RESPONSE ACTION PLAN

SItf'S SITEHARRIS COUNTYCROSBY, TEXAS

February 1981

\983607

TABLE OF CONTENTS

Summary of Actions to be Taken

Factual Background on Slke's SiteLocation and Physical DescriptionOperations of the SiteNature of WastesFederal, State, and Local Government ActivityLegal Proceedings

Site AssessmentSafety HazardsGroundwaterSurface WaterA1r QualitySon TestsDrums

Action PlanSecuritySHe Safety PlanGroundwater StudySampling and Analyses PlanImplementation of Sampling and Analysis PlanInterpretation of Data CollectedCourse of ActionMonitoringGeneral Legal ConsiderationsState-Federal Coordination and Public RelationsOSC After Action Report

Summary of Actions to be Taken: r-i

Action Responsibility Initiated Completed

OSC (Contractor)OSCEPA-Ada Lab.

Ada Lab. (Contract)

Gate ConstructionSite Safety PlanGroundwater StudyGround PenetratingRadarMonitoring Wel ls andTest Holes EPA-Ada Lab.Sampling:

ERT OP contractorERT or contractorERT or contractorERT or contractorERT or contractorERT or contractorContractor

PlanA1rHasteWaterSoilGroundwater

AnalysesInterpretation OSCRe-druB and Removal OSC (Contract)DisposalContainmentWater Treataent(Initial)Water Treatment(Continuing)MonitoringLegal Considera-tionsState-Federal Coor-dinationPublic Relations

OSC (Contract)OSC (Contract)

ERT or Contractor

StateStateRegion 6Enforcement

After Action Report OSC

OSCRegion 6 - OPA

Day 1before Day 1before Day 1

before Day 1Day 1Day 6Day 6Day 6Day 6Day 10Day 50

Day 1Day 1

Day 1Day 5Day 20Day 20Day 20Day 20Day 50Day 70

before Day 1

before Day 1before Day 1

ContinuingContinuing

Continuing

Est. Cost

$ 300

50,000

50.000

50,000

180,000

1,000

5,0001,000

Estlnatad Time; Six months Estimated Cost:

FACTUAL BACKGROUND ON SIKE'S SITErj

Location and Physical Description ~5

Sike 's site 1s located north of U.S. Highway 90, about one-half mile eastof the San Jadnto River. The site consists of 20-50 acres with four or•ore ponds In which various types of Industrial wastes were disposed of1n large mounts. The site 1s located In the San Jadnto River flood-plain and the slta has been Inundated numerous times..

.• There 1s a locked cable across the entrance to the site. The Slice's resi-dence and • four or five acre pond Is located about 0.4 «11«s fro» thegata (see Figure 2). There are drums scattered at various places on thesite - some In the woods along the entrance road, some In and near thelarge pond and sone near the ponds west of the house. There are lessthan 500 druns on site (probably around 200). The soil at the site Isvery sandy, probably river alluvluB. The elevation ranges from lessthan ten feet to 20 feet, the three ponds on the west side of the pro-perty presently have three to five feet of freeboard, but when they over-flow (evidenced by old tar 1n the drainage araa), It 1s diractty to the

-A , t San Jadnto R1vtr. The large pond (four»or five acres) on the east »1de; * 1$ at an elevation of 15 feet plus, and »ost of Us drainage 1s to the"_ east. The overflow area 1s covered with a black tar-Hke substance (300*' *•- - •- feet wide and one-half u11e long). The overflow areas are very spongy

; and when dug Into, they reveal a black gooey wterlal with a chemicalodor. When the water level 1n the pond 1s high enough, some of the ma-terial could flow to the north, under the railroad bridge, to JacksonBayou. Material flowing east out of the large pond eventually would mix

': with the French Limited discharge and move southwest, go under U.S. High-way 90 and discharge to the San Jadnto River about two miles to the

_ south after going through Gordon Lake, Rlckett Lake, Faucet Lake and„•'"' HcCracken Lake. The normal drainage would be very slow and sometimes beI s totally Inpo'undfd, but when the river 1s high, the entire area (otherN ..- ' . than .the railroad and highway) Is reported to be Inundated, There 1$^-«

• - . also probably subsurface seepage occurring at the site. See attachednaps (Figures 1 and 2) for location and general layout of the facility.

