1ST FIVE-YEAR REVIEW (Type la)

GENEVA INDUSTRIES SUPERFUND SITE

HOUSTON, HARRIS COUNTY, TEXAS

April, 1998

Prepared by:

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Region 6

Dallas, Texas146343

007068

1ST FIVE-YEAR REVIEW (Type la)GENEVA INDUSTRIES SUPERFUND SITE

Houston, TexasI. INTRODUCTION

Authority Statement Purpose. The U. S. Environmental Protection Agency (EPA) Region6 conducted this Five-Year Review pursuant to CERCLA Section 121(c), NCP Section300.430(f)(4Xu), and OSWER Directives 9355.7-02 (May 23, 1991) and 9355.7-02A. RemedialAction (RA) activities started at the site in May 1988. The purpose of a five-year review is to ensurethat the remedial action remains protective of public health and the environment and is functional asdesigned. This document will become a part of the site file and is a policy review. This review (Typela) is applicable to a site at which response is ongoing.

Site Characteristics. The Geneva Industries site is a 13-acre tract located at 9334 CanniffRoad in Houston, Texas. The site is east of Interstate Highway 45 (Gulf Freeway), north of AirportBoulevard/College Street, and about a mile east of Hobby Airport.

Prior to 1967, the land was used for petroleum exploration and production. The site is anabandoned refinery that manufactured chemicals such as biphenyl, polychlorinated biphenyl (PCB),phenyl phenol, naphtha and Nos. 2 and 6 fuel oils.

As of 1981, the site and adjoining property to the south contained processing tanks andpiping, a large wastewater lagoon, two smaller lagoons, a closed lagoon containing solid PCB wastes,a diked tank area, several drum storage areas, a landfill, and a possible land farm. As a result of pastpractices at the site, extensive soil and shallow ground water contamination occurred.

Prior to removal by Operable Unit 1 (OU-1), surface soil contamination had PCBcontamination levels as high as 12,200 ppm. The PCBs at the site were primarily detected as Aroclor1242. A number of non-chlorinated solvents (e.g. benzene) chlorinated solvents (e.g.trichloroethylene) (TCE), and polynuclear aromatic hydrocarbons (PAHs) were detected at the site.TCE was detected consistently in ground water, but was limited to the 30-foot sand and the 100-footsand beneath the site. A removal action was conducted by EPA during the periodOctober 17,1983, through February 3,1984, to close out three onsite lagoons, remove all drummedwaste on the surface, remove all offsite soils containing greater than 50 ppm PCBs, install a cap overall onsite soils containing greater than 50 ppm PCBs, and improve drainage. The removal includedinvestigation of the site's soil contamination. The site remedial investigation (RI) performed Junethrough September 1984 further assessed the nature, degree, and extent of the contamination. Basedon the results of detailed investigations, the site was ranked with the hazard ranking system (HRSscore = 59.46) and was proposed for the National Priorities List (NPL) in September 1983 andadopted in September 1984.

007069

IL DISCUSSION OF REMEDIAL OBJECTIVES: SOURCE/GROUND WATER

After reviewing the results of the remedial investigation/feasibility study (RI/FS), EPAissued a Record of Decision (ROD) for Geneva Industries on September 18, 1986. This RODaddressed contaminated structures and soils, as well as ground water at the site. The remedyselected in the ROD included eight major components:

1. Removal and disposal of all surface facilities;2. Plug and abandon unnecessary monitoring wells;3. Excavation of 22,500 cubic yards of soils contaminated with greater than 100 ppm

PCBs;4. Excavation of all buried drums;5. Disposal of excavated material in an EPA - approved offsite facility;6. Construction of a slurry wall barrier around the site with a pressure relief well

system;7. Construction of a permanent protective cap across the site surface; and8. Recovery and treatment ofTCE contaminated ground water in both the 30-foot

and 100-foot sands (ten-year pump/treat).

SOURCE:

The Geneva Superfund remedial action contract was awarded by TWC on April 8,1988,to Chemical Waste Management, Inc. ENRAC-South (CWM) for OU-1 (first seven of the eightmajor components discussed above) of the ROD. TWC issued CWM the notice to proceed onMay 23,1988, during the final preconstruction conference, and CWM began construction on May24, 1988.

