1ST FIVE-YEAR REVIEW

HIGHLAND ACID PIT SUPERFUND SITE

HIGHLANDS, HARRIS COUNTY, TEXAS

May 1996

Prepared by:

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Region 6

Dallas, Texas

FIRST FIVE-YEAR REVIEW HI6HLAIID ACID PIT SUPERFUED SITE

Eaxria County, Texas

I. 'imThe Environmental Protection Agency (EPA), Region 6, conducted a five-year review pxirsuant to Section 121(c) of the Comprehensive Environmental Response, Compensation, and Liability Act C'CERCLA”) as amended, the National Oil and Hazardous Substances Contingency Plan ("NCP") Section 300.400(f)(4)(ii), and the Office of Solid Waste and Emergency Response ("OSWER") Directives 9355.7-02 (May 23, 1991) and 9355.-7-02A (July 26, 1994). The statute and Directives require EPA to conduct five-year reviews at sites where, upon attainment of ROD goals, hazardous siibstances remain at levels that will not allow unlimited use or unrestricted access to the entire site. The purpose of the five-year review is to ensure that the rer.edial action remains protective of public health and the environment. This document will become part of the Site File. This is a Type I review, as defined by OSWER Directive 9355.7-02, and is applicable at a site at which the response is complete.

II. 8TTB HTSTORY

The Highlands Acid Pit Superfimd Site is located in Harris County, 16 miles east of Houston, Texas and 1.4 miles west of Highlands, Texas, just west of Crosby Lynchburg Road at the end of Clear LeUce Road and adjacent to the east side of the San Jacinto River. The site is bordered by a wooded area to the North, Grennel Slough to the West, Clear Leike to the South, and flooded sand pits to the East. The site is a 6-acre peninsula within the 10-year flood plain of the l^n Jacinto River.The site was used for the disposal of an unJcnown quantity of industrial waste sludge, believed to be spent sulfuric acid from a refinery process, during the early 1950's. In May 1978, a telephone call was received by the Texas Department of Water Resources (TDWR) [later Texas Water Commission (TWC), currently Texas Natural Resource Conservation Commission (TNRCC) ] concerning the site. In September 1978, saunples were taken, analyzed, and determined to have a low pH, low concentrations of heavy metals, high chemical oxygen demand (COD), and high total organic carbon (TOC) levels. In October 1981, ground water seunples were also taken, analyzed, and determined to contain concentrations of heavy metals and volatile organic compounds.

III. TUT. QBJ^GTIVBB

In September 1982, EPA and TWC entered into a Cooperative Agreement (CA) for a state-lead Remedial Investigation and Feasibility Study (RI/FS). The site was proposed for the National Priorities List (NPL) on June 30, 1982. Based upon the seunpling results, a Hazardous Ranking System (HRS) package for the Highland Acid Pit was finalized in September of 1983. The overall site score was 37.77. The contract to perform these investigations and studies was awarded by TDNR [now TNRCC] to Espey Huston & Associates (EH&A), with Roy F. Heston (WESTON) as a principal subcontractor. The field investigation was completed in April 1983. The investigation showed extensive contamination across broad areas of the site.The selected remedy was excavation/off-site disposal. It Included excavation of waste material to an approximate depth of 8 feet, transportation of waste to a permitted Class I hazardous waste disposal facility, backfilling the excavated area with clean fill, constructing a temporary site perimeter fence with warning signs, installing a ground water monitoring system, and performing ground water monitoring and site maintenance for a 30-year period. The EPA and the State of Texas (TNRCC) agree that the selected remedy met the National Contingency Plan (NCP) Section 300.430(f) criteria. In addition, the Centers for Disease Control reviewed and concurred with the recommended remedy since it would adequately alleviate any public health threat which might result from the site.The Source Control Record of Decision (ROD) was signed on June 25, 1984 and the Remedial Design was completed in December 1985. Construction activities began in February 1987 and were completed by July 1987. These activities included excavating the conteuninated soil, conveying the conteuninated soil to the Chemical Waste Management disposal site in Carlyss, Louisiana, and backfilling the excavation with clean soil.