Operations of the Site

Th« site Is located on property owned by Mrs. Mable S1kes. P.O. Box,«. Highlands, Texas 77562, who lives on the site with her two sons. The

' - * . . , . history of .site operations 1$ not known well and documentation does noty exist* Tfee site was operated by Mr. S1ke, now deceased, and 1t If sus-

pected that petrochemical waste fron the Houston area similar to what was.A.: • -' disposed In the French L1«1 ted site, across the highway, was also dis-

posed of at the Stke site. There has been no known dumping at this sitefor about 16 years.

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Nature of Wastes

Some of the drums are Intact and could be sampled, but to date no drumshave been sampled. Many of the drums, 1n and around the four or f ive acrepond east of the Slke's house, are deteriorated so that most of the con-tents have been lost and are now contained 1n the pond sediments or Inthe soils around the pond or In the overflow areas. Three water samplesand one soil saiiple were collected fron the site on April 17, 1980. Thefollowing are the analyses of those samples:

Sample Number 1 - Small pond of water south of Slke's house

2,4 - dloethylphenol - 0.053 ppwphenol - 0.198 ppnnaphthalene - 0,0493 ppmb1s(2 ethylhexyl) phthalate - 0.0591 ppmbenzene - 2.0043 ppmchlorobenzene - 0.0128 ppm1,2 - dlchloroethane - 0.3258 ppet1.1 - dlchloroethane - 0.1916 ppra1.2 - trans-dlchloroethane - 0.0479ethyl benzene - 0.0261 ppmmethylene chloride - ._ 0.0371 pprotoluene - 0.7738

Sample Number 2 - Composite of Four to Five Acre pond on east of S ike ' s house

Methyl (C.) naphthalene - 0.010 ppmC« - naphthalene - 0.015 ppmC^ - naphthalene - 0.025 ppmpfienanthrene/anthracene - 0.075 ppnC. and Cz

^phenanthrene/anthracene (total)- 0.060 ppetfluoranthene - 0.100 ppmpyrene - 0.060 ppmmethyl fluoranthene/pyrene - 0.035 ppmchrysens/benzo(a) anthracene - 0.030 pptnbenzo (g. h, 1} fluoranthene - 0.005 pptnbenzo (b) and/or benzo (k)-

-„ fluoranthene - _ 0.045 ppnbenzopyrene - - 0.015 ppnBenzene * 0.020 ppntoluene - 0.005 ppnchloropropene - 0.003 ppndimethyldlsulflde - 0.002 ppra

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kfent jto' characterizeof-cont*rtlMt^,Tpf t*< eot'tre £lte.

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SITE ASSESSMENT

Safety Hazards r\

Although some of the disposal ponds are located not more than 0.3 milesfrom the Rlverdale community, the site Itself 1s rather remote and In-accessible. It Is located on a heavily wooded tract on the floodplalnof the San Jadnto River. The river 1s on the west side, a railroad trackon the north, undeveloped woodland on the east, and a highway on thesouth. The only current access to the site 1s a single dirt road leadingup to the Stke's house. There 1s a cable locked Into position acrossthe entrance so that entry can only be made on foot. There 1s a sign atthe entrance reading "No walking onto this Property."

Aromatic vapors were only slight and did not register on the HNU exceptwhen the heavily contaminated soils around the disposal ponds were dis-turbed. There should be no problem of accidental Ignition except whenunwtather&d dn»s are opened or the contaminated soil Is being dug up.The only threat to life would be limited to direct contact with thehazardous naterlals on site or the 1ngest1on of contaminated surface orgroundwater leaving the site. How much contaminate 1s leaving the siteIs not known, and will need to be determined during the sampling phaseof the response action,

Groundwater

The only data that exists on possible groundwater contamination are thesamples collected by the Harris County Pollution Control Agency. Thesesamples were collected In connection with the French United disposalsite, which 1s adjacent to the Rlverdale community, and across the high-way from S1ke, but the results are Inconclusive for determining ground-water contamination.