The contractor actively pursued the contract work until October 7, 1988, when TWCissued, by letter, a delay notice in shipping of waste material. On October 21, 1988, the UnitedStates District Court for the Middle District of Alabama, Northern Division, issued a temporaryrestraining order. This was appealed and resolved by the courts by June 7, 1989. On June14,1989, TWC issued a directive to the contractor to resume performance of the contract by June26,1989, a delay of approximately nine months. Transportation of waste to the Emelle, Alabama,waste disposal facility began on July 2, 1989, and continued through September 1989.

The remedial action for OU-1 was completed on September 28, 1990, when EPAapproved the OU-1 Remedial Action Report.

The ROD estimate was that 22,500 cubic yards of soil would exceed the remedial goal of100 ppm PCBs. At the completion of the source control remedial construction in September1989, approximately 62,290 tons of contaminated material had been disposed of offsite. Usinga conversion factor of 1.6 tons per cubic yard of soil, this equates to about 38,900 cubic yards,or a 73 percent increase in volume. Despite the 73 percent increase in volume, the corresponding

2

007070

additional remediation cost attributable to that volume increase rose only approximately 21percent ($3.3 million of the $15.867 million). The increased volume was not "discovered" untilthe RA was well underway and the soil tests indicated more contaminated material needed to beremoved than was contemplated based on the information developed during the RI. This andother differences to the 9/18/86 ROD are recorded and documented in an "Explanation ofSignificant Difference to the Record Of Decision" (ESD), dated July 1993.

GROUND WATER:

The Geneva Superfund remedial action contract for Operable Unit 2 (OU-2) (eighth majorcomponent of the ROD as discussed above) was awarded by the TWC on July 22,1992, to WasteAbatement Technologies, Inc. (WATEC), and notice to mobilize was issued by TWC onDecember 21,1992. WATEC constructed 13 recovery and monitoring wells, 1878 linear feet ofabove-ground supported piping, a treatment building containing an activated carbon filtrationsystem, six 30,000 gallon storage tanks, related foundation facilities, service utilities, monitoringcontrols, asphalt site paving, and fencing. Substantial completion of this construction work isdocumented in the oversight engineer's letter of July 1,1993, to TWC. This contract includes a10-year treatment phase for recovery and treatment ofTCE from the ground water.

The post-remediation operation and maintenance plan dated January 1988 establishes anoperation and maintenance (0/M) plan that will be executed and implemented at the GenevaIndustries site.

As of February 1998, in excess of 11 million gallons of ground water have been treated,tested, and discharged. Major system modifications (by the addition of a heavy oil separator,related piping changes, charcoal filter material replacement, and system cleaning) were completedin September 1994.

The modified treatment system has been functioning as designed with periodicmaintenance. Operational problems have occurred from time to time regarding cartridge filtersclogging and corrosion of the process piping.

ffl. AREAS OF DISCHARGE NONCOMPUANCE, BASED ON TEST RESULTS:

The ROD for the treatment phase specifies a discharge limit of 5 ug/1 for TCE. During1997, TCE was not detected in any of the 100-foot recovery or monitoring wells. TCE has beenbelow detection limits since September 1993 in all the deep aquifer (100 foot sand) monitoringwells and the recovery well. TCE was the only contaminant addressed by the ROD for removal.

TCE Monitoring Results:

TCE has been detected in only two of the onsite shallow aquifer recovery wells, RW-3 andRW-4. TCE has also been detected in MW-26, a shallow aquifer monitoring well outside theslurry wall, in all sampling events in 1995, 1996, and three of the four sampling events in 1997;however, it was not detected in September and December 1994. Contamination in this outside

3

007071

area was observed during the RI/FS phase and the design phase prior to the installation of theslurry wall. This can best be explained because the ground water gradients on either side of theflood control channel are in opposite directions. Consequently, the probability of thecontamination moving farther away from the slurry wall is minimal as substantiated by themonitoring records showing consistent readings of the recorded contamination levels.

Oil and Grease Concentrations:

All oil and grease concentrations measured within the slurry wall area in the deep aquifer(RW-6) during the treatment phase have been less than 1 lmg/1. In July 1997, MW-22, outsidethe slurry wall, had 65 mg/1 with a discharge criteria of 15 mg/1 for the oil and grease.