The Ground Water ROD was signed June 26, 1987. The selected remedy was no action, with a recommendation for monitoring the surface environment (surface water & sediments) and ground water. The Ground Water ROD stated that, "upon completion of the Source Control Remedial Action, surface water conteunination from minoff will be eliminated; natural flow of ground water will cleanse the pore spaces within the shallow aquifer over time; ground water flow to surface water bodies will continue to carry some contaminants to the surface environment, but the heavy metals are not mobile at the pH of the transition region for ground water flow to surface water bodies, the orgeuilcs axe volatile upon contact with the atmosphere, and in view of the dynamics of the river and properties of the contaminants, the San Jacinto River should not be affected." Therefore, no health threats are anticipated with a no action Ground Water ROD since it meets the NCP criteria.

IV. KBKRa r:

Section 121(d)(2)(A) of CERCLA incorporates the CERCLA Compliance Policy, which-specifies that Superfund remedial actions must meet any federal standards, requirements, criteria, or limitations that are determined to be legally applicable or relevant and appropriate requirements (APARs). Also included is the provision that State APARs must be met if they are more stringent than Federal requirements.The Highland Acid Pit Superfund Site ROD identified the following as having an Impact on the proposed remedy:

(1) Resource Conservation and Recovery Act(2) Clean Water Act(3) Occupational Health and Safety Act(4) Clean Air Act(5) Texas Solid Waste Disposal Act(6) Texas Clean Air Act

The ARARs identified above were reviewed as a part of this 5-year review and found not to have been revised, since the time of the ROD, to the extent that they required reex^unination of the protectiveness of the remedy.

V. £ RY OP MOMITORlWa *PQ PaTB

Pursuant to 40 CFR section 300.510 of the NCP, the TNRCC has assxuaed all responsibility for Operation and Maintenance (O&M) at this Site. TNRCC has implemented the EPA-approved O&M plan. O&M has included the following activities to date:The FINAL INSPECTION for the Source Control on July 15, 1987, at which time the amended Site Post-Closure Monitoring and Maintenance Plan (SPMMP) prepared by EH&A, dated January 1986, was Implemented. The SPMMP called for monitoring and inspection of the site on a semi-annual basis. Since the Ground Water remedy was no action, EPA and TWC [TNRCC] decided to revise the SPMMP to make several changes, including quarterly, rather than semi-annual, sampling for the first year and annual saaqpllng for years 2-30. It was revised, finalized in May 1989, and called the Post-Closure Operation & Maintenance Plan.Prior to the first O&M sampling event, EH&A (under contract to TWC [TNRCC]) conducted a post action seunpling event based on the SPMMP. Three ground water wells (two in the upper aquifer and one in the deeper aquifer), three sediment samples, and three surface water samples were tested for a small niimber of constituents on October 6, 1987. The results of the S2unples were below the action levels and are contained in the Sampling Report prepared by EH&A, dated December 7, 1987.

The first year of O&M activities was conducted by EH&A from July 21, 1988, through March 21, 1989, which consisted of four quarters of sampling events. The first quarter of O&M sampling, conducted in July 1988, included sampling and analyzing ground water, surface water, and sediment seunples on and around the site. The sampling consisted of four upper aquifer (approximately 23 feet below the surface) monitoring wells (UA-3, UA**6, UA-10, UA-11), one middle aquifer (a non-continuous sand lens approximately 52 feet below the surface) monitoring well (MA-2), three deep aquifers (approximately 120 feet below the surface) monitoring wells (DA-1, DA-2, DA-5), three siirface water stations (SW-1, SW-2, SW-3), and three sediment samples (SD-1, SD-2, SD-3) taken at the scune surface water stations as the surface water samples. The following three quarters of O&M seunpling were conducted in September 1988, December 1988, and March 1989. The sampling during these quarters included the seune seu&ple points as the first quarter with the exception that no surface water or sediment samples were teUcen. Sampling analyses showed that there are no levels of concern with the sediments or sxirface water seunples; organic and inorganic conteunlnation exists in the upper aquifer; however, since it is not used as a potable water source, it presents a potential problem only if the constituents contaminate the deep aquifer or surrounding surface waters. Benzene was the only constituent found slightly above levels of concern in the deep aquifer. Therefore, additional seunpllng was required to determine if an adverse impact existed at the site. The results of these sampling events are contained in the O&M Reports prepared by EH&A regarding the July 1988, September 1988, December 1988, and March 1989 Post- Closure Monitoring Events at the Highlands Acid Pit.The Field Investigation Team (FIT) was tasked by EPA to conduct a technical-support-seunpling inspection at the site between October 23 and 27, 1989. This work was tasked to FIT because of the unavailability of TWO and EPA personnel and other contractors to conduct this work in a timely manner to help resolve the concerns of contaminants found above Maximum Contaminant Levels (MCL's) (drinking water standards) in the deep aquifer during previous seuapling events. This data was necessary to validate the protectiveness of the completed Remedial Action for the Source Control Operable Unit. This sampling inspection contained the seune seunple points as the first year, first quarter of O&M. Seunpling analyses showed organic and inorganic contamination remained in the upper aquifer. Holding times were missed for the volatile organic constituents for all water samples and therefore are estimates and considered provisional. Only lead and total chromium were detected slightly above the drinking water standards at that time in well DA-2 of the deep aquifer. Complete results can be seen in the Final Report for the FIT Sampling Inspection dated February 20, 1990.It was decided between EPA & TWC to continue with another year (four quarters) of sampling since it could not be determined from