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Slke's site 1s wlabt by sands, silts, and clays, which were depositedIn point bars, natural levees, stream channels, and backswamps of the oldSan Jadnto River* The sands are highly permeable and should readilytransmit groundwater. The thickness of the alluvium at the site Is notexactly know, but Is less than 200 feet. The alluvium overlies the pro-lific Gulf Coast Aquifer, which contains Fresh (<1,OOQ ppm dissolvedsolids) to Slightly saline (1,000 - 3,OCX) ppn) water down to a depth of3,000 feet. Hater levels In deeper wells (300+ feet) are 75 to 100 feetbelow the land surface, whereas the well depths 1n the Rlverdale communityrange between 12 and 52 feet. These are probably alluvium wells.

To adequately define the groundwater problem, and 1f contaminated, todetermine the extent of contamination, a thorough groundwater study ofthe area will be needed.

<**>

Average annual rainfall 1n this area 1s between 48 and 50 Inches, whereasthe annual evaporation 1s between 60 and 65 Inches.

A large amount of the rainfall on the site obviously soaks Into the sandysoil. The remainder ends up in one of the many ponds on the site. Whenthe ponds on the west overflow, the water goes directly to the San JaclntoRiver. Most of the overflow from the four to five acre pond on the eastside 1s to the east to another pond, which drains Into a drainage waycoming from the French Limited site. The flow moves southwest, apparentlygoes under U.S. Highway 90, through Gordon, Rlckett, Faucet, and McCrackenlakes, and eventually to the San Jaclnto River. When the water level 1nthe four to five acre pond 1s high enough, some of the material couldflow north, under the railroad bridge, to Jackson Bayou. Drainage fromall of the ponds and the site 1n general has not been determined, nor 1sthe type and amount of pollutant leaving the site known. The drainagefor the entire site, as well as the extent of contamination, will needto be determined during the early stages of cleanup.

" Mr Quality

:", "' The only air »on1tor1ng Information available 1s that taken with the HNUduring the April 1980 Inspection. There were no air quality problemsnoted except Immediately above the contaminated soil around the disposal

. .ponds, but only 1f disturbed by digging. The nearest residence to thesite, other than the Hike's house, which 1s located In the middle of the

'. Site, 1s 0.3 alles to the south. Air quality should not be a problea to_X Rlverdale residences during cleanup,

?5 Soil Test

No physical tests have been made on the soil (clay content, permeability,etc.) and no data are available on depth of penetration of the hazardous

• waste. The extent of soil contamination will need to be determined during„" the cleanup of the site.f - • - - •,' -Drums '

Many of the drums are deteriorated to the point that all volatile* are. gone, but some drums are Intact and will need to be sampled. Depending: on what Is found In the drums, some nay have to be re-drummed and/or

removed froa the site.

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ACTION PLAN

Security

A gate needs to be placed at the entrance to Slke's site to assure nounauthorized vehicular traffic. Warning signs Mill need to be placed atstrategic points around the perimeter of the site. The Initial sitesurvey team will determine where the signs need to be located. A guardwill not be necessary, unless It Is found later that he 1s needed to keepthe news foedla and other slghseers from entering the site.

Site Safety Plan

Initial field Inspection and sampling of the site has been completed.The analyses of water showed low levels of nany hazardous auterlals (see"Nature of Wastes"), but very high levels 1n the one soil sample analysis.The safety level *C" will be used Initially until It has been determined1f there are areas 1n which level *B" should be used and areas wtiere level"D" can be used. The OSC will be responsible for any modifications tothe safety plan. He will establish Exclusion Areas, Contamination Reduc-tion Areas, and Support Areas. A Command Post will be Initially estab-lished somewhere along the road 1n the vicinity (within 100 yards) of theSlke's house. Because of the size of the site, It night be necessary to•ove the Cocanand Post fron tine to time as work progresses. The CommandPost will maintain:

1. Approved first-aid kit2. Eye wash kit and portable body washer3. Local poison control center phone number4. Nearest hospital emergency room phone number5. Local ambulance service phone number•6. CHRIS and other hazardous chemical guides7. Telephone communications

All eating, drinking, and sacking 1s prohibited except 1n the SupportArea.

The following procedures and personnel protection will be used for eachproposed action to be taken at the tit*:

1. . Gate Construction - No special provisions are needed for thisictlvlty, other than what the contractor normally takes for

• construction of the gate.

2. Initial Site Survey -

a. OSC w1H obtain dally weather briefing from NWS.t>. OSC will brief the survey team on the objectives, antici-

pated hazards, and procedures (refer to Standard OperatingProcedures).