Ethylbenzene* Xylene, Toluene* Benzene and Xylene (BTEX) findings:

Ethylbenzene and Xylene concentrations have been below the discharge standards of 30ug/1 and 15 ug/1, respectively, in RW-6 and monitoring well 102 (MW-102) inside the slurry wall,but were consistently encountered in each sampling event. Toluene has also been encounteredat MW-102. BTEX has been below detection limits during most of the sampling events in thedeep aquifer monitoring walls outside the wall. With the exception of the July 1997 sampling dataat MW-22, benzene has not been encountered in the deep aquifer, during the treatment phase.In general, in 1996 and 1997, BTEX levels have been high in all shallow aquifer recovery wellswith the exception RW-8 and RW-9.

The continuing ground water monitoring will be performed by the treatment contractor,WATEC. All long-term ground water monitoring and the general long-term operation andmaintenance of the landfill cap will be under the direction of the State (TNRCC).

IV. RECOMMENDATIONS:

General Comments:1. Pumping from RW-6 (100 ft. sand) should be reduced or terminated and a monitoring

program initiated to determine if there is any "rebound" ofTCE concentrations in thiswell. Since the well does not influence the ground water flow conditions beneath the site,terminating the pumping should not have an effect on site conditions. In addition, furtherpumping from RW-6 could only increase the possibility of drawing TCE or othercontaminants downward from the shallow zone.

2. The reference to DNAPL, the only occurrence at the site appears to be the heavy oilcomponent. Based on TCE concentrations (both current and historic), there is no TCEDNAPL at the site. A TCE DNAPL at the site could be inferred if concentrations in themonitoring wells approached 1% (10 ppm) of the TCE solubility limit of 1000 ppm to1100 ppm. However, concentrations presented in the 1997 Annual Progress Report havenever approached the 10 ppm indicator. Therefore the potential threat of a TCE DNAPLis non-existent at the site. This is significant since a chlorinated solvent DNAPL wouldlikely open a pathway vertically through the clay separating the 30 ft. and 100 ft. sandsand horizontally through the surrounding slurry wall.

007072

3. The EPA recommends including the water level elevations for all monitoring wells takenduring sampling events with a potentiometric surface prepared for both the shallow anddeep aquifers.

4. Attachment #3 represents seven pages of photographs taken on a site inspection for thisreview on February 25,1998. One of the signs on the perimeter fence warning trespassersto stay off the property required replacement. In addition, the grating in the walkwayareas of the six large storage tank area was in a detonated and failing condition. TheTNRCC's Project Manager, Tom Benz, was present on this inspection and is to addressthese needed corrections.

Lockwood, Andrews & Newnam (LAN), Inc. (Site Oversight Engineers for the State,TNRCC) has recommended in its final 1997 annual report a risk assessment based on the currentground water conditions. The level of effort for risk evaluations of remedial alternatives dependsprimarily on the site-specific questions within the ROD that were addressed in the selected andimplemented remedy alternative of the ROD. LAN further addressed seven (7) objectives froma management point of view. These are addressed by EPA as follows:

(1) Determine the cause of operational problems and develop a solution to maximizesystem efficiency. This was a pronounced problem in the past, but since the addition of theheavy oil/water separator by Field Change Order No. 29-A, approved May 2, 1994, only thehigh-frequency replacement of the micron-filters has been a problem. It has been the practice ofLAN to continuously monitor the treatment system closely to identify and evaluate operationalconditions and provide preventive maintenance when possible. All solutions and proposals toaddress operational problems and system efficiency will take into account a cost benefit analysisand ensure that the operational savings justify the capital costs of any system change.

(2) Develop a methodology to effectively predict the estimated time and quantities toachieve ground water clean up in the shallow and deep aquifers.

The Engineer, LAN, and the TNRCC propose investigating the feasibility of developinga fate and transport model utilizing available information for contaminants determination in theshallow and deep aquifers and are currently pursuing deploying a modeling effort.

Because there is a multi-layer surface cap over the site, a slurry wall tied into the claybelow the 30-foot sand around the site perimeter, and documented five years of past pump data(11 million gallons) in 134 discharge sampling events reflecting no contamination in the 100-footdeep aquifer by migration or identifiable conveyance from the 30 foot sands, EPA finds there isno apparent utility in a fate and transport model, nor a basis for a risk assessment. The site iscapped, contained, and there is no record oflower (100-foot sand) aquifer contaminate infractionsat the current stage of this contract. The contaminants on the inside of the slurry wall areeffectively isolated from the surrounding and lower aquifer. Since the TCE is thought to bepresent in the heavy oil DNAPL, and the extent of the heavy oil (and any other remaining sourcearea) is apparently poorly defined, further delineation efforts would be necessary to accuratelypredict the eventual time for cleanup, given the unknown variables.