the previous sampling that the site was operational and functional (O&F) as required by 40 CFR §300.435(f)(2) which states:"A remedy becomes operational and functional either one year after construction is complete, or when the remedy is determined concurrently by EPA and the State to be functioning properly and is performing as designed, whichever is earlier. EPA may grant extensions to the one-year period, as appropriate."

Therefore, a second year of quarterly samples was conducted by EH&A, vinder contract with TNRCC, from December 18, 1990 through September 18, 1991. This second year of quarterly sampling included the same samples and sample points as the first year of quarterly sampling. Sampling analyses from the Jxine and September 1991 sampling events indicate that levels in the middle aquifer, deep aquifer, and the surface water do not exceed MCL's. Consequently, it is determined by EPA & TNRCC that the site is operational and functional in accordance with 40CFR §300.435(f) (2). The results of these sampling events are contained in the O&M Reports prepared by EH&A regarding the December 1990, March 1991, June 1991, a.id September 1991 Supplemental Monitoring Program Sampling Events at the Highlands Acid Pit.The State agency, Texas Water Commission, now known as Texas Natiiral Resource Conservation Commission (TNRCC), assumed all responsibility on June 29, 1993 (100 percent funding one year after completion of construction completion) for continuing the thirty years of O&M at the site to insure it remains protective of human health and the enviroiment as specified in the Ground Water ROD.The TNRCC employed EH&A to carry out monitoring, sampling, analysis, and reporting activities at Highland Acid Pit. EH&A's first monitoring and sampling effort was conducted in December 1992 but contract cost disputes ensued and the report of these activities was not received until November 1993 — after the contract disputes were resolved. A second sampling activity was conducted by EH&A in November 1993 and the report of these activities was received by TNRCC in February 1994.

TNRCC Issued a contract to Woodward-Clyde Consultants (WCC) in1994. Two new four-inch dieuneter monitoring wells (MA-3 and MA-4) were installed in the middle sand during the week of February 17, 1995 and the site monitoring, sampling, analysis, and reporting activities were transferred to WCC. Monitoring and sampling of the existing eight wells by WCC began in December 1994. The latest seunpling activities were conducted by WCC on the 28th, 29th, and 30th of June 1995 and the 12th, 13th, 18th, 19th, and 20th of July1995. WCC draft report dated September 1995 was received by EPA in October 1995.

By letter dated November 21, 1995, EPA proposed for consideration to TNRCC the delistment of this site from the NPL. TNRCC responded by letter, dated January 29, 1996, in which technical reasons and concerns were cited for TNRCC not concurring. These technical reasons or concerns were restated in TNRCC's letter dated February 16, 1996. EPA responded to each of TNRCC's reasons and concerns and further stated the necessity of expanding ciirrent monitoring progreua by letter dated April 9, 1996.

EPA and TNRCC have agreed on a revised well-development plan in a meeting held May 9, 1996, which proposes to add ten monitoring wells and a revised monitoring well strategy. A cost estimate for the revised action plan to medce the site operational and fvmctional has been prepared by TNRCC and review comments provided by EPA.