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c. The "buddy system" will be used during survey.d. One or more stand-by personnel will be stationed outside

of the Exclusion Areas, 1n level "B" protection, ready todon the SCBA In the event one of the survey team membersgo down. The person, or persons, shall Maintain visualcontact with the survey team, or teams, 1n the ExclusionArea at all tines.

a. The survey team will wear level "C" protection:

Full face.alr purifying respirator with appropriate car-tridgeRobertshaw escape maskChealcal splash suitGloves, Outer (chemical protective)Gloves, Inner (surgical)Boots, Outer (chemical protective heavy rubber)Boots, Inner (chemical protective, steel toe and -sCoveralls, chenlcal resistant "T

Underwear, cotton ;

f. Survey Instrumentation will Include:

Draeger Tubes for HCNRadiation detector (Gelger counter)Oxygen meterExplosion meterpH meterlonUatlon raeter (HNU and/or OVA)

g. Readings will be taken throughout the Exclusion Areas andthe dralnageways leaving the site. If areas of high organicreadings are encountered, the team will Immediately leavethat area. After completing the remainder of the survey,the team will return wearing SCBAs and delineate theboundaries of the hot areas.

h. Upon leaving the Exclusion Areas, each member will wash(with detergent and water) and rinse outer garments (non-disposable) exposed to liquids and/or sediments. Thedecontaminated clothing will be air dried and stored Inthe Contamination Reduction Area for subsequent samplingoperations. Disposable clothing will be placed 1n a plastic

. .bag and placed 1n one of the Exclusion Areas.

3. Groundwater Study - The part of the study conducted off-sftewill not require any special precautions for personnel safety.While on-slte (In the Exclusion Area), the personnel will followthe same procedures as outlined for the Initial Site Survey,unless based on Information obtained on the Site Survey, theOSC Increases or decreases the level of protection. All personsentering a hot area, delineated by the Site Survey Teams (see2.g above) will also wear an approved SCBA.

-3.For the ground penetrating radar and any monitoring wells whichmight be required on site, the contractors will take the normalsafety precautions used 1n their operations. In addition, theirpersonnel will follow the same procedure as outlined for thegroundwater study personnel 1n the preceding paragraph. Also,after drilling each hole, the drilling and sampling tools willbe decontaminated with detergent and water and rinsed before•ovlng to the next well site. A heavy equipment decontaminationstation will be established on site and all vehicles and otherheavy equipment leaving the Exclusion Areas will be decontami-nated.

4. Sampling - The sampling teams will follow the same proceduresas outlined for the groundwater study tew. In addition, tlsamplers will wear an approved SCBA anytime they are tapplgan unopened drum. /

5. Sampling of Monitoring Wells - No special precautions necessaryother than personal hygiene after collecting water samples and•voiding cross contamination of the sample.

6. Containment and/or removal of waste - Workers participating 1nthe cleanup work will follow the same procedures as outlinedfor the groundwater study team, and/or as prescribed by theiremployer.

Groundwater Study

To adequately define the groundwater problem, and 1f contaminated, todetermine the extent of contamination, a thorough groundwater study ofthe area 1s needed. Because of the proximity of the French Limited dis-posal site, the groundwater study will Include 1t and any other site withinthe study area which night have contributed to groundwater contamination.The study should be conducted by the groundwater staff of the Kerr Labora-tory 1n Ada, Oklahoma, because of their experience at Love Canal andother waste sites which have affected groundwater. Some of the work wouldbe contracted out, such as the ground penetrating radar, but would beunder the direction of the Ada Laboratory.

The objective of the Investigation 1s to determine If waste disposal sites1n the area have contaminated groundwater on and off the sites, and 1fso, to determine the extent of that contamination. The San Jadnto Riverwill be the west side of the study area, Jackson Bayou the north side,and extend the study far enough east to Include the French Limited siteand all of the Slke's property, and as far south as Rlckett Lake.

The scope of this study Includes the collection, compilation, and analysisof data related to groundwater quality and movement 1n the shallow (<50

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feet) alluvium aquifer In the study area, and the presentation of thesedata, results of analysis, and conclusions 1n a report to the OSC. In-cluded 1n the report will be tables of basic data and Illustrations toportray the existing groundwater conditions 1n the area.