007073

(3) Determine the expected concentration in the shallow and deep aquifer when bidquantities are exhausted. There is no apparent utility in a fate and transport model for this site(see comment above). There is also no apparent utility in another risk assessment beingperformed for this site. This assessment is based on the following: 1) the isolation of the groundwater contamination within the slurry wall prevents any reasonable future exposure scenariooutside of the site; and 2) the high TDS level (41,000 ppm) for the shallow aquifer indicates thatthe shallow aquifer in this area is not a potentially useable drinking water supply. Thus, there isno apparent risk to potential receptors outside of the slurry wall given the current TCEconcentrations.

(4) Determine the need to continue pump and treat operations upon exhaustion of bidquantities. The only apparent information required at the end of the current contract is whethercontinued pumping is needed to maintain the drawdown in the shallow aquifer and relieve anyhydrostatic pressure on the slurry wall. If the current integrity of the slurry wall can bemaintained without the drawdown, then continued pumping of the shallow aquifer would notappear to be necessary.

(5) Determine the characteristics of DNAPLs present in the groundwater anddetermine their effect on the treatment schedule. Since there is no apparent TCE DNAPL atthe site, further delineation and characterization of the existing DNAPL is unnecessary. Theslurry wall can effectively isolate the heavy oil DNAPL in the shallow aquifer preventing lateralmigration outside of the confinement area and the existing clays adequately prevent downwardmigration to the deep aquifer. Deed restrictions will notify future owners of the prohibition of anyexcavations or penetrations of the cap which may allow migration of the ground water from theupper 30 foot sands to the lower 100 foot sands.

The absence of DNAPL in the deep aquifer can be verified with the existing data and furthercharacterization in this sand is unnecessary.

The effect of DNAPLs on the cleanup schedule is uncertain, but with the isolation of thecontamination within the slurry wall and the absence of receptors to contamination in the shallowzone, continued pumping from the shallow aquifer is unclear. The remaining question is whethercontinued drawdown is necessary to relieve any hydrostatic pressure on the slurry wall (seecomment #4).

(6) Determine the effects of continued pumping and need of continued pumping of thedeep aquifer. Based on the existing data, continued pumping from the deep aquifer serves noapparent purpose other than to supply water to the treatment system. EPA recommends reducingor eliminating further pumping from the deep aquifer.

(7) Evaluation of contaminants outside the slurry wall.: Pumping from the shallowaquifer inside the slurry wall should prevent any migration across the slurry wall. Thus, thecontaminants outside the slurry wall should be the result of contamination existing at the time ofthe slurry wall installation. Further characterization of the contaminants outside of the slurry wallserves no apparent purpose.

6

007074

V. STATEMENT ON PROTECTIVENESS

I certify that the remedies selected for this site remain protective of human health and theenvironment, and are likely to remain so, based upon all records and finding to date.

VL THE NEXT FIVE-YEAR REVIEW

The next five-year review will be conducted in February 2003.

^^<P JCy^<-Myron (f.Knudson, P.I^DirectorSuperfund Division

</̂'Date

007075

GENEVA INDUSTRIESSUPERFUND SITE5-YEAR REVIEW

INDEX

DRAWINGS and PHOTOGRAPHS

Attachment No.

Attachment 1

Attachment 2

Attachment 3

Description

SITE LOCATION MAP

EXISTING SITE MAP

PHOTOGRAPHS Pages 1-7

007076

Attachment // 1

^wswasvanwiSwaftA^wwCTA.^,I""*——? — fVfSS!" •ff*'11——-/ ——

• ss'is'aa"'T wot9 WSSUK0 2SWMB—11

o WfOStSiSf

FIGURE 3-1MONITORING WELL

* RECOVERY WU. LOCATIONSAND OROUNOWATER El£VAT10NS

OROUNOWATER REMEDIA710N

GENEVA INDUSTRIES SUPERFUNO SITE

PmpwM forTNRCC. AUSTIN

By.LOCKWOO, ANOREWS ft NOHNAM. INC.

007077

007078

007079

007080

007081

007082

007083

007084

007085