similar to the waterside placement, a geotextile fabric is carefully placed on top of the eastern cell prior to the placement of rock.  Some initial clearing and grubbing of shrubs and trees took place prior to the placement of rock along the central and southern berms along the eastern cell.  As of March 28, 2011 approximately 1,110 tons of armor cap A and 897 tons of armor cap B/C have been placed. 

On March 28, 2011, the respondents began the waterside placement of armor cap A on top of the Northwestern portion of the western waste pit cell.

Total approximate rock placed (armor cap A, B/C, C, and D) to date is 19,675 tons which is 32% of the entire project.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

Currently, EPA is working with Respondents International Paper Company Inc. and McGinnes Industrial Maintenance Corporation under an EPA issued Administrative Order on Consent.  In December 2010, Respondents did not complete certain Work activities in accordance with the Work Schedule and stopped all Work activities on January 5, 2011 in violation of the AOC.   The EPA issued Notice of Violation Letters on January 14, January 21, January 24, and March 3, 2011 for noncompliance with the AOC.  Respondents have requested EPA to excuse their noncompliance with the AOC due to force majeure.  The EPA has reviewed the record and determined that there is no evidence of a force majeure event.  Respondents are in the process of correcting their noncompliance with the AOC.  On March 3, 2011 the EPA issued its first status of noncompliance letter to Respondents documenting the first corrections to their noncompliance activities under the AOC.




  2.2 Planning Section
    2.2.1 Anticipated Activities
o Continued placement the geotextile, Armor Cap A, Armor Cap B/C, and
Armor Cap C in the Eastern Cell of the SJRWP from both the land side and
the water side.

o Took delivery of roll-off boxes. These boxes were loaded with the
vegetative debris from the SJRWP and began being transported to the
approved off-site landfill.

o Maintained and moved turbidity curtain to enclose work that will be
performed from the water off the Northwestern Area of the SJRWP.

o Performed additional water quality monitoring related to the impacts of
barge and tug movement events, results of which were transmitted to
USEPA separately as attachments to the daily reports.

• Continued to implement site security measures as described in the Site Security Plan,
pursuant to which roving security patrols were discontinued after newly-installed
remote security cameras were connected.

• Provided TxDOT analytical data to landfill disposal waste approval personnel. Pending
waste approval documentation for soil from guard rail post installation, construction debris, and
other miscellaneous debris stockpiled on the TxDOT ROW.

2.2.1.1 Planned Response Activities
• Confer with USEPA on the results of the additional water quality monitoring that was
conducted to evaluate the potential impacts of barge and tug movements.

• Ship additional natural stone aggregate from the quarry to Texas City. This material will
be stored in Texas City until space becomes available at the LaBarge Site, or within the
Laydown and Stockpile Area constructed in the TxDOT ROW.

• Continue to implement the Site Security Plan.

• Maintain the Administration Site as necessary.

• Continue LaBarge Site activities including:
     o Continue to support marine construction activities.
     o Continue to supplement stockpile of aggregate as space becomes available.

• On the TxDOT ROW, continue to haul for off-site disposal vegetation, debris, and soil,
that were cleared from beneath the I-10 Bridge.

• On the SJRWP:
     o Continue clearing and grubbing of the Western Cell.
     o Continue installation of armor cap in Eastern Cell.
     o Continue installation of armor cap in the Northwestern Area.

2.2.1.2 Next Steps

2.2.2 Issues


  2.3 Logistics Section
    No information available at this time.

  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    No information available at this time.

3. Participating Entities
  No information available at this time.

4. Personnel On Site
  No information available at this time.

5. Definition of Terms
  No information available at this time.

6. Additional sources of information
  No information available at this time.

7. Situational Reference Materials
  No information available at this time.