To accomplish the objective and scope of the groundwater study, the fol-lowing Items of work will be required:

1. Location end Inventory of tn* shallow wells (<50 feet) 1n thearea. This will be done through a records search of the USGS,Texas Department of Water Resources, Harris County PollutionControl Agency, local well drillers and field Inventory.

2. Locate and describe all active and past disposal operationsX"the area (as far as possible). EPA Las Vegas has prepared aseries of air photographs over time which show the locationsof possible sites.

3. Collect water samples from wells and seeps for chemical analysis.Analyses of the wastes at the Site and French Limited will beavailable.

4. Measure water levels 1n as many of the wells Inventoried aspossible and determine elevations of wells, seep and waste sites.UStiS seven and one-half minute topographic sheets are availablefor elevation determinations.

5. Make a ground penetrating radar or other geophysical surveysto locate the nore permeable zones. These surveys may also aid

*" 1n locating burled drums on the sites.

•6. Test holes will be drilled to determine Hthology, penaeabUHy,and to obtain samples of possibly contaminated groundwater.The location of these holes will be determined from Informa-tion provided by the geophysical surveys conducted (see 5. above).

7. Selected test holes will be completed as groundwater Monitoringwells for changes 1n groundwater quality over time.

8. Prepare report. - .

Sampling and Analyses Plan

Both environmental and hazardous samples will be collected to characterizethe waste and Its concentration and to determine the extent of contamina-tion. The methods, sampling equipment, and procedures and type of analyseswill be determined and outlined by ERT or the contractor hired to do the

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work. All analyses will be made by a contract laboratory to minimize the —turnaround time. The following will outline the type of sampling desiredand purpose of each:

1. Air - The air (and radiation) sampling will be conducted by theInitial Site Survey Team to provide quick data on the personnelhazard which night be present 1n order to determine the safeprotection level to be afforded the workers. Gelger counters,Draeger tubes, oxygen meter, explosion meters, and 1on1zat1onmeters will be used to obtain this Information, and to definethe extent of hot areas.

Based on the findings, some or all of these Instruments willbe used during the remaining phases of the operations,

2. Waste - Samples of the sludge 1n the various ponds on the sitedrill be sampled. Any drums found Intact shall also be sampled.These samples are to determine the character of the waste andIts concentration.

3. Water - Samples of water will be taken from ponds which havehot already been sampled. Samples of water In the dralnagewaysleaving the site will also be sampled to determine the extentof contamination and the amount of treatment that will be neededbefore the water is allowed off the site.

4. Soil - Samples will be collected around the waste ponds, theobvious overflow areas, and along dralnageways. Core or augersamples will be taken to determine the depth of penetration ofthe wastes into the underlying earth materials, the type of

, material under the wastes, and the lateral extent of the con-'tanMnated soil. TOC (total organic carbon) and TOX (totalorganic halogens) analyses should be sufficient for these sam-ples. Head space analyses with the HNU and OVA should determinethe extent of this sampling.

5. Groundwater - Samples of water and Hthology will be collectedand analyzed from test holes drilled as part of the groundwaterstudy. Conductivity and pH of the groundwater samples collected

. - will be measured and the samples will be analyzed for TOC and.TOX.

Implementation of'Sampling and Analyses Plan

It would be desirable to have the ERT, who are familiar with this typeof sampling program, prepare and Implement the detailed sampling andanalyses plan to achieve the objectives stated 1n the preceding section.If the ERT is not available to do the sampling, then one f^ercber of the

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ERT should be assigned the task of preparing the detailed plan and be onscene during the sampling to direct the Implementation of the plan by acontractor. He would also supervise the contract with the analyticallaboratory, assure the transportation of the samples to the laboratory,and would be available to the OSC 1n the Interpretation of the analyses.It night be possible that the State could do some of the analytical workand speed up the turnaround time. They night also assist 1n locatinga suitable local laboratory for the regaining analytical work.

Interpretation of Data Collected

The OSC will have the ultimate responsibility for the Interpretation ofthe data and the recommendation for the course of action to be taken.But In so doing, he will need the consultation and recommendations ofboth the ERT and the State.

Course of Action

The actual course of action to be taken as a response ("Emergency") actionwill be determined by the Interpretation of data obtained during thegroundwater study and sampling program. With the limits of $1,000,000and six months on the "emergency action" phase, 1t appears from what weknow about the site at this point 1n time, that the following would bethe action taken under this plan:

1. Re-drum and remove the estimated 300 barrels on site. Most ofthese are 1n and around the large (four or five acre) pond eastof the Slke's residence. The regaining barrels are scatteredat various places on the site.