VI. S-YBAR REVIEW SITE INSPECTION

A Five-Year Review field trip and site inspection was made by EPA and TNRCC representatives on June 28, 1995. The visit is documented in the photographs attached to this review report. While the site is double fenced, neither fence is complete nor intact. The inner fence was damaged and down due to past flooding and the outer fence has a gap in several sections of the site perimeter and fails to provide controlled access and security to the site wells and leachate storage barrels. (See Attachment 2)

EPA recommended to TNRCC that individual fencing, a gate, and mask be installed around each of the site monitoring wells and the leachate barrels similar to those deployed by TNRCC at the Sikes Superfund Site. me project entrance fencing (chicken wire) was also in need of improvement and/or replacement and should be included in the proposed individual fencing of the site wells.

The construction and maintenance of individual fencing of the site monitoring wells would be more economical and less disruptive to site grazing or other usage by the owner.

Local contacts confirmed that they had not received any complaints about the site nor had they any reason to believe that the site is not secure and protected.

VII. STATl OP PROTEGTIVBMBSS AMD RE MioyeBased on the results of O&M seunpling and inspections to date and ATSDR's review, EPA, in consultation with TNRCC, has determined that human health and the environment in the vicinity of the site continue to be protected and that no further Superfund response is appropriate. Continuing O&N has been guaranteed by the State of Texas (TNRCC). A bibliography of reports relevant to the actions and reviews of this site can be found in Attachment 1.

VIII. NEXT RBVIBWEPA has scheduled the next five-year review for completion by February 5, 2000 (i.e., ten years after site mobilization).

Hyron O. Knudson, Director Superfund Division

Datd

ATTACHMENT 1HIGHLANDS ACID PIT

POST CLOSURE MONITORING & MAINTENANCE PLAN; Espey, HUSton, & Associates, Inc.; January, 1986.

PBPOPT OF THE GROUND WATER SAMPLING EVENT FOR POST CLOSURE; Espey, Huston, & Associates, Inc.; December 7, 1986.

POST CLOSURE OPERATION AND MA Associates, Inc.; MAY 1989.

ANCE PLAN; Espey, Huston, &

Q&M PKPORT OF JULY 1988. SEPTEMBER 1988. DECEMBER 1988. AND MARCH1989 POST CLOSURE MONITORING Inc.

rs: Espey, Huston, & Associates,

O&M FINAT. PEPORT FOR THE FIT SAMPLING INSPECTION: Ecology &Environment, Inc.;

OftM PPPOPTR OP THE OECEMBER 1990. MAPCH 1091. JUNE 1991. SEPTEMBER 1991 SUPPT.RMEWTAL MONITORING PROGRAM SAMPLING EVENTS; Espey, Huston, & Associates, Inc.

INTERIM CLOSE OUT REPORT. Environmental Protection Agency, Region 6, J\ine 29, 1992.

• TNRCC - EH&A:• TNRCC - EH&A:

1993• TNRCC - EH&A:• TNRCC - EH&A:

1994• TNRCC - WCC:

c TNRCC - WCC:• TNRCC - WCC:

1995• TNRCC - WCC:

1996

Sampling conducted December 1994

Sampling conducted June-July 1995

O&M Annual Monitoring Report dated September

- NCC: O&M Annual Monitoring Report dated January

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HIGHLAND ACID PIT SUPERFUND SITE

Date Taken: June 28, 1995Five Year Review Photographs

Highland Superfund Site

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TYPICAL MONITORING EQUIPMENT

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Woodward-Clyde - Sampling began June 28 : (1) VOA (2) SVOA (3) Total Organic Carbons & Halogens (4) BTEX (5) Metals (6) Pyridine (7) Phenols (8) Basic Water Quality Parameters

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Date Taken; June 28, 1995Five Year Review Photographs

Highland Superfund Site Page 3 of 3

Site Entrance Looking East Site Entrance Looking WestWoodward-Clyde - Sampling began June 28: (1) VGA (2) SVGA (3) Total Grganic Carbons & Halogens (4) BTEX (5) Metals (6) Pyridine (7) Phenols (8) Basic Water Quality Parameters

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Site Entrance-Looking Northeast @ Boat Club Entrance Site Entrance Looking Southwest