2. Dike the down-slope side of several ponds so as to provide aHlnlnwm of three feet of freeboard and dike and/or ditch theupslope side to prevent surface run-off from entering the ponds.The ponds Involved would be the three small ponds on the westside of the property, the large four or five acre pond on theeast side, and a pond on the far east side, which has receivedrun-off from the large pond, and any other contaminated pondsfound on site.

3. A waste treatment facility would be constructed by ERT or under •their direction and the water 1n the diked areas treated andreleased to the surface water drainage system. The treatmentfacility would remain 1n place to treat water accumulating 1nthe diked areas. The State would maintain the treatment facilityuntil remedial actions on this site have been completed.

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The above Items will not secure the site 1n the event of a majorflood, which 1s not uncommon to the area. The most recentfloods occurred In 1973 and twice 1n 1979. However, the aboveactions should eliminate any contaminated surface water fromleaving the site through normal run-off.

Monitoring

Groundwater monitoring wells, constructed during the groundwater study,will need to be sampled periodically for sometime Into the future. Waterlevels and samples should be taken at least once every six months. Thewater should be analyzed for TOC and TOX, and measurements made of theconductivity and pH. The wells should be monitored until one year afterfinal remedial action or until the TOC and TOX drops to an -Insignificantlevel. A complete analysis should be made on the final sample. It 1shoped that the State could make these measurements and collect the samples.

General Legal Considerations

Region 6 Enforcement Division will need to do the following:

1. Coordinate all legal actions with attorneys of the Texas Depart-ment of Water Resources.

2. Notify landowner as to his responsibilities un'der the SuperfundAct.

3. Obtain the necessary legal entry, permits, and manifest require-ments.

State-Federal Coordination and Public Relations

The State can provide valuable assistance to the OSC. This action planhas not yet been discussed with the State. At the time 1t 1s sent outfor review and comments, a copy should be taken to the Texas Departmentof Water Resources and explain to then what Is contemplated, what can bedone under a Superfund Response Action, Its limitations, the State'sobligations under Remedial Actions, and solicit their review and sugges-tions on this Response Action Plan so that their suggestions nay be Incorp-orated Into the. final approved plan.

It would be desirable to have both an ERT and State representative onscene with the OSC, once work has begun. The State's representative couldassist 1n locating necessary contractors, a proper disposal site, obtain-ing necessary State permits, and possibly have some analytical work done1n State laboratories. His knowledge of, the local area and conditionswould be a big help to the OSC 1n making a decision on the course of actionto be taken. His presence on scene will also assure that the State willbe Informed at all tines of the actions being taken or contemplated.

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Before any work begins at this site, but after the landowner has beennotified by Enforcement, the communities of Barrett and Crosby should benotified as to what 1s going on at the Slke's site, Including the ground-water study off-sKe. A press release should then be made to nearby news«*d1a. Including Houston. All such notifications should be nade by theOffice of Public Awareness after coordinating ill releases with the TexasDepartment of Water Resources. The Region 6 Office of Public Awarenesswill be kept advised of the progress and any major decisions «ad« duringthe work so they can Adequately respond to all Inquiries.

OSC After Action Report

The OSC will prepare an "After Action Report/ which outlines what hasbeen done, the costs, and the continuing Monitoring and water treatmentfacility maintenance. It will outline the remedial actions needed, anestimated costs, and the estimated State cost In the ultimate cleanup ofthe site. Although the remedial action course will have to be determinedafter tht" response action of this plan has been completed, there areseveral possibilities which can be considered. They are:

1. As an alternative to treating the ponded water, the drillingof an Injection well might be considered to dispose of waterfrom this site and French Limited, which Is located across thehighway.. If the well was located at the French Limited site,It could possibly be used 1n future Incidents where the Federalor State governwent finds Itself 1n possession of some diffi-cult to dispose of material.

2. Reaove the sludge and contaminated soil from the ponds anddralnageways. The material would have to be hauled to a com-mercial Incinerator, or they could look Into the feasibilityof constructing a temporary Incinerator on site to handle materialfrom both SUe and French Limited.

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